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Promote Map Accuracy and Outreach, but Opportunities Exist to Address 
Implementation Challenges' which was released on December 2, 2010. 

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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

December 2010: 

FEMA Flood Maps: 

Some Standards and Processes in Place to Promote Map Accuracy and 
Outreach, but Opportunities Exist to Address Implementation Challenges: 

GAO-11-17: 

GAO Highlights: 

Highlights of GAO-11-17, a report to congressional requesters. 

Why GAO Did This Study: 

The Federal Emergency Management Agency (FEMA), a component of the 
Department of Homeland Security (DHS), maps flood hazard areas across 
the country and makes flood insurance available to more than 20,100 
communities through the National Flood Insurance Program. From 2003 
through 2008, FEMA spent $1.2 billion in a comprehensive effort to 
update the nation’s flood insurance maps. In 2009, FEMA began an 
annual review of 20 percent of the nation’s flood maps, for which 
Congress allocated $440 million in 2009 and 2010. As requested, GAO 
reviewed the actions FEMA has taken to enhance the accuracy of updated 
flood maps, and FEMA’s outreach efforts in conducting flood mapping 
activities. GAO analyzed FEMA’s mapping standards and information 
systems, tested quality assurance processes, and interviewed FEMA 
officials and contractors. 

What GAO Found: 

FEMA has taken a number of steps to enhance the accuracy of flood 
maps, but challenges related to implementing standards to ensure map 
accuracy remain. Steps FEMA has taken include adopting a risk-based 
method to prioritize mapping projects, implementing mapping standards 
and guidance, establishing risk-based standards for topographic detail 
to ensure that the highest risk areas have the most accurate 
topographic data, and implementing quality control processes for 
ensuring engineering data is collected and used in accordance with 
standards. However, FEMA’s mapping standards could be improved. For 
example, FEMA has standards for determining the extent to which new 
and updated flood mapping data are sufficiently current to promote map 
accuracy, yet FEMA has not developed uniform guidance for the 
validation of existing mapping data. Doing so could help FEMA both 
track and report the accuracy of maps at the national and regional 
levels and better assess mapping data needs. FEMA’s quality control 
process for ensuring the accuracy of flood maps could also be 
improved. Audits of FEMA’s mapping contractors’ efforts have been 
conducted since 2006 by an independent verification contractor; 
however, FEMA officials said they planned to transfer responsibility 
for the verification audits, part of its independent verification and 
validation process, to its program management contractor by the end of 
this year, who will then monitor FEMA’s mapping contractors. The 
transfer of these responsibilities creates a potential conflict of 
interest because the program management contractor is to monitor the 
results of its program management efforts. According to industry best 
practices, verification and validation efforts should be independent 
and reported directly to senior management to provide added assurance 
that reported results on the project’s status are unbiased. The 
performance of the verification and validation function by an entity 
that is technically, managerially, and financially independent of the 
organization in charge of what it is assessing could better position 
FEMA to help ensure the independence of the verification and 
validation function, both in appearance and in fact. 

FEMA has taken a variety of steps to conduct outreach to state and 
local officials, including developing a national outreach strategy, 
but could enhance its efforts to improve public awareness and promote 
map acceptance. For example, FEMA has not developed performance goals 
or measures, or identified the resources needed for its flood mapping 
outreach efforts, which could help FEMA better determine whether its 
outreach efforts are achieving their intended results. In addition, 
FEMA could better quantify, allocate, and leverage resources needed to 
support national outreach efforts. For example, by tracking spending 
and using risk in its decisions for allocating outreach resources, 
FEMA could better allocate resources for flood mapping outreach 
efforts. In addition, FEMA could enhance its outreach efforts by 
leveraging existing flood insurance marketing resources and expertise 
during the mapping process to increase public acceptance of flood maps. 

What GAO Recommends: 

Among other things, GAO recommends that FEMA establish guidance for 
validating data, transfer responsibility for verification audits to an 
independent entity, and establish goals and measures for promoting 
public acceptance of mapping. FEMA concurred with 10 of the 11 
recommendations in this report, but disagreed with transferring 
verification audit duties to an independent entity because it believes 
its program management contractor is sufficiently independent. GAO 
believes this recommendation remains valid as stated in this report. 

View [hyperlink, http://www.gao.gov/products/GAO-11-17] or key 
components. For more information, contact William O.Jenkins, Jr.,at 
(202) 512-8757 or JenkinsWO@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

FEMA Has Taken Steps to Enhance Flood Map Accuracy, but Faces 
Challenges in Implementing Standards and Its Quality Assurance Process 
for Program Management: 

FEMA Has Taken Actions to Improve Outreach Efforts but Could Enhance 
Its Efforts to Improve Awareness and Promote Map Acceptance: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objective, Scope, and Methodology: 

Appendix II: Key Practices for Effective Communications to the General 
Public: 

Appendix III: Summary of Studies and Related Findings from 1997 
through 2009: 

Appendix IV: Comments from the Department of Homeland Security: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Mapping Partners Roles and Activities in the Flood Map 
Production Process: 

Table 2: Historical Data Quality Issues and Recommendations in FEMA's 
Flood-Mapping Efforts: 

Figures: 

Figure 1: Effects of Development on a Riverine Floodplain: 

Figure 2: Riverine Floodplain Boundary and the Base Flood Elevation: 

Figure 3: Map Production Process Overview: 

Figure 4: FEMA's Map Process Steps and Map Accuracy Standards: 

Figure 5: Light Detection and Ranging Technology Used to Generate 
Digital Elevation Data: 

Figure 6: Estimated Compliance Rates with FEMA Documentation 
Regulations: Counties Having Flood Mapping Projects Since 2005 That 
Resulted in a Change in Base Flood Elevation: 

Figure 7: GAO Analyst Examining Files at FEMA's Engineering Library: 

Figure 8: Overview of Outreach Steps in the Flood Mapping Process: 

Abbreviations: 

ASFPM: Association of State Floodplain Managers: 

BFE: Base Flood Elevation: 

CEO: Chief Executive Officer: 

CTP: Cooperating Technical Partners: 

DFIRM: Digital Flood Insurance Rate Map: 

DHS: Department of Homeland Security: 

FBS: Floodplain Boundary Standard: 

FEDD: Flood Elevation Determination Docket: 

FEMA: Federal Emergency Management Agency: 

FIRM: Flood Insurance Rate Map: 

FIS: Flood Insurance Study: 

IV&V: Independent Verification and Validation: 

LFD: Letter of Final Determination: 

LIDAR: Light Detection and Ranging: 

MIP: Mapping Information Platform: 

NFIP: National Flood Insurance Program: 

NVUE: New, Validated, or Updated Engineering: 

PTS: Production and Technical Services: 

QA/QC: Quality Assurance/Quality Control: 

Risk MAP: Risk Mapping Assessment and Planning: 

SFHA: Special Flood Hazard Area: 

USGS: United States Geological Survey: 

[End of section] 

December 2, 2010: 

The Honorable Sherrod Brown: 
Chairman: 
Subcommittee on Economic Policy: 
Committee on Banking, Housing and Urban Affairs: United States Senate: 

The Honorable Jeff Bingaman: 
United States Senate: 

The Honorable Charles E. Schumer: 
United States Senate: 

Unprecedented flooding in 2009 and 2010 in Atlanta, Georgia; 
Nashville, Tennessee; Oklahoma City, Oklahoma; and in 24 counties 
across Arkansas caused millions in property damages and heightened the 
nation's awareness of the importance of flood insurance.[Footnote 1] 
The Federal Emergency Management Agency (FEMA), a component of the 
Department of Homeland Security (DHS), is responsible for mapping 
flood-prone areas across the country. Based upon the estimated flood 
risk reflected in these maps, FEMA makes flood insurance available to 
property owners in more than 20,000 communities that participate in 
the National Flood Insurance Program (NFIP). We designated the program 
as a "high-risk" area in March 2006 because it likely will not 
generate sufficient revenues to repay the billions it borrowed from 
the Treasury to cover flood claims from the 2005 hurricanes.[Footnote 
2] From 2003 through 2008, FEMA was appropriated $1.2 billion for a 
comprehensive effort to update the nation's inventory of flood 
insurance maps--known as the Map Modernization initiative. In fiscal 
years 2009 and 2010, Congress appropriated a total of $440 million for 
FEMA to continue its flood mapping efforts.[Footnote 3] Federal law 
requires FEMA to assess the need to revise and update the nation's 
flood maps at least every 5 years;[Footnote 4] in response, FEMA 
reviews 20 percent of flood maps on an annual basis.[Footnote 5] 

As FEMA concluded in an August 2010 report to Congress, inaccurate 
maps create substantial difficulties by undermining confidence in the 
NFIP, leaving some individuals and organizations unaware of their 
risks, and imposing unnecessary costs on others whose risk is 
overstated.[Footnote 6] FEMA established its 5-year Risk Mapping 
Assessment and Planning (Risk MAP) program in 2009 to, among other 
things, improve the quality of flood data used for mapping and enhance 
public acceptance of flood maps. 

Ensuring the accuracy--and promoting public acceptance of--flood maps 
are ongoing challenges that FEMA faces in implementing its national 
flood mapping program, as evidenced by past reviews and 
recommendations made by us and others in assessing FEMA's efforts. For 
example, in our 2004 report on FEMA's mapping program, we assessed 
FEMA's plans to match the accuracy of flood data with communities' 
relative flood risk and reported that FEMA had not yet established 
data standards that describe the appropriate level of detail, 
accuracy, and analysis required to develop digital maps based on risk 
level.[Footnote 7] We recommended that FEMA develop and implement 
flood-mapping data standards for data collection and analysis for 
communities of similar risk. FEMA agreed and, in response, established 
a risk-based standard for the accuracy of mapping floodplain 
boundaries in 2005. In our report, we also reviewed FEMA's 
partnerships with states and local entities that conduct mapping 
activities and reported that FEMA had not yet developed a clear 
strategy for partnering with communities with few resources and little 
or no experience in flood mapping. We recommended that FEMA develop 
and implement strategies for partnering with state and local 
stakeholders and establish useful performance measures to assess its 
progress in increasing stakeholders' awareness and use of new maps. 
FEMA agreed and, in 2006, cited a number of activities the agency had 
taken to increase the effectiveness of its mapping partnerships, 
including the development and implementation of a national outreach 
strategy and the creation of an outreach consortium to share lessons 
learned. Recommendations to improve flood-mapping data quality and 
community outreach have also been made by the Technical Mapping 
Advisory Council,[Footnote 8] and by the Department of Homeland 
Security's Office of Inspector General.[Footnote 9] 

You requested that we review FEMA's flood mapping program. In 
response, this report addresses the following objectives: 

* To what extent has FEMA taken actions to enhance the accuracy of 
flood maps, and what challenges, if any, does FEMA face? 

* To what extent has FEMA taken actions to help promote community 
acceptance of flood maps, and what challenges, if any, does FEMA face? 

To address our first objective, we assessed FEMA's standards and 
guidance against criteria in recent reports by the National Academies 
of Sciences and the National Research Council.[Footnote 10] We 
discussed the reports' methodologies with the authors and with 
relevant FEMA officials, and analyzed reviews and critiques of the 
Academies' reports to determine that they were appropriate for our 
purposes. We analyzed information on FEMA's policies and plans for 
flood map modernization, data from FEMA's Mapping Information Platform 
(MIP) for the period of October 2005 through 2009, and systems for 
documenting compliance with FEMA's data quality standards.[Footnote 
11] To assess FEMA's internal controls and the reliability of computer-
processed flood map data, we examined FEMA databases, including the 
MIP, which was designed to monitor the mapping process and the 
completion of FEMA's quality assurance/quality control (QA/QC) 
process. We tested the controls on the QA/QC process by extracting and 
reviewing data on all projects initiated and completed from fiscal 
years 2006 through 2009. We also analyzed FEMA's Floodplain Boundary 
Standard (FBS) and New, Validated, or Updated Engineering (NVUE) 
verification systems that were designed to track implementation of 
data accuracy requirements. We tested the controls on the FBS and NVUE 
compliance process by extracting and reviewing data on all projects 
initiated and completed from fiscal year 2006 (when the FBS was 
established) through 2009 and compared them against criteria in 
Standards for Internal Control in the Federal Government.[Footnote 12] 
To assess the reliability of these databases, we compared data to 
FEMA's management reports, interviewed FEMA's three mapping 
contractors, and analyzed the original data. We determined that the 
FBS and NVUE compliance data were sufficiently reliable for our 
purposes. We also discussed FEMA's mapping process and standards with 
agency officials, as well as other federal stakeholders in geographic 
data collection and mapping, including officials at the U.S. 
Geological Survey, the National Oceanic and Atmospheric 
Administration, the U.S. Army Corps of Engineers, and subject-matter 
experts on flood hazards and floodplain management from national 
organizations, including the Association of State Floodplain Managers 
and the National Association of Flood & Stormwater Management 
Agencies, which are stakeholders to FEMA's mapping initiatives. We 
focused our review on FEMA's standards and processes related to flood 
hazard mapping for rivers and streams (commonly know as "riverine" 
flooding[Footnote 13]), which account for about 95 percent of FEMA's 
flood maps, according to FEMA. As a result, we limited our scope to 
exclude those standards and processes related to flood hazard mapping 
for coastal areas and the levee certification. In addition, FEMA has 
processes to modify and update flood map information during the time 
that a community's maps are in effect, called a Letter of Map Change, 
which is also outside the scope of our work. 

