Federal Flood Risk Management Standard (FFRMS)

The Federal Flood Risk Management Standard is a flood standard that aims to build a more resilient future. The FFRMS was established to encourage federal agencies to consider and manage current and future flood risks in order to build a more resilient nation. It requires agencies to prepare for and protect federally funded buildings and projects from flood risks. More specifically, it requires agencies to determine specific federal building or project dimensions – that is, how high and how wide and how expansive a building or project should be – in order to manage and mitigate any current or potential flood risks.

The FFRMS gives flexibility and requires agencies to select one of the three approaches for establishing the flood elevation (“how high”) and corresponding flood hazard area (“how wide”) used for project siting, design and construction:

  • Climate Informed Science Approach (CISA): The elevation and flood hazard area that result from using the best-available, actionable hydrologic and hydraulic data and methods that integrate current and future changes in flooding based on climate science;
  • Freeboard Value Approach (FVA): The elevation and flood hazard area that result from adding an additional 2 feet to the base flood elevation for non-critical actions and by adding an additional 3 feet to the base flood elevation for critical actions; or
  • 500-year floodplain: The area subject to flooding by the 0.2% -annual-chance flood.
 
The FFRMS increases the resilience of federally funded projects by incorporating anticipated changes in future flood risk into certain federally funded projects to ensure that those projects last as long as intended.
 

What are federally funded projects?

The FFRMS applies to federally funded projects. Federally funded projects are actions where federal funds are used for new construction, substantial improvement, or to address substantial damage to a structure or facility. Individual agencies will determine thresholds for what constitute substantial improvement and substantial damage (FFRMS Floodplain Determination Job Aid (2023)). Examples include the new construction of a bridge, substantial improvement to a hospital, or repair of substantial damage to a warehouse.

 

What are critical actions?

A critical action is any activity for which even a slight chance of flooding would be too great. E.O. 11988, Sec. 6(d), as amended by E.O. 13690. Some key questions to help identify whether the action is a critical action include:

  • If flooded, would the proposed action create an added dimension to the disaster?
  • If the action involves structures such as hospitals, nursing homes, prisons, and schools, would the occupants of the structure be sufficiently mobile and have transport capability to avoid loss of life and injury given the flood warning lead-time?
  • Would essential or irreplaceable resources, utilities, or other functions be damaged beyond repair, destroyed, or otherwise made unavailable?
  • Would the damage or disruption from a local flooding event lead to regional or national catastrophic impacts?
  • Would damage or disruption to a given facility or infrastructure component have potential for cascading damage or disruption to other facilities and infrastructure classes, some of which may already be stressed by flood conditions?

 

The 2015 Guidelines for Implementing EO 11988, Floodplain Management, and EO 13906, Establishing a Federal Flood Risk Management Standard and Process for Further Soliciting and Considering Stakeholder Input (2015 Guidelines) provide expanded descriptions of critical actions. If the answers to the above questions are all “No” or “not applicable,” then the action may be considered a non-critical action. Agencies may have more specific guidance on determining critical actions that should also be consulted.

Examples include evacuation routes, hospitals, hazardous materials storage, national laboratories’ research activities, irreplaceable records, or items of cultural significance.

 

What is the service life of a project?

Service life refers to how long the structure or facility will function. Flood risk may change over the life of the federal investment. In determining service life, factor in renovations that have been completed on the structure that extend the service life beyond the original planned date. For example, although a federal action provides a 30-year loan to the structure or facility, it may remain in service for much longer (for example, 50 to 100 years), and floodplain hazards may be relevant beyond the years of the federal action. Agencies may have their own protocols to establish the service life, so it is important to check with the agency that would propose the action for guidance on this point.


 

 
 
 

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