NFIP Guidance for Conducting Community Assistance Contacts and Community Assistance Visits

National Flood Insurance Program (NFIP)

Guidance for Conducting
Community Assistance Contacts
and Community Assistance Visits
FEMA F-776/April 2011

Table of Contents
Definition of Terms................................................................................................................v
Chapter 1. General Information....................................................................................... 1-1
1.1 Purpose............................................................................................................. 1-1
1.2 Applicability and Scope..................................................................................... 1-1
1.3 Authorities......................................................................................................... 1-1
1.4 References........................................................................................................ 1-1
1.5 Background....................................................................................................... 1-1
1.6 Objectives......................................................................................................... 1-2
1.7 Responsibilities................................................................................................. 1-4
1.8 Reporting Requirements................................................................................... 1-6
Chapter 2. Community Selection Process....................................................................... 2-1
2.1 General............................................................................................................. 2-1
2.2 Risk-Based Criteria for Selecting CAVs and CACs........................................... 2-2
2.3 Selecting Communities for a CAV..................................................................... 2-3
2.4 Other Situations that Require a CAV................................................................. 2-8
2.5 Selecting Communities for a CAC..................................................................... 2-9
Chapter 3. Community Assistance Contact..................................................................... 3-1
3.1 General............................................................................................................. 3-1
3.2 The Difference between Technical Assistance and a CAC............................... 3-1
3.3 Preparation........................................................................................................ 3-2
3.4 Community Contact........................................................................................... 3-3
3.5 Documentation.................................................................................................. 3-9
3.6 Follow-up......................................................................................................... 3-12
Chapter 4. Community Assistance Visit: Preparation...................................................... 4-1
4.1 General............................................................................................................. 4-1
4.2 Review Pertinent Community Information......................................................... 4-2
4.3 Compile a List of Issues and Sites.................................................................... 4-7
4.4 Contact the Community to Schedule a Visit...................................................... 4-7
4.5 List of Materials and Equipment for a CAV..................................................... 4-10
Chapter 5. Community Assistance Visit........................................................................... 5-1
5.1 General............................................................................................................. 5-1
5.2 The Floodplain Tour: Purpose and Strategy...................................................... 5-1
5.3 The Floodplain Tour.......................................................................................... 5-3
5.4 Documentation of Potential Floodplain Development and Mapping Issues...... 5-7
5.5 Meeting With Local Officials.............................................................................. 5-8
5.6 An Examination of the Floodplain Development Permit and Variance Files... 5-17
5.7 Summary Meeting With Local Officials........................................................... 5-19
5.8 Specialty CAVs................................................................................................ 5-20

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Guidance for Conducting CACs and CAVs

Chapter 6. Community Assistance Visit: Documentation................................................ 6-1
6.1 General............................................................................................................. 6-1
6.2 Community Assistance Visit Findings............................................................... 6-1
6.3 Letter to the Community CEO........................................................................... 6-5
Chapter 7. Community Assistance Visit: Follow-Up........................................................ 7-1
7.1 General............................................................................................................. 7-1
7.2 Provision of Community Assistance.................................................................. 7-1
7.3 Monitoring and Oversight.................................................................................. 7-3
7.4 Follow-up Documentation/Chronology.............................................................7-11
7.5 The Compliance Manual................................................................................. 7-12
Appendix A: CAC Checklist of Issues for Discussion......................................................A-1
A.1 Floodplain Management Regulations................................................................ A-1
A.2 Map Availability and Accuracy........................................................................... A-1
A.3 Development Review Process.......................................................................... A-1
A.4 NFIP Community Information Review and Verification..................................... A-2
A.5 Discuss Any Potential Violations, Deficiencies, or Compliments...................... A-2
A.6 Summarize the CAC Findings, Processes, and Follow-up Actions................... A-2
Appendix B: Sample Letter: Confirming CAV Meeting....................................................B-1
Appendix C: Floodplain Tour Checklist............................................................................C-1
C.1 Development in the Floodplain..........................................................................C-1
C.2 Map Accuracy....................................................................................................C-4
Appendix D: CAV Floodplain Development Review Worksheet......................................D-1
Appendix E: Community Assistance Visit: Checklist for Meeting
with Local Officials and Issues Discussion.................................................. E-1
E.1 Purpose of Meeting...........................................................................................E-1
E.2 Floodplain Management Regulations Review................................................... E-1
E.3 Map Availability and Accuracy........................................................................... E-2
E.4 Development Review Process.......................................................................... E-2
E.5 NFIP Community Information Review and Verification..................................... E-4
E.6 Floodplain Development Issues Identified on Floodplain Tour.......................... E-4
E.7 Other Floodplain Management Issues.............................................................. E-4
E.8 Summarize the CAV Findings, Processes, and Follow-up Actions................... E-4
Appendix F: The Community Rating System................................................................... F-1
F.1 The Community Rating System........................................................................ F-1
F.2 National Flood Insurance Program Community Rating System
Compliance and Retrograde Procedures.......................................................... F-2
F.3 CRS Verification Visits Are Not CAVs................................................................ F-6
F.4 Sample CRS Paragraphs.................................................................................. F-6

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Figures
Figure 2-1. Criteria for Selecting an Initial List of CAVs (Summary)................................. 2-5
Figure 4-1. Adoption of Building Codes............................................................................ 4-3
Figure 4-2. CAV Materials and Equipment List................................................................4-11
Figure 4-3. Quick Reference Checklist for CAV Preparation.......................................... 4-12
Figure 7-1. The Precedence Clause and Higher Standards............................................. 7-7
Tables
Table 7-1. Examples of Ways to Remedy Program Deficiencies................................... 7-13
Table 7-2. Examples of Ways to Remedy Violations...................................................... 7-13
Table F-1. Community Rating System Premium Discounts.............................................. F-1

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Definition of Terms
Definitions used in this document that relate to the National Flood Insurance Program
(NFIP) can be found in Code of Regulations (CFR) 44 Part 59. In addition, the following
definitions apply:
Community Compliance Program. The complete system developed to identify and
resolve program deficiencies and violations, with the objective of obtaining community
compliance with NFIP criteria. The emphasis of the system is on correcting program
deficiencies and remedying violations through community assistance and consultation
prior to the initiation of an enforcement action.
Enforcement Action. A measure initiated by FEMA to obtain community compliance
with NFIP floodplain management criteria by ensuring that communities correct program
deficiencies, remedy past violations, and enforce their ordinances for future development.
The action commences when a FEMA Regional Administrator notifies the community that
it will be placed on probation following the conclusion of a 90-day notice period. The
action can continue through suspension and/or until the community’s full program status
is restored.
Flood Loss Reduction. A combination of preventive and corrective measures taken by
individuals or communities to mitigate the adverse consequences of flooding.
Floodplain Management Regulations. Zoning ordinances, subdivision regulations,
building codes, health regulations, special purpose ordinances (such as a floodplain
ordinance, grading ordinance, or erosion control ordinance), and other applications of
police power. The term describes such local or State regulations, in any combination
thereof, that provide standards for the purpose of flood damage prevention and reduction.
International Building Code (IBC®). A model code that provides minimum requirements
to safeguard the public health, safety and general welfare of the occupants of new and
existing buildings and structures. Some States mandate community adoption of the IBC®.
It contains flood damage–resistant provisions that are consistent with the minimum design
and construction requirements of the NFIP.
International Residential Code (IRC). A model code that provides regulations for the
construction of single family houses, two-family houses, and buildings consisting of
three or more townhouse units. Some States mandate community adoption of the IRC. It
contains flood damage–resistant provisions that are consistent with the minimum design
and construction requirements of the NFIP.
Probation. Recommended by the Regional Administrator and occurring as a result of noncompliance with NFIP floodplain management criteria [44 CFR §59.24(b)]. A community is
placed on probation for one year (may be extended) during which time a $50.00 surcharge
is applied to all NFIP policies, including Preferred Risk Policies, issued on or after the
probation surcharge effective date. If a community does not take remedial or corrective
measures while on probation, it can be suspended.
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Guidance for Conducting CACs and CAVs

Program Deficiency. A defect in a community’s floodplain management regulations or
administrative procedures that impairs effective implementation of floodplain management
regulations or the standards in 44 CFR §60.3, 60.4, or 60.6.
Reinstatement. After a period of suspension from the NFIP for failure to adopt or enforce
floodplain management regulations or for repealing or amending previously compliant
floodplain management regulations, a community may be reinstated into the Program.
At a minimum, conditions for reinstatement may include that the community report to the
FEMA Regional Office all activities on the floodplain and each variance that it grants, and
that a review be conducted after a specified period of time to ensure that the community
is enforcing its floodplain management regulations. Flood insurance is available in
communities that have been reinstated. A community may be reinstated on probationary
status, however. In communities placed on probation an additional charge of $50.00 will be
added to the premium for each new or renewed policy for a period of no less than one year.
Substantive. A substantive program deficiency or violation is one that has resulted or
could result in increased potential for flood damages or stages during events up to or
equal to the base flood in the community.
Suspension. A community shall be subject to suspension from the NFIP for failure to
adopt compliant floodplain management measures [44 CFR §59.24(a)] or if it repeals
or amends previously compliant floodplain management measures [44 CFR §59.24(d)].
A community can also be suspended for failure to enforce its floodplain management
regulations [44 CFR §59.24(c)]. New flood insurance coverage cannot be purchased and
policies cannot be renewed in a suspended community.
Violation. The failure of a structure or other development to be fully compliant with the
community’s floodplain management regulations. A structure or other development without
the elevation certificate, or other certifications, required in 44 CFR §60.3(b)(5), (c)(4), (c)
(10), (d)(e), (e)(2), (e)(4), or (e)(5) is presumed to be in violation until such time as that
documentation is provided.

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Chapter 1
General Information
1.1 Purpose
This guidance document establishes the Department of Homeland Security, Federal
Emergency Management Agency (FEMA) procedures for conducting Community
Assistance Contacts (CACs) and Community Assistance Visits (CAVs) with communities
participating in the National Flood Insurance Program (NFIP). This is the second edition of
this document, which was originally published on August 30, 1989.

1.2 Applicability and Scope
This guidance document is applicable to all FEMA staff in Headquarters (HQ), FEMA
Regional Offices, Joint Field Offices, and State agencies that may be conducting CACs
and CAVs under the NFIP’s Community Assistance Program (CAP).

1.3 Authorities
a.
b.
c.
d.

The National Flood Insurance Act of 1968, as amended.
The Flood Disaster Protection Act of 1973, as amended.
The National Flood Insurance Reform Act of 1994.
The Flood Insurance Reform Act of 2004.

1.4 References
Title 44, Code of Federal Regulations (CFR), Parts 59, General Provisions; 60, Criteria for
Land Management and Use; 65, Identification and Mapping of Special Hazard Areas; 70,
Procedure for Map Correction; 72, Procedures and Fees for Processing Map Changes; 78,
Flood Mitigation Assistance; 79, Flood Mitigation Grants; and 80, Property Acquisition And
Relocation For Open Space.

1.5 Background
The major objective of the CAP is to ensure that communities participating in the NFIP
are achieving the flood loss reduction objectives of the program. To achieve this objective,
the CAP is designed to provide needed floodplain management assistance services to
NFIP communities. By providing these services, the CAP identifies, prevents, and resolves
floodplain management issues before they develop into problems that require enforcement
actions. The Community Assistance Program–State Support Services Element
(CAP‑SSSE), through its State partnering agreement, is designed to support and enhance
State floodplain management programs by making State personnel available to assist and

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Guidance for Conducting CACs and CAVs

supplement FEMA Regional Office staff. The CAP is a companion program to the NFIP
Community Compliance Program (CCP). If problems are encountered and cannot be
resolved during the implementation of the CAP, the CCP provides an orderly sequence of
enforcement options of varying severity for follow-up action by FEMA HQ and the FEMA
Regional Offices.

1.6 Objectives
a. Objectives of this Guidance Document
1. To serve as a guide and tool for selecting and conducting CACs and CAVs, and
2. To serve as a training document for staff not familiar with the procedures for
conducting CACs and CAVs.
This guidance document describes the step-by-step process for conducting CACs
and CAVs. The activities and issues listed under the CAC and CAV processes, while
comprehensive, may not be inclusive of all that may be required to identify, prevent,
and resolve floodplain management issues. Likewise, certain activities and issues
listed under the CAC and CAV processes may not be applicable to every community
or every situation. For example, if a community does not have mapped areas
protected by a levee system recognized by FEMA as providing protection from the
base flood, it is not necessary to discuss maintenance activities with the community
under the provision 44 CFR §65.10. FEMA Regional and State staffs are expected
to exercise discretion in evaluating community programs and the application of this
guidance. Although NFIP regulations are referenced throughout this document, it is
not the intention of this guide to supersede or replace the NFIP regulations.

b. Purpose of the CAC
1. The CAC provides a means to establish or re-establish contact with an NFIP
community for the purpose of determining any existing problems or issues and to
offer assistance if necessary. The CAC also provides the opportunity to enhance the
working relationship between the State or FEMA and NFIP communities, and creates
a greater awareness of the NFIP and its requirements.
2. A CAC can be conducted by a telephone call
to the community or a brief visit. Using either
method of contact, the CAC is intended to be
less comprehensive and less time-consuming
than a CAV. The CAC should not be conducted
in communities where more serious floodplain
management problems or issues are known or
suspected, especially in communities where growth
occurs in the floodplain, or in communities with a
high potential for damage to existing development.

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CACs and CAVs are two
key methods FEMA uses
to identify community
floodplain management
program deficiencies and
violations and to provide
technical assistance to
resolve these issues.

1. General Information

c. Purpose of the CAV
1. The CAV is a scheduled visit to an NFIP community for the purpose of conducting a
comprehensive assessment of the community’s floodplain management program and
of its knowledge and understanding of the floodplain management requirements of
the NFIP. The purpose of the CAV is also to provide assistance to the community in
remedying identified program deficiencies and violations.
2. The emphasis of the CAV is on resolving issues or problems by providing floodplain
management assistance; however, the subsequent findings and documentation of a
CAV form the basis for taking an enforcement action if deficiencies are not resolved
and violations are not remedied to the maximum extent possible given practical and
legal constraints.
3. The CAV offers an opportunity to establish or re-establish working relationships
between the State or FEMA and NFIP communities to create a greater awareness of
the NFIP and its requirements, and to provide ongoing technical assistance.
4. The CAV also provides an opportunity to assess the effectiveness of the
programmatic and regulatory aspects of the NFIP nationally by: gathering information
and making observations on local floodplain management programs; entering data
and comparing them to the information in FEMA’s Community Information System
(CIS); and identifying any issues or problems related to programmatic or regulatory
aspects of the NFIP and the effectiveness of the NFIP’s flood loss reduction efforts.
5. Because of the comprehensive nature of the CAV, priority visits should be
scheduled in communities experiencing rapid growth and development in the
Special Flood Hazard Area (SFHA), and where floodplain management problems
are known or suspected.

d. Timeframe
1. Ideally, each fiscal year contact should be made with all communities participating
in the NFIP, whereby community floodplain management programs are assessed
and floodplain management assistance services are provided. However, this task is
virtually impossible given that more than 20,000 communities participate in the NFIP
and that FEMA’s resources are limited.
2. FEMA has established a “risk-based” priority approach for selecting communities to
receive a CAV. This approach ensures that FEMA’s limited resources are applied
in the communities most in need of this comprehensive assessment. All other
communities will receive a CAC, training course, technical assistance contact, or
other appropriate activity.
3. Community assessment and floodplain management assistance may take a variety
of forms. In addition to CACs and CAVs, these activities may include: coordination
of new and revised Flood Insurance Studies (FISs), which require several meetings;
assistance to communities with updated floodplain management regulations;
technical assistance to communities that have experienced a recent disaster; and
other forms of direct, one-on-one contact with communities to provide assistance.

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4. By using a combination of CACs and CAVs in conjunction with all other technical
assistance activities, the process is designed to ensure that several thousand
communities are contacted each year so that, over time, no NFIP community
is overlooked.
5. The actual number of communities contacted or visited through the formal CAC and
CAV process in a given year may vary due to the following factors:
(a) The availability of staff resources within FEMA and State agencies;
(b) Competing priorities; and
(c) Recognition that where high rates of growth and development occur in the SFHA
and/or where program deficiencies and violations are identified, communities
may require more frequent CAVs or other forms of follow-up assistance, such as
field-deployed Emergency Management Institute (EMI) classes, Building Code
training, or Elevation Certificate workshops for surveyors, etc. This process
recognizes the need for and importance of resolving and preventing, to the
maximum extent possible, floodplain management problems and issues related
to development in SFHAs that would be at risk for future flood damages.

1.7 Responsibilities
a. FEMA Administrator
The FEMA Administrator is responsible
for the establishment, development, and
execution of policies and programs under
the National Flood Insurance Act of 1968,
as amended.

CAV Triggers – High rates of growth and
development in the SFHA, and/or identified
program deficiencies and violations – may
signify the need for more frequent CAVs.

b. Federal Insurance Administrator
The Federal Insurance Administrator (FIA), Federal Insurance and Mitigation
Administration (FIMA) is responsible for the following:
1. Administering the development of criteria and standards for the flood insurance,
risk assessment, and flood loss-reduction activities of the NFIP;
2. Providing guidance to FEMA Regional Offices to assist in their implementation
of the NFIP; and
3. When required, suspending or reinstating community eligibility to participate
in the NFIP in accordance with the provisions of 44 CFR §59.24.

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1. General Information

c. Floodplain Management Branch
The Floodplain Management Branch, FIMA is responsible for the following:
1. Administering the CAP, including the CAP‑SSSE partnering agreement, and the CCP;
2. Developing floodplain management policy and regulations to improve implementation
of the NFIP;
3. Developing floodplain management guidance and training materials to improve
implementation at the community level;
4. Implementing community NFIP eligibility and enrollment; and
5. Providing overall program management and coordination with the States, FEMA
Regional Offices, and participating communities for such program activities as the
Community Rating System (CRS), Section 1316 (denial of flood insurance coverage),
and on the CIS.

d. FEMA Regional Administrators
The FEMA Regional Administrators are responsible for the following:
1. Providing assistance to NFIP communities in adopting, administering and enforcing
local floodplain management regulations that meet or exceed the minimum criteria of
the NFIP;
2. Monitoring the floodplain management activities of NFIP communities to ensure
floodplain development is in compliance with the requirements of the NFIP;
3. Recommending imposition or removal of NFIP CRS retrogrades, as necessary;
4. Imposing or removing NFIP community probation, as necessary; and
5. Providing subsequent recommendations to the FIA to suspend or reinstate
community eligibility to participate in the NFIP.

e. Responsibilities of the NFIP State Coordinator
States have a significant role in the NFIP. Many have adopted floodplain statutes and
regulations and have established and funded their own State floodplain management
programs. Each Governor has selected a State coordinating agency for the NFIP. While
the role of this agency varies among States, common activities include the following:
1. Establishing minimum State floodplain management regulatory requirements
consistent with the NFIP;
2. Ensuring that communities have the legal authorities necessary to adopt and
enforce floodplain management regulations;
3. Providing technical and specialized assistance to local governments and the
general public;

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Guidance for Conducting CACs and CAVs

4. Ensuring that State floodplain management regulations or executive orders affecting
State-owned properties meet the minimum NFIP requirements;
5. Providing technical assistance to other State agencies proposing development on
State-owned property in SFHAs; and
6. Encouraging and assisting communities to qualify for NFIP participation and CRS
participation, and to maintain eligibility through ongoing community monitoring
and enforcement.
In addition to having an NFIP State Coordinator, most States participate in the
CAP‑SSSE, which funds States to provide assistance and monitoring to NFIP
communities through CACs, CAVs, and reviewing regulations in support of the
FEMA Regional Offices.

1.8 Reporting Requirements
a. CIS
The CIS is the management system primarily for NFIP floodplain management activities.
All CAC and CAV findings must be entered into the system within 30 days of the activity,
with further updates entered as needed. Documentation, correspondence, and other
pertinent information of community, State, and Federal actions must also be placed into
the CIS.
b. Purposes
These reports and documentation serve four purposes:
1. Provide a summary of the CAC or CAV by indicating the types of problems
or assistance needed in the NFIP community;
2. Serve as an administrative tool for advancing the CAC or CAV through the
assessment and assistance process by ensuring that necessary follow-up actions
are taken by the NFIP community in a timely manner;
3. Use information from these reports to evaluate how well NFIP communities are
achieving the flood loss–reduction objectives of the program; and
4. Provide information that will not only be useful for determining the overall
effectiveness of the NFIP, but will also assist FEMA’s efforts in determining if any
programmatic or regulatory adjustments to the NFIP are needed.

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Chapter 2
Community Selection Process
2.1 General
a. Selection of CACs and CAVs
The selection of CACs and CAVs occurs through the CAV-CAC prioritization process
described in this chapter. It is a major challenge to balance the staff resources available at
the FEMA Regional Office and State level with the number of communities requiring a CAV
or a CAC in a given year. This chapter describes a “risk-based” approach for community
selection for CACs and CAVs. The “risk-based” approach is intended to help ensure that
limited staff resources are applied in a cost-effective manner to the communities most in
need of a CAV or CAC in each fiscal year. The process for selecting CAVs and CACs for
each Federal fiscal year should occur during the last quarter of the previous Federal fiscal
year. At a minimum, FEMA and the State should agree on the number of CAVs and CACs
to be undertaken before the fiscal year begins. That initial agreement can be modified later
based on actual CAP‑SSSE funding received and other considerations.
b. Analysis of the Available Resources and the Types
of Floodplain Management Assistance Needs
Annually, FEMA analyzes the available resources and the types of floodplain management
assistance needs of communities participating in the NFIP. The resource analysis
includes not only FEMA resources, but also other resources outside FEMA. FEMA enters
into agreements with States under the CAP‑SSSE to provide floodplain management
assistance to NFIP communities. The CAV and CAC are two methods to assess an NFIP
community’s implementation of the floodplain management program.
1. Risk-Based Selection Tool
The HQ Floodplain Management Branch produces an annual risk ranking of communities
in each State, based on the criteria discussed in Section 2.3 and summarized in Figure
2-1. The FEMA Regional Offices, in coordination with State CAP‑SSSE representatives,
will use this report to identify a list of communities for CAVs for each State prior to
the fiscal year in which the CAVs are conducted. The guidelines for selecting which
communities will receive CAVs are provided in Sections 2.2 through 2.5. All communities
not identified for a CAV should receive a CAC or another form of contact.

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Guidance for Conducting CACs and CAVs

2. Determination of Resources
Once a preliminary list of CAVs has been identified for the upcoming fiscal year, the
FEMA Regional Offices, in coordination with their State CAP‑SSSE representatives,
must determine which resource (the FEMA Regional Office or State) will conduct specific
contacts or visits as well as other needed floodplain management services that support
the goals and objectives of the NFIP. In order to establish a final list of CACs and CAVs
for the beginning of each fiscal year, this coordination should occur prior to or during the
CAP‑SSSE Statement of Work negotiation process with States.
Note: When a CAV or CAC is required for a participating Federally Recognized Tribal
Government, the CAV or CAC must be done by FEMA Regional Staff, in recognition
of the established sovereign government to government relationship. (See Section 5.8).

2.2 Risk-Based Criteria for Selecting CAVs and CACs
A risk-based set of criteria will be used to identify communities that need a CAV and
communities that need a CAC. The term “risk-based” is used to identify those areas
where development has occurred or is likely to occur in the SFHA. Future Federal
disaster payments and flood insurance claims could be higher in communities with
floodplains subject to high growth pressure if
floodplain management regulations are not
Risk-based Approach
effectively enforced. These are the
communities where a CAV can have the
When development is permitted in
greatest impact on current and future
high-risk floodplains, property owners
development, including both new development
and communities are placed at a
and substantial improvements (e.g., additions,
greater risk of devastating flood losses.
rehabilitations, repairs, remodeling).
a. Risk-Based Community Selection Process
The risk-based community selection process will result in an annual ranking of all
communities in each State as produced by the required Risk-Based Selection Tool
(Section 2.2 c). The ranking is based on selected indicators from Figure 2-1 to
determine what level of formal NFIP attention is appropriate for each community. The
list of communities can be divided into two groups, a.k.a. “Tier 1 and Tier 2.” The first
Tier 1 group includes those communities with the highest flood risk relative to new and
existing development, in combination with suspected or potential floodplain management
problems. The length of the Tier 1 list will depend upon the number of CAVs the State
and FEMA Region can reasonably accomplish over a five-year cycle. The Tier 2 list
includes those communities that, based on their risk ranking, fall below the Tier 1 priority
listing. These communities should be scheduled for a CAC, training, or other contact
without regard to timeframe, subject to State and FEMA staff availability. However, FEMA
Regional Offices and States do have the flexibility to perform CAVs in appropriate Tier 2
communities, depending on resources and specialized knowledge of local conditions.

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2. Community Selection Process

b. Communities in the Five-Year Cycle
A Tier 1 community should have a CAV done
Tier 2
in order of its risk ranking at least once every
five years. It is anticipated that each year the
These communities should not be
highest priority (Tier 1) communities remaining
scheduled for a CAV unless levels of
in the five-year cycle identified by this process
permit activity, compliance problem
will have a CAV scheduled, and the next highest
indicators, or CAC results temporarily
group of communities (Tier 2) will receive a CAC
qualify them as a Tier 1 community.
or other contact without regard to any cycle. It is
also anticipated that new information obtained
each year will result in some priority changes within and between the two Tier lists. The
number of CAVs and CACs done each year will be subject to the staff resources available
from the FEMA Regional Office and the State CAP‑SSSE program. Given the significant
amount of staff resources required to do a CAV, a reasonable allocation of available staff
hours among CAVs, CACs, and other NFIP duties is essential. Of the amount of time
allocated to CAVs and CACs, the majority should be spent on CAVs in Tier 1 communities.
Some States with a relatively small number of communities are able to do a CAV on every
community (Tier 1 and Tier 2) in five years or less. Those States should evaluate the
comparative risk ranking of each community to determine whether some of the higher risk
communities should have a CAV more frequently than every five years, and if some of the
lowest ranked Tier 1 communities need only a CAC. The key is to focus limited NFIP staff
time on conducting risk-based CAVs for those communities where disaster and NFIP claim
costs will be increased should a community fail to implement its floodplain management
program correctly.
c. Risk-Based Selection Tool
The Risk-Based Selection Tool receives updates of insurance, floodplain management,
mapping, growth rates, and other data from multiple databases to ensure the annual RiskBased Selection Tool accurately reflects the latest information.