To address our second objective, we analyzed information on FEMA's 
policies, requirements for community outreach, and data from FEMA's 
information management systems (discussed above) for documenting 
compliance with statutory and regulatory requirements for documenting 
coordination with state and local officials involved in mapping 
projects. To determine FEMA's compliance with documentation 
requirements, we examined FEMA's Flood Elevation Determination Dockets 
(FEDD) files that are established for each mapping project. We 
reviewed FEDD files from a probability sample of 88 counties from a 
population of 431 counties that had completed studies from fiscal year 
2006 through 2009 that resulted in a change in base flood elevation. 
[Footnote 14] From this sample, we reviewed mapping partners' 
compliance with six documentation requirements.[Footnote 15] In 
addition, we analyzed the goals and performance measures of FEMA's 
outreach strategy for Map Modernization, and its Risk MAP national 
outreach strategy against prior GAO work reviewing federal agencies' 
practices for development of national strategies,[Footnote 16] as well 
as FEMA's budget and staff allocations related to outreach. 

To supplement our analyses of FEMA's flood mapping internal controls 
and program management activities related to data accuracy and 
community outreach, we selected four flood map modernization projects 
in Arizona, California, Florida, and North Carolina to visit. We 
selected these locations based on our 2004 review to highlight 
specific challenges associated with the mapping process, such as 
inclusion of levees, and the impact of varying degrees of community 
involvement and outreach in the 5 years since our review. The results 
from these locations cannot be generalized to all flood map 
modernization projects, but enabled us to describe challenges FEMA 
faces in conducting its national flood mapping activities by talking 
with relevant state and local officials. An expanded discussion of our 
scope and methodology is described in appendix I. 

We conducted this performance audit from August 2009 through December 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

FEMA is the primary federal agency responsible for assisting state and 
local governments, private entities, and individuals to prepare for, 
mitigate, respond to, and recover from natural disasters, including 
floods. Floods are the most frequent natural disasters in the United 
States, causing billions of dollars of damage annually. To address the 
increasing amount of flood damage, the lack of readily available 
insurance for property owners, and the cost to the taxpayer for flood- 
related disaster relief, Congress passed the National Flood Insurance 
Act of 1968, which created the NFIP.[Footnote 17] Since its inception, 
the NFIP has served as a key component of FEMA's efforts to minimize 
or mitigate the damage and financial impact of floods on the public, 
as well as to limit federal expenditures needed after floods occur. 
The NFIP seeks to minimize flood-related property losses by making 
flood insurance available on reasonable terms and encouraging its 
purchase by people who need flood insurance protection--particularly 
those living in the areas at highest risk of flooding, known as 
Special Flood Hazard Areas, designating a 1 percent annual chance of 
flooding. To do so, FEMA along with its state and local partners, 
identifies and maps flood-prone areas in the more than 20,100 
communities that currently participate in the program.[Footnote 18] 

When the NFIP was created, the purchase of flood insurance was 
voluntary. Congress amended the original law in 1973 to require the 
purchase of flood insurance in certain circumstances. The purchase of 
flood insurance is required for structures in Special Flood Hazard 
Areas of communities participating in the program if (1) any federal 
loans or grants were used to acquire or build the structures or (2) 
the structures have outstanding mortgage loans made by lending 
institutions that are regulated by the federal government. Property 
owners located in the Special Flood Hazard Area with mortgages from 
federally regulated lenders are required to purchase and maintain 
flood insurance policies. 

FEMA identifies flood hazards, assesses flood risks, and provides 
appropriate flood hazard and risk information to communities 
nationwide. To identify hazards and assess risks, mapping projects are 
performed in accordance with FEMA Guidelines and Specifications. Flood 
maps provide the basis for setting insurance rates and identifying 
properties whose owners are required to purchase flood insurance. 
FEMA's flood hazard maps are also used by lending institutions to 
determine who is required to purchase flood insurance and help ensure 
that flood insurance is purchased and maintained for these properties. 
Local government planning and zoning officials, land developers, and 
engineers use the maps for developing zoning regulations and designing 
new buildings and infrastructure to be safe from flooding. FEMA has 
estimated that local governments' compliance with the program's 
standards for new construction saves over $1 billion annually in flood 
damage avoided. 

Stakeholders from All Levels of Government and the Private Sector 
Participate in the Mapping Process: 

FEMA's Federal Insurance and Mitigation Administration, which manages 
the NFIP, is comprised of three divisions: Risk Analysis, Risk 
Reduction, and Risk Insurance.[Footnote 19] The Risk Analysis Division 
is responsible for flood mapping activities and develops flood mapping 
policy and guidance. FEMA's 10 Regional offices manage flood map 
production for their geographic areas. FEMA headquarters and regional 
staff monitor and report flood hazard mapping progress based on 
program management data provided by flood mapping partners. 

Mapping partners can include FEMA's 3 national Production and 
Technical Services (PTS) contractors, as well as state and local 
governments or regional agencies--including those state and local 
governments that are participating in FEMA's Cooperating Technical 
Partners (CTP) program. The PTS contractors are private engineering 
firms working under contract to FEMA and are each responsible for a 
regional portfolio of flood study projects. Table 1 summarizes the 
roles and responsibilities of FEMA, the mapping partners, and other 
actors in the flood map production process. 

Table 1: Mapping Partners Roles and Activities in the Flood Map 
Production Process: 

Stakeholders: FEMA headquarters staff; Requirement or responsibility 
or role: 
* Manage national flood-mapping program; 
* Monitor local governments' adoption of maps and updates to 
ordinances. 

Stakeholders: FEMA regional staff; 
Requirement or responsibility or role: 
* Oversee scoping meeting between all mapping partners; 
* Manage flood-mapping process; 
* Lead meetings to present preliminary maps with local government 
officials; 
* Provide local government officials with outreach tools; 
* Attend public meetings. 

Stakeholders: Mapping partners: 
* Contractors; 
* Cooperating Technical Partners (CTPs); 
* Other federal agencies[A]; 
Requirement or responsibility or role: 
* Assist in scoping meeting; 
* Collect required data or validates existing data; Assist FEMA in 
administering flood-mapping activities (see text above); 
* Analyze flood hazard data sources (i.e. climate, stream flow, soil, 
land use, elevation, hydraulic structure); 
* Produce flood hazard estimates; 
* Implement quality controls; 
* Create preliminary maps; 
* Attend public meetings; 
* Resolve appeals and/or protests to preliminary maps; 
* Create final maps. 

Stakeholders: State & local officials[B]; Requirement or 
responsibility or role: 
* Participate in scoping meeting; 
* Identify data assets and needs during scoping meetings; 
* Provide feedback on preliminary maps; 
* May conduct outreach to individuals in the community; 
* Collect appeals and/or protests to the preliminary maps from 
individuals and forwards to FEMA; 
* Update local governments' floodplain ordinances. 

Stakeholders: Community/general public (e.g., property owners, 
businesses, local real estate industry, etc.); Requirement or 
responsibility or role: 
* Attend public meetings; 
* Provide feedback on preliminary maps; 
* May file challenges--appeals and/or protests--to preliminary maps. 

Source: GAO analysis of FEMA data. 

[A] Other Federal agencies who work under interagency agreements with 
FEMA could include, for example, the U.S. Army Corps of Engineers, 
Natural Resources Conservation Service, U.S. Geological Survey, 
National Oceanic and Atmospheric Administration, and the Tennessee 
Valley Authority. 

[B] State and local officials can also be Cooperating Technical 
Partners. 

[End of table] 

FEMA relies on local governments to provide it with notification of 
changing flood hazard information and to work with FEMA to collect the 
information needed to reflect the updated flood hazards on the flood 
maps. Changes to communities such as new development can affect 
floodplain boundaries, as shown in figure 1 below. Thus, as we noted 
in our 2004 report, the ultimate success of FEMA's flood mapping 
program depends on the level of community investment and involvement 
in the process.[Footnote 20] 

Figure 1: Effects of Development on a Riverine Floodplain: 

[Refer to PDF for image: illustration] 

The illustration depicts before and after development, including re-
grading/filling and subsequent flooding. 

Sources: GAO analysis of FEMA data; and Art Explosion clipart. 

[End of figure] 

A community's flood hazard maps can be updated in response to a FEMA- 
initiated study or revised study of flood hazards and subsequent 
revision of NFIP flood maps or through a community-initiated revision. 
Each year, FEMA revises existing maps in communities across the 
nation. Because of funding constraints, FEMA can study or revise maps 
for only a limited number of communities each year. As a result, FEMA 
prioritizes new and revised study needs based on a cost-benefit 
approach whereby the highest priority is given to studies where 
development is greatest and where the maps are most outdated. 

Overview of Flood Mapping Production Process: 

[Side bar: 
Topographic Accuracy: 
Topographic accuracy is a function of detail and age. Detail is 
important because detailed topography has significantly fewer errors 
than less detailed alternatives and better accounts for hydraulic 
structures—structures that affect water flow—such as buildings, dykes, 
river banks, and roads. Age is important because topography can change 
over time due to development and ecological factors such as erosion. 
The topographic data used in mapping studies can have significant 
variances in age and detail, and thus, accuracy. Source: GAO analysis. 
End of side bar] 

[Side bar: 
Base flood elevation (BFE): 
The computed elevation of a flood having a 1 percent chance of being 
equaled or exceeded in a given year is the base flood elevation. It 
accounts for the volume and velocity of water moving through the 
watershed and reflects the cumulative effects of topography, soils, 
vegetation, surface permeability, and other factors. The BFE is the 
regulatory standard for the elevation or flood proofing of structures, 
and the relationship between the BFE and the elevation of a structure 
also determines the flood insurance premium. In general, the higher 
the first floor elevation, the lower the insurance premium. 
Consequently, the accuracy of BFEs on the flood maps is important for 
both regulating and insuring properties commensurate with the risk of 
flooding. Source: National Academies of Science. End of side bar] 

Flood mapping is a complex and technical endeavor. In order to create 
a map, engineers must conduct field surveys to assess the area to be 
studied and then develop data on the elevation of the terrain--called 
topographic data.[Footnote 21] Engineers develop flood hazard data 
that estimates the risk of flooding by performing analyses on the 
hydrologic conditions that affect the amount of water that flows 
downstream during a flood (for example, soil and vegetation absorb 
rain and reduce runoff while pavement and other impermeable manmade 
surfaces increase the flow of runoff) and the hydraulic conditions 
that affect the height of floodwaters in streams or waterways (for 
example, bridges may create narrower channels that raise the water 
level as it passes under the bridge). 

The results of the analyses of these different types of topographic 
and flood hazard engineering data are then combined and integrated 
into digital maps that describe how far (the floodplain boundary) and 
how high floodwaters will reach (the Base Flood Elevations, or BFEs) --
as shown in figure 2 below. Each step in the process contributes to 
the ultimate accuracy of the final map but also requires judgment and 
involves uncertainty. Without a long and well-documented record of 
flooding in a floodplain, the precision of flood hazard information is 
difficult to determine. Because weather predictions and land use are 
difficult to predict, the correctness of the flood maps cannot be 
determined with certainty. Instead, the maps must be evaluated based 
on a relative correctness or general reliability of the flood maps and 
flood insurance study. Some of the factors that impact reliability of 
the study are the type of topographic data used, the hydrologic and 
hydraulic models used and the assumptions computed, and the final 
mapping techniques by the mapping partners. 

Figure 2: Riverine Floodplain Boundary and the Base Flood Elevation: 

[Refer to PDF for image: illustration] 

The illustration depicts the following: 
* normal channel; 
* Base Flood Elevation (BFE); 
* Special Flood Hazard Area. 

Sources: GAO analysis of FEMA data; and Art Explosion clipart. 

[End of figure] 

Through various stages of the mapping production process, FEMA, in 
consultation with mapping partners and localities, determines the 
flood map study's level of accuracy and precision. In making this 
decision, required costs and resources, budget priorities, and 
communities' flood hazard identification needs are considered. An 
overview of the mapping production process is provided in figure 3 
below. This determination affects the study's cost and the resulting 
flood map's accuracy. Detailed flood studies incorporate greater 
amounts of data or more precise data into a map to provide greater 
granularity of information, for example, by determining BFEs within a 
Special Flood Hazard Area, to reduce uncertainty. In contrast, 
approximate flood studies generally require less precision in flood 
hazard data. For example, they are used for areas that are less 
subject to development and do not require the establishment of a 
regulatory base flood elevation, although base flood elevations may be 
identified on the flood map based on an agreement between FEMA, its 
mapping partners, and state and local governments. Even when 
floodplains are mapped with high accuracy, land development and 
natural changes to the landscape or hydrologic systems create the need 
for continuous map maintenance and updates. 

Figure 3: Map Production Process Overview: 

[Refer to PDF for image: illustration] 

(A) Local Needs Identified: 1–6 months; Multi-Year flood hazard 
identification; Scoping. 

