The National Flood Insurance Program's (NFIP) Community Rating System (CRS) is an incentive program that recognizes and encourages community floodplain management activities that exceed the minimum NFIP requirements. As a result, flood insurance premium rates are discounted to reflect the reduced flood risk resulting from the community actions meeting the three goals of the CRS: 1. Reduce flood damage to insurable property; 2. Strengthen and support the insurance aspects of the NFIP, and 3. Encourage a comprehensive approach to floodplain management.

When a community requests to enter the CRS program, FEMA utilizes a rating process to determine how the flood plain management program “rates” against a standardized point system. The benefit realized by the community is a reduction in NFIP insurance premiums and is a function of how many points are awarded. In order for the City of Sparks to join the CRS program and receive incentives the City must: 1. Be in full compliance with the minimum requirements of the NFIP 2. Maintain FEMA elevation Certificates for construction in the regulatory flood plain 3. Meet the minimum repetitive loss requirements 4. Have a minimum CRS score of 500 points. 5. Have no outstanding Community Assistance Visit (CAV) issues City Staff meet with FEMA in January of 2012 to discuss joining the CRS program. At the meeting FEMA presented City Staff with a checklist of documentation required to start the point rating and strongly recommended that the outstanding CAV issues be resolved before the City made a formal request to enter the CRS program. The City of Sparks currently has outstanding CAV issues documented with FEMA and the State of Nevada Division of Water Resources (attached letter dated January 29, 2010). These issues were identified during CAV audits in 1998, 2003 and 2009 and are in regard to seven (7) properties in the industrial district that were permitted to be constructed below the regulatory flood plain elevation. Staff has been working with FEMA to resolve the outstanding issues since 2010. FEMA has indicated to the City that the only acceptable mitigation is for the City to flood proof each of the structures. The cost to provide this level of mitigation is in excess of a million dollars. In May of 2012, the City retained the services of Manhard Consulting to provide assistance with evaluating the City’s existing program with regard to CRS scoring, and to assist the City with resolving outstanding CAV issues.

Manhard has evaluated the City’s existing program and has determined that our current CRS score is 382 points and with some additional work the score could easily be raised to 1330 giving the City of rating of 8 and corresponding benefit of 10%. Additionally, Manhard and City Staff have met with FEMA Region IX staff to discuss alternative mitigation methods to resolve the CAV issues. In August of 2012, Manhard conducted field surveys of each non-compliant structure to assess potential mitigation measures for each structure. The results of the field survey and proposed mitigation were summarized in a draft report in October of 2012 (attached). The report includes many potential mitigation methods (ranging from flood proofing to demolition and reconstruction) and an estimate of costs to the City. As noted in the report, the estimated cost to the City of Sparks for mitigation of the seven non compliant structures ranges from 2 to 13 million dollars.

Due to the high cost of implementation, Manhard recommended that the City of Sparks approach FEMA with a program that would rely upon the Truckee River Flood Management Authority (TRFMA) flood project in conjunction with minor flood proofing measures (raising electrical outlets, raising mechanical equipment and preparation of individual flood response plans) as a practical means of addressing the non-compliant structures included in the CAV. Manhard and City Staff met with FEMA region IX staff in January of 2013 to discuss the results of the CAV mitigation study and to propose the preferred mitigation method. FEMA region IX staff was hesitant to accept the proposed mitigation plan due to a lack of technical information regarding the TRFMA project. Specifically, FEMA requested that the City provide technical documentation, through hydrologic and hydraulic analyses, that better defines the level of service the TRFMA project would provide to the Sparks industrial area. Once the level of service the TRFMA project is understood, FEMA region IX staff will be able to determine if the proposed mitigation are acceptable to “clear” the outstanding CAV issues and the City would be able to apply for CRS.