CITY COUNCIL STAFF REPORT
Meeting: July 16, 2024
Subject
Annual Evaluation Report on the Federal Emergency Management Agency (FEMA) Community Rating System’s (CRS) Program for Public Information.
Recommended Action
Adopt Resolution No. 24-XXX accepting the Annual Evaluation Report for Fiscal Year 2024 (Year 3) of the 2021 Santa Clara County Multi-Jurisdictional Program for Public Information.
Reasons for Recommendation
The CRS is a voluntary program under the 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 flood emergency preparedness planning, maintenance of elevation certificates, 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), etc.
FEMA requires the elected body of each community that participates in the CRS program to approve a five-year Multi-Jurisdictional Program for Public Information (PPI) in order to receive points for the PPI CRS activity. The PPI allows communities to work together on messaging that helps to reduce flood risks 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 implemented program is within each participating community’s jurisdiction; however, it is expected to range from 80 to 200 points for communities that participate in the Santa Clara County (County) PPI.
Although Valley Water is not a land-use agency, FEMA recognizes Valley Water’s already robust public outreach efforts in flood risk reduction messaging 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 the County but also allows County communities participating in the CRS program to claim points earned by Valley Water. 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 to either begin or continue to earn points. 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 Cupertino 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 in order to remain an active PPI participant and continue receiving PPI points. City Council adopted Resolution No. 22-088 accepting the Annual Evaluation Report for FY 22 (Year 1) on July 19, 2022, and Resolution No. 23-090 accepting the Annual Evaluation Report for FY 23 (Year 2) on July 18, 2023.
Valley Water initiated the preparation of the third annual evaluation report by hosting meetings in March and May 2024 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 FY 24 (Year 3) of the 2021 County Multi-Jurisdictional Program for Public Information (Attachment B) is the third annual evaluation report under the 2021 PPI and is a culmination of the input provided by the participating communities from the two meetings.
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 5 percent flood insurance premium discount for properties located outside a SFHA. City property owners pay approximately $65,000 per year, cumulatively, in flood insurance premiums (as of June 2024, per the NFIP). The total annual savings to policy holders attributable to the City’s CRS discount is approximately $8,400 per year.
Neighboring cities have earned similar CRS ratings (Los Altos – 7, 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 City Council adopted Resolution No. 21-073 accepting the updated 2021 PPI, they allowed the City to begin earning points for this CRS activity which provides a larger buffer to comfortably maintain the 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 FY 24 Project Accomplishments are listed in Attachment 2 of the Annual Evaluation Report (Attachment B). 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.
California Environmental Quality Act
Not applicable.
_____________________________________
Prepared by: Jennifer Chu, Senior Civil Engineer
Reviewed by: Chad Mosley, Director of Public Works
Approved for Submission by: Pamela Wu, City Manager
Attachments:
A – Draft Resolution
B – Annual Evaluation Report for FY 24