(B) Data Development Period: 12-24 months; Engineering & Mapping data: 
Topographic, Hydrology, Hydraulics; Preliminary maps; 
Community review: 30-day period. 

(C) Regulatory Adoption Period: 6-9 months; Appeal; 
Map adoption. 

(D) Map maintenance begins. 

Sources: GAO analysis of FEMA data. 

Key: 

A - Local needs identified - FEMA, mapping partner, and local 
government officials meet to discuss a plan and schedule a Scoping 
Meeting(s) for flood mapping project, including data needs. 

B - Data Development period - Mapping partner collects data or 
validates existing data and uses a model to create preliminary maps. 
All maps inevitably contain some uncertainty because of technological 
limitations and budgetary constraints. Preliminary maps are presented 
to local government officials to identify issues. FEMA publishes 
notifications of new flood maps in the Federal Register and twice in 
the local newspaper. Local officials may decide to hold public 
meetings. 

C - Regulatory Adoption Period: 

Appeal Period - 90-day period for local government officials or 
individuals to challenge the preliminary maps as scientifically or 
technically inaccurate because they include, for example, inaccurate 
flood levels, flood boundaries not matching elevation of terrain, 
incorrect street names, city limits, etc. - After all appeals are 
resolved, FEMA sends a Letter of Final Determination (LFD) to the 
community CEO to say the maps are now "final." 

Adoption Period - After maps are final the local government must 
update its ordinances within 6 months. If the local government does 
not update its ordinances, it could be suspended from the National 
Flood Insurance Program. 

D - Map Maintenance - After maps are final, the local government or 
individuals can file a "Letter" to modify or update an individual 
property or parcels of land within the flood maps for reasons such as 
new development, mitigation efforts, or the limitation of map scale 
and the collection of more accurate ground elevations data on a given 
property. In addition, map maintenance also includes re-analysis and 
revision of maps - not by letter, but by republishing the entire map - 
based either on information provided by local government or by FEMA's 
identification of an update need. 

[End of figure] 

The National Flood Insurance Act of 1968, as amended, and federal 
regulations require that FEMA communicate potential changes in flood 
risk to the public when it decides to initiate a flood mapping study 
and when it is ready to release preliminary maps. At the beginning of 
the mapping process, FEMA is required to notify local governments. 
[Footnote 23] When FEMA is ready to release preliminary maps, the 
agency must publish the proposed base flood elevations in the Federal 
Register for public comment and notify the local government of the 
results of the study.[Footnote 24] When the final map is approved, 
FEMA publishes another Federal Register notice.[Footnote 25] FEMA is 
required to maintain documentation of selected elements of its public 
notification efforts.[Footnote 26] Outside of these statutory and 
regulatory requirements, FEMA has historically focused its outreach 
efforts on local government officials and has relied on local 
officials to inform the community at large (i.e., the public) of flood 
mapping efforts.[Footnote 27] 

Map Modernization to Risk MAP: 

Traditionally, flood maps were created and stored in paper format. In 
the early 1990s, however, some of the data and information FEMA 
collected to develop flood maps started becoming available in digital 
format. In 1997, FEMA developed its initial flood Map Modernization 
plan that outlined the steps necessary to update the nation's flood 
maps to digital format and streamline FEMA's operations in raising 
public awareness of the importance of the maps and responding to 
requests to revise them. FEMA's initial flood Map Modernization plan 
was to fully digitize all flood maps in the nation, first, by 
identifying those maps that required engineering updates and 
converting them to a digital format. FEMA's initial goal was to 
convert approximately 80 percent of existing paper maps to a digital 
format, update 20 percent of the existing maps with new flood risk 
information while converting them to digital format, and add 13,700 
completely new maps (also in digital format) to cover previously 
unmapped communities. Then, a planned maintenance phase would follow 
the Map Modernization initiative, whereby these maps would be updated 
with new engineering data. 

In March 2006, FEMA performed a mid-program evaluation that considered 
input from our prior work, as well as the Congress, the Department of 
Homeland Security's Inspector General, and other stakeholders. As a 
result, FEMA instituted a mid-course adjustment of the Map 
Modernization's program goals and objectives. FEMA's modified 
objectives for the initiative were to (1) produce new digital 
products; (2) provide new, updated, or validated engineering analyses; 
and (3) integrate a new Floodplain Boundary Standard into the digital 
maps. As part of this mid-course adjustment, FEMA ranked all 3,146 
counties in the United States in terms of flood risk from highest to 
lowest based on a number of factors, including, among other things, 
population, growth trends, housing units, flood insurance policies and 
claims, repetitive loss properties, and flood disasters. On the basis 
of this ranking, FEMA established its mapping priorities that the 
agency used to schedule mapping projects during the course of its Map 
Modernization initiative, which FEMA detailed in their Multi-Year 
Flood Hazard Identification Plans. From fiscal years 2003 through 
2008, FEMA spent $1.2 billion for flood map modernization. FEMA 
initiated the final year of production under Map Modernization in 
2008. [Footnote 28] 

In fiscal year 2009, FEMA began a 5-year effort--Risk MAP--with $300 
million in funding from the National Flood Insurance Fund and 
congressional appropriations for flood hazard mapping. According to 
FEMA, the vision for Risk MAP is to deliver quality data that 
increases public awareness and leads to action that reduces risk to 
life and property. According to FEMA's Risk MAP, Quality Assurance 
Management Plan, quality data is defined as accurate, credible, 
timely, and efficiently delivered. 

FEMA Has Taken Steps to Enhance Flood Map Accuracy, but Faces 
Challenges in Implementing Standards and Its Quality Assurance Process 
for Program Management: 

FEMA Has Developed Standards and a Quality Assurance Process to 
Enhance Map Accuracy: 

FEMA has implemented and tracks compliance with three standards for 
ensuring the quality of data used in developing flood maps: FEMA's 
Guidelines and Specifications; the Floodplain Boundary Standard (FBS), 
and 2 of the 3 elements of the New, Validated and Updated Engineering 
(NVUE) data standard. 

* Guidelines and Specifications for Flood Hazard Mapping Partners--
FEMA established the Guidelines and Specifications to define technical 
requirements, product specifications for Flood Hazard Maps and related 
NFIP products, and associated coordination and documentation 
activities. In addition, FEMA periodically amends the Guidelines and 
Specifications, through Procedural Memoranda. For example, in 
September 2010, FEMA revised Guidelines and Specifications for 
acquiring elevation to include risk-based standards for gathering and 
using topographic data. 

* Floodplain Boundary Standard--In response to stakeholders concern 
about the quality of flood data used to develop new flood maps during 
the Flood Map Modernization program, FEMA issued the FBS in October 
2007, in part, to help ensure that flood maps are tied to a 
topographic source. The purpose of the FBS is to ensure the locations 
of the predicted horizontal (floodplain boundary) and vertical (base 
flood elevation) lines drawn on flood maps are comparable to the 
topographic data that has been selected for the study area. For 
example, maps showing water running uphill could occur if inaccuracies 
existed when calculating the base flood elevation against the 
topographic data, according to mapping contractors. The FBS reduces 
the chance of such errors taking place, which enhances the public 
credibility of flood maps, according to mapping contractors. All 
studies contracted since 2006 must comply with the FBS. In FEMA's 2006 
Mid-Course Adjustment to the Map Modernization program, the agency set 
a goal that 75 percent of stream miles reflected on FEMA's issued maps 
were to be compliant with FBS by the end of Map Modernization. 
[Footnote 29] FEMA's last quarterly report of fiscal year 2009 
indicated that FEMA had met this goal; according to the report, flood 
maps have reached approximately 89 percent stream mile compliance with 
the FBS nationally. 

* New, Validated, or Updated Engineering (NVUE) standard--FEMA also 
developed a standard called the New, Validated, or Updated Engineering 
(NVUE) standard to provide a basis for assessing the engineering 
analysis used to develop flood elevations. FEMA developed the standard 
to help mapping partners determine where new study data should be 
collected, where updates to existing flood hazard data should be 
performed, and whether previously developed flood study data could 
still be considered valid. FEMA issued draft guidance for validating 
existing data in April 2007. FEMA intends to use the NVUE data quality 
standard in implementing its Coordinated Needs Management System. 
According to officials, the Coordinated Needs Management System is an 
assessment tool to determine mapping needs and a means for making 
funding allocation decisions. FEMA officials stated that the 
Coordinated Needs Management System is to provide FEMA with a national 
assessment of data needs. However, the system is under development and 
is projected to be implemented nationwide in 2011. According to FEMA 
officials, the Coordinated Needs Management System is to track 
information including the flood zone designation, risk assigned, study 
type, and the date the analysis was completed or validated. FEMA 
believes that this approach will provide better detail regarding the 
precision of a flood hazard analysis for end users that they can 
understand, and will be applied in a risk-based manner. 

To monitor the quality of the process used throughout development of 
flood maps in accordance with the standards in the Guidelines and 
Specifications, FEMA established the Mapping Information Platform 
(MIP) information system. The MIP provides mapping partners the tools 
and technology to create, validate, store, track and update flood data 
according to FEMA's standards using the MIP's map production 
processes. FEMA also developed quality assurance management plans and 
processes to work with local communities and flood mapping partners. 
FEMA's quality management plans identify quality assurance steps that 
are to occur during the creation, review, and editing of flood hazard 
study. On December 1, 2008, FEMA issued revised guidance for seven 
quality control reviews to be performed during the flood map 
production process. Figure 4 below provides an overview of FEMA's 
three data quality standards and the quality assurance process in the 
context of the steps in the mapping process. 

Figure 4: FEMA's Map Process Steps and Map Accuracy Standards: 

[Refer to PDF for image: illustration] 

(A) Local Needs Identified: 1–6 months; Multi-Year flood hazard 
identification; Scoping. 

(B) Data Development Period: 12-24 months; Engineering & Mapping data: 
Topographic, Hydrology, Hydraulics; Preliminary maps: Floodplain 
Boundary Standard (FBS); NVUE Compliance Standard; 
Community review: 30-day period. 

“Guidelines and Specifications” compliance for new data is applied 
from Scoping through Map Maintenance. 

(C) Regulatory Adoption Period: 6-9 months; Appeal; 
Map adoption. 

(D) Map maintenance begins. 

Sources: GAO analysis of FEMA data. 

[End of figure] 

In addition, FEMA established a quality assurance management system 
under both their Map Modernization and Risk MAP efforts to ensure that 
mapping products and processes comply with FEMA's specified 
requirements. Included in FEMA's quality assurance system are audits 
of the mapping process by Independent Verification and Validation 
(IV&V) audits. The IV&V contractor is to independently provide 
feedback to FEMA as part of the audit, such as sampling it conducted 
on the results of mapping projects performed by mapping partners. We 
previously reported that world-class, private sector corporations 
successfully employ best practices with quality assurance by using 
process controls to design products and by controlling production 
processes as the production is occurring.[Footnote 30] FEMA's quality 
management system and quality assurance process reflects the 
recognized best practice of reviewing the quality of the map product 
during the production process. 

FEMA Enhanced Its Guidelines for Topographic Data by Establishing Risk-
Based Standards: 

FEMA has recently published a quality standard to set a minimum level 
of topographic detail for all studies in its Guidelines and 
Specification. Specifically, it established standards for the level of 
topographic detail required to ensure that the maps of those areas at 
the highest risk from flooding have the most accurate topographic 
data, as suggested by the National Research Council and FEMA's Risk 
MAP strategy. In September 2010, FEMA published Procedural Memorandum 
61 to update its Guidelines and Specifications requiring mapping 
partners to align FEMA's topographic data specifications to levels of 
risk for flooding, as well as account for differing characteristics of 
elevation that can affect the accuracy and precision of base flood 
elevations. This procedural memorandum identifies the specifications 
of elevation accuracy and precision needed based on FEMA's previously-
identified risk classes for all 3,146 counties in the United States. 
As the National Academies of Sciences report stated, the level of 
detail used in a study should correspond to the area's risk. FEMA 
officials stated that they will only be starting new studies in areas 
where there are already existing updated and accurate topographic data 
or in areas that have sufficient need and risk to necessitate FEMA's 
funding the acquisition of such data. 

Prior to the issuance of Procedural Memorandum 61 in September 2010, 
FEMA delineated floodplains using the "best available" existing 
topographic data for the area being studied. In the absence of data 
provided by the mapping stakeholder or newly developed for a flood 
mapping project, a primary source for topographic data was the 
National Elevation Dataset maintained by the U.S. Geological Survey 
(USGS),[Footnote 31] which is over 35 years old on average. FEMA's 
existing standards for new topographic data required data that is 
about 10 times more accurate than USGS topographic data and required 
topographic data acquired or reviewed within the last 7 years to 
account for changes such as human development. FEMA plans to work with 
local officials to determine whether the existing data held by the 
locality or another source (such as the USGS), meets new the new 
standards, or to develop new data through means such as Light 
Detection and Ranging (LIDAR). As illustrated in figure 5 below and as 
we reported in 2004, FEMA has promoted the use of LIDAR remote sensing 
technologies to generate highly accurate, digital elevation data. The 
illustration shows an airplane equipped with laser-pulsing sensors 
using LIDAR to gather digital elevation data to measure the contours 
and crevices that determine where floodwaters collect. Elevation data 
are a key component needed to determine flood risk and identify 
floodplain boundaries. According to FEMA, for very flat areas where 
small changes in elevation can have a large impact on where flood 
plain boundaries are drawn, LIDAR can provide the level of detail 
needed to accurately delineate these boundaries. Communities can also 
use detailed, digital elevation data for planning and land development 
purposes. FEMA expects that LIDAR will be the primary technology used 
to acquire new digital elevation data for Risk MAP. 