2.3 Selecting Communities for a CAV
The FEMA Regional Office, in coordination with the State CAP‑SSSE representative,
will use the Risk-Based Selection Tool to produce the Tier 1 list of communities to
receive a CAV for the upcoming fiscal year. While the list is developed using risk-based
criteria in the best interests of the NFIP, FEMA Regional Offices and States may in
partnership, need to substitute a few alternate high-priority communities based on any new
information or localized knowledge that warrants the adjustment. For example, a surge of
floodplain development around an existing military base that benefited from the closure
of another base would be cause for altering risk-based rankings. A request for a CAV to
accommodate a new CRS applicant is another example of an appropriate substitution. The
overall criteria for selecting or modifying an initial list of CAVs are summarized in Figure
2-1. The Tier 1 and Tier 2 criteria use selected factors from these criteria. Substitutions
made by FEMA Regional Offices or States to the original risk-based CAV (Tier 1) priority

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Guidance for Conducting CACs and CAVs

list shall be noted in the CIS to ensure national priorities met, and any alternate criteria can
be incorporated into future listings.
a. Development Risk
A CAV should be conducted in communities that are experiencing development activity
in SFHAs, as shown by the “Indicators of High Risk to Current/Future Development,”
paragraph 2-3.b). In addition, selection must also consider high potential for damage
to existing construction in the SFHA, as shown in paragraph 2-3(c), “Indicators for
Communities with High Risk to Existing Buildings/Repetitive Loss Properties.” Lastly,
once a preliminary list is developed based on
these criteria, the highest priority in selecting
In determining which communities
a CAV for the upcoming fiscal year should
should receive the level of attention
be based upon “Indicators of Information
afforded by a CAV, a higher priority is
for Communities with Known or Suspected
given to those communities that are
Program Deficiencies or Violations,” as
experiencing development in the SFHA.
discussed in paragraph 2-3(d).

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2. Community Selection Process

Communities with Current and Future High Risk of Floodplain Development:

‰‰Population Growth (Current and Projected)
‰‰Number of building permits granted for new construction in SFHA
‰‰Number of CLOMRs and LOMRs
‰‰Annexations
‰‰Number of post-FIRM insurance policies
‰‰Number of NFIP claims in Zones B, C, and X
‰‰Number of State floodway permits or other higher standards (where applicable)
‰‰Increase in Policies in Force (PIF)
‰‰Percent of community in the SFHA
Communities with a High Risk to Existing Buildings/Repetitive
Loss Properties:
Other indicators that a CAV is needed:

‰‰Number of structures in the SFHA
‰‰Number of variances granted in the SFHA
‰‰Number of insured repetitive loss structures
‰‰Number of substantially damaged structures (claims)
‰‰Population in the SFHA
‰‰PIF (policy count pre- and post-FIRM buildings)
‰‰Number of flood insurance claims
‰‰Ratio of claims to PIF
‰‰Percentage of community land area vs. SFHA
‰‰Number of ICC claims
‰‰Number of structures included in Grant Projects
Communities with Known or Suspected Program Deficiencies or Violations:
Indicators of potential problem communities:

‰‰Unresolved issues from a past CAV or CAC
‰‰State agencies’ comments
‰‰Issues identified by CRS Verification Visit
‰‰Citizen complaints
‰‰Submit-to-Rate Applications
‰‰Insurance claim files indicating potential substantial damage/improvements
‰‰Number of variances
‰‰Probation/suspension history
‰‰FEMA declared disasters, including reports of NFIP compliance issues (SDE, etc.)
‰‰Number of CLOMRs and LOMRs that have raised apparent non-compliance issues
Communities with Other Requirements for a CAV

‰‰Prerequisite for CRS participation
‰‰Prerequisite for CRS Class 4 or better

Figure 2-1. Criteria for Selecting an Initial List of CAVs (Summary)

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Guidance for Conducting CACs and CAVs

As stated in paragraph 2-2(c), a Risk-Based Selection Tool is required to determine Tier 1
and Tier 2 priority communities. However, much of the criteria for CAV selection (indicators
and many sources) are available in the CIS in various reports, specific subject screens, or
by link to another appropriate database, such as the NFIP Bureau and Statistical Agent. As
stated previously, the Tier 1 and Tier 2 Risk-Based Selection Tool uses selected factors as
discussed below.
Note: Please refer to the annual CAP‑SSSE program guidance for any updates and policy
changes to the risk-based CAV and CAC selection criteria.
b. Indicators of High Risk to Current/Future Development
Indicators of a community’s current and future development in the SFHA are important
for targeting CAVs to ensure a community’s floodplain management regulations are being
implemented and enforced. Increases in potential flood damages to new and existing
floodplain structures will likely occur in rapidly growing communities lacking adequate
regulations or enforcement requirements. The following are several major indicators for
determining whether a community is experiencing development in the SFHA.
Multiple factors should be used in making this determination. Other factors may also
be used in conjunction with these data to verify development activity in the SFHA (e.g.,
Letters of Map Revision or LOMRs).
1. Population Growth (Current and Projected). Growth rates from the Census and
other sources.
2. Number of building permits granted in the SFHA. Sources for this information are
the historical Biennial Report, data gathered from the latest CAC or CAV, or any
other source.
3. Number of Conditional Letters of Map Revision (CLOMRs) and LOMRs. The source
for this information is mapping databases.
4. Annexations or boundary changes. Sources for this information are data gathered
from the latest CAC or CAV, mapping “suspense” files, the U.S. Census Bureau, or
any other authoritative source. However, the State Coordinator should be in contact
with the State Office that processes the annexations, and this listing from the State
Office should be consulted prior to conducting a CAC or CAV.
5. Number of post-Flood Insurance Rate Map (FIRM) flood insurance policies.
The source for this information is insurance data.
6. Number of NFIP Claims in Zones B, C, and X. The source for this information is
insurance claims data compared against the GIS-based National Flood Hazard Layer
from the effective FIRMs.
7. Number of State Floodway or other more restrictive State permits. The source for this
information is the NFIP State Coordinator, or the respective State permitting agency,
if different.

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2. Community Selection Process

8. A marked increase in NFIP Policies in Force (PIF). The source for this information
is insurance data.
9. Percent of community in the SFHA. This number is based on GIS analyses.

c. Indicators for Communities with High Risk to Existing
Buildings/Repetitive Loss Properties
Because existing development is especially vulnerable to future damages, communities
should be made aware of the preventive and corrective measures and the floodplain
management requirements of the NFIP for regulating redevelopment, such as substantial
improvements to existing structures. The following are indicators for determining whether
a community has a high potential for flood damage or repetitive losses to existing
development. Some of these indicators, when used alone, are insufficient for determining
whether a community has a high potential for flood damage or repetitive losses to existing
development. Multiple factors should be used in making this determination. Other factors
may also be used in conjunction with these data to verify existing development activity in
the SFHA.
1. Number of structures in the floodplain. Sources for this information are data gathered
from the latest CAC or CAV, historical Biennial Report data, CRS data, or data from
any other known source.
2. Number of variances granted in the SFHA. Sources for this information are
data gathered from the latest CAC or CAV, historical Biennial Report data, CRS
verification visit, or data from any other known source.
3. Number of insured repetitive losses. The source for this information is flood insurance
claims information.
4. Number of suspected substantially damaged structures. The source for this
information is flood insurance claim information.
5. Population in the SFHA. This estimated computation uses Digital Flood Insurance
Rate Map (DFIRM) and Census Tract data.
6. PIF. Number and dollar amount of pre- and post-FIRM flood insurance policies. The
source for this information is flood insurance application data.
7. Number and dollar amount of flood insurance claims. The source for this information
is flood insurance claims information.
8. Ratio of claims to PIFs. The source for this information is flood insurance claims and
policy data.
9. Number of increased cost of compliance claims. The source for this information is
flood insurance data.
10. Number of buildings included in Hazard Mitigation Assistance (HMA) Flood Grant
Projects (flood mitigation assistance [FMA], repetitive flood claims [RFC], severe
repetitive loss [SRL]).

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Guidance for Conducting CACs and CAVs

d. Indicators of Information for Communities with Known
or Suspected Program Deficiencies or Violations
The following are sources of information for identifying communities with known
or suspected floodplain management problems or issues:
1. Unresolved Issues from previous CACs and CAVs.
2. State or local agency comments.
3. Issues identified through a CRS verification visit.
4. Citizen complaints.
5. Submit-to-Rate Flood Insurance Applications that indicate that non-elevated
structures have been built with the lowest floor two feet or more below the Base
Flood Elevation (BFE), and that elevated structures have been built with enclosures
having the lowest floor 1 foot or more below the BFE. The source for this information
is flood insurance data.
6. Insurance claims data that may indicate substantial improvement problems. The
source for this information is flood insurance data.
7. Number of variances granted in the SFHA. Sources for this information are
data gathered from the latest CAC or CAV, historical Biennial Report data, CRS
verification visit, or data from any other known source.
8. Probation/Suspension history; requests to be reinstated.
9. Recent Presidentially declared disasters, including reports of NFIP
compliance issues.
10. Number of CLOMRs and LOMRs that have raised apparent non-compliance issues.

All of the above information, if applicable, can be found in FEMA databases, with the
exceptions noted above.

2.4 Other Situations that Require a CAV
a. Requests to Participate in the CRS Program
A CAV will be required for a community requesting to participate in the CRS, or for one
requesting reinstatement to the CRS. The community should receive a CAV by the State
or FEMA Regional Office staff within six months of an incoming request from the Chief
Executive Officer.
b. Changes in CRS Class
A CRS community improving to a Class 4 or better must receive a CAV.

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2. Community Selection Process

2.5 Selecting Communities for a CAC
The following are the major criteria FEMA will use in selecting communities for CACs.
Generally, all CAC locations should be identified prior to the beginning of the fiscal year
at the time of CAV selections.
a. Selection Criteria for CACs
CACs should be conducted for communities based on the following:
1. All communities that are identified for a CAC on the Tier 2 Risk-Based
Selection Report.
2. Communities experiencing minimal development and/or that are issuing a small
number of building permits, and have not been contacted by means of a CAC,
CAV, or any other type of floodplain management assistance service.
3. Communities that have requested assistance.
4. Communities that have appointed or designated a new local official with the
responsibility, authority, and means to implement the NFIP.

b. Contacts Through Brief Visits
Contact with communities by means of a brief visit should be conducted only in
conjunction with other floodplain management assistance services, for travel savings
and efficiency. For example, CACs can be clustered geographically or conducted in
conjunction with a CAV or other floodplain management services conducted in nearby
communities. If a telephone call is used as the method of contact, communities may be
selected in any logical order.
c. Communities with Serious Program Deficiencies
or Violations
A CAC should not be conducted in communities where more serious floodplain
management problems or issues are known or suspected, particularly in communities
where one or more substantive program deficiencies or violations have been identified,
or for CAV candidates identified in the Risk-Based Selection Tool.
Exception: An exception to the selection process for CACs and CAVs is the post-disaster
environment. In an effort to assist communities in recovering more quickly, increased postdisaster staffing often allows a greater opportunity to contact more communities over a
shorter period of time. Consequently, State, FEMA Regional Office, and FEMA disaster
assistance employees may need to perform post-disaster CACs on affected communities,
regardless of their risk-based status. Therefore, in deference to the community focus on
post-disaster recovery, it is not recommended to conduct a CAV sooner than six months to
one year after a disaster declaration.

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Chapter 3
Community Assistance Contact
3.1 General
The CAC is a telephone call or brief visit to an
NFIP community for the purpose of establishing
or re‑establishing contact to determine if any
program-related problems exist and to offer
assistance. A CAC consists of four distinct
phases: Preparation, Community Contact,
Documentation, and Follow-up. For each
phase, the activities to be conducted are much
less comprehensive than for a CAV. For this reason, a CAC should not be conducted in
communities with known or suspected substantive program deficiencies or violations.
CACs may also serve as a follow-up to ensure compliance issues have been resolved;
or as part of post-disaster community coordination to determine what level of NFIP
assistance beyond immediate identification of substantially damaged structures may be
needed. If a CAC reveals substantive compliance issues that cannot be resolved at that
level and a CAV is needed, staff should indicate in the CIS that a CAV be scheduled to
fully analyze and address these issues.
CACs are typically done to maintain
formal NFIP contact with lower risk
Tier 2 communities and to check on
the status of floodplain management
implementation after a new Floodplain
Administrator has been named.

3.2 The Difference between Technical Assistance
and a CAC
A technical assistance contact, done in person or by phone, may require addressing
one or more NFIP floodplain management issues in the community. Hundreds of these
general technical assistance interactions occur each year and are recorded in the General
Technical Assistance screen in the CIS. Technical assistance requests are typically
generated through phone calls or e-mails from community officials, complaints from
property owners, calls from building contractors, and inquiries from insurance agents.
In contrast, a CAC requires a more comprehensive discussion of the six basic CAC
topics: Floodplain Management Regulations; FIS and FIRM availability and accuracy;
Development Permit and Review Process; NFIP Community Information and Verification;
Potential Deficiencies or Violations; and any needed follow-up or community action. This
chapter addresses these topics. A discussion of these topics with the local Floodplain
Administrator should provide FEMA or the NFIP State Coordinator with a reasonable
sense of how the community is implementing the floodplain management program. A
CAC usually includes a level of technical assistance when specific issues are raised and
addressed as part of the broader discussion.

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Guidance for Conducting CACs and CAVs

3.3 Preparation
The FEMA or State staff person responsible for conducting a CAC should have a sound
knowledge of the NFIP, have taken the basic floodplain management course, and have
attended at least three CAC interviews conducted by an experienced FEMA or State
NFIP professional.
Before any contact is made with a community, certain key information should be reviewed.
At a minimum, the information listed in section 3.3 (a through e) should be reviewed prior
to the contact. Additional relevant data and information should be reviewed when a greater
familiarity with a community is necessary. A
A major source of information is the
list of suggested additional information and
community file that is maintained in
sources is provided in section 4.2 of this
the respective FEMA Regional Offices,
document. A list of suggested materials to bring
or similar files maintained by the State.
for brief visits is also provided in section 4.5.
a. Community Floodplain Management Regulations
State agencies conducting CACs on behalf of FEMA should contact or visit their respective
FEMA Regional Office to obtain or verify the latest floodplain management regulations,
including building codes. If new regulations are pending, it may be necessary to review
both existing and pending regulations.
b. Flood Insurance Study and Maps
The latest FIS and FIRM should be reviewed.
c. CAC and CAV Reports
Review previous CAV and CAC information to provide a basis for comparison with past
performance, to identify areas and issues, and to evaluate progress in implementing the
listed recommendations. If applicable, identify any unresolved compliance issues from
the most recent CAC or CAV.
d. NFIP Community Data
Review NFIP community data contained in the CIS and in the Risk-Based CAC/CAV
Selection Tool. Additional insurance data can be found online through the NFIP Bureau
and Statistical Agent. Use these data systems and other information to evaluate the
following issues:
1. If the community participates in the CRS program, identify its current CRS ranking
and verified activities.
2. Review the most recent claims, policies, or other insurance data for the community.
Identify the number of repetitive loss and severe repetitive loss buildings in the
community. If applicable, review the submit-to-rate flood insurance applications to
identify possible violations or improper variances.

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3. Community Assistance Contact

3. Review the number of LOMRs or Physical Map Revisions (PMRs) as a preliminary
measure of the community’s development activity and/or to determine whether a
restudy is necessary. Determine if there are any CLOMRs that have not been closed
with a LOMR. Determine if an FIS is currently underway for the community, and
determine the FIS status.
4. Review the building code adopted, if applicable, for flood provisions contained within.

e. Recent Correspondence
Review any recent correspondence with the community that may be useful in assessing
local attitudes toward land-use regulations and the NFIP. Use this correspondence to
assess the community’s level of NFIP-related activity, past history, technical assistance
needs, and problems in implementing NFIP requirements; to identify those at the local
level who are involved with NFIP implementation; and to determine any outstanding issues
that require follow-up or site investigation.

3.4 Community Contact
In conducting the call or brief visit, appropriate judgment should be used as to how much
detail to give regarding each aspect of the community’s program and where to focus
needed attention. This visit or call is brief, meant to discuss overall community knowledge
and implementation.
Purpose of Contact. Generally, the telephone call or brief visit should be with the local
official who has the responsibility, authority, and means to implement the NFIP and its
requirements. Before any detailed discussion of the community’s floodplain management
program begins, explain the purpose of the contact. The CAC includes six areas that
should be addressed: 1) floodplain management regulations; 2) map availability, accuracy,
and recent flooding history; 3) development permits and review process; 4) NFIP
community information review and verification; 5) potential deficiencies or violations; and
6) any follow-up and/or community action that is needed.
The recommended approach for addressing each of these areas is provided below
and includes a list of issues for discussion during the contact. The discussion should
be tailored to the method of contact (telephone or brief visit). A detailed set of CAC
discussion topics is listed in Section 3.4 (a through f), and an abbreviated checklist of
these issues (shown in Appendix A) may be used during the actual contact as a reference.
Several FEMA Regional Offices and States have developed their own CAC checklists
tailored to their needs. If, as a result of a telephone contact with a community, program
deficiencies or violations are suspected, it may be necessary to follow-up with a brief visit
or a CAV to the community to gain a better understanding of the problem(s) and/or to
verify suspected issues.

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Guidance for Conducting CACs and CAVs

Most CACs are done by telephone and are intended to establish or re-establish contact to
determine if any program-related problems exist, to provide technical assistance, and to
build a relationship that will encourage the community official to contact the State or FEMA
Regional Office when NFIP-related questions
A courtesy visit to meet a new
arise. CACs that can be made by a brief visit,
community official can be turned into
when practical, may provide more effective
a CAC: when, for example, the NFIP
communication with the community official.
representative is driving through a
Whether the CAC is done by brief visit or by
community for other purposes, such
telephone, preparation should be done in
as a final meeting or a CAV.
advance of the CAC.
If, however, the community visit occurs through a passing travel opportunity, the NFIP
representative can turn that visit into a CAC. The representative should call the community
official in advance, rather than dropping in unannounced. The community data and other
information should be reviewed later and the contact completed by telephone if necessary.
Floodplain Tour. A tour of the SFHA is not a requirement of the CAC; however, a tour
may be conducted to become familiar with the community; or may become necessary
should the CAC identify any problems or issues or if one or more substantive program
deficiencies/violations is suspected.
The following key points are a guide for discussions with the community.
a. Community Floodplain Management Regulations
1. Determine whether the floodplain management regulations reviewed are the most
current. If not, ask the community to either provide or send a copy of the current
adopted regulations, depending on the method of the contact.
2. Ask whether the community has adopted a building code (See Figure 4-1 Adoption of
Building Codes).
3. Discuss any inadequacies, omissions, and any overlaps between above adopted
regulations, building codes, or other problems identified during the prior review of the
regulations.
4. If appropriate, ask if the community needs assistance in updating or revising the
current floodplain management regulations. Discuss a schedule for working with the
community to accomplish this requirement.
5. Discuss other issues related to the community’s floodplain management regulations.

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3. Community Assistance Contact

b. Ascertaining Map Availability and Accuracy
1. Determine whether the FIS and FIRM in use by the community are the most current
versions. Determine whether community officials need instruction on using DFIRM
data. Be sure officials understand what types of resources are available from the
FEMA Map Service Center (MSC) web site.
2. Ask whether other maps or studies are used for regulating development in the SFHA.
If other maps and studies appear to have an impact on the effective BFEs, or if the
community has developed BFEs in areas where elevations have not been provided
by FEMA, obtain a copy of the maps or studies.
3. Determine whether the local official has any particular problems in using FEMA maps
or study data (e.g., determining a BFE in A Zones without BFEs).
4. Inquire whether the community has experienced any recent flooding. Ask the
appropriate individuals to briefly describe the extent (i.e., source and location) of
damage. For example, determine if any structures were substantially damaged and,
if so, whether the damage occurred in areas not designated as an SFHA. If so,
determine the general cause (e.g., stormwater/drainage problems, an event greater
than the 100‑year frequency flood, failure of a flood-control project, project design
standards exceeded, inaccuracies in the mapping, or issues of hydrology/hydraulics).
5. Inquire whether the local official has any problems with the accuracy or completeness
of the FIRM or FIS report. Try to narrow problem areas down to specific stream
segments and panels whenever possible.
6. Determine whether the boundaries of the community have been modified by
annexation or if the community has otherwise newly assumed or no longer has
authority to adopt and enforce floodplain management regulations for a particular
area. If so, determine if any corporate boundary change involved an SFHA.
Obtain a copy of an official community map showing the boundary changes and,
if one is available, obtain a copy of any ordinance or other legal description of the
community’s new boundary limits. This map may also be used by FEMA as part of
a map revision.
7. Inquire whether any structural flood-control projects are planned, are under
construction in the community, or have been completed since the date of the last
CAC or CAV. Ask if this project has changed or will change the boundary of the SFHA
on the FIRM. If so, determine whether officials plan to submit a LOMR, as is required
to update the FIRM.
8. Because many map revisions are based on channel modifications and associated
channel maintenance activities, determine whether the community is aware of its
maintenance responsibilities.
9. Determine whether local officials are familiar with the process for Appeals, Revisions,
and Amendments to FIRMs.
10. Discuss any other map- or study-related issues.

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Guidance for Conducting CACs and CAVs

c. Development Review Process
1. Determine what the development review, permit, inspection and appeals procedures
are for new construction and for rehabilitations, additions, or other improvements of
existing structures, particularly those that may meet the substantial improvement or
substantial damage definitions.
2. Determine what the review, permit, and inspection procedures are for development
other than structures. Examples are mining, dredging, filling, grading, paving,
excavation, or drilling operations.
3. Ask local officials to describe the results of the permit review process and how
determinations are recorded and maintained. For instance, some communities
purge files, such as certifications on a plat map or design drawings, every five years.
Remind communities that these records must be maintained in perpetuity.
4. Ask the Floodplain Administrator (FPA) what review procedure is used for ensuring
that all necessary permits required by Federal or State law have been received from
the responsible governmental agency. Such permits follow Section 404 of the Clean
Water Act, Section 10 of the Rivers and Harbors Appropriation Act, and Sections 9
and 10 of the Endangered Species Act [44 CFR §60.3(a)(2)]. Ask the community
whether it “withholds” or “conditions” the floodplain permits until a property owner
obtains the other permits.
5. Determine what procedure is used for the following:
(a) Obtaining the lowest floor elevation in all A Zones where BFEs are used
[44 CFR §60.3(b)(5)];
(b) Obtaining the elevation of the bottom of the lowest horizontal structural member
of the lowest floor in all V Zones [44 CFR 60.3(e)(2)]; and
(c) Maintaining a record of all “as-built” lowest floor elevation data. (Use of the FEMA
Elevation Certificate is required only for CRS communities/Flood Insurance
Policies and is recommended for non-CRS communities.)
6. Determine what procedure is used to secure certifications for the following:
(a) Floodproofed, non-residential structures [44 CFR §60.3(c)(4)];
(b) Openings for fully enclosed areas below the lowest floor subject to flooding when
the design differs from minimum NFIP criteria [44 CFR §60.3(c)(5)]; Cite/provide
Technical Bulletin 1;
(c) Anchoring of a pile-and-column foundation and structure attached
thereto in all V Zones [44 CFR §60.3(e)(4)]; and
(d) Breakaway walls in all V Zones when design strength exceeds the minimum
NFIP criteria [44 CFR §60.3(e)(5)]; Cite/provide Technical Bulletin 9.

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3. Community Assistance Contact

7. Determine what process the community uses to determine the following:
(a) Where floodways have not been designated, cumulative floodplain development
will not increase the water-surface elevation of the base flood more than 1 foot in
Zones A1–30 and AE [44 CFR §60.3(c)(10)]; and
(b) Where floodways have been designated, encroachments would not result in any
increase in the flood levels within the community during the occurrence of the
base flood discharge in SFHAs [44 CFR §60.3(d)(3)].
8. Determine the community’s process for ensuring that buildings are constructed with
electrical, heating, ventilation, plumbing, air conditioning equipment, and other service
facilities that are designed and/or located to prevent water from entering or accumulating within the components during conditions of flooding [44 CFR §60.3(a)(3)].
9. Determine the community’s process for ensuring that all new construction and
substantial improvements are designed (or modified) and adequately anchored
to prevent flotation, collapse, or lateral movement of the structure resulting from
hydrodynamic and hydrostatic loads, including the effects of buoyancy. Determine
the process for ensuring that construction is done with materials resistant to flood
damage [44 CFR §60.3(a)(3)]; Cite/provide Technical Bulletin.
10. In communities with A Zones without BFEs:

•

Find out whether local officials are requiring flood damage protection measures,
such as elevation, anchoring, and use of proper flood damage-resistant
construction materials. [44 CFR §60.3(b)(2)].

•

Determine whether local officials require BFE data for subdivisions of
at least 50 lots or 5 acres [44 CFR §60.3(b)(3)].

•

Also determine whether local officials obtain, review, and reasonably use any
BFE and floodway data available from a Federal, State, or other source [44 CFR
§60.3(b)(4)]. Discuss the option of having the community require that the permit
applicant develop a BFE.

Indicate that BFEs must be derived from other sources or be developed using
methodologies comparable to an FIS. Discuss available options such as Quick
2, described in Managing Floodplain Development in Approximate Zone A Areas
(FEMA‑265).
11. Ask the local officials to describe the process for inspecting development permitted
under the floodplain management regulations, including building codes. The
description should include how often and at what stages of the construction process
there are inspections for: proper floor elevations; number, size, and location of
openings; and protection of mechanical and electrical equipment; and whether there
are inspections at points during construction. Also, determine whether the community
has an ongoing inspection program to discover unpermitted development.
12. Ask the local officials to describe the formal enforcement procedures and actions the
community can take to remedy building and development violations. Inquire as to
actions currently being taken to remedy violations.

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Guidance for Conducting CACs and CAVs

13. Have local officials describe the regulatory standards and operating procedures
for variances. In cases where variances have been granted, obtain copies and ask
whether notifications to property owners were provided concerning the effect of the
variance on flood insurance rates.
14. Have local officials describe the process used to review proposals for subdivisions
within the SFHA, including what flood-related issues are reviewed.
15. Inquire about the general use of land in an SFHA and the potential for future
development in the floodplain.
16. Discuss any other issues related to the community’s floodplain management
practices or issues that affect enforcement/compliance and development conditions
in the floodplain.
17. Address any unresolved floodplain management issues from a previous CAV or CAC.

d. NFIP Community Information Review and Verification
1. Review and verify with local officials any relevant data contained in CIS (e.g., name
and address of CEO; address of Floodplain Administrator; number of PIFs and the
number of flood insurance claims paid; etc.).
2. Ask how long the current Floodplain Administrator has been in place, and how many
staff members support the floodplain management activities in the community.
3. Ask the Floodplain Administrator the type of training that he/she has had and whether
it included the NFIP. Ask whether the Floodplain Administrator, as well as any other
floodplain staff, is a Certified Floodplain Manager (CFM). Describe what NFIP training
is available and make recommendations for training.

e. Address Program Deficiencies and Potential Violations
Discuss any program deficiencies or potential violations identified during the CAC.
Highlight those areas where the community deserves a compliment for implementing
the local program.
f. Summarize the Findings and Follow-up Actions
Discuss the findings, next steps, and any follow-up assistance to provide. Identify any
community action that will be required.

