Billing Code: 9111-47
DEPARTMENT OF HOMELAND SECURITY
Federal Emergency Management Agency
[Docket ID: FEMA-2024-0022]
Request for Information on the National Flood Insurance Program’s Community Rating
System Redesign Effort
AGENCY: Federal Emergency Management Agency, Department of Homeland Security
(DHS).
ACTION: Request for information and notice of meetings.
SUMMARY: The Federal Emergency Management Agency (FEMA) is issuing this Request for
Information (RFI) to receive the public’s input on potential future changes to the Community
Rating System (CRS) under the National Flood Insurance Program (NFIP). This RFI seeks
further input on suggested alternative program features and approaches for a redesigned CRS
program, based upon public input from the August 23, 2021 “Request for Information on the
National Flood Insurance Program's Community Rating System” published in the Federal
Register. FEMA will host virtual public meetings at the times and dates listed below.
DATES: Comments must be received on or before [INSERT DATE 60 DAYS FROM DATE
OF PUBLICATION]. Submissions received after that date may not be considered.
For Public Meetings: FEMA will hold virtual public meetings on Wednesday, August 21, 2024
from 2:00 PM to 3:30 PM EDT and Thursday, August 22, 2024 from 3:00 PM to 4:30 PM EDT
for a general audience and on Tuesday, August 27, 2024 from 3:00 – 4:30 PM EDT focused on
issues specific to Indian Tribal governments. Depending on the number of speakers, the meeting
may end before the time indicated, following the last call for comments. Requests to participate
must be received via the virtual meeting website no later than Monday, August 19, 2024.
Registration must be completed using the links below specific to each meeting:

•

Register for the August 21, 2024 meeting using
https://cgstrategy.zoom.us/webinar/register/WN_4lNLtBUUQaqI2dxRPJtwHg

•

Register for the August 22, 2024 meeting using
https://cgstrategy.zoom.us/webinar/register/WN_qKV8jzlgQe6rt2LnpDqWOA

•

Register for the August 27, 2024 Tribal focused meeting using
https://cgstrategy.zoom.us/webinar/register/WN_t7ex0KIyRJGX8J0qYHHqDg

Reasonable accommodations are available for people with disabilities. To request a reasonable
accommodation (e.g., Communication Access Real-Time Translation [CART], sign language
interpretation), contact the person listed in the FOR FURTHER INFORMATION CONTACT
section below by Monday, August 19, 2024. Last minute requests will be accepted but may not
be possible to fulfill.
ADDRESSES: Interested persons may submit comments responsive to this RFI
electronically through the Federal eRulemaking Portal at https://www.regulations.gov. Follow
the instructions for submitting comments and use docket ID: FEMA-2024-0022. Submitting this
information makes it public; you may wish to read the Privacy and Security Notice on
https://www.regulations.gov.
Commenters are encouraged to identify specific question or questions they are
responding to by number. All submissions received must include the agency name and Docket
ID, and will be posted, without change, to the Federal eRulemaking Portal at
https://www.regulations.gov and will include any personal information you provide. Therefore,
submitting this information makes it public. You may wish to read the Privacy and Security
Notice that is available via a link on the homepage of https://www.regulations.gov. Responses
should not include any personally identifiable information or confidential commercial
information.
For Public Meetings: Public meetings for a general audience will be held virtually on
Wednesday, August 21, 2024 from 2:00 PM to 3:30 PM EDT and Thursday, August 22, 2024

from 3:00 PM to 4:30 PM EDT and for issues specific to Indian Tribal governments on Tuesday,
August 27, 2024 from 3:00 PM to 4:30 PM EDT. Links to register for the meetings are provided
above. If you would like to speak at a meeting, please so indicate on the registration form. For
the August 27, 2024 Tribal meeting, FEMA will be prioritizing comments from representatives
and members of Indian Tribal governments.
FOR FURTHER INFORMATION CONTACT: Shilpa Mulik, CRS Redesign Program
Manager, Hazard Mitigation Directorate, Resilience, FEMA. Phone: (202) 212-7313; Email:
FEMA-CRS-Redesign@fema.dhs.gov.
SUPPLEMENTARY INFORMATION:
I.