Figure 5: Light Detection and Ranging Technology Used to Generate 
Digital Elevation Data: 

[Refer to PDF for image: illustration] 

The illustration depicts LIDAR Laser scanner interaction with the 
countryside. 

Sources: GAO analysis of FEMA data. 

[End of figure] 

In a study commissioned by FEMA and issued in 2009, the National 
Academies of Sciences compared the effect of using USGS data versus 
LIDAR data at three geographic locations using the same hydrologic and 
hydraulic models. For each area studied, the two different sources of 
topographic data resulted in different BFEs and floodplain boundary 
locations. The report concluded that the quality of topographic data 
is the most important factor in determining water surface elevations, 
base flood elevations, and the extent of flooding and, thus, the 
accuracy of flood maps for riverine areas, which account for 
approximately 95 percent of FEMA's flood maps. FEMA officials agreed 
that accurate data are essential and that even the best models cannot 
produce an accurate flood map with inaccurate inputs, but they said 
there is a point of diminishing returns where the cost of developing 
highly accurate topographic data outweighs its overall benefit. 

Prior to fiscal year 2010, FEMA did not generally provide funding for 
mapping partners to acquire new topographic data in an effort to 
conserve resources and share responsibilities, according to FEMA 
officials.[Footnote 32] Historically, studies at all risk levels could 
have used the USGS National Elevation Dataset as the best available 
data, if obtaining better quality data was unaffordable, according to 
FEMA officials. Officials from the Association of State Floodplain 
Managers agreed with this characterization of historical mapping 
efforts and said that cost constraints limit local governments and 
mapping partners' ability to collect extensive data, a situation that 
has resulted, in some cases, in poor map quality. FEMA officials 
acknowledged that affordability issues have been the main reason high 
risk areas may rely on USGS data for their study. To address this 
issue, FEMA officials said they planned to provide $80 million in 
funding in fiscal years 2010 through 2013 to acquire new topographic 
data. 

FEMA's Existing Data Quality Standards Could Be Better Implemented to 
Match Mapping Data Precision with the Level of Flood Risk: 

FEMA's Floodplain Boundary Standard (FBS) reporting does not reflect 
the quality of topographic data or level of study detail, and 
according to FEMA officials, 1 of the 3 elements of the standard for 
New, Validated, and Updated Engineering (NVUE) data has not been fully 
implemented. 

The Floodplain Boundary Standard Could More Effectively Measure Map 
Accuracy: 

The accuracy of a map's floodplain boundary, in applying the FBS for 
an area, is dependent on two factors--the quality of topographic data 
and the level of detail used for a flood study. However, the method 
FEMA uses in measuring FBS compliance does not account for these 
factors when reporting FBS compliance rates for counties. Thus, two 
maps using topographical data of widely varying accuracy and currency, 
and based on studies of different levels of detail, can both be 
considered FBS compliant as long as the base flood elevation and 
floodplain boundaries are consistent with the topographic data used in 
each study. Consequently, FBS compliance rates across counties do not 
provide a means for FEMA management to compare the relative accuracy 
of maps. According to FEMA, the FBS was created to address problems 
that arose when existing paper map floodplain boundaries were 
transferred to digital format; the purpose was to ensure that mapping 
partners checked or revised preliminary maps to confirm they were 
consistent with available topographic data, not to compare map 
accuracy. The FBS, which is designed to help ensure the accuracy of 
floodplain delineations, is an important FEMA measure of the quality 
of flood maps. This is because individuals living within the 
floodplain boundary are considered to be in a Special Flood Hazard 
Area and are thereby required to purchase flood insurance while those 
outside of the boundary are exempt from this requirement.[Footnote 33] 

Stakeholders involved with the four mapping projects we contacted said 
that the quality of FBS as a measure of accuracy is only as good as 
the quality of the topographic data that measures land elevation. 
Because FEMA's standard has historically been that the mapping 
stakeholders should use the best available topographic data, the 
quality (including precision) of the topographical data used to match 
up with the floodplain boundary may vary widely depending upon the 
quality of what is available. 

The level of detail used in a flood study determines the requirements 
necessary for a map to achieve FBS compliance. Detailed studies have 
compliance standards more stringent than approximate studies that use 
less accurate, often outdated topographic information and models, 
according to the National Academies of Sciences report. According to 
FEMA, the determining factors when deciding whether to perform 
detailed or approximate studies for communities are the level of flood 
risk in the area, the likelihood of additional development, and the 
cost and benefits of performing a detailed study versus an approximate 
study, as detailed studies are significantly more expensive than 
approximate studies. Though FEMA advises against it, some communities 
in the highest risk class have chosen to undergo approximate studies 
due to fiscal restraints. 

Differences in the level of detail used in studies leads to 
significant variances in how precisely base flood elevations must 
match the elevation data used to comply with the FBS. The BFEs in 
detailed studies are required to be much more precise than those in 
approximate studies, but each are considered to be equally compliant 
as long as they meet the standards for their respective level of 
detail. For example, the BFE in detailed studies are required to match 
the topographic data within 1 foot, while BFEs in approximate studies 
can differ from the topographic data used by up to 20 feet and be 
considered compliant with FBS.[Footnote 34] For the purpose of 
reporting whether FEMA has met its goal for the percentage of maps 
that are FBS compliant, a compliant detailed study counts equally with 
a compliant approximate study, with no consideration for the differing 
requirements necessary to achieve this compliance. 

In 2003, we identified linkage and clarity of measures as two key 
attributes of successful performance measures.[Footnote 35] 
Establishing separate measures of compliance for detailed and 
approximate studies could allow FEMA to better use FBS compliance 
rates as a measure of map accuracy; however, the data necessary to 
accomplish this are presently not maintained by the agency. FEMA 
officials said that these data were not tracked at a national level 
because the significant increase in mapping activities associated with 
Map Modernization focused agency efforts on map production rather than 
data collection and analysis. FEMA officials acknowledged that the 
agency lacked a way to systematically track, at a national level, the 
types of topographic data or level of project detail used in each 
study, which limited their ability to effectively and comprehensively 
describe the accuracy of flood maps. Officials also stated that they 
did not consider the need to use data on FBS compliance rates for 
management decisions on map accuracy, as they believe that national 
reporting of differences in the level of detail used in studies does 
not provide significant insight into the flood data accuracy or 
reliability. Nonetheless, we continue to believe that FBS compliance 
rates reported for detailed and approximate studies within and across 
counties could provide information that would both enable FEMA 
management to compare the relative accuracy of maps, and be a more 
meaningful and understandable measure to FEMA's mapping stakeholders 
and the general public. 

While FEMA does not track this information at a national level, 
topographic data and other information regarding study detail, 
referred to as metadata, are recorded at the individual mapping 
project level within the MIP.[Footnote 36] As part of its Quality 
Assurance process, FEMA requires mapping partners to submit metadata 
within the MIP for review. FEMA checks the information to ensure its 
validity and informs the mapping contractor if there are any problems 
that may affect map accuracy. FEMA reviews this metadata, but the 
agency does not retain or store the metadata in a way that enables 
future analysis across all mapping studies that could support the 
management of the mapping program. Standards for Internal Control in 
the Federal Government provides that agencies should identify, capture 
and distribute pertinent information in order to effectively carry out 
the agencies' duties.[Footnote 37] While there is a cost associated 
with retaining and analyzing metadata, FEMA could minimize these costs 
by utilizing its existing technology, the MIP, to retain or store 
these data in a way that enables future analysis across all mapping 
studies. By doing so, FEMA could report additional information on FBS 
compliance and, thereby, have a potentially better measure of map 
accuracy. FEMA could then use this data to develop separate measures 
of FBS compliance for both detailed and approximate flood studies, 
each of which has a different range of accuracy. 

FEMA Could More Fully Implement Its New, Validated, and Updated 
Engineering Standard: 

FEMA implemented its NVUE standard in 2007 to provide a basis for 
flood mapping partners to assess the quality of new, validated, or 
updated engineering data in revising maps, but has not fully developed 
uniform guidance for the validation of existing data. Validation 
guidance for mapping partners has existed in draft form since 2007, 
but it has not yet been used, according to FEMA officials. This 
guidance consists of a set list of parameters that define whether data 
used in the past is adequate for current use, or whether the area 
being studied has changed to an extent that new data is necessary. 

FEMA's draft guidance on how to validate data was found to be 
ineffective due to differing interpretations and methodologies used by 
various mapping contractors, according to FEMA officials and FEMA 
contractors who oversaw NVUE data collection and internal controls 
during the Map Modernization effort. Prior to its being found 
ineffective, contractors used this guidance, issued in the form of 
checklists, to determine if enough changes had occurred in the area 
being studied to render existing study data invalid. However, two 
regions submitted validation figures to FEMA, each of which used a 
different methodology to obtain their calculations. According to FEMA, 
the agency determined that this process was too inconsistent to be 
acceptable as a data quality standard, so validation of existing data 
was discontinued until uniform guidance could be developed in 2011, 
leaving only new and updated data counting as NVUE compliant. 

As a result of the mid-course adjustment in 2006, FEMA set a goal of 
reaching an NVUE compliance rate of 30 percent, meaning 30 percent of 
the nation's stream miles would be mapped using new or updated 
engineering analysis by the end of Map Modernization. The goal under 
Risk MAP is to increase NVUE compliance to 80 percent to reflect this 
phase's heightened focus on ensuring data accuracy. In January 2010, 
FEMA reported the current rate of national NVUE compliance was 52 
percent. Validating existing data could assist FEMA in reaching this 
compliance goal. According to the NVUE standard, it is necessary to 
determine the relative accuracy of flood hazard data on a community's 
maps before a new mapping process begins, therefore, a needs 
assessment must be conducted to determine whether existing flood 
hazard information represents current conditions and is deemed valid 
or current. In an August 2010 report to Congress, the agency 
acknowledged that its Risk MAP strategy relies on validating the 
currency of a substantial portion of existing flood hazard 
information. FEMA officials said the development of a final version of 
this guidance had been a secondary focus as the agency was focusing 
its Map Modernization program resources on conversion of flood maps to 
digital format and updating the most significant engineering needs. 
Now that the initial map modernization program has been completed and 
FEMA is implementing its Risk MAP strategy, complete guidance for 
mapping stakeholders would be an effective and timely step to further 
implement its new program.[Footnote 38] While FEMA believes that a 
substantial portion of existing flood hazard information is still 
current in those areas where development has not been significant, 
establishing uniform guidance for the validation of existing data 
could help FEMA ensure mapping partners are consistently validating 
data, and thereby help FEMA both track and report the accuracy of maps 
at the national and regional levels and better assess mapping data 
needs. 

FEMA's Independent Verification and Validation Process Helps Ensure 
Maps Meet Minimum Requirements, but the Process Could Be Improved to 
Better Ensure Compliance and Data Reliability: 

FEMA has developed a quality assurance process to help ensure that 
mapping efforts are performed in accordance with minimum data quality 
standards, procedures, and requirements, including independent 
verification and validation (IV&V) audits of a sample of FEMA's 
completed mapping projects. However, we identified problems with this 
process, which could impede FEMA's ability to ensure mapping efforts 
are performed in accordance with requirements in FEMA's Guidelines & 
Specifications. The use of verification and validation is a recognized 
key practice for large and complex system development and acquisition 
projects. The purpose of the verification and validation function is 
to provide management with objective insight into the program's 
processes and associated work products. For example, IV&V audits can 
help FEMA identify problems related to compliance with data quality 
standards. However, the number of flood studies selected annually for 
IV&V is not based on probability sampling that would allow the results 
of the audits to be generalized to a larger population and used for 
quality assurance purposes. In addition, FEMA officials said the 
agency planned to transfer responsibility for the IV&V process to its 
program management contractor. However, the transfer of the 
responsibilities could create a potential conflict of interest because 
the program management contractor will be monitoring the results of 
its own program management efforts. Finally, the manner in which 
problems related to compliance with data quality standards has been 
documented in IV&V audit reports does not facilitate systematic 
analysis that could further enhance quality management efforts. 

IV&V Is Not Based on Probability Sampling: 

According to the IV&V auditor, its monthly reviews were based on a 
nonprobability sample of map studies and it did not take steps to 
ensure that the audit results would be generalizable to the entire 
population of map studies. Specifically, FEMA officials told us that 
although the IV&V contractor reported in its April 2010 report 
[Footnote 39] that map products are frequently not meeting FEMA's 
Guidelines and Specifications, FEMA regards these as minor issues in 
the agency's overall quality assurance framework because the IV&V 
contractor based their conclusions on a small sample of map studies 
(i.e., a nonprobability sample). The major limitation of 
nonprobability sampling is that the results cannot be generalized to a 
larger population, because some members of the population being 
studied have no chance or an unknown chance of being selected as part 
of the sample. However, if FEMA's IV&V auditor used probability 
sampling, FEMA program officials would have been better positioned to 
know whether the audit issues were isolated events or indicative of 
more systemic issues in its flood mapping efforts. 