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3.5 Documentation
a. The Findings of the Contact Shall be Entered in the CIS
to Facilitate FEMA’s Evaluation of Individual Floodplain
Management Programs and the NFIP Nationally
It is essential that sufficient documentation and comments/notes of the CAC are entered
into the CIS, as the CIS serves to document the types of problems or the assistance
needed in the community. It also serves as a tool for advancing the contact through the
assessment and assistance processes by ensuring that the necessary follow-up actions
required by the community are made in a timely manner.
b. Document in the CIS Whether a Community Floodplain
Management Program Deficiency has been Identified
For each floodplain management program category (e.g., floodplain management regulations, administrative and enforcement process and procedures, engineering-flood maps
and study, other), indicate whether the floodplain management problem is serious, minor,
or non-existent. The following guidance is provided for completing this section in the CIS:
1. Floodplain Management Regulations
Review the CIS ordinance screens for the community and update as necessary based on
the discussion with the community.
(a) Serious
Serious program deficiencies in the community’s floodplain management regulations are
defined as those not compliant with NFIP floodplain management criteria; or those that do
not contain adequate enforcement provisions; or those that cannot be enforced through
other mechanisms. Such deficiencies could result in the community’s suspension.
(b) Minor
Minor program deficiencies in the community’s floodplain management regulations are
those that need to be corrected, but that have not impeded the community’s ability to
enforce the NFIP floodplain management provisions or that are not critical to effectively
implement the regulations.
(c) None
“None” indicates that the community’s floodplain management regulations are compliant.

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Guidance for Conducting CACs and CAVs

2. Administrative and Enforcement Process and
Procedures
(a) Serious
Serious program deficiencies in a community’s administrative and enforcement processes
and procedures are those that have resulted or could result in substantive violations
that increase potential flood stages or damages in the community. Examples of such
substantive violations include:

•

Obstructions in floodways or stream channels that increase flood stages;

•

Residential structures that are located with a lowest floor below the BFE;

•

Non-residential structures having a lowest floor below the BFE and not
properly floodproofed; and

•

Structures in V Zones with non-breakaway walls below the BFE.

Further Examples of Serious Program Deficiencies Include the Following:

•

Failure to require permits for proposed construction or other development within floodprone
areas or failure to review such permit applications and subdivision proposals to ensure that
all such construction and development is adequately designed, located, constructed, and
anchored to minimize flood damage.

•

Failure to obtain and reasonably use any available flood data as criteria for setting local
elevation and floodproofing requirements.

•

Administrative procedures and practices that are not workable or cannot reasonably
ensure compliance with the local ordinance (e.g., the community does not inspect new
structures or changes to existing structures for compliance; the community does not
record “as built” elevations).

•

Variance procedures or variances granted that are not consistent with NFIP variance criteria.

(b) Minor
Minor program deficiencies in a community’s administrative and enforcement processes
and procedures are those that are easily corrected and have not resulted in multiple and
substantive violations or increased exposure to flood losses. Minor program deficiencies
generally involve some type of mitigating factor and can be resolved within a relatively
short period of time with technical assistance. Problems may be considered minor if a
community demonstrates a willingness to take positive action to resolve them.

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3. Community Assistance Contact

Examples of Minor Program Deficiencies Include the Following:

•

Permit or variance records that are not organized or easily accessible;

•

The BFE is not indicated on the permit; and

•

The community is unfamiliar with certain NFIP requirements (e.g., floodway
encroachments, notifying property owners of the effect of a variance on flood insurance
rates), but no specific violations resulted from the community’s lack of knowledge and
unfamiliarity with the requirements.

(c) None
None indicates that no problems were identified.
3. Engineering: Flood Maps and FIS
(a) Serious
Serious problems with the community’s flood maps or FIS are those that have
communitywide impact and involve major changes in the floodway or adjustments to the
BFE that can be remedied by a restudy, or include those involving a boundary change that
includes significant additional SFHAs. Serious problems with the community’s flood map or
study generally need immediate action for a map revision. Provide as specific information
as possible (FIRM Panel and Reach) to the FEMA Regional Office Engineer along with a
written description of the problem.
(b) Minor
Minor problems with the community’s flood maps or study are those that affect only one or
two map panels or one flooding source and can be remedied by a LOMR or PMR. Also, a
boundary change that does not include areas in the SFHA or that includes a relatively small
parcel of land in the SFHA with little or no development located on the property is considered a minor problem that generally can be resolved with the next comprehensive revision.
(c) None
None indicates that no problems were identified.
4. Other Problems or Issues that do not Fit into the
Regulations, Administrative, or Engineering Categories
(a) Serious
Serious problems are actions being taken by the community that are inconsistent with or
cannot reasonably ensure compliance with local floodplain management regulations.

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Guidance for Conducting CACs and CAVs

(b) Minor
Minor problems are actions being taken by the community that need to be corrected, but
that have not impeded the community’s ability to enforce the NFIP floodplain management
provisions; or are not critical to the effective implementation of the regulations.
(c) None
None indicates that no problems were identified.
c. Serious and Minor Issues Require that the CIS CAC
Fields Have Additional Narrative to Address the Details
that Support the Findings
These comments should be entered into the CIS CAC fields under the appropriate
heading, along with any other narrative findings.
d. CAC Information
CAC information, including the findings, should be entered into CIS within 30 days of
contacting the community.
e. Any Documentation Related to Follow-up Activities
Should be Entered into the CIS Within 15 Days from the
Date that Follow-up Activities are Completed and the CAC
is Considered Closed
A chronology of events or activities related to issues or problems identified during the
CAC, or related promises of assistance, should be entered into the CIS “Findings” or
“Follow-up” screens as appropriate and should include any other relevant follow-up
documentation.

3.6 Follow-up
a. The CAC Information Entered into CIS Should Indicate if
Follow-up Action is Required or if Further Action is Needed
A CAC is not concluded until each of the issues documented in the findings are resolved
and assistance is provided. Community assistance may take a number of different forms
depending on the situation and the problems and major issues discovered. It may be as
simple as providing a Technical Bulletin; or it may involve more extensive efforts, such
as providing assistance in updating the
The CAC report in the CIS should provide
community’s floodplain management
specific examples of the mapping problems
regulations, a workshop on implementing
identified and the appropriate FEMA
the NFIP and its requirements, or a CAV.
Regional NFIP engineer should be notified
Refer to Chapter 7 for additional guidance
of those issues.
on follow-up activities.

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3. Community Assistance Contact

b. A CAC Should not be Closed Until Each Issue or Problem
Identified has been Resolved or Remedied to the
Maximum Extent Possible, and any Assistance Promised
to the Community has been Completed
States should coordinate with FEMA Regional Offices to recommend whether a CAV,
enforcement action, or other extensive type of follow-up is required.
c. A Follow-up Letter is not Required to be Sent to Each
Community that has been Contacted – Especially Those
Where Problems Appear to be Non-existent. However, a
Follow-up Letter Should be Sent in the Following Instances
1. When a community raises a particular issue or problem and a letter would affirm the
response given or provide further clarification of the issue to the community.
2. When there are promises to provide information to the community (e.g., brochures,
handbooks, or other NFIP materials). If materials are mailed, a short cover letter
should be included. If the information is suitable for e-mail attachments, then an
e-mail message is appropriate. A copy of the letter or e-mail should be placed in the
community file (and copied into the CIS) to document that the follow-up action has
been completed.
3. When deficiencies in the floodplain management regulations, program deficiencies,
or possible violations have been identified in Section 3.6 (b above). Document
findings in a letter, along with any required follow-up, and inform the community if a
CAV may be scheduled in the future.

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Chapter 4
Community Assistance Visit: Preparation
4.1 General
The CAV is a scheduled visit to an NFIP
community for the purpose of conducting a
comprehensive assessment of the community’s
floodplain management program and its
knowledge and understanding of the floodplain
management requirements of the NFIP. The
purpose of a CAV is also to provide assistance
to the community to remedy program deficiencies and violations identified during the
CAV. The CAV consists of four distinct phases: 1. Preparation; 2. Community Visit;
3. Documentation/assessment or evaluation report; and 4. Follow-up. This chapter
addresses the first phase, Preparation.
The purpose of the CAV is to assess
the local floodplain management
program and offer assistance to the
community in understanding the
NFIP requirements.

The FEMA or State staff person responsible for conducting a CAV should have a
sound knowledge of the NFIP regulations, have attended at least two NFIP floodplain
management courses, and have assisted on three or more CAVs led by an experienced
FEMA or State NFIP professional.
a. Preparation and Background Work is Important for
Three Reasons
1. To become familiar with the community;
2. To ensure complete coverage of the issues when the visit takes place; and
3. To adequately characterize a community’s implementation of the NFIP by combining
the information gathered during this phase with the information obtained during the
actual visit.

b. Preparation and Background Work Involves the Following
Four Important Steps
1. Review pertinent information about the selected community;
2. Compile a list of issues and sites;
3. Contact the community to schedule a visit; and
4. Compile a list of materials and equipment for the CAV.

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Guidance for Conducting CACs and CAVs

4.2 Review Pertinent Community Information
In order to assess an NFIP community’s floodplain management needs and determine
the effectiveness of a community’s floodplain management program, it is necessary to
understand the individual community characteristics and NFIP background.
a. Sources of Data and Information
All sources of information should be reviewed as early as possible to determine whether
flood data and other floodplain management information are available. Pertinent
information for the CAV should be obtained well in advance so that issues and problems
can be compiled prior to the visit. The basic source of floodplain management data for this
purpose is FEMA’s CIS.
States conducting CAVs under an agreement with FEMA may acquire pertinent data
using their own community files, from information obtained by a visit to the FEMA
Regional Office, by using the CIS, or by requesting copies from the FEMA Regional
Office via e-mail.
b. Types of Data and Information
1. NFIP Community Data
Review NFIP community data contained in the CIS, insurance, mapping and other
databases, and in Regional digital storage files and community/State web sites for:
(a) The most recent claims, policies, or other insurance data for the community,
such as substantial damage reports. If applicable, review submit-to-rate flood
insurance applications to identify violations, improper variances, or insurance
data errors.
(b) Previous CACs and CAVs.
(c) FEMA grant projects showing acquisition and elevation projects by address (to
develop a sample to verify that acquisition projects remain as open space and
that elevation projects are NFIP compliant).
(d) Online information, such as ordinances, community permits, and FEMA
Elevation Certificates.

2. Floodplain Management Regulations
Review the latest floodplain management ordinance adopted by the community. If the
ordinance does not contain all of the NFIP minimum requirements, ask the officials
whether the requirements are contained in the community’s building codes, subdivision
regulations, zoning ordinance, or other regulations. These documents must also be
reviewed to determine whether the community’s floodplain management regulations are
compliant. State agencies should coordinate with the FEMA Regional Office to verify
that the latest versions of the floodplain management ordinance and other codes and

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4. Community Assistance Visit: Preparation

regulations are maintained in the community file. If new regulations are pending, including
any building codes, it may be necessary to review both existing and pending regulations.
In reviewing Figure 4-1, “Adoption of Building Codes,” inquire whether the community
has adopted one or more of the referenced codes. Find out which codes have been
adopted and whether those codes were amended in a way that modified or deleted the
flood-resistant provisions contained therein. Such changes could affect the consistency
and compliance with the NFIP requirements. Also, if applicable, find out whether the
community has adopted Appendix G of the International Building Code or another
companion ordinance to address those NFIP requirements that are not contained in the
body of the I-Codes™.
Any discrepancies among the community’s ordinance, building codes, and subdivision and
zoning ordinances will need to be flagged for clarification and resolution, starting with the
community meeting.

Adoption of Building Codes
With the publication of the International Code Series (I-Codes™) in 2000 and more
recent editions, and the National Fire Protection Association (NFPA) NFPA 5000:
Building Construction and Safety Code™ in 2003 and more recent editions, more
and more communities are enforcing floodplain management requirements through
their building codes. Both the I-Codes™ (2003 edition and more recent editions)
and the NFPA™ 5000 (2003 edition and more recent editions), if adopted without
amendments, are consistent with the minimum flood-resistant design and construction
requirements of the NFIP . The I-Codes™ includes the following series of codes:

•
•
•
•
•
•

International Building Code® (IBC®),
International Residential Code™ (IRC™),
International Plumbing Code®,
International Mechanical Code®,
International Fuel Gas Code®, and
International Private Sewage Disposal Code®.

FEMA Regions and the States are likely to find that adoption of the I-Codes™
is becoming more common.
Note that usually when States and communities adopt the IBC®, they also
adopt by reference the IRC™, which regulates detached one- and two-family
dwellings and multiple single-family dwellings (townhomes). If a State or

Figure 4-1. Adoption of Building Codes

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Guidance for Conducting CACs and CAVs

community does not adopt the IRC™, then the buildings regulated by
the IRC™ must be covered in a community’s floodplain management
ordinance, the IBC® or other regulations.
Although adoption of one of the new model building codes (either the
I‑Codes™ or NFPA™ 5000) by States and communities should improve
overall compliance with the flood-resistant design and construction requirements of the NFIP, extra effort may be required when reviewing community
floodplain management regulations in comparison with adopted building
codes, to ensure compliance with the minimum requirements of the NFIP.

Review of the State Building Code 
States that adopt the I-Codes™ or NFPA™ 5000 as the basis for their
State-mandated building code may also amend the base model code.  Any
amendments to the flood-resistant provisions of the code could directly
or indirectly affect the consistency of the code or compliance with the
minimum requirements of the NFIP.  For example, the State could change
the flood-resistant provisions of the code that makes them non-compliant,
or exempt certain types of structures from the State-mandated building
code, such as agricultural structures or one- and two-family dwellings as
described above. 

The first step is to determine whether States in the Region have a Statemandated building code that communities must adopt.  In States that
have adopted a State-mandated building code, the NFIP State Coordinator should contact the State building code office to determine whether the
State has adopted either the IBC® (and other I-Codes™) or NFPA™ 5000
as the basis for the State-mandated building code.  The NFIP State Coordinator should also find out whether the code was amended and determine
if any of the amendments affect the flood-resistant design and construction requirements in a way that make them non-compliant with the NFIP
requirements.  In addition, the NFIP State Coordinator will need to make a
determination of whether any more restrictive State floodplain management
requirements have been affected such as freeboard.  Ongoing coordination
should occur between the NFIP State Coordinator and the State building
code office.

Figure 4-1. Adoption of Building Codes, continued

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4. Community Assistance Visit: Preparation

Adoption of Building Codes by Individual Communities  
Similarly, in communities where there are no State-mandated building
codes or in communities where the State allows communities to amend
the State building code, the FEMA Regional and State staff will need to
determine whether the community has adopted either the IBC® (and other
I-Codes™) or NFPA™ 5000.  It is also necessary to find out whether the
code was amended and determine whether any of the amendments make
the flood-resistant design and construction provisions non-compliant with
the minimum requirements of the NFIP.
NFIP Provisions not Addressed by the Building Code 
While the NFIP requires communities to regulate all development in SFHAs, building codes typically apply only to the construction of buildings. 
Generally, they do not regulate other types of development, the location of
buildings, or the subdivision of land.  The community can adopt Appendix G
of the IBC® or Annex C of the NFPA™ 5000, which contains NFIP requirements that are not addressed in the body of the building codes, or they may
chose to adopt a companion floodplain management ordinance that may
contain many of the same provisions as in Appendix G. Communities may
also have floodplain requirements in the subdivision ordinance or other
regulations.  The building code, Appendix G, or a companion ordinance
must address all development.  The FEMA Regions and States will need
to ensure that all development is regulated and that there are no floodplain
management regulatory gaps.  In addition, the FEMA Regions and States
need to ensure sure that the FIRM and FIS are appropriately referenced;
and that the adopted building codes and the companion ordinance do not
have duplicative provisions, that could create confusion or result in noncompliant structures.
The guide, Reducing Flood Losses Through the International Code Series:  Meeting the Requirements of the National Flood Insurance Program,
3rd edition, dated 2007, can help communities decide how to integrate the
I-Codes™ into their current floodplain management regulatory processes in
order to meet the requirements for participation in the NFIP.  The checklists
and crosswalks presented in the guide can also help in reviewing community floodplain management regulations.

Figure 4-1. Adoption of Building Codes, continued

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Guidance for Conducting CACs and CAVs

3. CAV and CAC Reports
Review previous CAV and CAC reports as a basis for comparison with past performance
to identify areas and issues, and to evaluate progress in implementing recommendations
for follow-up.
4. Hazard Mitigation Plans, Comprehensive Plans,
Zoning and Subdivision Regulations, Building Codes,
Local Stormwater Management Ordinances, Drainage
Codes, Capital Improvement Programs, and other
Land-use Programs and Regulations
If available (check the community’s website), plans and regulations should be reviewed
in conjunction with floodplain management regulations and flood maps, noting the
community’s policies toward development both in general and specific to its floodplain,
the physical setting of the community’s land-use pattern and growth pressure, the type
and extent of potential development in the floodplain, the consistency of these plans
and regulations with the community’s floodplain management regulations, and potential
problem areas.
5. FIS and Maps
Review the latest FIS and FEMA map. Determine whether any restudy efforts are
underway. These maps can be obtained online from FEMA’s Map Service Center (MSC).
6. Letters of Map Change (LOMC)
Review Letters of Map Amendments (LOMAs), LOMRs, Conditional Letters of Map
Amendment (CLOMAs), CLOMRs, and Physical Map Revisions to determine the
community’s level of floodplain-related development activity; to determine changes
affected by hydrologic conditions, such as dams, diversion channels, or detention
basins; to determine changes affected by hydraulic conditions, such as channelization,
new bridges, culverts, or levees; to estimate the accuracy of current maps; and to verify
that a community is using these maps to regulate development. The addresses or
locations of areas where changes have occurred since the date of the most recent map
should be noted for use during the floodplain tour to verify activities, such as channel
maintenance. Verify permits and copies of LOMRs for any properties that were removed
based on fill placement.
7. Aerial Photography and Topographic Maps
Often available online, these maps should
be reviewed in conjunction with flood maps.
Note topography, specific land uses and land
patterns, type and extent of encroachments,
potential problems areas, and other
characteristics.

4-6

Aerial and topographic maps may help
identify potential flow constrictions and
other floodplain conditions and assist
in the identification of areas to tour in
communities with extensive floodplains.

4. Community Assistance Visit: Preparation

8. Community File Information
Review for citizen complaints, congressional correspondence, technical assistance
requests, or other information on the community.

4.3 Compile a List of Issues and Sites
Compile a list of issues and sites to be examined
during the CAV, based on the review of background
information and any available data from NFIP and
Hazard Mitigation Grant resources. For example,
the list might include sites that involve questionable
development in the floodplain, issues or problems
related to the implementation of NFIP requirements in each flood zone, questions of
map accuracy at specific sites, and flood-hazard reduction projects (which can include
open space acquisition programs, building elevation projects, Public Assistance 406
Mitigation Projects, stream maintenance programs, drainage or stormwater management
requirements, or retrofitting/floodproofing programs). Issues or questions pertaining
to specific site locations should be noted on the maps used during the floodplain tour.
This method is important when a tour of the entire floodplain is not possible because of
community size.
Issues or sites should be noted
separately and reviewed during
the floodplain tour or discussed
during the course of the visit.

4.4 Contact the Community to Schedule a Visit
Complete the following two steps for scheduling a visit: Contact the designated
local official who has the responsibility, authority, and means to implement the NFIP
requirements to schedule the visit; and send a follow-up letter to the CEO with a copy
to the designated FPA confirming the date and purpose of the visit (sample letter in
Appendix B). In the letter, ask that the CEO or FPA include all other community staff
involved in implementing the NFIP floodplain management program.
a. Telephone Contact
After reviewing background information and preparing a list of sites to examine and issues
about which to obtain information, contact the designated local official to schedule a visit.
This contact should be made at least 30 days before the visit. The designated local official
responsible for implementing the NFIP requirements may vary depending on the type,
size, and level of sophistication of the community. For example, in smaller communities,
the local official responsible for implementing the NFIP requirements may be the mayor,
city clerk, or county board chair. In a larger community with a separate zoning, building,
or public works department, the designated local official may be a zoning or building
administrator, building inspector, zoning compliance officer, or code enforcement officer.

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Guidance for Conducting CACs and CAVs

The following is a checklist of items that should be covered during the telephone contact to
schedule the visit:
1. Describe the purpose of the meeting to the local official and summarize the agenda.
2. Establish the date, time, and location of the meeting.
3. Obtain the name, title, address, and telephone number of the CEO (mayor,
county commission chair) to address the letter to the community confirming the
CAV meeting.
4. Request that local officials involved in floodplain management and the development
review process be present during the CAV meeting or be available for questions.
Those critical to the operation of the local floodplain development review and
approval process should attend. The following is a list of suggested local officials
typically involved in review and approval of development proposals. This list should
be used when the local official needs assistance in deciding who should attend the
CAV meeting:
(a) FPA;
(b) Building Official;
(c) Planning Official;
(d) Subdivision Review Official;
(e) Zoning Official;
(f) Public Works or Public Utilities Official;
(g) Housing and/or Community Development Official;
(h) CEO (Mayor, Council Chairman, County Board Chairman);
(i) Council Members;
(j) Planning Commissioners;
(k) Planning, Zoning, and Variance Board Members;
(l) Health Official;
(m) Transportation Official;
(n) Community Engineer/Surveyor;
(o) Community Attorney;
(p) Village, City, or County Clerk;
(q) Emergency Preparedness Official; and
(r) Designated CRS Coordinator.

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4. Community Assistance Visit: Preparation

5. Explain that there will be a tour of the community’s floodplain prior to the CAV
meeting. Depending on the circumstances, invite the FPA to attend the floodplain
tour. Explain that sites will be selected from the preparation research, and ask for
suggestions of additional sites to visit for typical examples of new construction,
subdivisions, channel modifications or other man-made changes, natural changes in
the floodplain, or areas where map accuracy is in question.
6. Ask the local official to identify the floodplain regulations that have been adopted,
including any building codes, subdivision/zoning regulations, or other floodplain
ordinances, etc. If the NFIP file copy is not what the official describes, ask that a
current version of the regulations be sent by e-mail as soon as possible or be made
available during the CAV.
7. Establish the local official’s (along with any other officials responsible for managing
the program) familiarity with the NFIP. For example, find out how long these officials
have worked with the NFIP, whether they have attended NFIP workshops, and
whether they are CFM(s).
8. Ask the local official to have the following items available during the meeting:
(a) The current FIRM and/or FIS report.
(b) Copies of the latest floodplain management regulations and any other plans,
regulations, or codes that are being used to assist in floodplain development
(e.g., comprehensive plans, building codes, stormwater management
regulations, flood hazard mitigation plans).
(c) Any other flood-related maps or studies currently in use.
(d) The community’s permit files for floodplain development for at least the past three
to five years. Ask the local official how these files are organized (by address,
name of property owner, tax parcel number, etc.). This knowledge may be useful
when relating structures identified during the floodplain tour to the permit file.
(Note: It may not be possible to review all floodplain development permit files
for any given year if a substantial number of permits were issued. In this case, a
critical sampling of permits or a cross section of development activity should be
reviewed in order to determine whether the community is properly implementing
the NFIP requirements and managing its floodplain. The number of permits that
should be reviewed will also depend on the extent of questionable development
activity discovered during the floodplain tour.)
(e) Forms, checklists, or other documents used to record permit activities.
(f) Variance files, including the documentation justifying the granting or denial of
variances.
9. Ask the local official to identify any other floodplain management issues or initiatives
beyond the regulations (e.g., acquisition program, flood warning system, mitigation
plans, hurricane evacuation plans, stormwater management plans).

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Guidance for Conducting CACs and CAVs

10. Mention that a letter confirming the CAV meeting will be sent to the CEO with a copy
to the local official.
11. Inquire whether any of the community information referenced here is available
digitally and can be provided in advance via e-mail. These materials will aid in
preparation, and will also make it easier to use local information to communicate
and document any concerns.

b. Confirmation Letter
A letter confirming the visit and information requests should be sent to the CEO with
a copy to the FPA. The sample letter provided in Appendix B of this document may be
revised to reflect the particular situation.

4.5 List of Materials and Equipment for a CAV
Figure 4-2 contains a suggested list of materials and equipment for use during the CAV.
Please note that this list is not all-inclusive.

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4. Community Assistance Visit: Preparation

•

The community’s floodplain management regulations

•

Flood Hazard Boundary Maps, FIRM panels, the FIS report, Digital Flood
Maps, or FIRMettes

•

Historical Community Biennial Report Data

•

Letter(s) confirming the CAV

•

NFIP Regulations

•

Flood insurance information for the community (e.g., number of policies in
force, dollar amount of coverage, claims data, etc.)

•

Blank Elevation Certificate Forms and Floodproofing Certificate Forms

•

Model Floodplain Management Ordinance

•

FEMA publications (See www.FEMA.gov for a list of Floodplain Management
related publications)

•

Digital equipment such as a camera, laptop, and GPS unit (for accurate
coordinate locations to be used within a Geographic Information System or
digital orthophoto overlays, allowing verification of properties in the floodplain)

•

Disaster history information such as public assistance and individual
assistance information, or Mitigation Assessment Team reports

•

Submit-to-rate flood insurance data

•

Substantial damage information, repetitive loss information from flood
insurance claims data, and property addresses

•

Topographic maps, digital orthophoto overlays, and digital orthosite images
available via the Internet

•

FEMA Grant Report to verify that acquisition projects are maintained as open
space, and that elevation projects are properly elevated (from SHMO)

•

FEMA 406 Hazard Mitigation completed Projects under Public Assistance

•

Various FEMA and State prepared outreach materials that are applicable to
the community’s flooding and development conditions, such as levee
outreach materials, and CRS and Mitigation Grant Programs brochures.