Background
A. The Community Rating System
Between 2000 and 2024, floods have cost approximately $107.7 billion dollars in damage

throughout the United States.1 Standard homeowners and commercial property insurance policies
do not cover flood losses.2 To meet the need for vital flood insurance coverage, FEMA
administers the National Flood Insurance Program (NFIP), which offers flood insurance
coverage for buildings and/or contents in communities that comply with the NFIP’s minimum
standards for floodplain management.3 To be covered by an NFIP flood insurance policy, a
property must be in a community that participates in the NFIP.4 To qualify to participate in the
NFIP, a community adopts and enforces local floodplain management standards which regulate

NOAA National Centers for Environmental Information, U.S. Billion-Dollar Weather and Climate Disasters
(2024). Found at https://www.ncei.noaa.gov/access/billions/events/US/2000-2024?disasters[]=flooding (last
accessed June 28, 2024).
2 Insurance Information Institute, Which Disasters Are Covered By Homeowners Insurance? Found at
https://www.iii.org/article/which-disasters-are-covered-by-homeowners-insurance (last accessed June 28, 2024).
3 42 U.S.C. 4022(a)(1).
4 Id.
development in the Special Flood Hazard Area (SFHA).5 Today, over 22,600 communities in
the United States participate in the NFIP.6
In 1990, FEMA implemented the Community Rating System (CRS) as a voluntary
program for recognizing and encouraging community floodplain management activities
exceeding the NFIP’s minimum standards for floodplain management.7 Communities that
undertake floodplain management activities exceeding the NFIP’s minimum standards for
floodplain management may apply to join the CRS program and the community will earn CRS
program credits (often referred to as “points/credits”) for those activities exceeding the minimum
floodplain management requirements of the NFIP which are approved by FEMA. In CRS
communities, credits lead to flood insurance premium discounts to reflect the reduced flood risk
resulting from the community’s higher floodplain management standards or programs. As of
October 2023, approximately 1,500 communities participate in the CRS program nationwide.8
This represents about seven percent of NFIP participating communities, which represent nearly
3.6 million (more than 70 percent) of all NFIP policies that are written.9 CRS program discounts
on flood insurance premiums range from 5 percent up to 45 percent based on the level of CRS
program credits awarded to communities.10
FEMA is exploring changes and improvements to the CRS program through a
programmatic review and improvement effort (called “CRS Redesign”). With the continuous
learning around flood, flood risk management, and flood risk reduction techniques, FEMA now

44 CFR 59.2(b); 44 CFR 59.1 (Special Flood Hazard Area “is the land in the flood plain within a community
subject to a 1 percent or greater chance of flooding in any given year. The area may be designated as Zone A on the
FHBM. After detailed ratemaking has been completed in preparation for publication of the flood insurance rate map,
Zone A usually is refined into Zones A, AO, AH, A1-30, AE, A99, AR, AR/A1-30, AR/AE, AR/AO, AR/AH,
AR/A, VO, or V1-30, VE, or V”).
6 FEMA, Flood Insurance, found at: https://www.fema.gov/flood-insurance (last accessed June 28, 2024).
7 42 U.S.C. 4022(b); Pub. L. 103-325, 108 Stat. 2255 (1994) (Congress authorized the CRS program under the
National Flood Insurance Reform Act of 1994).
8 FEMA, Communities Participating in the Community Rating System, found at fema_crs_eligiblecommunities_oct-2023.xlsx (last accessed June 28, 2024).
9 FEMA, Community Rating System, found at http://www.fema.gov/fact-sheet/community-rating-system (last
accessed June 28, 2024).
10 FEMA NFIP Community Rating System Coordinator’s Manual at 110-3, found at
https://www.fema.gov/floodplain-management/community-rating-system#manual (last accessed June 28, 2024).
has more information about, and understanding of, multi-frequency analysis, pluvial flooding,
climate change, and the extent of flood risk outside of the SFHA. This new understanding has
led FEMA to take a holistic look at the CRS program to determine how the program can best
meet FEMA and NFIP consumer needs through the CRS Redesign.
FEMA seeks input on ways the agency can improve the CRS program, specifically: (1) to
incentivize communities to take measurable actions and make sustained progress to reduce
current and future flood risk; (2) to embed equity as a foundation of the CRS program; (3) to
incentivize communities to encourage property owners to purchase flood insurance and thus
reduce their financial exposure to flood risk; and (4) to deliver a community participant-centered
and modernized program.
FEMA continually evaluates its programs, regulations, and policies to identify
opportunities to modify, streamline, expand, or repeal, as appropriate. FEMA does so through
legally mandated review requirements (e.g., Unified Agenda reviews and reviews under section
610 of the Regulatory Flexibility Act11), through existing RFIs, and through other informal and
long-established mechanisms (e.g., use of Advisory Councils, feedback from FEMA field
personnel, input from internal working groups, outreach to regulated entities and the public, and
Government Accountability Office program reports). This Federal Register notice supplements
these existing extensive FEMA regulatory and program review efforts.
B. Overview of 2021 CRS RFI and Public Comments on Suggested Changes to the
CRS Program
1. 2021 CRS RFI Summary
On August 23, 2021, FEMA published a request for information entitled “Request for
Information on the National Flood Insurance Program’s Community Rating System” in the
Federal Register12 (called “2021 CRS RFI”). The 2021 CRS RFI sought input from the public

