Comment Submitted by Association of State Floodplain Managers

In Re: Department of Homeland Security – DHS-2020-0067 Comments of the Association of State Floodplain Managers (ASFPM) on the FEMA Review Council Final Report (Released May 7, 2026) Dear Sirs: The Association of State Floodplain Managers (ASFPM) appreciates the opportunity to provide the following comments on the FEMA Review Council Final Report. ASFPM represents more than 21,000 floodplain management practitioners, emergency managers, engineers, planners, state officials, local officials, and others involved in reducing flood risk across the nation. Many ASFPM members are FEMA’s partners in implementing the National Flood Insurance Program (NFIP) and FEMA’s Hazard Mitigation Assistance programs. ASFPM shares the Council's desire to improve the effectiveness of federal disaster programs, reduce disaster losses, strengthen mitigation, and ensure that taxpayer dollars are used efficiently. We also recognize that rising disaster costs require thoughtful reforms and that state and local governments should play a strong role in disaster preparedness, mitigation, response, and recovery. ASFPM believes the report correctly identifies several of the issues in the implementation of FEMA’s programs and mission and contains some constructive recommendations. However, many of its most significant proposals are based on assumptions that do not reflect how floodplain management, hazard mitigation, flood insurance, and disaster recovery programs actually operate, together and simultaneously, in practice. In several instances, the report identifies real problems but recommends solutions that would likely make those problems worse. In others, the report calls for greater state responsibility while simultaneously reducing state authority or failing to provide the resources necessary to build and sustain state capability. ASFPM supports efforts to improve FEMA's effectiveness, reduce disaster losses, strengthen resilience, and ensure responsible stewardship of taxpayer resources. Meaningful reform, however, must be grounded in how these programs operate in practice. The Association respectfully recommends that future reform efforts focus on: • Completing the nation's flood hazard mapping needs; • Modernizing NFIP minimum standards; • Addressing NFIP legacy debt; • Strengthening flood insurance affordability and participation; • Preserving the state-led nature of hazard mitigation programs; • Building state capability through dedicated capacity programs; • Authorizing CAP-SSSE and Cooperating Technical Partners; • Establishing a hazard mitigation capability program modeled after CAP-SSSE; • Improving mitigation project delivery through streamlined processes and adequate staffing; and • Ensuring FEMA maintains and supports the workforce and grows the technical expertise necessary to fulfill its mission. The nation's disaster challenges are growing in complexity and cost. The solution is not to weaken the federal-state partnership that has evolved over the past half century, but to strengthen it. ASFPM looks forward to working with Congress, FEMA, the Administration, and other stakeholders to advance reforms that improve resilience while preserving the programs and partnerships that communities rely upon every day. Our full comments are attached.