Figure 4-2. CAV Materials and Equipment List

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Guidance for Conducting CACs and CAVs

‰‰Review Pertinent Community Information:
‰‰Floodplain management regulations
‰‰FIS report and maps
‰‰Past CAV and CAC response(s)
‰‰Mitigation plans, comprehensive plans, zoning and subdivision regulations,
building codes, local stormwater management, drainage codes or
ordinances, and other land-use regulations

‰‰Aerial photography and topographic maps
‰‰Historical Biennial Report data
‰‰Latest claims, policy, CRS and other insurance data
‰‰LOMAs, LOMRs, CLOMAs, CLOMRs, and physical map revision information
‰‰Correspondence, including citizen complaints, congressional inquiries
‰‰Community website for ordinances, regulations, permits, procedures
‰‰Compile Issues and Sites List
‰‰Contact the Community to Schedule a Visit
‰‰Telephone call to schedule date and time of meeting
‰‰Follow-up letter to CEO to confirm date and time of meeting
‰‰Compile appropriate materials and equipment for the CAV
‰‰Community floodplain management regulations
‰‰Effective FEMA Maps and the FIS
‰‰CIS data
‰‰Letter(s) confirming the CAV
‰‰NFIP regulations
‰‰Flood insurance information on the community
‰‰Elevation certificate forms and floodproofing certificate forms
‰‰Model floodplain management ordinance
‰‰FEMA publications, including floodplain management and technical bulletins
‰‰Camera, GPS, laptop
‰‰Disaster history information
‰‰Submit-to-rate flood insurance data
‰‰Substantial damage information from flood insurance claims data
‰‰Topographic maps

Figure 4-3. Quick Reference Checklist for CAV Preparation

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4. Community Assistance Visit: Preparation

Please also note that most communities desire these items in digital format so they can
incorporate the data into their own digital systems. Many State and FEMA Regional Office
staffs bring this and other “library” type documents in digital format, along with selected
printed information, such as forms and brochures. Figure 4-3 provides a checklist to aid in
preparing for CAVs.

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Chapter 5
Community Assistance Visit
5.1 General
The community visit is the critical part of conducting a CAV. Onsite analysis and
face‑to‑face meetings provide the best gauge of the effectiveness of a community’s
floodplain management process.
The Community Visit has the Following Four Elements:
1. The floodplain tour;
2. Meeting with local officials;
3. Examination of the floodplain permit, variance, and subdivision files; and
4. A summary meeting of the information gathered and issues identified.

The process described in this chapter is for the meeting with local officials that occurs prior
to the permit and variance file review. However, depending on circumstances, a variation
of this process may be performed (e.g., permit and variance files may be reviewed prior
to the meeting with local officials). While the number of days to conduct the community
visit will vary depending on the community size, permit activity, and extent of floodplain
management issues identified, in most cases, all four elements described here can be
completed during the community visit phase.

5.2 The Floodplain Tour: Purpose and Strategy
a. The Three Major Purposes of the Community
Floodplain Tour
1. To become generally familiar with the community’s floodplain areas, including
overall land use patterns, density and type of floodplain occupancy, and availability
of undeveloped land inside and outside of the floodplain.
2. To gather site-specific information on development and to document potential
floodplain management problems in order to assist in the review of the community’s
permit and variance files.
3. To gather information on the accuracy and completeness of the community’s effective
FEMA maps. A tour of the floodplain should generally precede the meeting with local
officials and the permit review. It may be necessary to tour certain floodplain areas
of the community following the meeting to verify site-specific information obtained
during the permit and variance file review.

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b. Tour of the Floodplain with the FPA
The floodplain locations visited during the tour
should be guided by information obtained through
the CAV preparation – for example, information
gathered by combining community-provided digital
floodplain permits with digital preparation files
(submit-to-rate, LOMC, etc.). These preparation
data can be a “layer” added to “off-the-shelf”
GPS programs to streamline the identification of the most effective tour route, and to
help determine how effectively the community implements its floodplain management
requirements for new and existing development. Should the number of site locations prove
to be too extensive, an appropriate sample should be selected of residential and nonresidential buildings (new and improved) in each of the years since the last CAV (generally
no earlier than the past five years).
The floodplain tour should be done
with the community Floodplain
Administrator or representative
whenever possible for
programmatic and safety purposes.

When the FPA is included on the floodplain tour, his or her participation should be verified
in the pre-CAV confirmation letter. A joint floodplain tour can: open up helpful dialogue;
provide first-hand field training; may help with access to private and community property;
assist with local travel routes and traffic patterns; provide direct access to permit files
through calls to office staff; garner a local perspective on floodplain development issues;
identify future development pressures that may not surface in a formal meeting, and
also address personal safety concerns. At the end of a joint floodplain tour, the FPA will
be better able to obtain appropriate records for the meeting and will understand why the
information is needed. If the FPA was not on the floodplain tour and issues arise from the
CAV meeting that require additional clarification, ask if a follow-up tour of specific problem
sites is possible.
c. Helpful Equipment
Digital cameras, GPS units, laptop or tablet computers, and other supporting equipment
should be used to help document the status of sites visited. GPS navigation systems that can
be imported into a spreadsheet or database are particularly useful. The ability to show digital
photos and precise map locations during the meeting with local officials better facilitates
communication. This digital data also becomes an essential part of the CAV report.
d. Landowner/Resident Permission
When conducting a tour of the floodplain, expressed permission of the landowner or
resident must be obtained before entering private property. This is often facilitated by
touring with a local official in a community-owned vehicle. Otherwise, equipment brought
for site documentation should be used from the street or other public right-of-way.
e. Focus on Problem Sites
In smaller communities, it may be possible to tour the entire floodplain, but in larger
communities with extensive floodplain areas and development, this may not be feasible.
When a tour of the entire SFHA is not possible, emphasis should be placed on sites

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with known or suspected problems and on sites and stream reaches noted during the
preparation phase. Otherwise, in order to determine the effectiveness of a community’s
floodplain management program, representative stream reaches should be inspected to
provide sufficient examples of local floodplain management efforts.

5.3 The Floodplain Tour
Check the community’s SFHA from two standpoints:
a. Floodplain Development
Development in the floodplain should be examined for impacts of local enforcement
and compliance efforts. Sites in each mapped flood zone should be visited to ensure
the community understands how to issue permits for each flood zone. Floodplain areas
that have not been developed should be noted for further discussion during the meeting,
and evaluated in relation to the community’s adopted comprehensive land use plans or
approved development plans, if any exist. Adjacent areas to the SFHA should also be
inspected for any floodplain impacts.
b. Map Accuracy
Map accuracy issues should also be examined for impacts of local enforcement and
compliance efforts.
The following should be used as a guide when examining any development or map-related
issues during the tour of the floodplain. A summary checklist of the items listed below is
provided in Appendix C for quick reference during the actual floodplain tour.
Floodplain Tour – Development in the Floodplain
Floodplain development should be evaluated based on the level of the ordinance adopted
by the community. The following items provide some examples:
1. In A Zones (applies to new construction and substantial improvements)
[44 CFR §60.3 (a) through (d)], verify that:

‰‰Residential structures have lowest floors (including basement) elevated to or
above the BFE.

‰‰Non-residential structures are elevated or floodproofed to or above the BFE.
‰‰Structures with enclosures below the BFE are used only for parking, access, or

limited storage. Where such enclosures exist, if possible check for a minimum of
two openings to equalize hydrostatic flood forces on exterior walls, and verify that
the bottom of the openings are not more than 1 foot above grade.

‰‰Existing structures that have indications of substantial improvements show

evidence of flood protection. NOTE: Additions to structures will likely be the most
identifiable substantial improvement, whereas rehabilitations to structures will

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be more difficult to detect. Where available, use flood insurance claim data to
identify possible substantially damaged structures.

‰‰Structures that have electrical, heating, ventilation, plumbing and air-conditioning
equipment, and other service facilities, are designed and/or located so as to
prevent water from entering or accumulating within the components during
conditions of flooding.

‰‰Manufactured homes, (except in existing manufactured home parks or

subdivisions) are located with the lowest floor at or above the BFE. Also check
that manufactured homes are securely anchored to an adequate foundation
system. (This may not be recognizable during the floodplain tour.)

‰‰Manufactured homes in existing manufactured home parks or subdivisions are

located with the lowest floor at or above the BFE or with the lowest floor 36
inches above grade. Also check that manufactured homes are securely anchored
to an adequate foundation system. (This may not be recognizable during the
floodplain tour.)

‰‰There are no encroachments within the adopted regulatory floodway, including

new construction or substantial improvements. Also check other development,
such as mining, dredging, filling, grading, paving, excavation, drilling operations,
or other structures (e.g., gas and liquid storage tanks).

‰‰There is adequate drainage in new subdivisions that decreases exposure to
flood hazards.

‰‰FEMA was notified of any altered or relocated portion of a watercourse and that
the flood-carrying capacity within the altered or relocated portion of any watercourse is maintained (i.e., there is no evidence of excessive vegetation growth
and excessive sedimentation in channelized and concrete lined channels).

‰‰There are adequate drainage paths around structures on slopes to guide
floodwater around and away from structures in areas of shallow flooding.

2. In V Zones (applies to new construction or substantial improvements)
[44 CFR §60.3(e)], verify that:

‰‰Structures are elevated on pilings or columns so that the bottom of the lowest
horizontal structural member of the lowest floor is at or above the BFE.

‰‰Manufactured homes (except in an existing manufactured home park or

subdivision) are elevated on pilings or columns so that the bottom of the lowest
horizontal structural member of the lowest floor is at or above the BFE.

‰‰The space below the lowest floor of an elevated structure appears to be free of

obstructions or appears to have breakaway walls. Check the permit record to see
whether breakaway walls are identified in the specifications and signed off on by
an engineer.

‰‰Structures with enclosures below the BFE are to be used only for parking,

access, or limited storage. Photograph any walls of enclosures below the
BFE and determine through the permit review whether they are designed as
breakaway walls, if the building is post-FIRM.

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‰‰Structures that have electrical, heating, ventilation, plumbing and air-conditioning
equipment, and other service facilities, are designed and/or located so as to
prevent water from entering or accumulating within the components during
conditions of flooding.

‰‰Post-FIRM structures are located landward (not seaward) of mean high tide.
‰‰Fill is not used for structural support of buildings.
‰‰There is no alteration of sand dunes or mangrove stands.
3. Note vacant structures with boarded-up windows, tall grass, etc. Some of these
structures, if rehabilitated, may become substantially improved and are required
to meet floodplain management requirements.
4. Review FEMA grant-acquisition projects by address for sites located in the
community. The Acquisition regulations (44 CFR §80.19) require that FEMA verify
that the property shall be dedicated and maintained in perpetuity as open space for
the conservation of natural floodplain functions. Include a sample of these properties
with other properties selected for site visits to ensure that:

‰‰Use of the land acquired for open space purposes is consistent with the

regulations under each mitigation program and the community’s Land Use Reuse
Plan for open space or recreational use.

‰‰If a new public facility is allowed, verify that the facility is open on all sides and
functionally related to open space or recreational use.

‰‰Any public restroom or other structure compatible with open space use must be
elevated/floodproofed to at least the BFE plus 1 foot of freeboard (or greater if
required by FEMA or by any State or local ordinance).

‰‰The open space property is maintained in good condition, and all debris or other

improvements, such as any concrete slabs or foundations that are not part of the
reuse plan were removed.

5. Visit an elevation or floodproofing FEMA Grant and NFIP Increased Cost of
Compliance (ICC) project to confirm that the selected buildings are still properly
elevated and have not been compromised by enclosures below the BFE or by
other modifications.
6. Check maintenance of, or physical changes to, the floodplain, such as dams,
diversion channels, detention basins, channelization, new bridges, or levees that
resulted in, or may require, a Map Revision (44 CFR §65.6).
7. If there are open CLOMRs in the community that have not been closed out by
an approved LOMR, visit all or sample sites to assure that no encroachments or
other violations have occurred. Any new development must meet the floodplain
management requirements based on the SFHA boundaries and BFEs on the
effective FIRM. In some cases, a CLOMR is used to improperly allow new
development before the flood-control improvements to be done under the CLOMR
have been completed and accredited by FEMA through an approved LOMR. If the
project detailed in the CLOMR is in place, especially if it appears that it has not
been constructed in accordance with the CLOMR specifications, make sure the CAV

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follow-up letter notifies the community that it must complete the LOMR within 180
days of the time the development was substantially complete [44 CFR §60.3(c) and
65.3]. If there is a floodway increase, then 44 CFR §60.3 (d)(4) and 65.12 apply.
8. For accredited levee systems, check for general maintenance of the levee system.
For earthen levees, check for general conditions, such as grass cover that is
manicured, animal burrows, noticeable erosion or gullies, clean watercourses,
and flap gates free of debris. Note any closures and whether they are manual or
automatic; structure crossings, such as railroads or roads through the levee; and
mud on the landward side (signifying structural instability); and other observations.
For floodwall-type levees, check for general conditions, such as a lack of noticeable
cracks, or settlement.
Note: For the purpose of a CAV floodplain tour, this is expected to be a very limited
non-engineering check of a sample of the most significant levees (in combination
with other field work) to see if there are any obvious issues that should be brought to
the attention of the FEMA Regional Office Engineer (44 CFR §65.10).
9. Sample selected structures for which a submit‑to‑rate flood insurance application has
been submitted to FEMA.

Map Accuracy Field Review
During the floodplain tour, check the following types of sites where map accuracy may be
an issue.
1. New bridges or roads, or major modifications to existing ones, in a designated
floodway or an area that would divert significant flood flows from the SFHA indicated
on the effective FIRM.
2. Extensive filling or debris dumping, especially in the adopted regulated floodway, or
in SFHAs where floodways have not been designated.
3. Major new developments, especially in the floodway or an area that would divert
significant flood flows from the SFHA indicated on the effective FIRM.
4. New flood-control or related modifications, such as levees, berms, dikes, floodwalls,
channel relocation, detention or retention ponds, concrete channels, hurricane
protection levees, dams, reservoirs, etc.
5. Modified channels to ensure the watercourse is free of debris, and excessive
vegetation/sedimentation.
6. Construction of low-water crossings.
7. Natural changes in the floodplain, such as flood-related channel relocation or
modification, landslides, mudslides (i.e., mudflows), debris slides, significant erosion
or sedimentation, significant vegetation or debris buildup, and other natural changes
that clearly conflict with the SFHA on the effective FIRM.

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8. If using contour maps or orthophoto maps, note any obvious discrepancies between
those maps and the Flood Hazard Boundary Maps (FHBMs), FIRMs, or Flood
Boundary/Floodway Maps.
9. Areas suspected of posing special risks to life and property due to the depth, velocity
and duration of flooding, debris in the water, or other factors. High flood hazards
include: alluvial fans, areas behind unsafe or inadequate levees, areas below unsafe
or inadequate dams, coastal erosion, flash flood areas, flooding due to ground failure
such as subsidence, fluctuating lake levels, ice jams, and mudslides.

5.4 Documentation of Potential Floodplain
Development and Mapping Issues
Structures and sites that are questionable floodplain developments and appear to be in
violation must be documented during the floodplain tour, and followed up with local officials
during the CAV meeting, to verify that proper floodplain management procedures were
followed. Additional research may be needed at the State or FEMA Regional Office to
verify LOMC or insurance rating information. Map accuracy issues should also be noted
during the floodplain tour. This information should be discussed with local officials and
used to verify the information in conjunction with review of the community’s permit and
variance files. Guidance for documenting the floodplain tour findings for both developmentrelated issues and map-related issues is provided below.
a. Documenting Development-Related Issues
1. Mark the development location on the affected flood map by address and
GPS location.
2. Photograph all inspected structures on the tour. For at least each of the “problem”
sites, including street view and rear-view angles of specific problem areas will prove
helpful for later office review.
3. Estimate the lowest floor elevation of questionable structures in relation to the natural
ground, or at least note that the structure may be below the BFE, and document the
finding if there appears to be a violation.
4. Estimate whether proper openings are present and at the correct elevation above the
ground for enclosed areas below the lowest floor, and document the finding if there
appears to be a violation.
5. Record information (address/GPS location of development, nature of potential
violation, etc.) on the sample CAV Development Review Worksheet (Appendix D),
National Flood Mitigation Data Collection Tool, or other digital spreadsheet. Although
other similar worksheets may be used to document questionable structures, the
applicable information contained in Appendix D should be obtained for each structure
as a minimum.
6. If the community has designated floodways, determine whether any appear to be post–
FIRM encroachments. If so, document the site and ask about it at the CAV meeting.

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b. Documenting Map-Related Issues
The general requirements for technical and scientific data needed to substantiate
Appeals and Map Revisions are similar. There are, however, procedural differences that
determine the amount of data required and when the data may be submitted. The specific
mechanisms for maintaining, updating, revising, and appealing these flood risk data are
outlined in 44 CFR §65, 70, and 72. These regulations establish the mechanisms by which
individuals, State and local governments, and public and private organizations can work
with FEMA to effect changes to flood hazard maps, and ensure that the best available
data are applied for management of the Nation’s flood-prone areas. During the tour of the
floodplain, any map-related issues should be documented for discussion purposes with
local officials, and findings should be included in the documentation portion of the CAV
process. The findings on map-related issues should be forwarded to the FEMA Regional
NFIP Engineer who will ensure that it is entered into the FEMA web-based geospatial
database to document and prioritize floodplain mapping needs and requests. At a
minimum, the following should be recorded:
1. The location of the site marked on the flood map;
2. The nature of the map-related issue and/or an estimate of the scope of the needed
map revision;
3. The existence of any apparent violations;
4. A photograph of each problem at the site and a development site review form,
if applicable, to address these issues; and
5. Data gathered from mapping/GIS tools that aid in demonstrating the deficiency.

5.5 Meeting With Local Officials
The meeting with local officials will identify most of the community’s assistance needs and
define any compliance problems and issues that need to be resolved to ensure that the
community is achieving the flood-loss reduction objectives of the program. The CAV and
this meeting have two basic purposes: to assess the community’s floodplain management
program, and to provide technical assistance. This meeting is critical to developing a
mutual trust in support of future FEMA/State relationships with the community.
A convenient checklist of these discussion points is provided in Appendix E for use during
the meeting. Determine if there is a representative at the meeting from each community
department that has responsibility for the permit process and for subdivision reviews for
floodplain development.
a. Introduction
The following should be used as a guide to ensure that local officials understand the
purpose of the meeting and what is to be accomplished.

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1. Explain the Purpose of the Meeting
Introduce other members of the CAV team (other Federal or State personnel) and outline
their role in the community visit. Summarize the agenda, give an estimate of the meeting’s
duration, hand out an attendance list, and describe some of the preparation work, such as
a tour of the floodplain and research of community flood history, to establish familiarity with
the local situation.
2. Outline the Program Goals
Depending on the local officials’ knowledge of the NFIP, provide a brief overview of the
goals, objectives, and requirements of the program. Discuss the basic components of
how the NFIP works, including non-structural means of flood damage reduction, and flood
insurance availability to protect against financial loss.
3. Existing Flood Insurance Statistics
Provide local officials with a printout or digital file of policies and claims (summary or
by address, along with the appropriate Privacy Act Statement) and include or highlight
additional community flood insurance information (e.g., number of flood insurance
policies in force, dollar amount of coverage, number of flood insurance claims including
Repetitive Loss, dollar amount of claims, etc.). A summary sheet from the FEMA CIS
may be adequate for this purpose. Discuss characteristics of the flood insurance policy
(where to purchase, policy term, examples of property covered, examples of property not
covered, rate of coverage, cases where flood insurance is required, and how floodplain
management affects insurance rating).
4. Floodplain Management
Procedures
Advise local officials that they will be asked to
describe the procedures they use to implement
their floodplain management program, including
the permit and inspection processes, subdivision
reviews, floodway development reviews, variance
process, etc.

Before any detailed discussion
begins regarding the community’s
floodplain management program,
a brief overview of the purpose of
the meeting and summary of the
agenda should be provided.

5. File Review
Confirm with local officials that permit, variance, and subdivision files will be reviewed after
the meeting.
6. Questions
Address any questions from local officials that need immediate clarification before
proceeding.

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b. Floodplain Management Regulations Review
1. Determine whether the floodplain management regulations reviewed are the most
current. If not, ask the community for a copy of the current adopted regulations. Keep
in mind that the floodplain management regulations may be a standalone document or
may be included in more than one ordinance or code, such as a building code, zoning
ordinance, subdivision regulations, health and safety codes, drainage codes, etc.
2. Ask for an explanation of anything in the regulations that appears to be unclear.
Ask if local officials have any questions or problems concerning interpretation and
administration of the regulations.
3. Determine if the community either has or intends to adopt the IBC® or I-Codes™
(see Figure 4-1). If the community has adopted the I-Codes™, determine whether
the community removed or modified any portions of the standard standalone NFIP
floodplain management ordinance. If parts of the standard ordinance have been
removed, obtain a copy of the relevant sections of the I-Code used by the community
to verify that all NFIP requirements are covered. The community may have the
I-Codes™ including Appendix G, the I-Codes™ plus a companion ordinance and
appendices, or an alternate arrangement.
4. If, for reasons other than adoption of the I-Codes™, the floodplain management
regulations are segregated from other planning, zoning, subdivision, drainage
regulations, or buildings codes, find out if any of the floodplain management
requirements are referenced in these documents. Obtain and/or review copies
of these documents to determine level of coordination and consistency with
the minimum NFIP requirements. Determine to what extent segregation of the
community’s floodplain management regulations is affecting the community’s ability
to administer the NFIP. Request copies of any other regulations or plans that relate
to the community’s floodplain management program.
5. Discuss any inadequacies, omissions, and any overlaps between above adopted
regulations, building codes or other problems identified during the prior review of
the regulations.
6. Determine whether the community has adopted the latest map and study.
7. Determine whether the community’s floodplain management regulations are more
restrictive (e.g., freeboard), and if so, determine if the community has had any
problems in implementing the more restrictive requirements. For a CRS community,
discuss the activities it received credit for under higher regulatory standards.
8. In a community where the Federal Insurance Administrator has approved a
community proposal to adopt standards for floodproofed residential basements below
the BFE in Zones A, AR, AO, and AE, determine whether the community has adopted
adequate floodplain management regulations for new construction and substantial
improvements, and whether any such construction has occurred.
9. For communities with unique high-hazard flood areas (e.g., alluvial fans, subsidence,
erosion), review ordinances for special construction standards and/or other
regulations that address these hazards.
10. If appropriate, ask if the community needs assistance in updating or revising the
current floodplain management regulations. Discuss a schedule for accomplishing
this requirement.
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11. Determine if the boundaries of the community have been modified by annexation,
incorporation or disincorporation, or if the community has otherwise assumed or no
longer has authority to adopt and enforce floodplain management regulations for
a particular area. If so, obtain either a digital version of the map or a paper map of
the community suitable for reproduction and, if available, the annexation ordinance
delineating the new corporate limits or new area for which the community has
assumed or relinquished floodplain management regulatory authority.

c. Map Availability and Accuracy
1. Determine whether the FIRM and FIS reports in use by the community are the most
current. If FIRMs are paper, ask where the reports are kept and if they are available
to the public. For the DFIRM, ask how the maps are being made available to the
public. If a restudy is underway, discuss with the community the status of the study,
when to expect a preliminary map, when to expect a final meeting, and when the
community is expected to update its regulations to adopt the FEMA maps and FIS.
Remind the community that it must, at a minimum, continue to regulate floodplain
development consistent with the current maps and FIS until the appeals period is
over and the new maps and FIS are in effect. However, if BFEs are going up and/or
floodplains are widening, there is opportunity for the community to consider a higher
standard, such as freeboard, to protect new development in the interim.
2. Ask whether other maps or studies are being used for regulating development in
the SFHA. Point out the community’s ability under the NFIP to use more restrictive
requirements than those shown on the FIRM (such as a higher elevation requirement
than the BFE), but emphasize that it cannot use less restrictive requirements than
those on the effective FIRM. If other maps and studies appear to have an impact on
the effective BFEs, or if the community has developed BFEs in areas where FEMA
BFEs have not been determined, obtain a copy of the maps or studies.
3. Determine whether local officials have any problems with using the maps, FIS report,
or DFIRM data. Ask them to describe how they present the FEMA maps to permit
applicants and to the public. (If necessary, work through a sample floodplain and/
or elevation determination, or demonstrate use of the DFIRM tools and advise the
officials of any additional DFIRM training that may be available).
4. Inquire whether local officials have any problems with the accuracy or completeness
of the maps or FIS. Record the areas in question and the nature of the problems
(e.g., an error in the original map or physical changes that have occurred since the
effective date of the map or study).

If information appears to support the need for map changes or justifies further review,
determine whether local officials have available technical data to assist in making any changes.
Communities are responsible for notifying FEMA of physical changes affecting flooding
conditions by submitting technical and scientific data in accordance with 44 CFR §65.3 and
65.4. Activities most likely to cause such changes include fill, watercourse modifications, floodcontrol projects, bridges, culverts, levees, floodwalls, etc. Ask what level of coordination the
community has with the State Department of Transportation.

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5. Inquire whether the community has experienced any recent flooding and ask to
briefly describe the extent (source and location) and damage (e.g., whether any
structures were substantially damaged or whether flooding was significant in areas
not designated as an SFHA). If so, determine the general cause (e.g., stormwater/
drainage problems, an event greater than the 100-year frequency flood, failure
of a flood-control project, the design standards for the project being exceeded,
inaccuracies in the mapping, or hydrology/hydraulics).
6. For mapped areas protected by an accredited levee system or for other flood
protection works, such as dams, retention basins, diversions, and channelization
projects, determine whether the community is aware of its maintenance
responsibilities and whether such maintenance is documented. Where problems are
noted, determine whether the community performs the necessary follow-up to correct
the problems (44 CFR §65.10).
7. Inquire whether any structural flood-control projects are planned, under construction,
or have been otherwise completed since the date of the last CAC or CAV. Inquire
as to the name of the agency that assisted in implementing the structural measures
and what the current operation and maintenance procedures are. Determine the
effectiveness of the structures in reducing flood damage potential and whether the
structure has been tested in an actual flood event.
8. Determine whether the community has identified any unique high hazard flood area
(e.g., uncertain flow paths, subsidence, ice jams, or coastal erosion). Determine
whether the community is having problems in regulating development in these areas.
9. Determine how familiar local officials are with the process for appeals, revisions, and
amendments to flood maps. Determine whether the community has a system to log
and retrieve LOMAs, LOMRs, CLOMAs, and CLOMRs. Ask local officials to describe
what limitations on development exist during the period between when a CLOMR has
been issued and before the LOMR for that project becomes effective.
10. Discuss any map-related issues that were raised by the CAV preparation review or
during the floodplain tour.

d. Development Review Process
This portion of the meeting should
include a discussion of the community’s
For LOMRs and CLOMRs based on fill,
inquire whether the local official understands
floodplain development review process
that his or her signature affirms that the
from the time a development permit
project has been determined as reasonably
is requested through the time the
safe from flooding, and that there is
Certificate of Occupancy or equivalent
documentation supporting the review.
acceptance is issued. Community
enforcement procedures that support
the implementation of the floodplain
management ordinance should also be addressed. It is critically important to help
community officials understand the difference between a “deficiency” in their regulations,
procedures, or checklists versus a floodplain management violation that may result from
a deficiency. Both types of problems must be identified as part of the CAV process and
corrected by the community.