11
5 U.S.C. 601 et seq.
86 FR 47128 (Aug. 23, 2021).

that would help the agency determine public interest in potential improvements to the CRS
program. Specifically, the 2021 CRS RFI sought public input on broad CRS programmatic
issues, such as:
•

Strengths and challenges of the CRS program;

•

Methods to increase equity and participation of disadvantaged communities;

•

Methods to reduce flood risk to communities through the CRS program;

•

Methods to incentivize participation and increase floodplain management standards;

•

Methods to streamline administrative burdens, CRS program credits, and decrease
program participation burdens of the CRS program;

•

Methods to decrease future losses to repetitive loss structures; and

•

Methods to increase collaboration and participation through cross jurisdictional entities
and increase integration with other floodplain management activities, such as building
standards.
2. 2021 CRS RFI Comments
FEMA received comments from 211 commenters addressing 116 unique topics in

response to the 2021 CRS RFI. Commenters included private citizens; State, local, and Tribal
governments; non-profit organizations; and professional associations. FEMA completed a
thorough review of the comments and considered whether to explore alternative CRS program
features and approaches suggested by stakeholders. Stakeholder feedback proposed a wide range
of alternative program features and approaches for the CRS program. FEMA also hosted virtual
public meetings to solicit input about the CRS program during the 2021 CRS RFI comment
period. A non-exhaustive overview of the comments from the 2021 CRS RFI and associated
public meetings is provided below:
Comments on CRS Strengths

Commenters indicated that the CRS program offers flexibility for communities to select
among many CRS activities, that the CRS program has strengthened communities’ floodplain
management efforts, and that CRS’ incentives resulted in reduced flood risk.
Comments on CRS Challenges
Commenters stated that the complexity and administrative burden of the CRS program
make it difficult for communities to participate in CRS, that the CRS program raises equity
concerns, and commenters questioned the degree to which the CRS incentivizes (or does not
sufficiently incentivize) increases in community flood risk reduction. Commenters also
expressed concern regarding CRS’s alignment with the NFIP’s current pricing approach and the
overall affordability of NFIP flood insurance. Additionally, commenters questioned whether the
CRS program is needed given the NFIP’s current pricing approach which calculates actuarially
based premiums, whether the CRS discount classes should be modified, and whether NFIP
policy premiums will need to increase to support CRS’s premium discounts.
Comments on CRS and Equity
Commenters suggested providing direct technical assistance and grant funds to
underserved communities to increase CRS participation and to build local floodplain
management capacity. Commenters also expressed a desire for CRS to provide more effective
outreach tools for underserved communities and for a CRS scoring system that accounts for
multiple aspects of a community including, but not limited to, a community’s size, development
density, economic status, and administrative capacity.
Commenters also suggested that CRS program credits should be shared with the
community, if not fully provided to the community instead of only being provided to the
policyholders as communities are doing the work to reduce flood risk. Commenters also
suggested that the communities should be allowed to decide how to use the available CRS

