CITY COUNCIL STAFF REPORT
Meeting: July 19, 2022
Subject
Consider adoption of a Resolution accepting the Annual Report on the FEMA Community Rating System’s (CRS) Program for Public Information.
Recommended Action
Adopt Resolution No. 22-XXX (Attachment A) accepting the Annual Evaluation Report for FY22 (Year 1) of the 2021 Santa Clara County Multi-Jurisdictional Program for Public Information.
Background
The Community Rating System (CRS) is a voluntary program under the Federal Emergency Management Agency’s (FEMA) National Flood Insurance Program (NFIP) that allows communities to earn flood insurance premium discounts for their residents and businesses by conducting floodplain management activities that exceed NFIP minimum requirements. Communities earn CRS points for activities that promote flood risk reduction practices and encourage the purchase of flood insurance. Activities eligible for CRS points include, but are not limited to, flood emergency preparedness planning, maintenance of elevation certificates and benchmarks, open space preservation within the designated floodplain, and public outreach and education of flood risk and flood insurance. The CRS class ratings are assigned to participating communities based on points earned, with each 500-point increment resulting in a better class rating. Each incremental improvement in class rating (CRS class ratings range from 10 to 1) qualifies residents and businesses within the participating community to an additional five percent discount on flood insurance premiums for properties located within a Special Flood Hazard Area (SFHA.) For example, 500 points earned would equate to a CRS class rating of 9 (or a five percent discount,) 1,000 points earned would equate to a CRS class rating of 8 (or a 10 percent discount), etcetera.
The Federal Emergency Management Agency requires the elected body of each community who participates in the CRS program to approve a five-year Multi-Jurisdictional Program for Public Information (PPI) to receive points for the PPI CRS activity. The PPI was introduced into Santa Clara County’s (County) CRS program in 2013 upon FEMA’s release of the updated 2013 CRS Coordinator’s Manual. Participation in the PPI is voluntary. The PPI allows communities to work together to decide which flood risk reduction messages are the most appropriate based on local needs and to design a collective outreach program that delivers these messages effectively and efficiently. The number of points earned as a result of having an approved PPI will vary depending on how extensive the program is that is implemented within each participating community’s jurisdiction; however, it is expected to range from 80 to 200 points for communities who participate in the County PPI.
Although Santa Clara Valley Water District (Valley Water) is not a land-use agency, FEMA recognized Valley Water’s already robust public outreach efforts in flood risk reduction messages and approved the classification of Valley Water as a fictitious community within the CRS program. This unique arrangement not only allows Valley Water to act as the lead agency in creating the first PPI for Santa Clara County but also allows the Santa Clara County communities participating in the CRS program to claim points earned by Valley Water. In 2013, Valley Water initiated the PPI preparation process by inviting local agency staff and stakeholders from throughout the County to participate in the drafting of the plan. The Valley Water District Board adopted the first PPI in 2015 for use by communities within the County that participate in the CRS program.
The PPI is required to be updated every five years to evaluate the public outreach messaging and to adjust the PPI as needed and FEMA requires the governing bodies of the participating CRS communities to approve the updated 2021 PPI in order to either begin or continue to earn points.
In February 2020, Valley Water hosted the start of the second five-year PPI process, in which fifteen (15) communities, including the City of Cupertino, worked together to review and update the 2015 PPI. Due to the COVID-19 pandemic, FEMA provided an extension for completing the PPI update to early 2021. Due to many communities shifting priorities to respond to the public health crisis, Valley Water reconvened efforts to update the PPI in October 2020. Staff and external stakeholders from each of the communities participated in the drafting of the updated document. The draft 2021 PPI was reviewed by FEMA to ensure its provisions fully complied with FEMA requirements. The Valley Water District Board approved the updated 2021 five-year PPI on April 27, 2021 and provided the document to participating jurisdictions for approval and implementation with the communities’ existing CRS programs. In turn, the City Council adopted Resolution No. 21-073 approving the 2021 PPI on August 17, 2021.
In addition to updating the PPI every five years, FEMA requires an annual evaluation report describing PPI implementation efforts and requires the participating communities to share each annual report with their governing bodies to remain an active PPI participant and continue receiving PPI points. Valley Water initiated the preparation of the first annual evaluation report by hosting meetings in March and May where staff and stakeholders from each participating community were invited to provide input on their respective PPI project accomplishments for this fiscal year. The Annual Evaluation Report for FY22 (Year 1) of the 2021 Santa Clara County Multi-Jurisdictional Program for Public Information (Attachment B) is the first annual evaluation report under the 2021 PPI and is a culmination of the input provided by the participating communities from the two meetings.
Discussion
The City has participated in the CRS program since 2005 and has a current CRS class rating of 7, which equates to a 15 percent flood insurance premium discount for properties located within a SFHA and a five percent flood insurance premium discount for properties located outside a SFHA. As noted in the updated 2021 PPI, City property owners pay approximately $86,000 per year in flood insurance premiums (as of November 2020, per the NFIP.) The total annual savings to policy holders attributable to the City’s CRS discount is approximately $9,600.
Neighboring cities have earned similar CRS ratings (Los Altos – 8, Mountain View – 7, Sunnyvale – 7, Palo Alto – 6.) It would be challenging and require additional staff resources for the City to earn enough additional CRS points to qualify for a CRS class rating of 6 without undertaking significant new efforts requiring additional funding or major floodplain management policy changes. However, when the City Council adopted Resolution No. 21-073 accepting the updated 2021 PPI, it allowed the City to begin earning points for this CRS activity which provides a larger buffer to comfortably maintain its CRS class rating of 7 and continue to provide lower cost flood insurance to Cupertino residents and businesses.
The City continues to be an active PPI participant. The City’s FY22 Project Accomplishments are listed in Attachment 2 of the Annual Evaluation Report. By adopting the resolution to accept the annual report, the City is meeting FEMA’s requirements to continue earning points for this CRS activity.
Sustainability Impact
No sustainability impact.
Fiscal Impact
No fiscal impact for accepting the Annual Evaluation Report. _____________________________________
Prepared by: Jennifer Chu, Senior Civil Engineer
Reviewed by: Chad Mosley, Acting Director of Public Works Reviewed and Approved for Submission by: Dianne Thompson, Acting City Manager Attachments:
A – Draft Resolution
B – Annual Evaluation Report for FY22