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The following list should be used as a guide to ensure that all aspects of the development
review process are covered. For each aspect, determine who is involved, his or her role,
how coordination is achieved between different community departments responsible for
various aspects of the development review process, and whether any forms or written
procedures exist.
1. Ask local officials to describe what the development review procedure is for new
construction and for any rehabilitation, addition, or other improvement of an existing
structure, particularly those that qualify as substantial improvement.
2. Ask local officials if they understand the concept of substantial damage under
the NFIP. Have them describe their process for determining substantial damage,
their experience in making these determinations, any issues encountered, and,
specifically, their role in initiating ICC coverage.
3. Ask local officials what the review procedure is for development other than structures,
such as mining, dredging, filling, grading, paving, excavation, or drilling operations.
4. Ask local officials to describe the results of the permit review process and how
determinations are recorded and maintained. For instance, some communities
purge files, such as certifications on a plat map or design drawings, every five years.
Remind communities that these records must be maintained in perpetuity.
5. Ask the FPA what review procedure is used for ensuring that all necessary permits
have been received from those governmental agencies from which approval is
required by Federal or State law, including but not limited to: Section 404 of the
Clean Water Act (USACE – wetlands filling); Section 10 of the Rivers and Harbors
Appropriation Act (USACE – navigable waterways), and Sections 7 and 10 of the
Endangered Species Act (USFWS or NMFS) [44 CFR §60.3(a)(2)]. Ask them to
describe what other Federal, State, and local requirements for permits are generally
needed and cite specific agencies. Ask the community whether it “withholds” or
“conditions” the floodplain permits until a property owner obtains the other permits.
Note: It is highly recommended that communities “withhold” the floodplain permit until
the other permits or approvals are obtained. This helps assure coordination occurs
between various levels of government on projects impacting floodplains. Withholding
the floodplain permit also has the benefit of protecting permit applicants by making
sure they are aware of and obtain all of the other permits necessary before any
floodplain development occurs; and prior to making any irreversible financial
investments. Permit applicants are not well served if they are allowed to proceed with
a project only to have work stopped because they have not obtained proper permits.
6. Ask local officials what procedure is used for the following:
(a) Obtaining the “as built” lowest floor elevation in all SFHAs where BFEs are used
[44 CFR §60.3(b)(5)], and
(b) Obtaining the “as-built” elevation of the bottom of the lowest horizontal structural
member of the lowest floor in all V Zones [44 CFR §60.3(e)(2)].
(c) Maintaining a record of all “as-built” lowest floor elevation data. (Use of the FEMA
Elevation Certificate is required only for CRS communities/Flood Insurance
Policies and is recommended for non-CRS communities.)

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7. Ask local officials what procedure is used to secure certifications for the following:
(a) Floodproofed, non-residential structures [44 CFR §60.3(c)(4)];
(b) Openings for fully enclosed areas below the lowest floor subject to flooding when
the design differs from minimum NFIP criteria [44 CFR §60.3(c)(5)]; Cite/provide
Technical Bulletin 1;
(c) Anchoring of a pile-and-column foundation and structure attached thereto in all
V Zones [44 CFR §60.3(e)(4)]; and
(d) Breakaway walls in all V Zones when design strength exceeds minimum NFIP
criteria [44 CFR §60.3(e)(5)]; Cite/provide Technical Bulletin 9.
8. Determine the community’s procedures for ensuring that all new construction and
substantial improvements are designed (or modified) and adequately anchored
to prevent flotation, collapse, or lateral movement of the structure resulting from
hydrodynamic and hydrostatic loads, including the effects of buoyancy, and for
ensuring that all new construction and substantial improvements are built with
materials resistant to flood damage [44 CFR §60.3(a)(3)]; Cite/provide Technical
Bulletin 2.
9. Ask to see the process that local officials use to ensure that buildings constructed
with electrical, heating, ventilation, plumbing, and air- conditioning equipment, and
other service facilities, are designed and/or located so as to prevent water from
entering or accumulating within the components during conditions of flooding [44
CFR §60.3(a)(3)(iv)]. While this usually means elevation, evidence of waterproofing
can be an alternative. Heating and air conditioning units installed at ground level are
a common violation.
10. Ask local officials if they have an understanding of the floodway concept. If they do,
ask what process is used to determine the following:
(a) Cumulative floodplain development will not increase the water-surface elevation
of the base flood more than 1 foot in Zones A1–30 and AE where floodways have
not been designated [44 CFR §60.3(c)(10)]; and
In areas where a floodway has not been designated, ascertain whether there
has been any construction, development, or fill in any of those SFHAs. If there
has, make sure the community has a formal system in place to monitor the
cumulative increase in BFE for each SFHA to meet the intent of 44 CFR §60.3(c)
(10). For any such A Zone, find out whether, when all existing and anticipated
development is included, the cumulative increase in the surface elevation of the
base flood would be increased by more than 1 foot. The community should have
a record of a pre-construction CLOMR for the project, in accordance with 44 CFR
§65.12, that was followed with a LOMR when the project was completed [44 CFR
§60.3(c)(13)].
(b) That floodway encroachments would not result in any increase in the flood
levels within the community during the occurrence of the base flood discharge in
SFHAs where floodways have been designated [44 CFR §60.3(d)(3)].
Where a floodway has been designated and there also appears to be floodway
encroachments that were identified on the floodplain tour that may have caused

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5. Community Assistance Visit

BFE increases find out whether the community obtained a CLOMR under the
provisions of 44 CFR §60.3(d)(4) and §65.12 before construction began and then
followed with a LOMR when the project was completed. At the CAV meeting,
ask whether the community has documentation showing that it has prohibited
floodway encroachments unless a hydrologic and hydraulic analysis showed that
there would be no increase in flood level during the base flood discharge
[44 CFR §60.3(d)(3)].
11. Based on the information gathered during the floodplain tour, determine if LOMRs
have been requested, or are planned within 180 days, for development where it
appears physical changes have occurred that may have increased or decreased
BFEs in the community (44 CFR §65.3).
12. In communities with A Zones without BFEs:

•

Find out whether local officials are requiring flood damage protection measures,
such as elevation, anchoring, and use of proper flood damage-resistant
construction materials. [44 CFR §60.3(b)(2)].

•

Determine whether local officials require BFE data for subdivisions of at least
50 lots or 5 acres [44 CFR §60.3(b)(3)].

•

Also determine whether local officials obtain, review, and reasonably use any
BFE and floodway data available from a Federal, State, or other source [44 CFR
§60.3(b)(4)]. Discuss the option of having the community require that the permit
applicant develop a BFE.

Indicate that BFEs must be derived from sources outside of the community or be
developed using methodologies comparable to an FIS. Discuss available options
such as Quick 2, described in Managing Floodplain Development in Approximate
Zone A Areas (FEMA‑265).
13. Ask about the variance process. Evaluate any granted variances as part of the
permit-review segment of the CAV process.
14. Ask the local officials to describe the process used to review subdivision proposals [44
CFR §60.3(a)(4)]. Find out what flood-related issues are reviewed. Find out how many
subdivisions have been approved in the floodplain since the date of the last CAC or
CAV, and the estimated number of lots within the approved subdivisions. Find out
whether subdivisions adjacent to the SFHA are reviewed for their impact on flooding.
15. Ask the local officials to describe the process used to review capital improvements,
such as public buildings, streets, bridges, utilities, parks, etc., that are located in the
SFHA. Determine if the community has any major capital improvements planned
which may impact the SFHA.
16. In a community where the Federal Insurance Administrator has approved a
community proposal to adopt standards for floodproofed residential basements
below the BFE in Zones A, AR, AO, and AE, determine what the procedures are for
inspecting and verifying that residential structures with floodproofed basements are
built according to the certified basement design [44 CFR §60.6(c)].
17. Ask the local officials to describe the process for inspecting development permitted
under the floodplain management regulations, including building codes. The

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description should include how often and at what stages of the construction process
there are inspections for: proper floor elevations; number, size, and location of
openings; and protection of mechanical and electrical equipment; and whether there
are inspections at other points during construction. Also, determine if the community
has an ongoing inspection program to discover unpermitted development.
18. Ask the local officials to describe the formal enforcement procedures and actions the
community can take to remedy building and development violations. Inquire as to
actions currently being taken to remedy violations.

e. NFIP Community Information Review and Verification
Verify with local officials the community data from the CIS. In particular, the following data
should be reviewed and/or verified if not already discussed:
1. The number of policies in force and the number of flood insurance claims paid,
especially repetitive loss claims, and any related substantial damage issues. Ask if
community officials understand the ICC process and Mitigation Grant Programs that
may help reduce future flood damages.
2. Any other relevant data contained in the CIS, including up-to-date names, addresses,
phone numbers, and e-mail address of the CEO and of community contacts.
3. Ask how long the current FPA has been in place, and how many staff members
support the floodplain management activities in the community.
4. Ask the FPA what type of training that he/she has had and whether it included the
NFIP. Ask whether the FPA, as well as any other floodplain staff, is a CFM. Describe
what NFIP training is available and make recommendations for training.

f. Floodplain Development Issues Identified on the
Floodplain Tour
Discuss floodplain development issues identified by the CAV preparation and the
floodplain tour. Use digital photos and GPS/annotated maps to help present these issues.
g. Other Floodplain Management Issues
1. Determine the potential for future floodplain development and to what extent the
community encourages or discourages development. For example, based on the
discussion with local officials, determine the community’s attitude toward growth
(e.g., the community works to site and protect floodplain development from flooding
or discourages certain types of development altogether).
2. Find out how the community addresses flood threats to existing development and,
specifically, how it addresses repetitive flood losses, if applicable. Determine the
status of any existing FEMA flood mitigation projects in the community, including
acquisitions, relocations, elevations, or flood-control projects. Ask if future flood
mitigation projects are identified in the community mitigation plan, and/or if there is
interest in Mitigation Grant Programs. Provide grant contact and outreach materials.

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3. Discuss any higher floodplain management standards the community may currently
be using and provide information on recommended higher standards that the
community can consider. Include a discussion of the Community Rating System,
and building codes such as the I-Codes™.
4. Discuss whether the community has a post-disaster plan in place, and if they have
any other issues related to flood disasters or post-flood mitigation efforts.

h. Questions and Answers
Address any questions or concerns the community may have regarding its floodplain
management program or aspects of the NFIP before going on to the permit and variance
file review step.

5.6 An Examination of the Floodplain Development
Permit and Variance Files
A review of the community’s floodplain development files, specifically its floodplain
management development permits (building permit, zoning permit, subdivision files and
variance files), is an excellent means of assessing the effectiveness of the community’s
floodplain management program. Make a point of examining several floodplain permit files
for each year since the last CAV (or at least the past five years, whichever is most recent)
to detect any significant variations in the proper documentation of the files that may
warrant further investigation. For each questionable structure or development, use the
previously discussed CAV Floodplain Development Review Worksheet (Appendix D),
National Flood Mitigation Data Collection Tool, or similar worksheet to document
information found in the community files and to verify the information against the floodplain
tour information.
In Reviewing These Files, the Following Issues Should be Addressed
and Documented:
1. Does the community maintain permit and variance files?
2. Do the files support the local official’s description of the development process and what
was discovered during the floodplain tour?
3. How accessible are the permit and variance files?
4. How complete is the information contained in the files?

1. Confirm that the BFE and the required elevation of the lowest floor for a residential
or non-residential structure or the floodproofed elevation for a non-residential
structure are properly identified in the permit application. For a CRS community,
make sure this information appears on the Elevation Certificate since the date of
initial CRS participation.

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2. Be sure the community maintains a record of the following information, and ask local
officials to what extent the public, such as insurance agents, has sought information
on these data:
(a) Lowest “as-built” floor elevation in all A Zones where BFEs are used.
(b) “As-built” elevation of the bottom of the lowest horizontal structural member of
the lowest floor in all V Zones.
3. Confirm that certifications (or other documentation as may be required by the
community) by an architect or engineer are on file for the following:
(a) Floodproofed non-residential structures in A Zones where BFEs are used.
(b) Openings for fully enclosed areas below the lowest floor subject to flooding when
the design differs from minimum NFIP criteria.
(c) Anchoring of a pile-and-column foundation and structure attached thereto in all
V Zones.
(d) Breakaway walls in all V Zones, when design strength exceeds minimum NFIP
criteria.
(e) Designs meeting ASCE 24-05 as required under the flood-related provisions of
the I-Codes™, when so adopted.
4. In communities where floodways have not been designated, check for documentation
that the community is maintaining a cumulative record of past and proposed
floodplain development within Zones A1–30 and AE on the community’s FIRM. This
documentation is needed to ensure that proposed development will not increase the
water-surface elevation of the base flood more than 1 foot [44 CFR §60.3(c)(10)].
5. In communities where floodways have been designated, check for documentation
that demonstrates through hydrologic and hydraulic analyses that the floodway
encroachment would not result in any increase in the flood levels during the
occurrence of the base flood discharge.
6. There should be documentation that flood damage protection measures are being
required for development in A Zones without BFEs.
7. Communities must require developers of new subdivisions and other developments
(including proposals for manufactured home parks and subdivisions) larger than
50 lots or five acres in A Zones without BFEs to provide BFEs as a condition for
approval. The community should have records in the subdivision files that indicate
this requirement has been implemented and that BFEs have been used to require
elevations as per 44 CFR §60.3(b)(4).
8. In a community in which the Federal Insurance Administrator has approved a
community proposal to adopt standards for floodproofed residential basements below
the BFE in Zones A, AH, AO, and AE, the
permit files should indicate that the
The purposes of the summary
community inspects and verifies that
meeting are to summarize the
residential structures with floodproofed
findings, offer technical assistance,
basements are built according to the
and answer questions.
certified basement design.

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9. Variance justifications must be available and should appear adequate. Be sure
each affected property owner was notified of the effect of the variance on flood
insurance rates.
10. Confirm that a record exists indicating that the community has inspected floodplain
development during or after construction to ensure that the project is built according
to the approved plans.
11. Permit files must contain records that document the process followed to ensure
that all necessary permits have been received from those governmental agencies
from which approval is required by Federal or State law, including but not limited to:
Section 404 of the Clean Water Act (USACE – wetlands filling); Section 10 of the
Rivers and Harbors Appropriation Act (USACE – navigable waterways), and Sections
7 and 10 of the Endangered Species Act (USFWS or NMFS) [44 CFR §60.3(a)(2)].
12. To ensure all information has been collected, check for the following after the permit
file review:
(a) Necessary documentation, photographs, etc., have been collected;
(b) Sites have been visited, or determination has been made as to whether
a site needs to be checked or rechecked in the field; and
(c) Appropriate local officials have been interviewed.

5.7 Summary Meeting With Local Officials
a. Summarize the Findings
Local officials should be given a verbal summary of the preliminary findings that were
made based on the tour of the floodplain, discussion of the community’s floodplain
management program, and review of the development permit files. The strengths and
weaknesses of the community’s floodplain management program should be discussed.
b. Offer Technical Assistance
Provide technical assistance to resolve issues that need immediate attention or do not
require much time to resolve (e.g., suggestions for minor changes in the community’s
permit procedure, instructions for filling out an Elevation Certificate, suggestions for a
community flood awareness program). Any deficiencies that require extensive time to
correct (e.g., the floodplain management regulations need amending, or the community
has a pattern of widespread program deficiencies or violations) should be documented
in a follow-up letter. Use this opportunity to recommend training opportunities for the FPA
and/or other support staff. Completion of such training may be selected as one of the
corrective action items for the community. The timeframe for providing follow-up technical
assistance and for the community to resolve any program deficiencies or violations should
be discussed. The community should be informed that a follow-up letter summarizing
the findings of the community visit will be sent to the community CEO, along with any
appropriate follow-up actions and timeframes.

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c. Address CRS Options
If warranted by the CAV findings to this point, discuss the possibilities of either joining
the CRS or upgrading an existing CRS classification. If the community appears to be a
good CRS candidate, compliment local officials on their best management practices and
activities that may qualify for the CRS. Provide the CIS “What-If CRS Report” showing
projected policy savings for Classes 1–9 specific to the community.
d. Be Complimentary and Answer Questions
There are always positive aspects of every program, many of which can be used as
examples in other CAVs and training. Be sure to compliment the officials on good
practices. Provide another opportunity to address any questions or concerns the
community may have regarding its floodplain management program or aspects of the NFIP
before ending the community visit.

5.8 Specialty CAVs
Over the years, several types of “specialty CAVs” have been developed by various States
and FEMA Regional Offices to address specific situations. The basic CAV process and
format does not change, but the way the CAV is staffed or directed may be adjusted for a
given situation. Brief descriptions of some of these specialty CAVs are given below.
a. Team CAV
The Team CAV or Group CAV is typically done for a large, densely populated city or county
where one person could simply not accomplish and document an adequate floodplain tour
in a reasonable amount of time. The Team CAV may consist of FEMA staff, State staff,
and contractors. The team must be well organized and be consistent in its approach and
documentation procedures so that findings can be quickly assembled for the CAV report
and meeting with local officials.
The team members are given specific assignments, and typically a grid system is used
to make sure the SFHA is covered efficiently. The team members may conduct the
floodplain tour individually or in pairs, often accompanied by a local official. Typically, all
team members will meet at the end of each day to compare notes and analyze findings.
In some cases, members of the Team CAV may also be used to review the community
permit files if the team leader determines that level of assistance is required. Only the CAV
team leader and one or two team members will attend the community meeting, to avoid
overwhelming local officials. While a Team CAV is more labor intensive than a standard
CAV, the format for the community meeting and the CAV report are basically the same.
The key difference is that a larger number of questions and findings can be expected due
to the extensive floodplain development that triggered the decision to do a community visit
as a Team CAV.

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b. State CAV
The State CAV, or more often the State Agency CAV, can be done for one or more State
agencies. Because the State participates in the NFIP, any development that is permitted
by the State must be done in accordance with the minimum floodplain management
standards of the NFIP. State development and State-owned property are eligible for
various types of Federal financial assistance, and are also eligible for disaster assistance
if the development process meets NFIP standards.
State CAVs are led by a FEMA Regional Office staff person because only this person can
present any necessary corrective actions State agencies must take. The person leading
the State CAV will request the legal basis (Governor’s Executive Order, State legislation,
etc.) for that particular State’s equivalent of a floodplain management ordinance, along
with the administrative processes for enforcement. In many cases, a State may implement
floodplain management requirements contained in an ordinance or State Building Code
through an Executive Order. While the State agency for floodplain permitting and oversight
may be an agency, such as the State Finance or Administrative Office, often there are
exemptions provided to other State agencies, including the Department of Transportation
(roads and bridges), Department of Education (schools, community, and State colleges),
the State Architect (hospitals and other State-developed or owned facilities), Bureau of
Prisons, etc., that lead to complicated reviews.
The Office of the NFIP State Coordinator, while providing key contact, coordination, and
assistance, is seldom responsible for permitting State buildings in the SFHA. The need
for a State CAV is often triggered by a series of findings from the standard city and county
CAVs that certain types of State development and facilities in those communities may
not be meeting the minimum standards of the NFIP. Given the size and complexities of
reviewing an entire State, careful planning is required. For instance, usually one State
agency is responsible for permitting most State-owned buildings, or at least seeing that
insurance is maintained for them. Exceptions, as mentioned earlier, vary by State and
must be researched. Inventories of all State-owned buildings must be obtained before any
field work is started.
c. Tribal CAV
A key aspect of a Tribal CAV is that each tribe has its own unique form of self-governance
that may bear little resemblance to the types of county and city governments that FEMA
staff commonly work with.
In recognition of the sovereign government-to-government direct relationship between
Federally Recognized Tribal Governments and the Federal Government, Tribal CAVs must
be led only by FEMA Regional Office staff. FEMA staff conducting Tribal CAVs should
coordinate with the designated FEMA Regional Office “Tribal Liaison” and other staff who
may have worked with the tribe recently and can provide advice on points of contact,
organization, and customs. The basic elements of the CAV process do not change, but
the success of a Tribal CAV will depend on understanding the tribal organization, its
customs and practices in managing development issues, and how tribal leaders choose
to coordinate with the Federal Government. Additional time may be necessary for NFIP

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training and technical assistance if previous contacts have been infrequent. Anyone
planning to visit a Tribal Government should take the EMI Independent Study Class, IS650, “Building Partnerships with Tribal Governments.”
The Following are a Few Unique Advance Planning Reminders
(That Differ From a Typical CAV) to Consider Before FEMA Regional Office Staff
Conduct a State CAV:

•

Begin planning for a State CAV one year in advance.

•

The NFIP State Coordinator is a key ally for coordination and assistance – ask this
person to help research State Executive Orders, ordinances, building codes, and if not
already done, to sponsor quarterly meetings with all State agencies that handle floodplainmanagement responsibilities for State buildings. Plan to attend at least the kickoff meeting.

•

Once the lead State-permitting agency is established, hold an introductory meeting to
explain the process and the coordination help you will need over the coming months.

•

Request a digital inventory of all State-owned buildings with an appropriate breakdown by
type, age, flood zone, etc.

•

Contact FEMA HQ underwriting to request a list of “State-owned” insured buildings, and
ask for a breakdown by Submit to Rate, repetitive loss, suspected substantially damaged,
ICC, and other fields per CAV preparation in Chapter 4.

•

Floodplain Tour Planning – due to the size of most States, it will save time to analyze the
State inventory, DFIRM data, and insurance information to develop a manageable plan to
sample buildings Statewide for the floodplain tour.

•

Plan several trips to complete the floodplain tour based on your sample, or use a Team
CAV approach. Coordinate with FEMA HQ’s Floodplain Management Branch, which can
offer support, technical assistance, and serve as liaison with other FEMA HQ resources.

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Chapter 6
Community Assistance Visit: Documentation
6.1 General
The amount of detail, specificity, and supportive documentation needed is based on
the complexity of the issues and problems identified during the community visit. Many
problems may be resolved through technical assistance. However, in cases where
commencement of an enforcement action is necessary (such as retrograding CRS
participation, imposing probation, suspending a community from the NFIP, denying
insurance to a structure under Section 1316 of the National Flood Insurance Act, or other
enforcement options), detailed, accurate, and comprehensive documentation of program
deficiencies and violations is required.
Documentation consists of (a) entering the CAV findings in the CIS, with supporting
documentation; (b) the letter to the CEO of the community regarding the findings of the
visit; and (c) any follow‑up contacts with the community.

6.2 Community Assistance Visit Findings
The findings of the CAV shall be entered in the CIS to enable FEMA’s evaluation of
individual community floodplain management programs, as well as its evaluation of the
NFIP. It is essential that the CAV findings contain adequate comments to document the
types of program deficiencies and suspected violations identified and the assistance
provided to the community. The documentation in the CIS also serves as a tool for
advancing the visit through the assessment and assistance processes by ensuring that the
necessary follow-up actions required by the community are completed in a timely manner.
Additionally, this documentation is necessary to establish a basis for enforcement actions.
During the CAV, suspected deficiencies
and violations in community floodplain
management regulations or implementation
procedures may be identified. Causes of
suspected violations may include a deficiency
in an ordinance or implementation procedure,
local officials not following their own
regulations and implementation procedures, or property owners ignoring the floodplain
management requirements established by permits. Therefore, an essential part of a CAV
is to track down the actual cause of any suspected program deficiency or violation in order
to identify appropriate corrective actions and prevent future violations.
The CAV Report should not be
completed during the contact with local
officials or provided to local officials to
complete. It should be completed online
after the meeting, using the CIS.

The CAV findings in the CIS indicate whether floodplain management program deficiencies
or potential violations have been identified. For each floodplain management program
category (Floodplain Management Regulations, Administrative and Enforcement Process

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Guidance for Conducting CACs and CAVs

and Procedures, Engineering - Flood Maps and Study, Other Problems), indicate whether
the program deficiency is serious, minor, or non‑existent. If there are any potential
violations, these must also be identified in CIS. The following guidance is provided for
completing this section of the CAV Report in the CIS.
a. Floodplain Management Regulations
1. Serious
Serious program deficiencies in the community’s floodplain management regulations are
defined as those not compliant with NFIP floodplain management criteria, or those that do
not contain adequate enforcement provisions, or those which cannot be enforced through
other mechanisms. Such deficiencies could result in the community’s suspension. An
example is when the local zoning requirements conflict with local floodplain management
regulations.
2. Minor
Minor program deficiencies in the community’s floodplain management regulations are
those that need to be corrected, but that have not impeded the community’s ability to
enforce the NFIP floodplain management provisions or are not critical to the effective
implementation of the regulations.
3. None
None indicates that the community’s floodplain management regulations are compliant.
b. Administrative and Enforcement Process and Procedures
1. Serious
Serious program deficiencies in a community’s administrative and enforcement process
and procedures are those that have resulted or could result in substantive violations
that increase potential flood damages or stages in the community. Examples of such
substantive violations include: obstructions to floodways or stream channels that increase
the base flood elevation; residential structures that are located with the lowest floor below
the BFE; non-residential structures with the lowest floor below the BFE that are not properly
floodproofed; and structures in V Zones with non-breakaway walls below the BFE.
Additional examples are:
(a) Failure to require permits for proposed construction or other development
within floodprone areas and/or failure to review such permit applications and
subdivision proposals to ensure that all such construction and development
is adequately designed, located, constructed, and anchored to minimize
flood damage.
(b) Failure to obtain and reasonably use any available flood data as criteria for
setting local elevation and floodproofing requirements.

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6. Community Assistance Visit: Documentation

(c) Administrative procedures and practices that are not workable or cannot
reasonably ensure compliance with the local ordinance (e.g., the community
does not inspect new structures or changes to existing structures for compliance
and does not record “as-built” elevation data).
(d) Variance procedures or variances granted that are not consistent with NFIP
variance criteria.