program credits, including the ability to get a cost share to support local CRS staff or mitigation
funds to reduce a community’s flood risk.
Comments on CRS and Future Conditions
Commenters indicated a desire to better incorporate future conditions through mapping
and modeling of future risk, to incentivize communities to adopt programs related to future
conditions, to create a flexible credit system for creative efforts and innovative approaches that
improve communities’ resilience, and for FEMA to disseminate more guidance and data to
communities to better incorporate future conditions and climate resiliency into a community’s
CRS program.
Comments on Floodplain Management and Flood Risk Management
Commenters stated that the CRS program should continue to support and should expand
incentives for community-level action and floodplain management and to better align measurable
risk reduction in communities of both current and future risks with program incentives (e.g.,
creditable activities and discounts). Commenters also suggested that FEMA should continue to
incentivize effective floodplain management and community involvement through more
effective outreach, technical assistance, capability-building, and funding to support floodplain
management efforts in the CRS program.
Commenters also suggested that CRS activities and credits should be limited to those
activities that lower flood risk and result in development that is less susceptible to flooding.
Commenters noted that the cost of CRS to the NFIP is too high, that credits must be given more
carefully, and that enforcement of compliance with NFIP minimum floodplain management
requirements within CRS communities must be improved. Commenters noted that many CRS
activities and credits are unrelated to flood risk reduction, such as providing credits to incentivize
community activities to protect endangered species.
Comments on CRS Simplification

Commenters requested simplification of the CRS program application process and
simplification of CRS credits and activities. Commenters suggested that the document submittal
procedures to initially join the CRS program and the scoring system in the CRS Coordinator’s
Manual should be simplified to increase transparency. Commenters also suggested that the CRS
activities should be simplified by reducing the number of activities that receive credit to allow
communities to focus on activities that result in the largest flood risk reduction (e.g., higher
elevation standards or limiting development in the SFHA).
Comments on CRS Collaboration, Integration, and Alignment
Comments suggested that FEMA should establish a grant program to fund local CRS
positions or establish a cost-share program across multiple municipalities to support CRS
implementation. Commenters also suggested the FEMA should increase the sharing of success
stories and best practices among CRS participating communities and allow multi-jurisdictional
or regionalized activities/elements where communities could work together to submit regional
documentation allowing multi-jurisdictional partnerships to make CRS more accessible (e.g.,
communities could work together through a multi-jurisdictional entity to regionally implement
the CRS program).
Commenters also suggested that the CRS should be fully integrated into the NFIP by
reimagining the NFIP’s current pricing approach and enrolling all communities into the CRS
program as part of NFIP participation starting at a CRS class 0 if the community only meets the
NFIP minimum floodplain management standards. Under this suggestion, communities could
move up in CRS class rating to increase their CRS discount with a maximum discount of up to a
50%. Commenters also suggested that a community should also be penalized for actions that
increase flood risk in the community (e.g., such as allowing violations of adopted floodplain
management development standards) down to a CRS negative class with corresponding premium
surcharges on all NFIP policies in that community.
C. Overview of GAO-23-105977 Report’s Findings and Agency Recommendations

On July 31, 2023, the Government Accountability Office (GAO) issued report number
GAO-23-105977, Flood Insurance: FEMA’s New Rate-Setting Methodology Improves Actuarial
Soundness but Highlights Need for Broader Program Reform.13 GAO-23-105977 included the
following two FEMA agency recommendations relating to improving the CRS program:
•

The Assistant Administrator of FEMA’s Federal Insurance Directorate (FID) should
adjust CRS by calculating a community’s rating based only on community activities that
reduce flood risk and by incorporating discounts into the full-risk premium based on the
actuarial evaluation of risk reduction. (Recommendation 1); and