We recognize that conducting probability samples of map studies could 
involve additional costs. However, not conducting IV&V audits on a 
generalizable sample could also be costly. This is because using a 
generalizable sample could better position FEMA to identify and 
resolve systemic issues in flood mapping efforts, which is a critical 
task in helping to ensure that future efforts are performed in 
accordance with FEMA's standards and quality assurance management 
plans. FEMA officials stated that the terms of work for a new IV&V 
audit contractor had not yet been finalized and that while the 
officials had not determined whether the benefits outweigh the costs 
of conducting probability samples, they felt that reviewing the 
results from probability samples would be beneficial. Implementing 
probability samples in its IV&V audit process, to the extent that the 
benefits outweigh the costs, could help FEMA management use the 
results from its IV&V auditing process more strategically. 

Transfer of IV&V Responsibilities to Program Management Contractor 
Creates Potential Conflict of Interest: 

Audits of FEMA's mapping contractors' efforts have been conducted 
since 2006 by an independent verification contractor; however, FEMA 
officials said they planned to transfer responsibility for the IV&V 
process to its program management contractor by the end of this year, 
which will then monitor the FEMA's mapping contractors. The transfer 
of these responsibilities creates a potential conflict of interest 
because the program management contractor is to monitor the results of 
its program management efforts. FEMA officials said they integrated 
the verification and validation process into its program management 
contract because the current IV&V contract was expiring and they 
believed that using FEMA's program management contractor for the 
product quality management would be the most effective and efficient 
approach for an integrated quality management program. FEMA officials 
did not believe the revised approach limited the program management 
contractor's independence or presented a conflict of interest. FEMA's 
quality management plan called for independent verification and 
validation of activities of the Program Manager as well as the mapping 
contractors. FEMA officials stated that, in situations where program 
activities of the program management contractor are to audited, FEMA 
officials would either perform the audit or hire an external auditor. 
Nevertheless, as we recently reported, the independence of the 
verification and validation contractor is a key component of a 
reliable verification and validation function.[Footnote 40] According 
to industry best practices, the verification and validation activity 
should be independent of the project and report directly to senior 
management to provide added assurance that reported results on the 
project's status are unbiased. An effective verification and 
validation review process should provide an objective assessment to 
management. The verification and validation reports should identify to 
senior management the issues or weaknesses that increase the risks 
associated with the project or portfolio so that they can be promptly 
addressed. FEMA management has correctly recognized the importance of 
such a function; however, the performance of the verification and 
validation function by an entity that is technically, managerially, 
and financially independent of the organization in charge of what it 
is assessing could better position FEMA to help ensure the 
independence of the verification and validation function, both in 
appearance and in fact. 

Documentation of Compliance Problems Does Not Facilitate Analysis: 

Under FEMA's Independent Verification and Validation audit process, 
the IV&V auditor is not required to present its findings in a format 
readily conducive for performance monitoring and data analysis. For 
example, according to one PTS contractor, FEMA advised its mapping 
contractors that the IV&V audit findings are informational, rather 
than actionable; therefore, the contractors are not required to 
implement or track any changes. However, we found that at least one of 
the PTS contractors does have a system for addressing corrective 
action based on the IV&V audit findings--a corrective action process 
that is documented in the contractor's Quality Management Plan that it 
provided to FEMA. The corrective action process is used to address 
deficiencies identified by the IV&V auditor and prevent future 
occurrences during the mapping process, which are reported to FEMA 
through a quarterly internal quality audit report. 

Standards for Internal Control in the Federal Government states that 
monitoring should assess the quality of performance over time and 
ensure that the findings of audits and other reviews are promptly 
resolved.[Footnote 41] In addition, we have previously reported that 
when agencies lacked systematic analysis and reporting of data, it 
adversely affected their ability to provide complete information on 
the results of their operations.[Footnote 42] We reported that this 
type of information could be useful to better understand the nature of 
a problem, to help plan ways to address it, and to assess progress 
made. In our analysis, we found that FEMA has several opportunities 
for improving quality outcomes using its current practices. First, 
FEMA could devise its own systematic data collection framework for the 
audits. Second, FEMA could provide more guidance to the IV&V auditor 
on how to present the audit findings. The IV&V auditor reported that 
FEMA provided no guidance on how to present the results of the monthly 
audits. FEMA could also require more comprehensive reporting as part 
of its agreement with the mapping contractors, similar to the internal 
efforts of the mapping contractor described above. The IV&V auditing 
process could include all three mapping contractors and relevant 
Cooperating Technical Partners, and FEMA could provide similar 
guidelines for reporting metrics. The IV&V audits collectively produce 
data that could be used to enhance FEMA's quality management if the 
information is leveraged properly. For example, a database of audit 
findings that is readily searchable could be used to identify trends, 
quantity recurring problems, and potentially isolate mapping issues to 
a specific region or PTS contractor. Therefore, in the absence of 
systematic data reporting, FEMA's ability to establish a corrective 
action plan to resolve issues, one of the key requirements of its 
quality assurance management program, is greatly diminished. FEMA 
officials stated that they have not required systematic data reporting 
of IV&V audit results because they viewed the findings as isolated 
cases to find individual map irregularities to assist regions in 
improving map accuracy rather than potentially systemic issues. 
However, FEMA officials agreed with our assessment that a methodical 
approach to IV&V data collection could allow the agency to better 
track map quality issues, better analyze the data, and more easily 
adopt a corrective action plan. These actions could ensure that FEMA 
adhere to its quality management plan and enhance map quality. 

FEMA Has Taken Actions to Improve Outreach Efforts but Could Enhance 
Its Efforts to Improve Awareness and Promote Map Acceptance: 

FEMA Is Developing Toolkits and a Lessons Learned Library for State 
and Local Mapping Stakeholders and Intends to Use Social Media Tools 
to Reach Out to the Public: 

FEMA has taken steps to increase the accessibility of outreach 
toolkits and the awareness of outreach practices, through the Internet 
and internet-based social media tools, to better equip state and local 
officials with the resources needed to effectively reach out to the 
public regarding flood mapping. FEMA previously developed and 
distributed outreach toolkits for state and local officials at the 
regional level by regional contractors. Under Risk MAP, FEMA's program 
management contractor is developing standardized outreach toolkits for 
state and local officials, which FEMA plans to provide nationally. 
FEMA is also developing a Lessons Learned Library and a secure Web 
site for flood mapping partners. As the outreach toolkits that include 
standardized information and templates are developed, the site is 
designed to share resources among FEMA regions and with state and 
local officials. FEMA officials said that the site also includes 
information from national and regional conferences that can be used by 
FEMA Regions and state and local officials to conduct outreach to the 
public. According to FEMA officials, FEMA Regions will use the secure 
Web site to upload examples of their key practices and associated 
materials. 

In addition to better equipping state and local officials with the 
resources needed to effectively reach out to the public, FEMA is also 
conducting outreach directly to the public. Specifically, while FEMA's 
regulatory and statutory flood mapping outreach requirements focus on 
notifying the public about flood mapping through newspaper 
publications and Federal Register notices, FEMA officials said they 
were considering the use of social media sites as well.[Footnote 43] 
FEMA has been engaging in internet-based social media tools and Web 
sites nationwide as part of its mission to prepare the nation for 
disasters. FEMA uses these tools--such as national-level news feeds 
that provide subscribers with automated updated information and a 
multimedia site that hosts videos, podcasts, photos and text-based 
documents--for flood mapping outreach efforts as part of their 
outreach strategy. 

FEMA's Risk MAP goals with social media include providing timely and 
accurate information related to disaster preparedness response and 
recovery and providing the public with another avenue for insight into 
the agency's operations. In addition, FEMA's use of social media 
provides additional outreach and channels for input. According to 
FEMA, citizens can engage more easily with the emergency management 
community through social media sites, and increase their role in 
disaster preparedness, response, and recovery. For example, FEMA has 
been using Twitter since October 2008 as a means to offer information 
about the agency's mission, efforts, and perspective. The agency also 
launched a YouTube page in October 2008 to provide stories about how 
its programs work in communities nationwide as they prepare for, 
respond to, and recover from disasters. FEMA believes that these tools 
could help the agency and its state and local mapping partners to more 
effectively communicate with communities about flood mapping efforts. 

FEMA Does Not Maintain Most Required Public Notification Documentation: 

In our review of a random sample of files containing documentation of 
public notification efforts, we found that FEMA does not maintain the 
required documentation for public notification. Further, FEMA does not 
have a process in place to ensure that its mapping partners 
consistently document their actions to notify the public. FEMA is 
required by law to document certain actions taken to notify the public 
regarding the status of its flood mapping efforts. FEMA has 
requirements in place for mapping partners to provide such required 
documentation, but it does not have a process in place to ensure that 
mapping partners are meeting these documentation requirements. As a 
result, FEMA cannot be reasonably assured that it is complying with 
public notification regulations. 

FEMA is required to maintain a Flood Elevation Determination Docket 
(FEDD) file for every local government that is affected by a flood 
mapping project that results in a change in base flood elevation. 
[Footnote 44] The FEDD file provides a record of all matters 
pertaining to flood elevation determinations, including public 
notification requirements established by the National Flood Insurance 
Act of 1968. These FEDD files are required to contain documentation 
demonstrating that a mapping contractor took the following six public 
notification actions: 

* notifying the community's CEO of the proposed flood elevation 
determination, 

* notifying the public of the proposed flood elevation determination 
via an initial newspaper publication, 

* notifying the public of the proposed flood elevation determination 
via a 2nd newspaper publication, 

* notifying the public of the proposed flood elevation determination 
via a notice in the Federal Register, 

* notifying the public of the final flood elevation determination via 
a notice in the Federal Register, and: 

* notifying the community's CEO of the final flood elevation 
determination. 

Based on our file review of a random sample of counties with flood 
mapping projects, FEMA did not have a FEDD folder on file for 
approximately 67 percent of the counties that had completed mapping 
projects since 2005.[Footnote 45] We estimate that FEMA complied with 
some, but not all documentation requirements for 16 percent of the 
counties, and complied with all 6 documentation requirements for the 
remaining 17 percent, as illustrated in figure 6 below. Because FEMA 
does not sufficiently maintain documentation of its public 
notification activities, the FEDD files do not provide a means for the 
agency to provide reasonable assurance that it is complying with 
public notification regulations. As a result, FEMA cannot use the FEDD 
files to determine the extent to which a community was notified about 
new mapping projects in accordance with the six public notification 
actions. 

Figure 6: Estimated Compliance Rates with FEMA Documentation 
Regulations: Counties Having Flood Mapping Projects Since 2005 That 
Resulted in a Change in Base Flood Elevation: 

[Refer to PDF for image: pie-chart] 

Compliance cannot be determined; FEDD file not found: 67%; Compliance 
for all 6 of the required actions: 17%; Compliance for less than 6 of 
the required actions: 16%. 

Source: GAO analysis of FEMA data. 

[End of figure] 

FEMA officials said that they rely on mapping partners to document 
completion of public notification requirements in FEDD files and FEMA 
provides mapping partners with background on public notification 
documentation requirements. FEMA also directs mapping partners to 
document compliance with notification requirements in FEMA's Document 
Control Procedures Manual. In reviewing FEMA's manual, we determined 
that if mapping contractors followed the guidance in the manual, they 
should be able to comply with public notification documentation 
requirements. FEMA's manual provides details on the procedures to be 
followed and the documents to be used for each NFIP map action 
including FEMA-initiated, FEMA-contracted, and community-initiated map 
studies and revisions. 

FEMA relies on mapping partners to comply with these requirements, but 
the agency does not have a process in place to ensure that these 
mapping partners consistently document their actions to notify the 
public. FEMA regulations require that public notification 
documentation reside in FEDD files, which we observed as part of our 
file review, as shown in figure 7 below. 

Figure 7: GAO Analyst Examining Files at FEMA's Engineering Library: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

FEMA's contractor oversees its Engineering Library, where the hard 
copy FEDD files are maintained. FEMA officials said that the agency is 
aware that its mapping partners are not complying with public 
notification documentation requirements and is drafting a procedural 
memorandum that reiterates the processes that mapping partners are to 
comply with to ensure that all documentation from completed studies 
are sent to FEMA in a timely manner. 

Standards for Internal Control in the Federal Government states that 
controls should generally be designed to assure that ongoing 
monitoring occurs in the course of normal operations. This may include 
regular management and supervisory activities, comparisons, 
reconciliations, and other actions to ensure compliance with 
applicable laws and regulations. FEMA established its Mapping 
Information Platform (MIP) to manage the mapping production process, 
and the system includes data fields for each of the public 
notification requirements, but the agency does not use the information 
in the MIP to document compliance. Mapping partners have used the MIP 
to document four of the six public notification requirements (related 
to publications in the local newspaper for preliminary maps and the 
Federal Register for preliminary and final maps). However FEMA 
management does not have access to the two data fields in the MIP 
related to requirements to notify the community's CEO of the proposed 
flood elevation determination and of the final flood elevation 
determination. FEMA officials said that these two fields could be made 
accessible so that all six public notification requirements could be 
documented by mapping partners in the MIP. FEMA officials said that 
they do not use the MIP to document compliance with public 
notification requirements because the FEDD folder is the official 
record maintained for that purpose. A mechanism to monitor compliance 
with public notification documentation regulations and statutes could 
help FEMA obtain reasonable assurance that its contractors are 
complying with documentation requirements, which can help FEMA ensure 
that the public is being notified as required. 

