FR 2021-03352

The Federal Emergency Management Agency (FEMA) has issued a public notice inviting comments on a proposed reinstatement of an information collection activity, namely the Residential Basement Floodproofing Certification. This initiative is part of FEMA's broader efforts to manage floodplain requirements and help communities mitigate flood risks. Through the collection, FEMA aims to ensure that residential structures adhere to specific floodproofing standards, potentially allowing homeowners to access reduced rates on flood insurance premiums. The notice seeks public input on the practicality and efficiency of the data collection process.

Key Issues and Concerns

One of the significant issues highlighted in the document is the lack of clarity regarding the estimated costs associated with the information collection. The notice provides figures for respondent costs ($21,525), operation and maintenance costs ($35,000), and federal government costs ($3,543) but fails to elaborate on how these numbers were derived. Without a transparent breakdown of these calculations, stakeholders might question the validity and necessity of the proposed activities.

The notice sets a 30-day window for the public to submit comments, yet there is no detailed explanation on how these comments will be assessed or their potential impact on the decision-making process. This lack of transparency might discourage public participation or create skepticism about the agency's responsiveness to stakeholder inputs.

The use of bureaucratic language and technical jargon also poses accessibility challenges, especially for members of the general public who might be directly affected by these regulations. References to specific Code of Federal Regulations (CFR) sections and technical floodproofing requirements may not be easily understood, potentially limiting effective public participation and feedback.

Although the document references previous comments and FEMA's responses, it lacks sufficient detail about why certain suggestions were not considered. This opacity can lead to confusion or frustration among stakeholders who feel their input has been disregarded without adequate justification.

Potential Impacts on the Public

Broadly, the document could have both positive and negative implications for the public. On the positive side, the emphasis on ensuring compliance with floodproofing standards could result in increased safety for residents in flood-prone areas and possible economic relief through reduced insurance premiums. However, the administrative burden associated with completing the required certification might serve as a deterrent for some property owners or professionals, especially if the cited costs are perceived as onerous.

Impacts on Specific Stakeholders

For businesses and professionals, such as surveyors, engineers, and architects, this document introduces potential new work by mandating their involvement in the floodproofing certification process. However, it also implies additional responsibilities and potential liabilities, which might necessitate adjustments in workload management or costs. On the other hand, communities and homeowners who achieve compliance could benefit economically and experience reduced flood risks, thereby enhancing property values and fostering a sense of security.

In conclusion, while FEMA's reinstatement proposal carries the potential for strengthened floodplain management and community resilience, new financial burdens and procedural complexities present challenges that need careful consideration and transparent communication. The agency's engagement with stakeholders through open channels of feedback and clarification can foster trust and improve outcomes for all involved.

The document outlines several financial aspects associated with the Residential Basement Floodproofing Certification process conducted by FEMA. These financial references include estimated costs and budget implications for various parties involved.

The Estimated Total Annual Respondent Cost amounts to $21,525. This figure represents the collective financial burden on those who are required to respond to the information collection, such as businesses or other profit-oriented entities. However, the document does not provide any insight into how this cost was derived, leaving the public without an understanding of what constitutes these expenses or whether they are justified. This lack of transparency could be a barrier for stakeholders who need to evaluate the fairness and accuracy of this requirement.

Additionally, the Estimated Respondents' Operation and Maintenance Costs are projected to be $35,000. Similar to the respondent costs, this calculation is presented without a breakdown or explanation of what specific maintenance activities or operational tasks necessitate this level of expenditure. This absence of detail does not allow stakeholders to verify if the estimated costs align realistically with the activities required under the program.

The document indicates no Respondents' Capital and Start-Up Costs, listing this as $0. While clearly presented, the document does not provide a rationale, which would be beneficial to confirm that this is an accurate reflection of real-world scenarios for entities preparing to engage in this program for the first time or maintaining ongoing compliance.

For the federal government, the Estimated Total Annual Cost to manage and carry out the floodproofing certification is cited as $3,543. Once more, the text lacks elaboration on how this figure is calculated, which could enable reviewers to assess the efficiency and effectiveness of the resources allocated.

The issues identified within the document, such as its reliance on technical language and the absence of a detailed methodology for cost estimates, further obscure the financial transparency of the program. A more detailed disclosure could quell uncertainties and provide clarity around how financial estimates are reached, benefitting both the respondents subjected to these costs and stakeholders analyzing government spending.

In summary, while the document provides specific financial figures related to the floodproofing certification process, the absence of detailed explanations for these amounts raises important questions regarding transparency and accountability. Clearer documentation and justification of these estimates would likely enhance public understanding and trust in the program's financial practices.