2. Minor
Minor program deficiencies in a community’s administrative and enforcement process
and procedures are those that are easily corrected and have not resulted in multiple or
substantive violations or increased exposure to flood losses. Minor program deficiencies
generally involve some type of mitigating factor and can be resolved within a relatively
short period of time through the provision of technical assistance. The community should
take actions to resolve past problems.
Examples of minor program deficiencies include:
(a) Permit or variance records are not organized or not easily accessible;
(b) The BFE is not indicated on the permit; and
(c) The community is unfamiliar with certain NFIP requirements (e.g., floodway
encroachments, notifying property owners of the effect a variance may have
on flood insurance rates), but no specific violations have resulted from the
community’s lack of knowledge and unfamiliarity with the requirements.

3. None
None indicates no problems were identified.
c. Engineering: Flood Maps and Study
1. Serious
Serious problems with the community’s flood maps or study impact the entire community
and involve: major changes in the floodway, adjustments to the BFE that can be remedied
by a restudy, or a boundary change that includes significant additional SFHAs. Serious
problems with a community’s flood map or study generally need immediate action for a map
revision. Identify, document, and summarize the problems in the CAV report by location and
forward to the appropriate FEMA Regional Office Engineer for follow-up action.
2. Minor
Minor problems with a community’s flood maps or study are those that affect only one or
two FIRM panels or one flooding source and can be remedied by the LOMR or Physical
Map Revision process. Minor problems with a community’s flood map or study can
generally be resolved with the next comprehensive restudy or revision.

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3. None
None indicates no problems were identified.
d. Other Problems or Issues not included in the
Regulations, Administrative, or Engineering Categories
1. Serious
Serious problems are actions being taken by the community that are inconsistent with,
or cannot reasonably ensure compliance with, local floodplain management regulations.
For example: A CLOMR is issued based on a proposed project that will remove a portion
of the effective SFHA to outside the SFHA. The community then begins allowing atgrade development in the area before the project is finished or before the “as-built”
condition is submitted for a LOMR to officially remove the area from the SFHA.
[44 CFR §60.3(c), 65.3].
2. Minor
Minor problems are actions being taken by the community that need to be corrected, but
that have not impeded the community’s ability to enforce the NFIP floodplain management
provisions, or are not critical to the effective implementation of the regulations.
3. None
None indicates no problems were identified.
e. States Conducting CAVs on Behalf of FEMA
States conducting CAVs on behalf of FEMA must enter the CAV findings into the CIS
and provide any supporting documentation to the FEMA Regional Office within 30 days
from the date of the CAV. The CAV becomes part of the community’s permanent record
maintained in the CIS and the NFIP community files at the FEMA Regional Office.
f. Regional Office Staff
Regional Office staff must enter their CAV findings into the CIS within 30 days from the
date of the CAV along with any supporting documentation. The CAV becomes part of the
community’s permanent record maintained in the CIS and the NFIP community files at the
FEMA Regional Office.

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6. Community Assistance Visit: Documentation

g. Copies of Documentation
Copies of documentation that support the CAV findings (e.g., any NFIP-floodplain
development review forms or similar, the community’s development permit form and
review procedures, examples of floodplain development permits or variances granted,
other documents related to the community’s development review process, other maps
or studies used to regulate floodplain development, elevation certificates, and other
certifications) should be included in the community file.
In addition, the following information should be included with the community file and/or
in the CIS:

•

Community contacts,

•

The list of attendees,

•

Current floodplain management regulations, if different than the copy reviewed, and

A letter to the CEO informing the community of the findings of the visit and any follow-up
correspondence with the community.

6.3 Letter to the Community CEO
The initial follow-up letter is the official method
The amount of information in the
of informing the community of the CAV findings.
initial follow-up letter to the CEO will
While there is no specified format, most States
depend on the findings of the CAV
and FEMA Regional Offices rely on a cover
and the type of technical assistance
letter with an attachment detailing program
needed by the community.
deficiencies and possible violations identified
as part of the CAV. The follow-up letter should
be sent to the CEO, with a copy to the local official responsible for implementing NFIP
floodplain management regulations, within 30 working days from the date of the CAV.
If there is more than one office implementing floodplain management regulations in the
community, each office should receive a copy. For States conducting CAVs on behalf of
FEMA, a copy of the follow-up letter should be sent to the FEMA Regional Office within
30 working days from the date of the CAV.
If one or more substantive program deficiencies or possible violations are identified,
the follow-up letter should be sent via certified mail to the CEO. A substantive program
deficiency or violation is one that has resulted or could result in increased potential flood
damages or flood stages in the community. If no particular problems are identified, or if
program deficiencies are relatively minor (e.g., there is no history of prior violations and
the community has indicated a willingness to resolve the issues or problems, or if only a
single program deficiency has occurred), the follow-up letter to the CEO would not have
to be sent via certified mail.

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Guidance for Conducting CACs and CAVs

When one or more substantive program deficiencies or suspected violations are identified,
States conducting CAVs on behalf of FEMA should coordinate with the FEMA Regional
Office before the letter is sent to the CEO. In most instances, the State should prepare and
send the follow-up letter to the community. When major compliance problems are found
during the CAV, States may prepare a brief letter to the community informing it of the intent
to notify FEMA of the findings, and that FEMA will be contacting the community. This type of
follow-up letter to the community must receive prior approval from the FEMA Regional Office.
Sufficient detail should be provided in the follow-up letter so that the actions required
by the community to correct any program deficiencies and possible violations are easily
understandable. The follow-up letter should be positive. It should thank the community
for its help and offer assistance in the event the community has a particular floodrelated problem or question about the NFIP. If no particular problems are identified in the
community, and if the community appears to be doing a good job in administering the
NFIP and is implementing higher standards, the community should be complimented for
its efforts and recommended for the CRS. It is important to make this recommendation as
soon as possible and to note this recommendation in the CIS to provide appropriate CRS
coordination and follow-up.
The follow-up letter should set specific deadlines by which the community must respond.
While a structure or other development is presumed to be in violation until documentation
is submitted, communities should be afforded a reasonable timeframe to provide
this information. If serious deficiencies and/or potential violations are identified, they
must be stated in the initial follow-up letter. The letter should set specific deadlines for
specific actions, such as adopting NFIP or regulatory requirements, correcting program
deficiencies, and providing documentation for possible violations. Depending on the
requested community action, there must be specific deadlines provided (e.g., 30, 45, 60,
or 90 days for the community to respond to the letter itself and to the specific actions cited
in the initial follow-up letter). After a community submits the information requested as part
of the CAV follow-up, it should receive a response within 30 days.
Participating CRS communities must always be in full compliance with the minimum NFIP
requirements. If a CRS-participating community is identified with program deficiencies
or suspected violations, it is expected to expeditiously correct program deficiencies and
remedy violations to the maximum extent possible or face retrograde out of the CRS as
the first step of compliance actions. Please refer to Appendix F and Chapter 7 of this
document for more detail regarding CRS community retrograde process.
The initial follow-up letter to the community will contain the CAV findings. When
suspected violations are found, the community must be given specific deadlines to submit
documentation (e.g., as-built elevation data if the lowest floor appears below the BFE).
The initial follow-up letter will need to address each situation identified. It is important
that this initial letter bring to the CEO’s attention all of the issues that he/she will have
to resolve without delay. Deferring citations of suspected violations until future follow-up
letters sends the CEO a mixed message.

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6. Community Assistance Visit: Documentation

Where program deficiencies and possible violations are identified, the following items
should be used as a guide in developing the follow-up letter to the CEO:
a. Restate the date of the CAV and its purpose, and include the names of the participants.
b. Include an assessment of the CAV findings, detailing specific program deficiencies and/or
possible violations, if any, and the community’s NFIP history.
c. List the required corrective actions, including preventive measures and procedural
changes by the community (e.g., begin requiring permits for fill, revise the permit
application form to include the BFE, revise the floodplain management regulations to
incorporate NFIP regulatory changes). Also indicate the need for additional supporting
data (e.g., a copy of the revised permit application form, lowest floor elevations, etc.).
If the community’s floodplain management regulations do not meet the minimum
requirements of the NFIP, cite the changes that are needed to bring the regulations into
compliance.
A structure or other development is
presumed to be in violation until the following
documentation is provided:

While a structure or other
development is presumed to be
in violation until documentation is
submitted, communities should be
afforded a reasonable timeframe
to provide the information.

1. Evidence that buildings constructed with
electrical, heating, ventilation, plumbing,
and air-conditioning equipment, and
other service facilities, are designed and/
or located so as to prevent water from
entering or accumulating within the components during conditions of flooding [44 CFR
§60.3(a)(3)(iv)];
2. Obtaining the “as built” lowest floor elevation in all SFHAs where BFEs are used
[44 CFR §60.3(b)(5)];
3. The lowest floor elevation of structures in A Zones when BFEs have been determined/
developed [44 CFR §60.3(c)(2) and (3)];
4. Evidence of certification of floodproofed non-residential structures [44 CFR §60.3(c)(4)];
5. Evidence that openings meet the minimum openings criteria of the NFIP or,
alternatively, certifications for the design of openings of a fully enclosed area below
the lowest floor subject to flooding criteria [44 CFR §60.3(c)(5)];
6. Evidence of a “no rise” certification for development in the floodway [44 CFR §60.3(d)(4)];
7. The “as-built” elevation of the bottom of the lowest horizontal structural member of the
lowest floor in all V Zones [44 CFR §60.3(e)(2)];
8. Record of certification that the pile-and-column foundation and structure attached is
anchored to resist flotation, collapse, and lateral movement [44 CFR §60. 3(e)(4)]; and
9. Certification for a breakaway wall when design strength exceeds minimum NFIP
criteria [44 CFR §60.3(e)(5)].
d. Provide details on the assistance provided or promised.

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Guidance for Conducting CACs and CAVs

e. Stress the importance of the community’s responsibility to monitor development in the
SFHA and to enforce floodplain management regulations. Emphasize that effective
enforcement of community regulations not only minimizes flood damages to structures,
but also results in lower flood insurance rates.
f. If a restudy is underway, reiterate the discussion or clarify issues raised during the CAV
(e.g., when to expect a preliminary copy of the study, when to expect a final meeting, and
when the community should update its regulations).
g. Suspected violations that impact FEMA FIRMs/BFEs should also be copied to the FEMA
Regional Office Engineer for entry into the spatial geodatabase, which documents and
prioritizes floodplain mapping needs and requests.
h. Provide the name, address, and telephone number of the person to whom the
community’s actions should be reported or from whom assistance should be requested.
The agency that conducted the CAV should be the most likely contact for the community
during the initial CAV follow-up. However, States should coordinate with the FEMA
Regional Office to determine the appropriate strategy for CAV follow-up, including
whether a Corrective Action Plan (when substantive program deficiencies or violations
are discovered) is required.
Enclose information materials as promised (e.g., copies of Elevation Certificates or
Floodproofing Certificates, NFIP regulations, Technical Bulletins, Floodplain Management
Bulletins, or other publications). See the available publications list on the FEMA.GOV
Floodplain Management Web Page under “Resources.”

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Chapter 7
Community Assistance Visit: Follow-Up
7.1 General
It is important that the recommendations and corrective actions indicated in the CAV
findings in the CIS and cited in all letters to the community be actively monitored and
pursued to ensure that the community is complying with the NFIP floodplain management
requirements. Even actions required of those other than the community (e.g., for map
revisions) need to be monitored and pursued on a timely basis. It is also very important
that all technical assistance promised by FEMA or the State be provided to the community
on a timely basis.

Three important aspects of the CAV follow-up phase include:
1. Provision of community assistance;
2. Monitoring and oversight; and
3. Documentation through a detailed chronology of all follow-up actions; technical assistance;
and contacts among and between FEMA, the State, and the community.
If the deficiencies and violations identified by the CAV are not resolved in a reasonable
time during the CAV process, this chronology will become an essential part of initiating
formal compliance actions (e.g., probation and/or suspension) described in the NFIP
Community Compliance Program Guidance manual (hereafter referred to as the
Compliance Manual).

7.2 Provision of Community Assistance
Most CAVs will require at least some follow-up by the community, the State, or FEMA.
A CAV should not be closed until each of the issues or problems identified have been
resolved or remedied to the maximum extent possible and all assistance promised to the
community has been provided. CAVs that do not require follow-up action or community
assistance should be closed. If follow-up assistance is required, every effort must be made
to provide it within 90 days from the date of the CAV. The “closed” date of the CAV will be
determined by the FEMA Regional Office in close coordination with the State, especially if
the CAV is conducted by State staff.

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Guidance for Conducting CACs and CAVs

Technical Assistance is the First Step.
Community officials want to do the right thing, but may not always know what the right
thing is. Most deficiencies in community programs or violations of local ordinances are
likely due to ignorance of NFIP criteria, lack of technical skills, failure to understand
the rationales behind program requirements, or lack of an appreciation of insurance
implications and other consequences of a decision. Most problems may be resolved
through community assistance efforts prior to commencement of an enforcement action.
a. Types of Community Technical Assistance
For many CAVs, some follow-up technical assistance will be necessary to resolve or
remedy program deficiencies and/or violations. The types of technical assistance available
to communities after the CAV is conducted include:
1. Assisting the community in preparing and adopting floodplain management
regulations that meet or exceed NFIP requirements.
2. Encouraging the Floodplain Administrator and/or other local officials to attend NFIP
training courses as appropriate.
3. Assisting local officials in identifying and correcting any program deficiencies that led
to a violation.
4. Discussing with local officials possible remedial actions that are within the bounds
of the community’s legal authority and consistent with the NFIP requirements. The
discussion may include citing the property as a violation and notifying the property
owner of corrective actions to take in a specific timeframe; noting the ability to issue
penalties; expressing a willingness to pursue the violations in court; documenting the
violation on the deed and/or title to the property, and/or requesting a Section 1316
Denial of Flood Insurance.
5. Assisting the community in developing a permit system, including use of a permit
application, permit approval process, inspections, certificate of occupancy, recordkeeping, checklists, and coordination among the FPA, the Building Department and
any other departments involved in the planning and permit review procedures.
6. Assisting the community in obtaining and completing Elevation Certificates,
floodproofing certificates, or equivalent documentation.
7. Assisting the community in understanding the procedures for filing, reviewing,
and processing variances.
8. Assisting the community in specific NFIP floodplain management technical building
requirements under 44 CFR §60.3, such as: V Zone coastal construction standards,
protecting machinery and equipment, understanding the enclosure and openings
requirements, and following the flood-related provisions of the I-Codes™, if adopted.
9. Assisting the community in obtaining and using the FEMA Maps, FIS, and DFIRM.
10. Guiding the community on flood-loss reduction techniques and methods such as
elevation, floodproofing, retrofitting, land acquisition, development controls, higher
regulatory standards, adoption of I-Codes™ and ASCE 25-05 and best management
property protection measures including No Adverse Impacts.
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7. Community Assistance Visit: Follow-Up

11. Guiding the community on how to obtain or develop flood elevations in A Zones
without BFEs and how to perform floodway calculations.
12. Assisting the community in understanding the procedures for LOMCs and Physical
Map Revisions.
13. Encouraging CRS participation and providing application assistance.

7.3 Monitoring and Oversight
It is necessary to ensure that local officials pursue actions to resolve or remedy any
program deficiencies and/or violations to the maximum extent possible. For example,
updating floodplain management regulations and permitting processes are common CAVrelated activities that are typically resolved in a shorter timeframe than remedying structure
violations. While it can take three months to one year in some communities to amend an
ordinance, remedying a structure violation can take longer. It is important that local officials
pursue these short- and long-term activities simultaneously.
a. Corrective Action Plans
A corrective action plan is the community’s commitment (in any format, including by letter)
to resolve all program deficiencies and violations to the maximum extent possible, in an
agreed upon timeframe. The corrective action plan is noted with a lower-case “p” and is
not a formal Plan, such as a Hazard Mitigation Plan. It is also sometimes referred to as a
“remediation plan.”
If the community has substantive proven violations or is not adequately proceeding
toward resolution of the identified program deficiencies, a corrective action plan should
be considered. In most cases, a corrective action plan should be requested after the
initial CAV follow-up letter has been sent and the community has provided documentation
that confirms the existence of the suspected program deficiencies and violations. The
corrective action plan can also be used when the more straightforward corrective actions
(for deficiencies) have been completed and only the more complex, time-consuming
corrective actions (for violations) remain.

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Guidance for Conducting CACs and CAVs

Corrective Action Plan (aka: Remediation Plan): Key Points and Benefits

•

Created by the community to demonstrate community ownership of remediation and
intent to comply;

•

Cites all deficiencies and violations to be addressed;

•

Provides specific remediation methods for all violations that ensure that each is fully
corrected or mitigated to the maximum extent practicable by law;

•

Provides specific revisions to administrative procedures to address all program
deficiencies; and

•

Provides milestones for all required actions, including the frequency of reporting progress
to FEMA.

b. Corrective Action Plan Process
The FEMA Regional Office or State sends
a letter to the community CEO with the CAV
results and requests any follow-up actions per
section 6.3 of this document. The community
responds to the letter with some or all
requested documentation. The Region or State
reviews the documentation and determines
any remaining identified deficiencies and
substantive violations to be included in the second follow-up letter to the CEO. This
letter should request a corrective action plan with timeframes for how the community will
resolve each identified program deficiency and substantive violation to the maximum
extent possible. Communities should be provided with a reasonable degree of latitude in
determining how to correct a program deficiency or remedy a violation if they are operating
on specific, agreed upon timeframes for resolution. However, the Regional Office or State
should provide recommendations on a range of possible remedial actions. If the initial
follow-up letter did not include it, consider requesting a “resolution of intent to comply”
from the community.
A corrective action plan acknowledges
the specific program deficiencies and
individual violations, and specifies
what the community will do to remedy
each issue and by what date the
corrective action will be completed.

The corrective action plan helps ensure progress toward resolving any identified issues
or problems, and all actions should be periodically reviewed by telephone contact, e-mail,
or meeting with local officials as necessary. A corrective action plan helps focus the local
official’s attention in an effort to resolve these issues before FEMA initiates the formal
compliance actions of probation and/or suspension. This plan acknowledges the specific
program deficiencies and individual violations, and specifies what the community will do to
remedy each issue and by what date the corrective action will be completed.
The letter to the CEO should set a 30- to 60-day limit on when the corrective action plan
must be provided to FEMA, and it should include dates for resolving each of the program

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7. Community Assistance Visit: Follow-Up

deficiencies and violations. The most common timeframes for completing corrective
actions for deficiencies are 30, 60, and 90 days. However, judgment must be used to set
reasonable and achievable deadlines based on the nature and complexity of the problems.
Keeping a timetable of expectations/milestones for completing corrective actions and
documenting all follow-up is critical to the process. Once a corrective action plan is in
place, the milestones should be updated in the CIS Compliance Follow-up screens to track
and monitor progress.
Failure to Respond or Inadequate Response
The FEMA Regional Office should consider pursuing an enforcement action leading to
probation or suspension if:

•

The community CEO does not produce an acceptable plan within 30 to 60 days of the
request (or reply by addressing all issues in a letter);

•

The remedies are not completed per the cited milestones (and there are no extenuating
circumstances); or

•

At any time in this process, one or more of the corrective actions is not resolved
appropriately after several attempts to gain compliance following the issuance of the
CAV report and follow-up letter(s).

The Compliance Manual explains the documentation that will be needed for FEMA to
take an enforcement action. It further provides the process for placing a community on
probation and/or suspension. States and the FEMA Regional Office should coordinate
closely before the FEMA Regional Office initiates an enforcement action. Regional
Offices must coordinate all enforcement actions with the FEMA HQ Floodplain
Management Branch.
c. CRS Retrogrades
In order to participate in the CRS, communities are required to have a CAV to verify that
they are fully compliant with the minimum standards of the NFIP. Once participating, they
must remain in compliance to continue receiving CRS premium discounts. Therefore,
when a CAV has identified any deficiencies and/or violations in a CRS community,
corrective actions must be expeditiously completed by the community or the premium
discount benefit must be removed by retrograding the community to a Class 10. In
addition, if a CRS community is not implementing or enforcing certain CRS activities that
it is receiving credit for, such as the higher regulatory standard of “Freeboard,” it will lose
the credits for this activity. Removing the CRS discount is considered the first step in a
compliance action against a CRS community. Retrograding the community from CRS
removes the flood insurance discounts the community earned for its policyholders through
its CRS rating. Beyond the loss of the CRS discount, the unresolved deficiencies or
violations that triggered the CRS retrograde may ultimately lead toward the enforcement
action of probation and suspension. The CRS retrograde action must be done according
to the CRS retrograde process as described in Appendix F, including coordination with the
Regional Office CRS Coordinator.
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Guidance for Conducting CACs and CAVs

d. Notifying FEMA Regional Offices
States should contact the FEMA Regional Office when communities have not taken the
required corrective action(s) within the established and agreed-upon timeframes and after
all attempts to assist the community have failed. Contacting the Regional Office should
occur at the earliest possible point when the identified issues may require an enforcement
action or other follow-up assistance by FEMA. The FEMA Regional Office, in consultation
with the State, will determine the appropriate follow-up action.
Ensuring that communities comply with NFIP floodplain management requirements by
conducting enforcement actions is ultimately a FEMA responsibility and cannot be delegated to
States. FEMA supports and encourages States to provide community assistance and to consult
with communities on ways to correct program deficiencies and remedy violations.

States are also expected to initiate enforcement actions based on their own statutory or
regulatory authorities. The FEMA Regional Offices support State-initiated enforcement
actions by providing technical assistance and initiating FEMA enforcement action, where
appropriate. Based on the precedence clause in 60.1(d) of the NFIP regulations, FEMA
will support these State-initiated enforcement actions even in instances where State
regulations are more restrictive than NFIP minimum criteria. The precedence clause states
that “any floodplain management regulations adopted by a State or a community which
are more restrictive than the criteria set forth in this Part are encouraged and shall take
precedence.” However, if a State chooses not to enforce its own regulation, FEMA must
limit its enforcement actions to compliance with NFIP minimum criteria.
If a community is not enforcing its own locally adopted higher standards (that are not
backed by State requirements), the CAV should include discussion of the community’s
intentions for enforcing the higher regulatory standards. If the community indicates that it
does not intend to enforce one or more of its adopted higher standards, the State or FEMA
Regional Office should encourage the community to revise its floodplain management
regulations. However, FEMA can only take an enforcement action against a community for
failing to enforce a higher NFIP standard when it was required by State law, and the State
is enforcing that law. Please refer to Figure 7-1 for a full discussion of the Precedence
Clause and Higher Standards.
The FEMA Regional Offices will consult with State agencies conducting CAVs on behalf of
FEMA prior to initiating an enforcement action and will periodically inform the State agency
of actions taken to achieve community compliance.

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7. Community Assistance Visit: Follow-Up

Community has Adopted Higher Regulatory Criteria but is not
Enforcing the Criteria
A number of participating NFIP communities have adopted higher regulatory
criteria, such as freeboard, either because a State statute or regulation required
it or communities have chosen to adopt higher regulatory criteria on their own.
If during a CAC, CAV or other contact with the community, it is discovered that
the community is not enforcing its higher regulatory criteria, FEMA and the State
need to find out why. Detailed guidance is provided below on the following three
scenarios:
1. Communities in a State with a statute or regulation requiring higher
regulatory criteria;
2. Communities that have chosen to adopt higher regulatory criteria in States
that do not have such a statute or regulation; and
3. Community Rating System (CRS) communities that receive credits for higher
regulatory criteria.
Communities in a State with a statute or regulation requiring higher regulatory criteria:
Some States may have a statute or regulation that is more restrictive than the NFIP
floodplain management criteria. Communities in those States may be required
to adopt and enforce those State higher regulatory criteria. If a State requires its
communities to adopt higher regulatory criteria and a community does not adopt
or enforce the State-required higher regulatory criteria, the State may initiate
an enforcement action under its authorities. If the State does not approve the
community’s regulations because those regulations do not meet State criteria,
FEMA can suspend the community. However, FEMA cannot suspend a community
for failure to adopt higher regulatory criteria contained in the State model ordinance
unless the State has a statute or regulations in place requiring the adoption of
higher regulatory criteria.
Based on the precedence clause in 44 CFR §60.1(d), FEMA will support a State
initiating an enforcement action against a community in instances where the
community is not enforcing its higher regulatory criteria but is required to do so
based on a State statute or regulation. The precedence clause states that “any
floodplain management regulations adopted by a State or a community which are
more restrictive than the criteria set forth in this Part are encouraged and take
precedence.” FEMA can take an enforcement action against a community if a State
also pursues enforcement actions against a community that has failed to enforce
the more restrictive criteria established under State statute or regulation.

Figure 7-1. The Precedence Clause and Higher Standards

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Guidance for Conducting CACs and CAVs

If a State chooses not to enforce its own statute or regulation pertaining to high
regulatory criteria, FEMA shall limit its own enforcement actions to those assuring
compliance with NFIP criteria. FEMA should coordinate with the State in contacting
the community to find out whether the community is willing to enforce the State
higher regulatory criteria. Because of concerns over legal enforceability of the
community’s regulations [44 CFR §60.2(b)], FEMA should approach the State and
find out whether the higher regulatory criteria in the community’s regulations can be
removed. However, it may not always be possible to remove the higher regulatory
criteria if those criteria are required under State statute or regulation.
Communities that have chosen to adopt higher regulatory criteria in States that do
not have such a statute or regulation:
The precedence clause quoted above [44 CFR §60.2(b)] also applies to
communities that have voluntarily adopted higher regulatory criteria. FEMA can
only condition acceptance of participation in the NFIP based on NFIP requirements
and not on more restrictive community criteria [44 CFR §59.24(a) and §59.24(d)
and §60.1(d)]. Therefore, FEMA must limit its enforcement actions to the NFIP
criteria. Further, FEMA cannot take an enforcement action against a community for
not enforcing its adopted higher regulatory criteria.
As part of the CAV or CAC follow-up, FEMA or the State should ask the community
to either effectively enforce the higher regulatory criteria or to remove the
criteria from the community’s regulations. The concern is that if the community’s
regulations contain provisions that are not being enforced, the community may be
challenged over legal enforceability of its regulations [44 CFR §60.1(b)].
Community Rating System
The CRS recognizes community efforts that go beyond the minimum NFIP
floodplain management criteria through reduced flood insurance premiums.
Communities can receive credit for adopting such things as freeboard,
enclosure restrictions, and requiring that all structures be free of obstruction
in V Zones. If a CRS community receives credit for higher regulatory criteria,
but does not effectively enforce those criteria, FEMA must remove those CRS
credits. The loss of CRS credits applies to both situations described above in
the first two subsections.