•

The Assistant Administrator of FEMA’s FID should evaluate other means for
incentivizing desirable community activities that cannot be actuarially justified but are
currently a basis for discounts in CRS. (Recommendation 2).
The GAO-23-105977 report stated that the premium discounts provided under the CRS

program are not actuarially justified and are paid for, in large part, through a cross-subsidization
by NFIP policyholders that are not receiving the CRS discount. The GAO-23-105977 report also
stated that it is likely that policyholders receiving CRS discounts are paying lower premiums that
do not fully reflect their flood risk. The amounts of CRS discounts—both to individual
properties and program wide—are not closely linked to potential loss reduction of currently
insured properties. While the activities that FEMA promotes through CRS are important, few of
them directly mitigate flood risk to the property. For example, the GAO-23-105977 report noted
that the CRS discounts related to public information, warning and response, and mapping and
regulations do not reduce the potential for flood loss to currently insured properties. The GAO23-105977 report also stated that the NFIP’s new pricing approach accounts for some individual
premium rating variables, such as a structure’s elevation in relation to flood sources, which are
also included in CRS’ community-wide activities and credits. This may result in NFIP double

GAO-23-105977, Flood Insurance: FEMA’s New Rate-Setting Methodology Improves Actuarial Soundness but
Highlights Need for Broader Program Reform, found at https://www.gao.gov/products/gao-23-105977 (last accessed
June 28, 2024).
counting risk reduction techniques/measures during rating and discount determination and
policyholders in certain CRS communities receiving a CRS discount that is not based on the
actuarial reduction of flood risk to currently insured properties.
II. Maximizing the Value of Public Feedback
The impacts of Federal regulations and policies tend to be widely dispersed on society.
Members of the public are likely to have useful information, data, and perspectives on the
benefits and burdens of FEMA’s existing programs, regulations, information collections, and
policies. FEMA seeks additional public feedback relevant to FEMA’s potential redesign and
improvement efforts for the CRS program given the 2021 CRS RFI comments and the findings
and agency recommendations summarized above from the GAO-23-105977 report.
The following is meant to assist members of the public in formulating comments. This
notice contains a list of questions, the answers to which will assist FEMA in understanding
which suggested alternative program features and approaches CRS program stakeholders support
or oppose and why. FEMA encourages public comment on these questions and seeks any other
national-level data commenters believe are relevant to FEMA’s CRS redesign efforts.
Commenters should identify, with specificity, the program feature, policy, or process at issue.
Below are recommendations for commenters to use when making comments in response to this
RFI, so that FEMA can better evaluate the suggested changes to the CRS program:
•

Commenters should explain, with as much detail as possible, why an aspect of the CRS
program should be modified, streamlined, expanded, or repealed, and provide specific
suggestions of ways the agency can better achieve its objectives;

•

Commenters should provide specific national-level data that document the costs, burdens,
and benefits of potentially new requirements to the extent they are available.
Commenters might also address how FEMA can best obtain and consider accurate,
objective information and data about the costs, burdens, and benefits of a redesigned CRS

program and whether there are existing sources of data that FEMA can use to evaluate
the effects of the CRS program over time; and,
•

Commenters should identify with specificity administrative burdens, CRS program
requirements, information collection burdens, waiting time, or unnecessary complexity
that may impose unjustified barriers in general, or that may have adverse effects on
equity for all, including those in underserved communities.

III. Specific Information Requested
FEMA seeks comments on all suggested program features of a redesigned CRS program,
and specifically, FEMA has additional follow-up questions from the 2021 CRS RFI on suggested
CRS program changes. FEMA’s goal is to obtain diverse feedback on the CRS program that
helps inform FEMA decision-making on the future of the CRS program.
List of Questions for Commenters
(1) Should FEMA provide each community with a report highlighting potential CRS program
credits (often referred to as “points/credits”) that the community could earn to mitigate risk and
reduce insurance premiums, explaining strategies on how to receive more points, and flagging
NFIP minimum floodplain management standards compliance issues? Why or why not?
(2) Should FEMA auto enroll all NFIP participating communities into the CRS program to give
the community CRS credit for activities that they already undertake that exceed NFIP minimum
floodplain management standards (e.g., community has an open space preservation program to
reduce flooding)? Auto enrollment means all communities would automatically participate in
CRS by virtue of participating in the NFIP.
(3) Would there be any advantage if FEMA were to assess an escalating surcharge on NFIP
policy premiums for NFIP participating communities that are not in compliance with the NFIP
minimum floodplain management standards? This would be in addition to the NFIP Probation
policy surcharge that is in 44 CFR § 59.24(b).