FEMA Could Better Assess the Effectiveness of Its Outreach Efforts: 

FEMA is collecting some data on the quantity and nature of appeals to 
the mapping studies, but the agency is not capturing data on all 
appeals and protests in a manner that could be used to inform its 
decisions about where to focus outreach efforts. Before flood maps 
that result in a change in base flood elevation become effective, 
regulations require that FEMA hold a 90-day appeals period. Appeals 
and protests can be submitted by state and local officials or by 
individual members of the public. Appeals challenge the proposed base 
flood elevation based on technical or scientific inaccuracy, while all 
other challenges to the flood maps are treated as protests. State and 
local officials are responsible for collecting and reviewing all 
individual appeals and protests and forwarding them to FEMA. An 
official may also submit an appeal on behalf of the local government 
itself. Figure 8 below provides an overview of the flood mapping 
process and where the appeals period occurs in the process. 

Figure 8: Overview of Outreach Steps in the Flood Mapping Process: 

[Refer to PDF for image: illustration] 

(A) Local Needs Identified: 1-6 months; Multi-Year flood hazard 
identification; Scoping. 

(B) Data Development Period: 12-24 months; Engineering & Mapping data: 
Topographic, Hydrology, Hydraulics; Preliminary maps; Community 
review: 30-day period. 

1-2 weeks prior to 1st newspaper publication, publish BFEs on web. 1st 
newspaper publication 7-10 days prior to start of appeal period. 2nd 
newspaper publication; marks beginning of 90-day appeal period. 

(C) Regulatory Adoption Period: 6-9 months; Appeal; 
Map adoption. 

(D) Map maintenance. 

Sources: GAO analysis of FEMA data and Art Explosion clipart. 

[End of figure] 

FEMA divides appeals into two groups--eligible and ineligible. FEMA 
defines eligible appeals as appeals from communities or individuals 
which are based on knowledge or information indicating that the 
elevations proposed by FEMA are scientifically or technically 
inaccurate and that contain supporting documentation. To qualify as 
eligible appeals, requests must also be submitted to FEMA within the 
90-day appeal period. FEMA defines ineligible appeals as appeals that 
do not meet these requirements--for example, if an appeal is based on 
something other than the scientific or technical accuracy of the 
elevations, or does not include supporting documentation. 

During our analysis of the MIP, we found that FEMA does not broadly 
capture information on the appeals and protest that can be used to 
analyze trends nationally. For example, FEMA does not use the MIP to 
track ineligible appeals or protests from local communities or 
individuals, even though these appeals and protests may reflect state 
and local officials' or the public's disagreement with a flood map. 
Rather, when FEMA receives ineligible appeals or protests, it combines 
the data in the MIP with comments that are received from state and 
local officials prior to the end of the appeal period. FEMA then 
labels all of the ineligible appeals, protests, and comments as 
protests, even though ineligible appeals data could serve as an 
indicator of the public's acceptance of, or resistance to, flood maps. 
FEMA officials stated that they do not comprehensively collect and 
analyze data on appeals and protests, as FEMA uses information in the 
MIP for project-by-project supervision of flood map studies, rather 
than as a strategic management tool to analyze trends. Also, FEMA has 
not yet considered the costs and benefits of such analyses. We have 
previously reported that in order to monitor progress, performance 
data should be gathered to determine how well performance goals are 
being achieved.[Footnote 47] While we recognize there is a cost 
associated with collecting and analyzing all data on appeals and 
protests, should FEMA determine that the benefits outweigh the costs, 
taking such action could help FEMA evaluate the extent to which public 
acceptance is being achieved and better target outreach activities to 
more resistant communities. 

In addition, FEMA has not established guidance for how to collect and 
review appeals and protests, nor has it established guidance on how to 
report appeals and protests data in the MIP. Instead, flood community 
officials are directed to collect the appeals and protest data, review 
them, and decide which ones to submit to FEMA. Once FEMA receives the 
appeals and protests, it reviews them to determine whether they are 
eligible. If any issues arise or if additional supporting data is 
needed, FEMA will work with community officials, mapping contractors, 
or other mapping partners to acquire it. FEMA resolves appeals using 
the documentation originally submitted or it will consider additional 
data or supporting information if supplied generally within 30 days. 

However, in the absence of guidance on a standardized process, state 
and local officials may collect and review appeals and protests in 
different manners from one another, or from FEMA, and FEMA officials 
stated that they do not know what process any one contractor used to 
make its decisions about which appeals and protests to refer to FEMA. 
For example, in the case of Hillsborough County, Florida, county 
officials stated that they received over 1,000 appeals and protests. 
The county hired a contractor to review the appeals and protests the 
county received; the contractor consolidated them into approximately 
400 appeals and protests, and responded to the remainder at the local 
level, according to the contractor. After the contractor's review and 
recommendation, the county submitted approximately 150 appeals and 
protests to FEMA for review and disposition. FEMA officials then 
aggregated these appeals and protests to input into the MIP, according 
to FEMA officials. MIP records indicate that Hillsborough County, 
Florida, has 60 appeals and protests from this study. Thus, more than 
1,000 appeals and protests were condensed to a fraction of that total, 
and FEMA has no way of knowing what criteria its contractor used when 
making decisions about which appeals and protests it submitted to 
FEMA. FEMA officials acknowledged that they have not established a 
standardized process for contractors on how to enter appeals and 
protest data. 

In 2009, FEMA identified appeals and disputes arising from the study 
and mapping process as a concern of mapping partners, and requested 
the Association of State Floodplain Managers to review FEMA's mapping 
processes to identify ways of improving the quality and effectiveness 
of FEMA's communications with state and local officials prior to and 
during the floodplain study and mapping process. This study is still 
ongoing and is expected to be completed by the end of year 2010. 
[Footnote 48] Standards for Internal Control in the Federal Government 
provides that agencies to establish policies and procedures, 
techniques and mechanisms to enforce management's directives. 
Providing guidance to standardize the process mapping partners use to 
make decisions about which appeals and protests to submit to FEMA 
could help the agency better ensure it has complete information on 
appeals and protests in each community. 

FEMA Has Not Identified Performance Goals or Developed Measures to 
Evaluate Its Efforts to Increase Public Acceptance of Flood Maps: 

FEMA has not identified performance goals for public acceptance of 
flood maps and has not developed measures to evaluate the extent to 
which it would achieve these goals. FEMA's Risk MAP National Outreach 
Strategy includes objectives for achieving 5 percent increases in the 
publics' and local officials' awareness and understanding of flood 
risk and future vulnerability to flooding by fiscal year 2011. 
However, this strategy does not include a performance goal and 
performance measures for the public's acceptance of flood maps. While 
we recognize that developing measures to gauge public acceptance of 
flood maps is not easy, it is possible to develop indicators of public 
resistance to flood maps. For example, the volume of appeals and 
protests of a particular mapping study could be an indicator of public 
resistance to flood maps. Thus, FEMA could develop a performance goal 
related to increasing public acceptance of flood maps and could use 
ineligible appeals as an indicator of the public's resistance of flood 
maps, which could serve as a performance measure for this goal. For 
example, assuming that a certain percentage of individuals will be 
opposed to a map if it requires them to purchase flood insurance, FEMA 
could determine an expected rate of ineligible appeals and use this as 
a baseline measure. 

Our past work on the experience of leading organizations has 
demonstrated that the principles of establishing measurable goals and 
related measures, developing strategies for achieving results, and 
identifying the resources that will be required to achieve the goals 
are the basic underpinning for performance-based management--a means 
to strengthen program performance.[Footnote 49] FEMA officials stated 
that they have considered developing performance goals and measures 
related to public acceptance of maps, but have not taken any action to 
date. According to FEMA officials, the agency does not currently 
collect information on outreach activities because it is not within 
the scope of the Risk MAP Quality Assurance Management Plan. While 
this plan identifies quality standards and metrics for outreach as 
potential future scope, it does not identify in what years such 
outreach metrics are to be addressed. Developing performance goals and 
measures for public acceptance of flood maps could help FEMA better 
determine whether its outreach efforts are achieving their intended 
results. 

FEMA Has Not Determined What Resources Are Needed for Outreach and Has 
Not Established Risk-Based Mapping Priorities for Outreach Activities: 

FEMA has not determined the financial or human resources that are 
necessary to conduct flood mapping outreach efforts. FEMA officials, 
and the state and local officials we spoke with in all four mapping 
project we reviewed said that they devote most of their resources to 
map production. As a result, outreach activities that could lead to 
increased map acceptance may be under-resourced because map accuracy 
is a higher priority for FEMA and its mapping partners. For example, 
FEMA does not have a line-item in its budget for flood mapping 
outreach, and agency officials said that outreach staffing costs are 
paid out of general NFIP funds, and are not individually tracked. In 
addition, FEMA is unable to analyze outreach spending within the CTP 
program as a whole. However, while FEMA is able to track total state 
and local contributions under their CTP contracts,[Footnote 50] FEMA 
is unable to specifically track the amount of funding going toward 
outreach versus other mapping activities, according to FEMA officials. 

FEMA's Risk MAP strategy states as one of its goals to improve the 
utilization of resources, but the agency cannot determine this if it 
does not track the resources it is devoting to its various activities. 
Furthermore, a key purpose of the Government Performance and Results 
Act[Footnote 51] is to create closer and clearer links between the 
process of allocating scarce resources and the expected results to be 
achieved with those resources.[Footnote 52] FEMA officials stated that 
annual budgeting for its flood mapping activities is allocated across 
FEMA regions based on the regions' level of mapping activities and by 
FEMA's risk based strategy, and it is up to each region to identify 
the outreach personnel and resources needed within their regional 
mapping budgets. However, FEMA officials could not provide us with 
budget or expenditure information on outreach activities at FEMA 
regions because FEMA has not established a reporting structure with 
which the regions can provide that information to it. 

In addition, while FEMA has developed its Risk MAP outreach strategy, 
it has not developed a risk-based approach for conducting outreach 
activities for flood mapping that could enable it to target resources 
effectively. In 2004, as part of Map Modernization, FEMA established 
risk-based mapping priorities by ranking all 3,146 counties from 
highest to lowest for risk of flooding based on a number of factors, 
including population, growth trends, housing units, flood insurance 
policies and claims, repetitive loss properties, and flood disasters. 
FEMA has not incorporated these risk-based priorities into its Risk 
MAP outreach strategy. FEMA officials stated that risk class is 
considered in an effort to anticipate possible outreach needs on a 
case-by-case basis. According to FEMA officials, certain issues will 
trigger a greater emphasis on outreach efforts. For example, as result 
of an increased focus on protection provided by levees since 2005, 
some communities--historically protected by levees--are now considered 
to be Special Flood Hazard Areas and subject to mandatory purchase of 
flood insurance.[Footnote 53] While FEMA's approach considers these 
issues on a case-by-case basis, its response to events is reactive to 
these events and does not enable FEMA to systematically plan and 
budget its resources more efficiently and effectively. We reported in 
December 2005, that risk management is a widely endorsed strategy for 
helping policymakers make decisions about allocating finite resources. 
[Footnote 54] By providing a reporting structure for regions to 
identify and justify their outreach resource needs, FEMA could better 
plan for and report on specific outreach activities for flood mapping 
on a regional or national level. Likewise, by using risk in its 
decisions regarding the allocation of outreach resources--for example, 
by considering the number of high risk counties or the number of 
mapping projects under way in a particular region--FEMA could ensure 
that its resources for flood mapping outreach efforts are allocated in 
the most effective manner. 

FEMA Does Not Leverage FloodSmart Marketing Resources to Enhance Its 
Outreach Efforts: 

FEMA does not leverage its existing resources by using NFIP FloodSmart 
marketing resources to enhance its flood mapping outreach efforts. 
FEMA has three divisions in its Mitigation Directorate that share 
roles and responsibilities in conducting outreach: the Risk Analysis 
Division, the Risk Insurance Division, and the Risk Reduction 
Division. The Risk Insurance Division is responsible for a marketing 
effort called FloodSmart. According to FEMA, FloodSmart is a national 
integrated marketing campaign that utilizes mail, television, 
internet, and print media as marketing tools to promote the purchase 
of flood insurance policies. 

One mechanism FloodSmart uses to help market flood insurance is 
through direct mail to the public. According to FEMA officials, to 
support insurance agents in talking to their clients about flood 
insurance, FloodSmart provides insurance agents access to a Mail-On-
Demand program through a Web site. The Mail-On-Demand program includes 
a direct mail template that informs property owners about proposed map 
changes in their community and how those changes may affect their 
flood insurance needs. The Mail-On-Demand program allows insurance 
agents to access a list of potential flood insurance purchasers. In 
addition, this Web site contains a schedule that shows the preliminary 
date, appeals dates, Letter of Final Determination date, and effective 
dates for communities undergoing a mapping study. 