Figure 7-1. The Precedence Clause and Higher Standards, continued

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7. Community Assistance Visit: Follow-Up

e. Notifying FEMA Headquarters (HQ)
The FEMA Regional Offices should identify enforcement actions or other issues that
require FEMA HQ involvement, action, and/or assistance at the earliest stage possible.
Since the CAV report will be in the CIS, the FEMA Regional Office should forward only
the relevant CAV supporting documentation needed by the respective FEMA HQ program
offices (Floodplain Management, Mapping, Insurance) with a brief cover memorandum or
e-mail stating the issue(s) that need(s) to be addressed. The FEMA Regional Office will
similarly forward State CAVs to FEMA HQ. Guidance for forwarding CAV reports to the
FEMA HQ program offices is provided below.
1. Possible Enforcement Actions
CAVs of communities with identified serious program deficiencies and violations resulting
in a recommendation for potential enforcement action should be forwarded to the FEMA
HQ Floodplain Management Branch. These CAVs should remain open until the program
deficiencies and violations have been resolved or an enforcement action has been
initiated.
2. Engineering or Mapping Issues
CAVs that identify deficiencies in an FIS report or FIRM, or that identify other engineering
issues requiring FEMA HQ action or assistance should be forwarded to the FEMA HQ
Mapping Branch, to ensure that the information is entered into the spatial geodatabase to
document and prioritize floodplain mapping needs and requests. Otherwise, all identified
mapping issues specific to a community should be forwarded to the FEMA Regional Office
Engineer for appropriate follow-up.
3. Flood Insurance Rating Issues
The person conducting the CAV is not an insurance underwriter and cannot be expected
to specifically determine whether a structure is or is not correctly rated. A number of
violations and/or variances in a community could be indicators of possible misrated
policies, especially for buildings altered after initial ratings. If misrating is suspected,
certain information (such as CAV Floodplain Development Review Worksheet-Appendix D
and Elevation Certificates) should be gathered for each structure and forwarded to FEMA
HQ Insurance Underwriting Branch for verification and possible rerating in accordance
with established procedures. In addition, issues related to the provisions in the Flood
Insurance Manual – or those related to routine flood insurance policy servicing, including
agent instruction or complaints – should also be forwarded to the FEMA HQ Insurance
Underwriting Branch.
4. Flood Insurance Claims Issues
CAVs that identify issues related to flood insurance claims (including ICC claims) or
issues related to agent or other claims complaints should be forwarded to the FEMA HQ
Insurance Claims and Appeals Branch. 

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Guidance for Conducting CACs and CAVs

5. Programmatic Issues
These issues may require a policy or regulation interpretation or technical assistance
on flood-loss reduction strategies or techniques. Occasionally, a CAV will highlight an
issue that has implications broader than the individual community. A CAV could show, for
example, that there is widespread misunderstanding of a NFIP floodplain management
requirement or of guidance in a FEMA publication. Programmatic issues could require
a regulation change or a need to update existing guidance, or could require a technical
bulletin, a floodplain management bulletin, or other publication. These issues should be
forwarded to the FEMA HQ Floodplain Management Branch.
6. Possible Lender Issues
CAVs that identify issues related to lending practices should be sent to the FEMA HQ
Insurance Industry & Public Relations Branch.  The Flood Disaster Protection Act of
1973 and the National Flood Insurance Reform Act of 1994 require Federal financial
regulatory agencies to adopt regulations prohibiting regulated lending institutions from
making, increasing, extending, or renewing a loan for improved real estate or a mobile
home located or to be located in an SFHA of a community participating in the NFIP,
unless the property securing the loan is covered by flood insurance. The Reform Act
also applies flood insurance requirements directly to the loans purchased by the Federal
National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage
Corporation (Freddie Mac). It also applies flood insurance requirements to agencies that
provide government insurance or guarantees. Such agencies include the Small Business
Administration, Federal Housing Administration, and the Veteran’s Administration. 
Although implementation of the mandatory flood insurance purchase requirements is the
responsibility of the various Federal lending agencies, FEMA routinely assists lenders by
providing guidance that helps lenders meet their obligations under the Acts.
7. Executive Order 11988: Floodplain Management
If, during a CAV, a Federal facility appears not to have been properly protected to the
100-year flood, or a Federal critical facility does not appear to have been protected to the
500-year flood, the FEMA Regional staff person conducting the CAV may want to contact
the regional office of that Federal agency to discuss procedures for evaluating new or
improved Federal facilities in the floodplain (States should forward information to the
FEMA Regional Office). While Federally owned facilities are not subject to local permits,
Federal agencies should be encouraged to coordinate with the community in which they
are located. Note: FEMA has no authority over other Federal agencies in implementing
EO 11988. However, FEMA is a consultation agency under EO 11988 and often provides
technical assistance when requested by Federal agencies. Therefore, if there are
particular issues concerning a Federal facility in the floodplain, the person conducting
the CAV may contact or forward information from the CAV to the FEMA HQ Floodplain
Management Branch.

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7. Community Assistance Visit: Follow-Up

8. CAVs of Special Interest
Some CAVs are of special interest even though they may not identify significant problems
or require enforcement or other follow-up action. Examples of these CAVs include
communities that have implemented exemplary floodplain management programs or
innovative solutions to floodplain management problems, or chronic problem communities
that now have effective programs. In addition, there are some CAVs that may prove
controversial, such as those conducted one year or more after a major Presidentially
declared disaster (e.g., 1994 Midwest Floods, Hurricane Katrina). These CAVs should be
brought to the attention of the FEMA HQ Floodplain Management Branch.

7.4 Follow-up Documentation/Chronology
All follow-up activities (actions by the community and/or technical assistance promised to
the community by FEMA or States) must be thoroughly documented in the CIS. Because it
is impossible to know whether an enforcement action will become necessary, it is important
to document relevant community activities. States should enter all documentation in the
CIS in the appropriate fields, send signed correspondence via e-mail (with copies placed in
the CIS CAV fields), and retain oversized documents in the State file until requested by the
FEMA Regional Office when follow-up activities have been completed.
The chronology is also critical when undertaking a formal enforcement action of probation
or suspension, to demonstrate to Federal, State, and local officials (and possibly
the media) that every effort has been made to obtain compliance (highlighted by all
documented responses) before a formal enforcement action follows. Please refer to the
Compliance Manual for additional advice on the above issues.
Documentation of follow-up activities must include the following:

•

A chronology of follow-up telephone contacts, e-mails, letters, and meetings;

•

Copies of follow-up letters;

•

A chronology of assistance provided to the community; and

•

A chronology of actions taken by the community and supporting evidence (e.g., adopted
floodplain management regulations, revised permit procedures, written evidence of
certifications of lowest floor elevations for structures suspected to be in violation of
community floodplain management regulations).

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Guidance for Conducting CACs and CAVs

Completed corrective actions for floodplain management program deficiencies and
violations identified during the CAV process fall into three basic categories:
1. Resolving the problem by amending the floodplain management regulations or by
making a full correction to a program deficiency, such as adding or adjusting steps/
procedures/checklists in the permit implementation process to ensure all floodplain
management requirements are met as part of that process.
2. Making a full correction to a violation (e.g., elevating the lowest floor of a structure
constructed below the BFE; filling in a basement; installing openings; removing living
space in an enclosure that is below BFE).
3. The third, more challenging category occurs when a community cannot make a
full correction to a structure in violation, but must still remedy the violation “to the
maximum extent possible,” as defined in 44 CFR §59.1 and discussed in detail in the
Compliance Manual.

7.5 The Compliance Manual
When the CAV follow-up process, including requesting a corrective action plan, has not
resolved the substantive program deficiencies and/or violations that were identified,
the appropriate NFIP enforcement actions of probation and/or suspension should be
initiated. Guidance for undertaking enforcement actions can be found in the Compliance
Manual, which establishes the procedures for the NFIP community compliance program.
It describes enforcement actions tailored either to communities or property owners,
depending on with whom the problem originated. The Compliance Manual also describes
the steps required to implement these enforcement actions and the coordination with
FEMA HQ staff that is a necessary part of the enforcement process. Regions should
consider an array of enforcement options in obtaining community compliance, allowing for
differing community situations. No two enforcement actions will be the same since there
are many types of communities and many kinds of program deficiencies and violations. As
a result, various aggravating and mitigating factors will need to be taken into consideration
as outlined in the Compliance Manual.
The following tables from the Compliance Manual illustrate common examples of ways to
remedy program deficiencies and violations.

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7. Community Assistance Visit: Follow-Up

Table 7-1. Examples of Ways to Remedy Program Deficiencies

•

Amend ordinances to close loopholes or correct other program deficiencies that allowed
the violations to occur.

•

Amend ordinances to include more effective enforcement provisions or add penalty provisions.

•

Change administrative procedures to improve the permitting and inspection process. This
could include revisions of permit, certification, or inspection forms, changes in inspection
procedures, or changes in procedural instructions given to the building inspector and
other staff.

•

Pass a resolution of intent to fully comply with NFIP requirements.

•

Change or increase staff or resources used to enforce the local ordinances (FEMA
generally does not mandate this remedial measure).

•

Provide missing elevation, V Zone, or floodproofing certificates.
Table 7-2. Examples of Ways to Remedy Violations

•

Demonstrate that the structure is not in violation by providing the missing elevation,
V Zone, or floodproofing certificates.

•

Submit engineering data showing that floodway fill results in “no increase” in flood stage.

•

Rescind permits for structures not yet built or in the early stages of construction.

•

Tear down or modify the non-compliant structure or remove fill from the floodway. (If
the structure or other development cannot be made fully compliant, a lesser degree of
protection should still be provided.)

•

Develop and implement a master drainage plan or construct flood-control works to protect
non-compliant structures.

•

Seek civil/criminal penalties as provided for in the local ordinance or community code. In
the case of a judgment in court against the community in such an action, the community is
expected to appeal the decision if there are grounds for doing so.

•

Initiate licensing actions against architects, engineers, builders, or developers responsible
for the violations.

•

Submit survey data/documentation required to verify insurance rates for existing policies.

•

Issue declarations and submit them for Section 1316, Denial of Insurance.

•

Submit evidence that the structure cannot be cited (legal constraints in State or local
legislation, deficiencies in the ordinance, etc.).

•

Submit sufficient data to verify the information submitted by the property owner of an
uninsured building so that FEMA can ensure the building is properly rated if a policy is
applied for in the future.

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Guidance for Conducting CACs and CAVs

A. CAC Checklist of Issues for Discussion

A.1 Floodplain Management Regulations
‰‰Ensure regulations reviewed are the most current.
‰‰Determine if floodplain management is administered through a stand-alone

floodplain management ordinance, through one or more of the building codes
listed in Appendix G of the International Building Code, or through a companion
floodplain management ordinance.
‰‰Discuss any inadequacies, omissions from, and overlaps among the above
adopted regulations or building codes. Discuss any other problems identified
during the prior review of the regulations.
‰‰Offer assistance in updating the community’s floodplain management regulations.
‰‰Discuss any other issues related to the community’s floodplain management
regulations.

A.2 Map Availability and Accuracy
‰‰Determine whether the community has current FEMA maps and study.
‰‰Determine whether the community uses other maps or studies for regulating
the floodplain.

‰‰Determine whether the community needs training on DFIRMs or on supporting

digital tools.
‰‰Identify problems using FEMA maps or study, such as A Zones without BFEs.
‰‰If recent flooding history, ask for a description of the cause, extent, and damage.
‰‰Identify problems with accuracy of FEMA maps or study.
‰‰Identify boundary changes, annexations, or de-annexations.
‰‰Determine community’s familiarity with LOMC and Physical Map Revision Process.

A.3 Development Review Process
‰‰Investigate the following development review procedures, which monitor new

construction, substantial improvements, and other development (e.g., filling,
grading, dredging, etc.).
‰‰Operating procedures for the following:
‰‰Obtaining the “as-built” lowest floor elevation in A Zones with BFEs.
‰‰Obtaining the “as-built” elevation of the bottom of the lowest horizontal
structural member of the lowest floor in all V Zones.
‰‰Maintaining a record of all “as-built” lowest floor elevation data. (Use of the
FEMA Elevation Certificate is required only for CRS communities/Flood
Insurance Policies and is recommended for non-CRS communities.)
‰‰Operating procedures for securing certifications for the following:
‰‰Floodproofed non-residential structures.
‰‰Openings for enclosed areas below the lowest floor when design differs from
minimum NFIP criteria.
‰‰Anchoring of a pile-and-column foundation and structure attached thereto in
all V Zones.
‰‰Breakaway walls in all V Zones when design strength exceeds minimum criteria.

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Guidance for Conducting CACs and CAVs

‰‰Development review procedures for floodplain/floodway development:
‰‰1 foot or less elevation increase in the SFHA [44 CFR §60.3(c)(10)] when no

floodway is designated.
‰‰Any elevation increase in the regulatory floodway [44 CFR §60.3(d)(3)] where
a floodway is designated.
‰‰Process for reviewing development in A Zones without BFEs.
‰‰Understanding of the requirements for addressing subdivisions of at least 50 lots
or 5 acres in A Zones without BFEs [44 CFR §60.3(b)(3)].
‰‰Procedures for assuring that mechanical and electrical equipment (e.g., HVAC) are
designed and located to prevent flood damage [44 CFR §60.3(a)(3)].
‰‰Procedure for ensuring that buildings are constructed with materials resistant to
flood damage [44 CFR §60.3(a)(3)].
‰‰Local officials’ descriptions of the process for inspecting development, including:
how often, at which stages of the construction process, issuance of Occupancy
Permits, and process for checking unpermitted development;
‰‰Variance procedures, including notice of the effects of the variance on flood
insurance rates.
‰‰Subdivision review process in accordance with §60.3(a)(4).
‰‰General use of land in the SFHA and the potential for future development
in the floodplain.
‰‰How permit review determinations are recorded/maintained (clarify that
the records should be kept permanently).
‰‰Any unresolved questions from previous CACs, CAVs, or other source.
‰‰Other issues related to the community’s floodplain management program.

A.4 NFIP Community Information Review and Verification
‰‰Provide the number of flood insurance policies in force, claims paid, and any

other relevant CIS community data.
‰‰Determine how long the current Floodplain Administrator has held the position,
how many other staff are involved in floodplain management, how many are
CFMs, and whether any NFIP training is needed or recommended.

A.5 Discuss Any Potential Violations, Deficiencies, or Compliments
‰‰Discuss any potential violations or program deficiencies identified during CAC.
‰‰Highlight those areas where officials deserve a compliment for implementing
their floodplain management program.

A.6 Summarize the CAC Findings, Processes, and Follow-up Actions
‰‰Summarize the findings and discuss any planned follow-up actions with the

Floodplain Administrator so he or she will know what to expect, and will have the
opportunity to ask questions or make suggestions about the follow-up assistance
that is offered.

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Guidance for Conducting CACs and CAVs

B. Sample Letter: Confirming CAV Meeting

,
RE: COMMUNITY ASSISTANCE VISIT
Dear :
A Community Assistance Visit (CAV) has been scheduled with ,
Floodplain Administrator, to discuss the participation
in the National Flood Insurance Program (NFIP), and to address any
questions your community may have about its NFIP responsibilities.
will conduct the meeting. It is scheduled to begin
at on in office.
The Department of Homeland Security (DHS) Federal Emergency
Management Agency (FEMA) conducts these visits to maintain
periodic contact with communities participating in the NFIP, to assess
the effectiveness of a community’s implementation of its floodplain
management regulations, and to provide technical assistance. Community
officials involved in the review of floodplain development, including
permitting, inspection, and subdivisions review must be present during
the meeting or available for questions.
In this regard, we ask that your staff have available at the meeting:
1. Copies of your current regulations affecting floodplain development,
including ordinance(s), adopted flood provisions of the building code
and any amendments or companion regulations that cover floodplain
development not addressed by the codes. Your staff members should
review and familiarize themselves with the floodplain development
regulations prior to the meeting.
2. Records of permits for all development in the designated Special
Flood Hazard Areas (SFHAs) issued since (date of last CAV
or past five years, whichever is more recent).
3. Records of the as-built lowest floor elevations in accordance with
44 CFR §60.3 (b)(5), of structures built in the designated SFHAs.
Compliance records must be maintained (and available at the
meeting) on all development in SFHAs, in order to ascertain
whether or not the development complies with applicable floodplain
management regulations.

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Guidance for Conducting CACs and CAVs

4. Appropriate staff to explain the process the community uses to
review proposed development in the SFHAs, including new buildings
and other structures, new and replacement manufactured homes,
improvements to or repairs of damages to existing buildings and
structures, development other than buildings (e.g., dredging, filling,
grading, paving, excavation, or drilling operations), and stream or
channel alterations and maintenance
5. Appropriate staff to explain the process for reviewing new subdivision
proposals including manufactured home parks and subdivisions in
designated SFHAs.
6. Appropriate staff to explain the community’s on-site inspection of new
and on-going development in the SFHAs.
7. Appropriate staff to explain the community’s enforcement procedures.
8. Appropriate staff to explain the variance process, along with any
records of all variances requested (denied or approved) since
(date of last CAV or five years, whichever is most recent).
9. Any questions or concerns your community may have pertaining
to the Flood Insurance Rate Map and the Flood Insurance Study
including their accuracy, completeness, or need for other data.
will need to tour the floodplain areas to familiarize
with your community to determine the types of development
occurring, and would like your Floodplain Administrator to accompany
. Should you have any questions regarding the CAV, please
phone < FEMA/STATE REP> at or by E-MAIL at
.
Thank you.
Sincerely,

cc: , STATE COORDINATOR
, Floodplain Administrator

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Guidance for Conducting CACs and CAVs

C. Floodplain Tour Checklist

The following checklist should be used as a guide when examining any development or
map‑related issues during the tour of the floodplain. In order to assemble the supporting
data regarding specific development sites, mapping issues, or permit review findings,
it is recommended that the optional CAV Floodplain Development Review Worksheet
(Appendix D), National Flood Mitigation Data Collection Tool, or other similar tools.

C.1 Development in the Floodplain
Check development in each type of A Zone or V Zone in the community to assure the
community is implementing the correct floodplain management requirements for each type
of SFHA.
In all A Zones (applies to new construction and substantial improvements): Check for the
following per 44 CFR §60.3(a) through (d):

‰‰Residential structures have lowest floors (including basement) that are elevated
to or above the BFE.

‰‰Non-residential structures are elevated or floodproofed to or above the BFE.
‰‰Structures with enclosures below the BFE are not used for purposes other than
parking, access, or limited storage. If possible, where such enclosures exist,
check for a minimum of two openings to equalize hydrostatic flood forces on
exterior walls, and that the bottom of such openings are not more than 1 foot
above grade.

‰‰Existing structures that have indications of substantial improvements show

evidence of flood protection. NOTE: additions to structures will likely be the most
identifiable substantial improvement, whereas rehabilitations to structures will
be more difficult to detect. When available, use flood insurance claims data to
identify substantially damaged structures.

‰‰Structures that have electrical, heating, ventilation, plumbing, or air-conditioning
equipment, and other service facilities, are designed and/or located so as to
prevent water from entering or accumulating within the components during
conditions of flooding.

‰‰Manufactured homes, except in existing manufactured home parks or subdivisions, are

located with the lowest floor at or above BFE. Also check that manufactured homes are
securely anchored to an adequate foundation system (this may not be recognizable
during the floodplain tour).

‰‰Manufactured homes in existing manufactured home parks or subdivisions are

located with the lowest floor at or above the BFE or with the lowest floor 36
inches above grade. Also check that manufactured homes are securely anchored
to an adequate foundation system (this may not be recognizable during the
floodplain tour).

‰‰There are no encroachments within the adopted regulatory floodway including

new construction or substantial improvements; other development, such as
mining, dredging, filling, grading, paving, excavation, or drilling operations; or other
structures, such as gas and liquid storage tanks.
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Guidance for Conducting CACs and CAVs

‰‰There is adequate drainage in new subdivisions, such that exposure to flood
hazards is decreased.

‰‰FEMA was notified of any altered or relocated portion of a watercourse, and

that the flood carrying capacity within the altered or relocated portion of any
watercourse is maintained, i.e., there is no evidence of excessive vegetation
growth and excessive sedimentation in channelized and concrete‑lined channels.

‰‰There are adequate drainage paths around structures on slopes to guide
floodwater around and away from structures in areas of shallow flooding.

In V Zones (applies to new construction or substantial improvements): Check for the
following per 44 CFR §60.3(e):

‰‰Structures are elevated on pilings or columns so that the bottom of the lowest
structural member is at or above the BFE.

‰‰The space below the lowest floor of an elevated structure appears to be free of

obstructions or appears to have breakaway walls. Check the permit record to
see if breakaway walls are identified in the specifications and signed off on by an
engineer.

‰‰Structures with enclosures below the BFE are used only for parking, access,

or limited storage. Photograph any walls of enclosures below the BFE and
determine, through the permit review, whether they are designed as breakaway
walls (if the building is post-FIRM).

‰‰Manufactured homes, (except in an existing manufactured home park or

subdivision), are elevated on pilings or columns so that the bottom of the lowest
horizontal structural member is at or above the BFE.

‰‰Structures that have electrical, heating, ventilation, plumbing or air-conditioning
equipment, and other service facilities, are designed and/or located so as to
prevent water from entering or accumulating within the components during
conditions of flooding.

‰‰Post-FIRM structures are located landward (not seaward) of mean high tide.
‰‰Fill is not used for structural support of buildings.
‰‰There is no alteration of sand dunes or mangrove stands.
‰‰In all SFHAs: Note vacant structures with windows boarded up, tall grass, etc.

Some of these structures, if rehabilitated, may become substantially improved
and are required to meet floodplain management requirements.

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C. Floodplain Tour Checklist

‰‰Review FEMA grant-acquisition projects by address for sites located in the

community. The Acquisition regulations (44 CFR §80.19) require that FEMA
verify that the property shall be dedicated and maintained in perpetuity as open
space for the conservation of natural floodplain functions. Include a sample of
these properties with other properties selected for site visits to ensure that:

‰‰Use of the land acquired for open space purposes is consistent with the

regulations under each mitigation program and the community’s Land Use
Reuse Plan for open space or recreational use.

‰‰If a new public facility is allowed, verify that the facility is open on all sides
and functionally related to open space or recreational use.

‰‰Any public restroom or other structure compatible with open space use must
be elevated/floodproofed to the BFE plus 1 foot of freeboard or greater if
required by FEMA, or by any State or local ordinance.

‰‰The open space property is maintained in good condition, and all debris or

other improvements, such as any concrete slabs or foundations, which are
not part of the reuse plan, were removed.

‰‰Visit a sample from the listing of FEMA Grant and NFIP Increased Cost of

Compliance (ICC) elevation or floodproofing projects to confirm that the selected
buildings are still properly elevated and have not been compromised by
enclosures below the BFE or by other modifications.

‰‰Check maintenance of physical changes to the floodplain, such as dams,

diversion channels, detention basins, channelization, new bridges, or levees,
which resulted in a Map Revision (44 CFR §65.6).

‰‰For accredited levee systems, check for general maintenance of the levee

system. For earthen levees, check for general conditions, such as grass
cover that is manicured, animal burrows, noticeable erosion or gullies, clean
watercourses, and flap gates free of debris. Note, among other observations, any
closures and whether they are manual or automatic; structure crossings, such as
railroads or roads through the levee; and mud on the landward side (signifying
structural instability). For floodwall type levees, check for general conditions,
such as no noticeable cracks or settlement. For the purpose of a CAV floodplain
tour, this is expected to be a very limited non-engineering check of a sample of
the most significant levees (44 CFR §65.10).

‰‰If there are open CLOMRs in the community that have not been closed out by an

approved “as built” LOMR, visit the site to assure that no encroachments or other
violations have occurred based on the future condition. Any new development
must meet the floodplain management requirements based on the SFHA
boundaries and BFEs of the current effective FIRM [44 CFR §65.3, 65.12, and
63.3(c)(10) and (d)(3)].

‰‰Sample selected structures for which a submit-to-rate flood insurance application
has been submitted to FEMA.

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Guidance for Conducting CACs and CAVs

C.2 Map Accuracy
‰‰Check the following sites identified during the floodplain tour.
‰‰New bridges/roads or major modifications to existing ones in a designated

floodway or an area that would divert significant flood flows from the SFHA
indicated on the effective FIRM.

‰‰Extensive filling or debris dumping, especially in the adopted regulated
floodway or in SFHAs where floodways have not been designated.

‰‰Major new developments, especially in the floodway or an area that would

divert significant flood flows from the SFHA indicated on the effective FIRM.

‰‰New flood control or related modifications, such as levees, berms, dikes,

flood walls, channel relocation, detention or retention ponds, concrete
channels, hurricane protection levees, dams, reservoirs, etc. In modified
channels, check to ensure that the watercourse is free of debris, and free of
excess vegetation and sedimentation.

‰‰Modified channels to ensure the watercourse is free of debris,
and excessive vegetation/sedimentation.

‰‰Construction of low-water crossings.
‰‰Natural changes in the floodplain, such as flood-related channel relocation or
modification, landslides, mudslides (i.e., mudflows), debris slides, significant
erosion or sedimentation, significant vegetation or debris buildup, and other
natural changes that clearly conflict with the SFHA on the effective FIRM.

‰‰If using contour maps or orthophoto maps, note any obvious discrepancies be-

tween those maps and the FHBMs, FIRMs, or Flood Boundary/Floodway Maps.

‰‰Identify areas suspected of posing special risks to life and property due to the

depth, velocity and duration of flooding, debris in the water, or other factors.
Such high flood hazards include alluvial fans, areas behind unsafe or inadequate
levees, areas below unsafe or inadequate dams, coastal erosion, flash flood
areas, flooding due to ground failure (such as subsidence) fluctuating lake levels,
ice jams, and mudslides.

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D. CAV Floodplain Development Review Worksheet

Guidance for Conducting CACs and CAVs

Community Name:

CAV Date (mm-dd-yyyy): Conducted by:

Community ID:

FIRM Date (mm-dd-yyyy): FIRM Panel Number(s)

FBFM Panel Number(s)

Claims History: Describe Date and Amount of
Previous Claims (if applicable)

Building Currently
Insured?