(4) What are the advantages and/or disadvantages of providing technical assistance to
communities to support CRS participation? Would communities take advantage of technical
assistance and if so, what type(s) of technical assistance would be most helpful? Examples of
suggested technical assistance include assisting communities with the preparation of required
CRS documents, CRS project management, CRS program support, and preparation of repetitive
loss analysis.
(5) FEMA currently offers premium discounts for many CRS activities through the NFIP’s
current pricing approach. In CRS participating communities, this may lead to policyholders
receiving “double” discounts for the same CRS activities (e.g., elevation of individual structure
above the NFIP’s minimum elevation requirement resulting in a structure level discount through
the NFIP’s current pricing approach and a CRS credit for a community-wide higher structure
elevation regulation).
(a) If FEMA were to provide NFIP premium discounts to individual policyholders for
CRS activities, through the NFIP’s current pricing approach, should FEMA offer duplicate CRS
discounts for the same activities that are already reflected in individual premiums? Why or why
not?
(b) Assuming no to (a), would communities be incentivized to adopt measures in excess
of FEMA’s minimum floodplain management standards for community-wide activities that
reduce future flood risk (e.g., stormwater management regulations or enhanced future land use
planning) if FEMA were to only offer CRS discounts for those community-wide activities that
reduce future flood risk?
(6) Are there additional community-level activities that are not currently included in the CRS
program that measurably reduce flood risk to property? Please describe and, if available, provide
national-level data that demonstrate how the activities measurably reduce current and/or future
flood risk reduction to property.

(7) Would a participating CRS community be willing to exchange CRS insurance policyholder
premium discounts (e.g., all, some, or none) in a community for other comparable communitylevel benefits, such as enhanced technical assistance for the local CRS program or capacitybuilding grants? For example, if the aggregate amount of CRS discounts offered to individuals in
the community totals $100,000, would the community be interested in redistributing the total
individual CRS discounts (e.g., $100,000) among the community and the individual
policyholders (e.g., $50,000 to the community for enhanced technical assistance grants and
$50,000 to be distributed to individual policyholders in the form of CRS discounts)? By
redistributing the CRS insurance policyholder premium discount benefits from the policyholders
to the community, there would be a potential for both wider risk reduction and larger financial
benefit to the community. Would such an approach make non-participating CRS communities
more inclined to join the CRS program?
(8) Besides individual flood insurance financial premium discounts, what other benefits would
best incentivize communities to maintain participation in or to join the CRS program?
(9) The current CRS program credits 19 activities and 90+ elements recognized by the CRS
program and identified in the CRS Coordinator’s Manual along with the credit points assigned to
each activity. An activity is a floodplain management activity for which CRS credit has been
established (e.g., mapping and regulations – higher regulatory standards). Elements are discrete
parts of an activity that if implemented result in CRS credit points under that activity (e.g.,
community-wide prohibition of outdoor storage in the SFHA, which is an element of the activity
of higher regulatory standards). What are some advantages and/or disadvantages of reducing the
number of activities and elements, and streamlining CRS reporting requirements?
(10) What are the advantages and/or disadvantages of communities working with other
communities to implement CRS under a regional approach? For example, a regional approach
may include a regional watershed or planning commission that implements a CRS program for
multiple communities or a shared CRS coordinator position among several communities.

(11) What else should FEMA consider for potential improvements to the CRS program and how
can FEMA better engage with stakeholders to effectively implement the CRS program?
FEMA notes that this notice is issued solely for information and program-planning purposes. The
suggested approaches do not reflect an agency position or official action. Responses to this
notice do not bind FEMA to any further actions related to the response.
Deanne Criswell,
Administrator,
Federal Emergency Management Agency.
[FR Doc. 2024-15271 Filed: 7/10/2024 8:45 am; Publication Date: 7/11/2024]