FEMA FloodSmart officials said they also had developed two "toolkits" 
of media materials that FloodSmart employees may provide to state and 
local officials, insurance agents, and other stakeholders. One of the 
toolkits is designed to provide information on the mapping process, 
and the second toolkit provides information on levee safety and 
certification and the effect of levees on FEMA flood maps. FEMA 
Floodsmart officials said these media kits include general templates 
of informational materials that can be customized for specific areas 
and used to communicate the importance of flood insurance surrounding 
map and levee changes to communities where the flood risk designation 
has changed as a result of an assessment or flood mapping efforts. 
According to FEMA officials, they created the map change toolkit 
materials in partnership with Hillsborough County, Florida, and the 
levee toolkit was developed in conjunction with the Sacramento Flood 
Control Agency. They said they share the toolkits at industry and 
stakeholder conferences, mail them out in response to specific 
requests, and post the materials on FloodSmart.gov. FEMA's FloodSmart 
marketing efforts are initiated at the request of a FEMA region. 
FloodSmart team members said that, in those instances, they typically 
do not send out direct mailers regarding the importance of flood 
insurance until right before maps become effective. FEMA officials 
stated that the Risk MAP program's outreach strategy is promoting 
greater coordination and regular meetings between FEMA's FloodSmart 
team, flood mapping staff, and FEMA staff responsible for floodplain 
management. 

FloodSmart marketing efforts could be used by FEMA in the process to 
help promote community awareness, education, and acceptance of flood 
maps. We have previously reported that collaborative efforts are 
enhanced when agencies identify and address needs by leveraging 
resources to support a common outcome.[Footnote 55] In this case, 
FEMA's Risk Analysis Division and its Risk Insurance Division could 
enhance their collaboration by applying this practice. Given that 
FloodSmart already has efforts under way to help to educate the public 
on the potential flood risk in communities and to encourage them to 
take action, these efforts could be targeted toward educating the 
public about, and encouraging public acceptance of FEMA's flood 
mapping efforts. While FEMA officials stated that the Risk MAP 
outreach strategy is promoting greater coordination with FEMA's 
FloodSmart team, FEMA could enhance its flood mapping outreach efforts 
by leveraging FloodSmart's marketing resources and expertise to 
increase public acceptance of flood maps. 

Conclusions: 

The results of the flood mapping process on individual property owners 
subject to resulting flood insurance requirements can be significant. 
To effectively implement FEMA's 5-year Risk MAP program goal of 
improving the accuracy of flood maps, FEMA will need to continue to 
improve its data standards and its management processes. Since federal 
law requires FEMA to assess the need to revise and update the nation's 
flood maps at least every 5 years, determining how best to use mapping 
resources will be crucial. Establishing separate measures of 
compliance for detailed and approximate studies could allow FEMA to 
better use FBS compliance rates as a measure of map accuracy; however, 
the data necessary to accomplish this are presently not maintained by 
the agency. By retaining and analyzing metadata, FEMA could report 
additional information on FBS compliance and, thereby, have a 
potentially better measure of map accuracy. Further, FEMA's NVUE 
standard provides a basis for flood mapping partners to assess the 
quality of new, validated, or updated engineering data in revising 
maps; however, establishing uniform guidance for the validation of 
existing data could help FEMA ensure mapping partners are consistently 
validating data. This step could help FEMA both track and report the 
accuracy of maps at the national and regional levels and better assess 
mapping data needs. In addition, FEMA's IV&V process helps ensure that 
mapping efforts are performed in accordance with minimum data quality 
standards, procedures, and requirements. However, implementing 
probability sampling during the IV&V auditing process, to the extent 
that the benefits outweigh the costs, would ensure that the results 
are generalizable and could help FEMA management use the information 
more strategically. Likewise, to maintain the independence, both in 
appearance and fact, of FEMA's verification and validation function, 
this auditing function should be performed by an entity that is 
technically, managerially, and financially independent of the 
organization in charge of what is being assessed. And finally, in the 
absence of systematic data reporting, FEMA's ability to establish a 
corrective action plan to resolve issues identified through the IV&V 
process, one of the key requirements of its quality assurance 
management program, is greatly diminished. 

Regarding outreach, FEMA has taken positive actions regarding its 
innovative use of new media to enhance its outreach efforts. However, 
there are areas in which FEMA could enhance its outreach efforts. For 
example, without a mechanism to monitor mapping contractors' 
compliance with public notification documentation requirements, FEMA 
is limited in its ability to provide reasonable assurance that the 
agency is notifying the public as required. Opportunities also exist 
for FEMA to better utilize data on community appeals and protests to 
inform its decisions about where to focus outreach efforts, and 
provide guidance to standardize the process by which mapping partners 
analyze appeals and protests data to the extent that the benefits 
outweigh the costs. Moreover, without specific performance goals and 
measures to assess the effectiveness of outreach efforts related to 
flood mapping, it may be difficult for FEMA to determine whether its 
outreach efforts are achieving their intended results. Further, by 
providing a reporting structure for regions to identify and justify 
their outreach resource needs, FEMA could better plan for and report 
on specific outreach activities for flood mapping on a regional or 
national level. Likewise, by using risk in its decisions regarding the 
allocation of outreach resources--for example, by considering the 
number of high risk counties or the number of mapping projects under 
way in a particular region--FEMA could ensure that its resources for 
flood mapping outreach efforts are allocated in the most effective 
manner. Finally, FEMA has the opportunity to leverage existing 
resources by broadening the scope of the FloodSmart program that 
supports the NFIP to help promote public acceptance of flood maps. 

Recommendations for Executive Action: 

We are making 11 overall recommendations. 

To address challenges in ensuring the accuracy of flood maps, we 
recommend that the Administrator of the Federal Emergency Management 
Agency: 

* establish separate measures and collect data needed to assess 
compliance with the Floodplain Boundary Standard for detailed and 
approximate flood studies, and: 

* establish uniform guidance for the validation of existing 
engineering data to help FEMA fully implement the NVUE standard and 
provide a basis for mapping partners to validate flood hazard data. 

To enhance the independent verification and validation (IV&V) audit 
process, we recommend the Administrator of the Federal Emergency 
Management Agency: 

* implement probability sampling during the IV&V audit process to the 
extent that the benefits outweigh the costs, to ensure that the 
results are generalizable for decisionmaking; and: 

* transfer IV&V duties back to an independent entity to help ensure 
impartiality; and: 

* adopt a systematic approach to IV&V data collection, so FEMA can 
better track map quality issues, more easily analyze the data, and 
adopt a corrective action plan. 

To address challenges in improving community outreach, we recommend 
that the Administrator of the Federal Emergency Management Agency: 

* establish a mechanism to better ensure compliance with the 
documentation requirements of public notification regulations; 

* collect and analyze data on appeals and protests, including those on 
ineligible appeals, to the extent that the benefits outweigh the costs; 

* issue guidance to mapping stakeholders to standardize the process 
for analyzing appeals and protests and submitting this data to FEMA; 

* establish performance goals and measures for promoting public 
acceptance of flood maps; 

* develop a reporting structure for regions to use to identify 
resources needed to conduct flood mapping outreach activities, and 
implement a risk-based approach to allocate outreach resources; and: 

* leverage, as appropriate, existing FloodSmart marketing resources 
and expertise to help increase public acceptance of flood maps. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS for review and comment. DHS 
provided written comments, which are reprinted in appendix IV. DHS 
also provided us with technical comments, which we considered and 
incorporated as appropriate. We also provided a draft of this report 
to the U.S. Army Corps of Engineers, but it did not provide written 
comments on the report. However, in an email on November 3, 2010, the 
Corps of Engineers liaison indicated that the Corps had no comments on 
the report. 

In commenting on the draft report, DHS stated that it concurred with 
10 of the 11 recommendations. For the recommendations for which DHS 
concurred, the agency identified actions taken or plans to implement 
them. Specifically, FEMA agreed with our recommendation to establish 
tracking and reporting that will allow FEMA to report the level of 
precision by flood source. FEMA plans to implement this tracking as 
part of the Coordinated Needs Management System that will be fully 
implemented this fiscal year. FEMA agreed with our recommendation and 
will finalize and issue uniform guidance for the validation of 
existing engineering data under its New, Validated, or Updated 
Engineering (NVUE) standard in this fiscal year. FEMA also agreed to 
assess the additional costs and expected benefits to expand the scope 
of the IV&V, and to implement probability sampling and will work with 
the contractor performing audits to redesign the reporting of map 
quality issues. FEMA stated it will issue guidance to address our 
recommendations to ensure compliance with the documentation 
requirements and to standardize the process for submitting appeals and 
protests data to FEMA in order to improve the collection and analysis 
of this information. FEMA also stated it will explore potential new 
measures and look for ways to quantify and track outreach activities 
that are integrated into map production activities. In addition, FEMA 
also concurred with our recommendation to leverage existing FloodSmart 
marketing resources, stating that FEMA's flood mapping program is 
working with its FloodSmart program as part of the Risk MAP program to 
identify areas where outreach effectiveness can be increased and 
consistent messages can be delivered. These actions should address our 
recommendations and help FEMA improve its efforts to ensure flood map 
accuracy and enhance the agency's outreach efforts in developing and 
implementing new flood maps. 

DHS did not concur with our fourth recommendation that the 
Administrator of the Federal Emergency Management Agency should 
transfer independent verification and validation duties (IV&V) back to 
an independent entity to help ensure impartiality. The department's 
response stated that FEMA's Program Manager contractor is technically, 
managerially, and financially independent of the flood hazard 
development process and that the contractor is helping FEMA to 
integrate the program, monitor program performance, and implement a 
quality management process. FEMA believes that the quality audit 
function is more effective if it is integrated into the overall 
quality management process rather than performed externally to the 
quality management process. However, as we noted in the report, 
according to industry best practices, the verification and validation 
activity should be independent of the project and report directly to 
senior management to provide added assurance that reported results on 
the project's status are unbiased. As FEMA states, its flood mapping 
Program Manager contractor is an integral part of FEMA's flood mapping 
program management, and as such we continue to believe that the 
program management contractor's programmatic responsibilities and 
involvement prevent it from having a clearly independent role in 
validating and verifying the results of flood map production 
activities, because the contractor has a vested interest in overall 
program performance. Therefore, we believe that FEMA should transfer 
independent verification and validation duties back to an independent 
entity to help ensure impartiality. 

We are providing copies of this report to interested congressional 
committees, the FEMA Administrator, the Secretary of Homeland Security 
and other interested parties. This report will also be available at no 
charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-8757 or by e-mail at jenkinswo@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report are listed in appendix V. 

Signed by: 

William O. Jenkins, Jr. 
Director: 
Homeland Security & Justice Issues: 

[End of section] 

Appendix I: Objective, Scope, and Methodology: 

This report addresses the following objectives: 

* To what extent has FEMA taken actions to enhance the accuracy of 
flood maps and what challenges, if any, does FEMA face? 

* To what extent has FEMA taken actions to help promote community 
acceptance of flood maps, and what challenges, if any, does FEMA face? 

We focused our review on those standards and processes related to 
flood hazard mapping for rivers and streams (commonly know as 
"riverine" flooding[Footnote 56]), as these account for about 95 
percent of FEMA's flood maps. As a result, we limited our scope to 
exclude those standards and processes related to flood hazard mapping 
for coastal areas and the levee certification. In addition, FEMA has 
processes to modify and update flood map information during the time 
that a community's maps are in effect, called a Letter of Map Change, 
which is also outside the scope of our work. 

To evaluate the extent that FEMA has taken actions to ensure data 
quality standards are consistently met for flood maps updated since 
2005 and to what extent has FEMA measured whether implementation of 
the data quality standards results in accurate flood maps, we analyzed 
information on FEMA's policies and plans for flood map modernization 
and data from FEMA's Mapping Information Platform (MIP) and systems 
for documenting compliance with data quality standards. Specifically, 
we reviewed documents including FEMA's Risk Mapping, Assessment and 
Planning (Risk MAP) strategy, the Risk Map Multi Year Plan, and Map 
Modernization Guidelines and Specifications for Flood Hazard Mapping 
Partners and its associate appendices. We assessed FEMA's standards 
and guidance to criteria developed in recent reports by the National 
Academies of Sciences and the National Research Council, specifically 
the Academies' report "Mapping the Zone: Improving Flood Map Accuracy. 
[Footnote 57] We discussed the reports' methodologies with the authors 
and with relevant FEMA officials, and analyzed reviews and critiques 
of the Academies' reports to determine that they were appropriate for 
our purposes. We tested the controls on the quality assurance/quality 
control (QA/QC) process by extracting and reviewing data on all 
projects initiated and completed for the period of October 2005 
(corresponding to FEMA's Mid-Course Adjustment to its Map 
Modernization Initiative) through 2009. We also reviewed FEMA's 
Floodplain Boundary Standard (FBS) and New, Validated, or Updated 
Engineering (NVUE) verification systems that were designed to track 
implementation of data accuracy requirements. We tested the controls 
on the FBS and NVUE compliance process by extracting and reviewing 
data on all projects initiated and completed from fiscal year 2006 
(when the FBS was established) through 2009 and compared them against 
criteria in Standards for Internal Control in the Federal Government. 
[Footnote 58] To assess the reliability of these databases, we 
compared data to FEMA's management reports, interviewed FEMA's three 
mapping contractors and reviewed the original data generated by these 
contractors. We determined that the FBS and NVUE compliance data were 
sufficiently reliable for the purposes of this report. We also 
compared FEMA's QA/QC process to effective practices we have 
identified for quality assurance.[Footnote 59] Finally, we discussed 
FEMA's mapping process and standards with agency officials, as well as 
officials from other federal stakeholders including the U.S. 
Geological Survey, the National Oceanic and Atmospheric 
Administration, the U.S. Army Corps of Engineers; national 
organizations including the Association of State Floodplain Managers, 
and National Association of Flood & Stormwater Management Agencies. We 
also discussed FEMA's mapping process and standards with agency 
officials, as well as officials from other federal stakeholders in 
geographic data collection and mapping including the U.S. Geological 
Survey, the National Oceanic and Atmospheric Administration, the U.S. 
Army Corps of Engineers and the National States Geographic Information 
Council; subject-matter experts on flood hazards and floodplain 
management from national organizations including the Association of 
State Floodplain Managers, and National Association of Flood & 
Stormwater Management Agencies who are stakeholders to FEMA's mapping 
initiatives, as well as state and local officials involved in mapping 
projects we selected in Arizona, Florida, California, and North 
Carolina (a discussion of the selection process is included below). 