Policy Number:

 Yes  No
Location (Intersection) or Address of Development:

In Floodway?
 Yes  No

 New Construction  Substantial Damage/Improvement  Repetitive Loss  Submit for Rate
Type of Development:
 New Construction  Substantial Damage/Improvement  Repetitive Loss  Submit for Rate
Provide a Brief Description of Development:
Describe Issue:
Permit Number:             

Permit Date (mm-ddyyyy):            

Base Flood
Elevation:               

Freeboard:               

FIRM Zone:               

Date of Construction or Other Development (mm-dd-yyyy):
Legal Street Address or Physical Location:
Latitude (if available):

Longitude (if available):

Tax Parcel/Parcel ID:

Elevation Data:

Lowest Floor Elevation:

Elevation Certification Date:

 Yes  No
If floodproofed non-residential building, is certification available?  Yes  No
If V Zone, is certification available?  Yes  No

Proper openings?  Yes  No

If in floodway, is No Rise Certification available?  Yes  No
Enclosed area below BFE?
 Yes  No

Enclosed area used for access/storage/parking?
 Yes  No

Is mechanical/electrical/utilities elevated or water resistant?  Yes  No
Variance granted?  Yes  No

Was adequate justification provided?  Yes  No

Variance Justification Comments:

 Violation  Compliant  Other (describe):

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Guidance for Conducting CACs and CAVs

E. Community Assistance Visit: Checklist for Meeting
with Local Officials and Issues Discussion

E.1 Purpose of Meeting
‰‰Explain purpose of the meeting and the process of the CAV.
‰‰Introduce other members of the CAV team.
‰‰Summarize agenda.
‰‰Give estimate of the meeting’s duration.
‰‰Determine whether a representative from each permit-related department
is present.

‰‰Circulate attendance list.
‰‰Provide an overview of NFIP.
‰‰Provide NFIP community statistics.
‰‰Advise that permit and variance files will need to be reviewed.
‰‰Address any questions from local officials.
E.2 Floodplain Management Regulations Review
‰‰Ensure that the regulations reviewed are the most current and, if not, request
a copy.

‰‰Determine whether floodplain management is administered through a standalone ordinance, the community building code and companion regulations,
and any other regulations such as the subdivision or zoning ordinance.

‰‰Identify what building code the community uses and the flood provisions therein.
Ask whether the community has amended the flood provisions of the code;
obtain a copy.

‰‰If using the IBC®, determine whether the community adopted Appendix G or

used a companion ordinance (separate ordinance for floodplain provisions not
covered in building code).

‰‰Discuss inadequacies of, omissions from, and overlaps among above adopted regulations and building codes; discuss other problems identified during prior review.

‰‰Determine whether the community has adopted the latest FEMA map and study.
‰‰Find out whether officials have any problems concerning interpretation or
administration of the regulations.

‰‰Determine if the community has any more-restrictive floodplain management
requirements and any problems implementing those requirements.

‰‰Identify boundary changes, annexations, or de-annexations.
‰‰Ascertain whether the community has identified any unique hazards (e.g.,
subsidence, ice jams, erosion, etc.).

‰‰Offer assistance in updating the community’s regulations.

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Guidance for Conducting CACs and CAVs

E.3 Map Availability and Accuracy
‰‰Determine availability of current FEMA FIRMs and FIS.
‰‰Determine if other maps or studies are used for regulating development.
‰‰Ascertain if community has any problems using maps, study or DFIRM data.
Offer DFIRM training or training on supporting digital tools.

‰‰Identify problems using FEMA FIRMs or FIS, such as A Zones without BFEs,
floodways, etc.

‰‰If recent flooding history, ask for description of cause, extent, and damage.
‰‰Identify problems with the accuracy of FEMA maps or study.
‰‰Determine flood-control projects and associated maintenance responsibilities.
‰‰Ascertain whether the community has identified any unique hazards (e.g.,
subsidence, ice jams, erosion, etc.), and whether it has encountered any
problems in regulating these areas.

‰‰Determine community’s familiarity with LOMCs or physical map revision processes.
‰‰Identify if any CLOMRs were issued without follow-up LOMRs that were based on
as-builts. Be sure officials understand the development limitations of a CLOMR.

E.4 Development Review Process
Ask the community officials to describe the following procedures. Obtain actual copies of
issued permit forms, as well as other related checklists, instructions, procedures, etc., for
the development process.

‰‰Development review procedures for new construction, substantial improvements,
and other development (e.g., filling, grading, dredging, etc.).

‰‰Process for determining substantial damage – and community’s role in ICC process.
‰‰Review procedure for development other than for structures, such as mining,
dredging, filling, grading, paving, excavation, or drilling operations

‰‰Process to ensure that all other necessary permits required by Federal/State

laws have been received (e.g., ESA Sections 7 and 10, 404 Wetlands, etc. per
[44 CFR §60.3 (a)(2)]).

‰‰Operating procedures for the following:
‰‰Obtaining the “as-built” lowest floor elevation in all A Zones with BFEs.
‰‰Obtaining the “as-built” elevation of the bottom of the lowest horizontal
structural member of the lowest floor in all V Zones.

‰‰Maintaining a record of all “as-built” lowest floor elevation data. (Use of the
FEMA Elevation Certificate is required only for CRS communities/Flood
Insurance Policies and is recommended for non-CRS communities.)

E-2

E. Community Assistance Visit: Checklist for Meeting
with Local Officials and Issues Discussion

‰‰Operating procedures for securing certifications for the following:
‰‰Floodproofed, non-residential structures.
‰‰Openings for enclosed areas below the lowest floor when design differs from
the minimum NFIP criteria.

‰‰Anchoring of a pile-and-column foundation and structure attached thereto
in all V Zones.

‰‰Breakaway walls in all V Zones when design strength exceeds
minimum criteria.

‰‰Review procedures for floodplain/floodway development:
‰‰Cumulative development not to increase BFE more than 1 foot in the SFHA
[44 CFR §60.3(c)(10)] when no floodway is designated, or

‰‰Any BFE increase in the designated regulatory floodway [44 CFR §60.3(d)(3)].
‰‰If increase, was CLOMR obtained [44 CFR §60.3(d)(4) and 65.12].
‰‰Process for reviewing development in A Zones without BFEs.
‰‰Procedures for ensuring that mechanical and electrical equipment (e.g., HVAC),
are designed and located to prevent flood damage [44 CFR §60.3(a)(3)].

‰‰Procedure for ensuring that all new construction and substantial improvements

are designed (or modified) and adequately anchored to prevent flotation,
collapse, or lateral movement of the structure resulting from hydrodynamic and
hydrostatic loads, including the effects of buoyancy, and are to be constructed
with materials resistant to flood damage [44 CFR §60.3(a)(3)].

‰‰Variance procedures, including notice concerning the effects of the variance on
flood insurance rates.

‰‰Subdivision review process, including:
‰‰Number of subdivisions approved since last CAV, 5 years or, at a minimum,
within the calendar year.

‰‰Number of lots within approved subdivisions.
‰‰Requiring developers of new subdivisions larger than 50 lots/5 acres to
develop BFEs when none are provided on FIRM.

‰‰How are permit review determinations recorded/maintained (clarify that the
records should be kept permanently).

‰‰Process used to review capital improvements in the SFHA.
‰‰Inspection procedures for development in the SFHA – whether issued permit
or not, how often and at what stages, and when certificates of occupancy
are issued.

‰‰Enforcement procedures to remedy any discovered violations.
‰‰If applicable, procedure for inspecting/verifying residential structures with

floodproofed basements (when previously approved by Federal Insurance
Administrator).

‰‰Any unresolved issues from previous CAC, CAV.
E-3

Guidance for Conducting CACs and CAVs

E.5 NFIP Community Information Review and Verification
‰‰Provide the number of flood insurance PIF and claims (including Repetitive Loss)
and review/verify any other relevant data contained in the CIS, such as contact
information.

‰‰Determine how long the current Floodplain Administrator has held the position;
how many staff support the program and how many are CFMs. Determine
whether NFIP training needed or should be recommended.

E.6 Floodplain Development Issues Identified on Floodplain Tour
‰‰Discuss issues identified in CAV preparation and/or on floodplain tour. Use digital
photos, files, or annotated maps to help explain.

E.7 Other Floodplain Management Issues
‰‰Determine the community’s potential for floodplain development and the extent
they encourage or discourage development.

‰‰Determine how the community deals with threats to existing development, e.g.

repetitive losses, and whether any acquisition, elevation, or relocation programs
exist, or if they are interested in future projects.

‰‰Confirm that officials understand the ICC coverage and the community’s role in
the process.

‰‰Determine any higher floodplain management standards and include a
discussion of the CRS or building codes, such as the I-Codes™.

‰‰Discuss whether the community has a post-disaster plan in place and whether it
has any questions on post-flood mitigation activities.

‰‰Questions and Answers. Wrap up discussion to this point and answer any

questions before going on to the Permit and Variance file review step. Remind
the local officials that a Summary meeting will take place after file review.

E.8 Summarize the CAV Findings, Processes, and Follow-up Actions
‰‰Summarize the preliminary findings and discuss any potential deficiencies
or violations.

‰‰Discuss the follow-up process and next steps, and offer technical assistance.
‰‰Discuss CRS options and compliment local officials on positive aspects of their
floodplain management program.

‰‰Ask whether there are any questions.

E-4

F. The Community Rating System

Guidance for Conducting CACs and CAVs

F.1 The Community Rating System
The NFIP CRS is administered by the
Department of Homeland Security’s FEMA.
The CRS was implemented in 1990 to
recognize and encourage community
floodplain management activities that exceed
the minimum NFIP standards. The National
Flood Insurance Reform Act of 1994 codified
the CRS in the NFIP. Under the CRS, flood
insurance premium rates are adjusted to
reflect the reduced flood risk that results from
community activities that meet the three goals
of the CRS:

•

Reduce flood damage to insurable
property,

•

Strengthen and support the insurance
aspects of the NFIP,

•

Encourage a comprehensive approach to
floodplain management.

Table F-1. Community Rating System
Premium Discounts
Class

SFHA*

Non‑SFHA

1

45%

10%

2

40%

10%

3

35%

10%

4

30%

10%

5

25%

10%

6

20%

10%

7

15%

5%

8

10%

5%

9

5%

5%

10

0%

0

* Special Flood Hazard Area. Non-SFHA
premium reductions apply to B, C, D, X, 
A99, and AR Zones.

Although premium discounts are one of the benefits of CRS participation, it is more
important that communities carry out activities that save lives and reduce property damage.
There are ten CRS classes: Class 1 requires the most credit points and gives the largest
premium reduction while Class 10 receives no premium reduction.
The purpose of this Appendix is to update
and replace existing CRS compliance
policy guidance for new, reapplying, and
currently participating CRS communities.
The CRS Coordinator’s Manual cites
two prerequisites to becoming a Class 9
community or better:

•
•

The CRS recognizes 18 creditable activities,
organized under four categories numbered
300 through 600: Public Information,
Mapping and Regulations, Flood Damage
Reduction, and Flood Preparedness.

The Community must have been in the Regular Phase of the NFIP for at least one-year
The Community must be in full compliance with the minimum standards of the NFIP. At
any time, if a CRS community is determined to not be in full compliance, it will revert to a
CRS Class 10.

To maintain the credibility of the CRS, FEMA requires every community in the CRS to
be fully compliant. This means that FEMA must determine that a community is compliant
under the minimum NFIP requirements (the terms “minimal” or “substantial” compliance
are, therefore, inapplicable). Compliant communities are expected to have an updated
ordinance, have remedied violations to the maximum extent possible, and have corrected
deficiencies in floodplain management programs or be moving rapidly in that direction.

F-1

Guidance for Conducting CACs and CAVs

Since 1996, FEMA has required a “clean” CAV before a new community may participate
in the CRS. In 2002, the following “retrograde” policy was added to provide guidance in
dealing with situations for communities already in the CRS, but following the discovery of
substantial unresolved problems by a CAV. A number of CRS communities were found in
this situation, and based upon recommendations from the FEMA Regional Offices, these
communities were subsequently retrograded to Class 10.
It is expected that a CRS community with a large amount of floodplain development may
have some minor program deficiencies and possible violations. However, once these
program deficiencies and violations are identified and brought to the community’s attention
in the CAV follow-up letter, CRS communities are expected to move expeditiously to correct
the program deficiencies and remedy the violations to the maximum extent possible.
In addition, if a CRS community is not implementing or enforcing an activity, e.g. a higher
regulatory standard such as freeboard, it will lose the credits for this activity, and also
experience any cumulative effects this change has on the community classification.

F.2 National Flood Insurance Program Community Rating System
Compliance and Retrograde Procedures
a. A Community Applying to, Reapplying to, or Participating in
the CRS is not in Full Compliance if any of the Following Apply
1. Within the previous two years, the community has been suspended or put on
probation for lack of enforcement. For the purposes of the CRS, a community that
has corrected previous violations or deficiencies and has been taken off probation or
suspension is not deemed to be in full compliance for two additional years. This is to
ensure that it has actually “changed.” (Applies to CRS Applications Only).
2. An enforcement action has been initiated or is underway against the community at
any time during the past two years. The term “enforcement action” is as defined in
the Community Compliance Program Manual. (Applies to CRS Applications Only).
3. The community’s ordinance does not meet all current NFIP criteria.
4. There are outstanding program deficiencies or violations from a CAC or CAV.
5. There are outstanding compliance issues, such as unanswered inquiries from the
FEMA Regional Office involving citizen complaints or submit‑to‑rate properties.

A CAV must be conducted by the FEMA Regional Office or State before the FEMA
Regional Office can provide a community with the positive compliance determination letter
required for initial CRS participation, or for improvement to Classes 1–4 (See Situation
Sample D-1). In addition, applicant communities (including those reapplying after
retrogrades) cannot be considered in full compliance if they have not had a recent CAV
(within the past year). It is recommended (given the resource issues of doing CAVs) that
FEMA Regional Offices ask the Chief Executive Officer of a community to put his or her
request for this determination in writing.

F-2

F. The Community Rating System

Every attempt should be made to schedule
the visit within 90 days of the community
request or upon receipt of the actual CRS
application. FEMA Regional Offices should
remind States of the FEMA Community
Assistance Program (CAP) policy that allows
States to change locations of previously
scheduled CAVs due to unexpected priorities,
such as requests for CRS CAVs. If the
CAV identifies program deficiencies or
possible violations, the positive compliance
determination should not be provided until
the issues are remedied and the CAV is closed.

A community CRS application should
be viewed as an opportunity to close
out CACs or CAVs. If local officials have
not responded to the FEMA Regional
Office’s latest request for ordinance
revisions or other actions identified
in the CAC/CAV or other activity, the
FEMA Regional Office should inform
the community it is not considered in full
compliance until it submits the requested
information.

CRS-participating communities should be scheduled for a CAV or CAC based on selection
criteria as described in Chapter 2 of this document. If possible violations or program
deficiencies are identified by the CAV or CAC, the community must correct the program
deficiencies and remedy the violations to the maximum extent possible within timeframes
established by the FEMA Regional Office. Timeframes for CRS communities are discussed
in part (b) of this procedure.
The FEMA Regional Office, in close cooperation with the State, judges the community’s
compliance with NFIP requirements. The FEMA Regional Office must maintain
documentation as to why it determined a community to not be in full compliance.
b. Due Process Community Timeframes
Once suspected violations or program deficiencies are reported, the community must be
allowed a reasonable timeframe to respond to the CAV report findings and either prove
there are no deficiencies/violations or correct them. CRS communities are expected to
show immediate action to remedy the problems.
The FEMA Regional Office may allow up to six months after the date of the CAV followup letter for a community to correct program deficiencies or remedy all violations to the
maximum extent possible. This six-month period allows for an initial response from the
community and additional follow-up on the part of the FEMA Regional Office. Extensions
may be granted to the community if remedial measures are underway but not completed.
However, FEMA Regional Offices should recommend retrograde to Class 10 prior to the
completion of the six months (see subparagraph (c)(2) below) if, at any time, a community
is not responsive (insufficient or no remedial actions undertaken), or the community
does not have a fully functioning floodplain management program. A non-responsive
community is one that has not met deadlines established in the initial CAV follow-up letter
or subsequent letters, and has not initiated the necessary actions to correct the identified
program deficiencies or remedy the violations.

F-3

Guidance for Conducting CACs and CAVs

A non-fully functional floodplain management program means that the community has
not required floodplain management permits, does not have a Floodplain Administrator,
or otherwise does not have a functioning system. While not generally expected in the
CRS, there may be small communities where these shortcomings could be encountered,
especially if exacerbated through staff turnover.
Finally, CRS discounts are add-on benefits for communities that have exemplary floodplain
management programs built upon a fully compliant base program. Therefore, when
deficiencies and or violations are discovered and proven, it is CRS policy to withhold any
improved class until the community remedies these problems and, when necessary, to
retrograde non-compliant communities to Class 10.
c. Deadlines for Processing CRS Retrogrades
CRS class changes become effective twice a year, on May 1 and October 1. Insurance
companies (Write Your Own [WYO] companies) and internal processing require that all
class changes, including Class 10 retrogrades, be final no later than 120 days prior to
these CRS effective dates. Accordingly, all FEMA Regional Office recommendations for
retrograde of a community to Class 10 must be made at least 180 days prior to the CRS
effective date. If the community’s deadlines fall after that date, the recommendation must
be delayed to coincide with the next CRS effective date.
FEMA Regional Office (RO) recommendations for retrogrades to Class 10 must adhere to the
following schedule:
1. RO sends one or more CAV follow-up letters with ascending CRS warnings;
2. At least seven months prior to May 1/Oct 1 (Oct 1/Mar 1): RO notifies community of
recommended CRS retrograde (advance copy to HQ CRS Program Manager);
3. At least six months prior to May 1/Oct 1 (Nov 1/April 1): RO sends memo to HQ
recommending retrograde;
4. At least five months prior to May 1/Oct 1 (Dec 1/May 1): HQ sends official notice to
community of CRS retrograde;
5. At least four months prior to May 1/Oct 1 (Jan 1/June 1): HQ notifies BSA to process all
CRS classes for WYO companies;
6. At least three months prior to May 1/Oct 1 (Feb 1/July 1): WYO companies program data
and process renewals;
7. On May 1/Oct 1: Insurance Agents’ Manual and WYO companies reflect new/revised
CRS Classes.
Note: The 30-day period between the FEMA Regional Office’s recommendation of retrograde
to Class 10 and the FEMA HQ notice to the community is not a formal appeals period, but does
allow time to resolve issues raised by the community.

F-4

F. The Community Rating System

d. To Encourage Communities to Take Corrective Actions
and to Provide Ample Warning and Chronology
Supporting a Possible CRS Retrograde, all Follow-up
CAV or CAC Correspondence to Communities MUST
Contain CRS Statements (or Appropriate Variations)
Tailored to Fit at Least the Following Situations
1. The community is a CRS participant, and minor compliance issues warrant a warning
citing the CRS standing (Situation Sample D2).
2. The community is a CRS participant, serious issues were identified, and the
community is clearly warned that unless the violations are resolved to the maximum
extent possible and program deficiencies are corrected by a specific date, the FEMA
Regional Office will recommend that the community be retrograded to Class 10
(Situation Sample D3).
3. The community is a CRS participant that has not adequately met the established
deadlines as cited in previous correspondence that included Samples D2 and D3. The
FEMA Regional Office formally states to the community its intention to recommend
to FEMA HQ that the community be retrograded to a CRS Class 10. This may be a
separate letter notifying a community of this recommendation, or it may be added to
the latest of several CAV follow-up letters. This memo must be coordinated in advance
of mailing with FEMA HQ CRS Program Management (Situation Sample D4).
4. The community is a CRS participant that has not adequately met the established
deadlines and the FEMA Regional Office formally recommends to HQ that the
community be retrograded to a CRS Class 10. (Situation Sample D5).

It is recognized that imperfect situations exist and a community may be limited in what
it can do to remedy a violation. However, the community must remedy violations to the
maximum extent possible. “Maximum extent possible,” according to the Compliance
Manual, means that the community has gone so far as to take the issue to court, has
otherwise done all it can do to remedy the violations, and has corrected all administrative
procedures related to the problems.
While there will always be issues to be addressed, such as national/regional and State
consistency, strengthening the compliance program, and problems of perception, fairness
and avoidance of community embarrassment when a rating is pulled, the judgments used
in CRS retrogrades have been no different than those in NFIP probation and suspension
decisions. FEMA Regional Offices, in cooperation with States, must use common sense
and judgment.
For this reason, FEMA does not support the concept of “zero tolerance” as applied to
CRS communities, since it does not allow for FEMA Regional Office judgment or an
opportunity for communities to remedy any identified violations. While CRS communities
should always be in full compliance, they cannot be held to such a concept if they are
doing everything possible to remedy the problems within the FEMA Regional Office
timeframe. This does not mean, however, that while communities are correcting their
violations they should receive the benefit of a pending CRS class. As stated previously,

F-5

Guidance for Conducting CACs and CAVs

it is CRS policy that any pending class improvement will be held in abeyance until
compliance issues are resolved.

F.3 CRS Verification Visits Are Not CAVs
FEMA uses consultants to process applications and provide technical assistance to
FEMA, States, and communities. Consultants schedule a verification visit to review the
community’s activities according to the scoring criteria in the CRS Coordinator’s Manual.
The visit is conducted both in the office and in the field with the community’s designated
CRS Coordinator. Documentation is required for all activities, and the community can
submit any missing pieces to help verify its credit. A final report is prepared showing
the awarded points by activity and the awarded CRS class. There are over 1,100 CRSparticipating communities. In addition to its original verification visit for joining the CRS,
each community will receive another field verification on a 3- to 5-year cycle (sooner if it
submits a two-class improvement), depending on its CRS Class.
While a CRS verification visit shares some of the same general attributes of a CAV, it
varies in one key area. A CAV primarily evaluates the community’s implementation of
the minimum NFIP criteria, while the CRS verification visit assumes full compliance and
only measures activities that are above and beyond the minimum NFIP requirements.
However, there is sufficient crossover to allow for information sharing, primarily from
data gathered on the CRS visit. For example, the CRS visit examines sample Elevation
Certificates to ensure there is sufficient information to rate a policy. When applicable,
CRS credit is provided based on the verified sample, regardless of whether some floor
elevations are above or below the BFE. However, a process is in place to forward to FEMA
Regional Office staff any specific samples containing floor elevations below the BFE or
other suspected violations. The information should be noted in the CIS and placed in a
suspense file for a possible follow-up CAC or CAV.

F.4 Sample CRS Paragraphs
The following paragraphs contain sample wording for five possible situations. They are
listed in progressive order of severity. As samples, they can be adjusted to better fit each
unique situation. It is helpful to cite a community’s CRS discount and how that community
will be affected by losing the discount. A helpful tool is the “What-If” Data from the CIS.
However, a community cannot be retrograded without the warning or similar wording as
contained in Situation Samples D3 and D4, and the recommendation to FEMA HQ in
Sample D5. Share any drafts with FEMA HQ CRS Program Management for coordination.
(Situation Sample D1). The community is not a CRS participant and the CAV
findings and community program are such that they are recommended for CRS
participation.
After reviewing your floodplain management program and the quality manner in which it
is implemented, we recommend your community (to the FEMA Regional office, if a State
is writing the letter) for participation in the NFIP’s Community Rating System (CRS). The
CRS is a program that rewards …
F-6

F. The Community Rating System

(Situation Sample D2). The community is a CRS participant, and minor compliance
issues warrant a “friendly” warning citing its CRS standing.
We would like to remind your community that the basic requirement for participation in
the CRS is a community’s full compliance with the NFIP. Because of the compliance
deficiencies cited, we encourage you to provide us with all the requested information
showing corrective actions by X date, in order to remain in full compliance and continue to
be eligible for CRS participation.
(Situation Sample D3). The community is a CRS participant and serious issues were
identified. The community is clearly warned that unless the deficiencies/violations
are resolved to the maximum extent possible and the program deficiencies
corrected by a specific date, the FEMA Regional Office will recommend that the
Federal Insurance Administrator retrograde them to Class 10.
Section 211 of the CRS Coordinator’s Manual states that the basic requirement for
CRS participation is that “the community must be in full compliance with the minimum
requirements of the NFIP. If a community is determined at any time to not be in full
compliance, it will revert to a Class 10.” Due to identified serious compliance issues
(deficiencies and/or violations), we will be recommending that your community’s
participation in the CRS be withdrawn if we do not receive (the requested information, a
plan addressing your corrective actions for the deficiencies/violations, or other data) by
X date. You should note that this is the first step in a series of compliance actions that
could lead to probation and eventual suspension from the NFIP.
(Situation Sample D4). The community is a CRS participant that has not adequately
met the established deadlines as cited in previous correspondence that included
Situation Samples D2 and D3. At least seven months prior to Oct 1/May 1, the FEMA
Regional Office formally states to the community that it is recommending to the
Administrator that the community be retrograded to a CRS Class 10. This may be
a separate letter notifying a community of this recommendation or it may be added
to the latest of several CAV follow-up letters. This memo must be coordinated in
advance with FEMA HQ CRS Program Management.
As you are aware, the CRS rewards NFIP communities for exemplary practices in
floodplain management. These practices go beyond minimum requirements of the NFIP
and are aimed at reducing the Nation’s flood losses. Your community has not remedied,
to the maximum extent possible, the identified violations of your community’s floodplain
management ordinance (and/or you have not corrected deficiencies in your administrative
procedures). Therefore, we have found that the “City of X” is no longer fully compliant
with the minimum requirements of the NFIP, and are recommending to the Administrator
that your CRS rating be retrograded to a Class 10, at the next possible opportunity. The
Federal Insurance Administrator will notify you soon to confirm the CRS retrograde and
effective date.
We cannot continue to provide your community with CRS reductions in flood insurance
rates now that we have determined that your community is no longer fully compliant with
the minimum requirements of the NFIP.
F-7

Guidance for Conducting CACs and CAVs

(Situation Sample D5). At least six months prior to Oct 1/May 1, the FEMA Regional
Office provides FEMA HQ with the formal recommendation to retrograde a
community due to the previously cited violations, as found in prior correspondence
that used Sample D2 or D3.
Please be advised that we are recommending that “No Discount Community” be
retrograded to Class 10 because it is no longer in full compliance with the minimum
standards of the NFIP.
Deficiencies and violations were noted in various correspondence (copies attached), as
follow-up to the Community Assistance Visit conducted on 00/00/0000. We will continue to
work with the community to resolve the issues.
Note: While only FEMA Regional Offices may recommend CRS retrogrades, States and
FEMA Regional Offices must coordinate closely as some variation of these paragraphs
must be included in all follow-up correspondence with a CRS community. States can and
should send Samples D1 and D2. States with more regulatory authority could even send
Sample D3 if recommending the retrograde to their FEMA Regional Office. However, only
FEMA Regional Offices can send Samples D4 and D5. Also, while FEMA Regional Offices
determine compliance standings and recommend CRS retrogrades, only FEMA HQ can
retrograde a CRS community (due to insurance rating implications). Conversely, it is highly
recommended that States help prospective communities by recommending CRS participation during the CAV meeting, and by adding appropriate language in the follow-up letter.

F-8

FEMA No. F-776
Catalog No. 11049-1