To assess the extent to which FEMA has taken actions to help promote 
community acceptance, and ensured that regulatory requirements for 
documenting public notification efforts are consistently met for flood 
maps updated since 2005 we analyzed information on FEMA's policies and 
plans for community outreach and data from FEMA's Mapping Information 
Platform and systems for documenting compliance with statutory and 
regulatory requirements for coordination with state and local 
officials involved in mapping projects. Specifically, we reviewed 
FEMA's previous Outreach Strategy for Map Modernization and its new 
Risk MAP National Outreach Strategy, and analyzed the goals and 
performance measures of FEMA's outreach strategy for Map 
Modernization, and its new Risk MAP national outreach strategy against 
our prior work reviewing federal agencies' practices for development 
of national strategies compared it to effective practices we have 
identified for national strategies,[Footnote 60] as well as review 
FEMA's budget and staff allocations related to outreach. To assess 
FEMA's internal controls and program management of community outreach 
efforts, we examined several FEMA databases, including the Mapping 
Information Platform (MIP), discussed above, designed to document 
state and local mapping stakeholder information. As noted above, we 
tested the controls on the MIP by extracting and reviewing data on all 
projects initiated and completed from 2005 through 2009 and assessed 
the reliability of these databases by checking them against documents, 
such as FEMA's management reports and Flood Elevation Determination 
Dockets (FEDD) that are established for each mapping project. We also 
interviewed FEMA, state, and local officials involved in flood map 
outreach to obtain their perspectives. For our review of FEMA's 
compliance with public notification documentation requirements, we 
examined FEMA's Flood Elevation Determination Dockets (FEDD) that are 
established for each mapping project, selecting a probability sample 
of 88 counties from a population of 431 counties that had completed 
studies since 2005, that resulted in a change in base flood elevation. 
From this probability sample we reviewed mapping partners' 
documentation of compliance with six documentation requirements below: 

* notifying the community's CEO of the proposed flood elevation 
determination, 

* notifying the public of the proposed flood elevation determination 
via an initial newspaper publication, 

* notifying the public of the proposed flood elevation determination 
via a 2nd newspaper publication, 

* notifying the public of the proposed flood elevation determination 
via a notice in the Federal Register, 

* notifying the public of the final flood elevation determination via 
a notice in the Federal Register, and: 

* notifying the community's CEO of the final flood elevation 
determination. 

Because we followed a probability procedure based on random 
selections, our sample is only one of a large number of samples that 
we might have drawn. Since each sample could have provided different 
estimates, we express our confidence in the precision of our 
particular sample's results as a 95 percent confidence interval (e.g., 
plus or minus 9 percentage points). This is the interval that would 
contain the actual population value for 95 percent of the samples we 
could have drawn. Percentage estimates based on our sample of counties 
have 95 percent confidence intervals no wider than +/-9 percentage 
points. 

To supplement our analyses of FEMA's flood mapping internal controls 
and program management activities related to both data accuracy and 
community outreach, we selected four flood map modernization projects 
in Arizona, Florida, California, and North Carolina. We selected these 
locations based on our 2004 review to highlight specific challenges 
associated with the mapping process, such as inclusion of levees, and 
the impact of varying degrees of community involvement and outreach in 
the 5 years since our review. Because we selected a nonprobability 
sample of flood mapping projects, the results of the information 
collected from these localities cannot be generalized to all mapping 
projects but provided insights on the challenges experienced by these 
localities. 

We conducted this performance audit from August 2009 through December 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit perform the audit to 
obtain sufficient, appropriate evidence to provide a reasonable basis 
for our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Key Practices for Effective Communications to the General 
Public: 

In our discussion with localities, we identified a number of potential 
key practices that FEMA, state and local officials, and mapping 
partners identified as successful. These practices included getting 
the public involved early-on in the mapping process through task 
forces, holding open houses for the public to attend, and sending 
direct mailers to the public. For example, Charlotte-Mecklenburg 
County, North Carolina, has been recognized by county officials 
involved with flood mapping outreach and subject matter experts in 
flood mapping outreach as a leader in effectively using some of these 
key practices. While a variety of factors can influence map 
acceptance, Charlotte-Mecklenburg County officials reported zero 
appeals and protests as a result of their 2005 mapping effort, and 
North Carolina state officials reported very few appeals and protests 
as a result of their most recent studies, which suggests their 
outreach efforts may have been more successful than many other 
counties'. 

For example, Charlotte-Mecklenburg County, North Carolina, officials 
stated that utilizing a land use task force was vital to the public's 
acceptance of flood maps. To address the need for accurate current and 
future land use data, a land use task force is convened to represent 
the interests of the watershed. Task force members include homeowners' 
association leaders, realtors' association members, and other local 
leaders. The task force presents findings regarding the flood mapping 
to the community and engages local media to do a story. This process 
allows the county to gain vital support from the public and the county 
to say that the data used in the flood mapping is approved by the 
public. Furthermore, Charlotte-Mecklenburg county officials and state 
officials both said that early involvement from the public can make 
map acceptance easier later in the process. These officials stated 
that if the public is presented with the facts and the study's 
methodology early on, while it may be disgruntled when the maps are 
created, it will be more supportive. 

Another outreach technique that was used in 3 of the 4 locations we 
reviewed was the use of community "open houses" set up by local 
governments during the appeal period of the preliminary maps. The 
official community meetings that FEMA holds with state and local 
officials can be very formal and technical, so counties host separate 
open houses for the public to attend, according to officials we spoke 
to as part of our reviews of Charlotte-Mecklenburg, Hillsborough, and 
Maricopa counties. These open houses are designed to accommodate 
members of the public's different schedules and lets them drop-in at 
any time. A variety of kiosks with brochures and staff are available 
throughout the open house. The kiosks include mapping contractors and 
county engineers who can provide information on modeling and data used 
to create the flood map and insurance agents who can provide 
information on insurance rates and grandfathering. FEMA officials 
stated that they attempt to attend these open houses, but sometimes 
their travel budgets prevent them from attending. 

In addition, Charlotte-Mecklenburg county officials said that direct 
mailers are also key to community acceptance of flood maps. The county 
used targeted mailings to property-owners within the watershed that 
was being mapped. They used these direct mailings in order to make the 
public aware of the mapping study/project and to seek input. Charlotte-
Mecklenburg officials stated that the result of seeking input is a 
worthwhile effort because it helps gain public support. 

[End of section] 

Appendix III: Summary of Studies and Related Findings from 1997 
through 2009: 

Data Quality and Community Outreach Are Long-standing Issues: 

Data quality and community outreach are long-standing/inherent issues 
in FEMA's flood mapping program. There have been other reviews of 
flood map accuracy in the past: 

In 2004, we reviewed Flood Map Modernization[Footnote 61]. We reported: 

* Ensuring the accuracy and public acceptance of flood maps are 
fundamental challenges inherent in federal efforts to establish and 
maintain a national program. 

* In developing digital flood maps, FEMA planned to incorporate data 
that are of a level of specificity and accuracy commensurate with 
communities' relative flood risk--there is a direct relationship 
between the types, quantity, and detail of the data and analysis used 
to develop maps and the costs of obtaining and analyzing those data. 

* FEMA has developed partnerships with states and local entities for 
mapping activities. However, the overall effectiveness of FEMA's 
future partnering efforts was uncertain, especially in partnering with 
communities with less resources and little or no experience in flood 
mapping. 

In 2009, the National Academy of Sciences published Mapping the Zone: 
Improving Flood Map Accuracy,[Footnote 62] which reported that: 

"...the extent of potential floods must be predicted from statistical 
analyses and models; all of which have uncertainties that affect the 
accuracy of the resulting flood map. Other findings include: 

* The most appropriate flood study method to be used for a particular 
map depends on the accuracy of the topographic data and the overall 
flood risk, including flood probability, defined vulnerabilities, and 
consequences. 

* Flood maps with base flood elevations yield greater net benefits-- 
however, only the more expensive of FEMA's flood study methods-- 
detailed studies and most limited detailed studies--yield a base flood 
elevation." 

FEMA's 2001 food map progress report summarizes recommendations of the 
Technical Mapping Advisory Council (established by Congress in the 
National Flood Insurance Reform Act (NFIRA) of 1994 to provide 
recommendations to FEMA on how to improve the accuracy, quality, 
distribution, and use of Flood Insurance Rate Maps. Table 2 below 
summarizes the findings and recommendations FEMA's flood mapping 
program identified by these studies. 

Table 2: Historical Data Quality Issues and Recommendations in FEMA's 
Flood-Mapping Efforts: 

1997 Technical Mapping Advisory Council[A]: Base Maps. Improve base 
maps and review and update existing standards, in consultation with 
the Federal Geographic Data Committee. Ensure strict adherence to the 
Federal Geographic Data Committee's standards; 
1998 Technical Mapping Advisory Council: 1. Map Availability and 
Accuracy. Implement programmatic changes to improve accuracy, 
reliability, and availability of digital and graphic map data. 
2. Minimum Base Map Standards. Revise and ensure adherence to minimum 
base map standards, consistent with Federal Geographic Data Committee 
standards; 
GAO 2004[B]: Develop and implement data standards that will enable 
FEMA, its contractor, and its state and local partners to identify and 
use consistent data collection and analysis methods for communities 
with similar risk; 
OIG 2005[C]: Develop guidelines to help ensure compliance with FEMA's 
minimum standard for producing accurate and reliable flood insurance 
rate maps; 
National Academies of Sciences (National Research Council) 2007: 
Within the limits of the available elevation data, the updated 
floodplain maps are adequate for this purpose. The nation's land 
surface elevation data need to be modernized and mapped more 
accurately to properly support FEMA Map Modernization and the nation's 
flood-mapping and management needs. This report recommends a new 
national digital elevation data collection is required. The committee 
proposes that this program be called Elevation for the Nation; 
National Academies of Sciences (National Research Council) 2009[D]: 
The extent of potential floods must be predicted from statistical 
analyses and models; all of which have uncertainties that affect the 
accuracy of the resulting flood map. Other findings include: 
* The most appropriate flood study method to be used for a particular 
map depends on the accuracy of the topographic data and the overall 
flood risk, including flood probability, defined vulnerabilities, and 
consequences; 
* Flood maps with base flood elevations yield greater net benefits-- 
however, only the more expensive of FEMA's flood study methods-- 
detailed studies and most limited detailed studies--yield a base flood 
elevation. 

Source: GAO. 

[A] The Technical Mapping Advisory Council was established by Congress 
in the National Flood Insurance Reform Act (NFIRA) of 1994 to provide 
recommendations to FEMA on how to improve the accuracy, quality, 
distribution, and use of Flood Insurance Rate Maps (FIRMs). 

[B] GAO, Flood Map Modernization: Program Strategy Shows Promise, but 
Challenges Remain, GAO-04-417 (Washington, D.C.: Mar. 31, 2004). 

[C] Department of Homeland Security Office of the Inspector General, 
Challenges in FEMA's Flood Map Modernization Program, OIG-05-44 
(Washington, D.C., September 2005). 

[D] National Research Council (U.S.). 2007. Elevation Data for 
Floodplain Mapping. Washington, D.C.: National Academies Press. 
http://books.nap.edu/catalog.php?record_id=11829 August 2007. 

[E] National Research Council (U.S.), and United States. 2009: Mapping 
the Zone: Improving Flood Map Accuracy. Washington, D.C.: National 
Academies Press. http://www.nap.edu/catalog.php?record_id=12573 May 
2009. 

[End of table] 

Appendix IV: Comments from the Department of Homeland Security: 

Department or Homeland Security: 
Washington, DC 20525: 

November 4, 2010: 

William 0. Jenkins Jr. 
Director, Homeland Security and Justice: 
441 G Street, NW: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Jenkins: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office (GAO) draft report GAO-11-17, entitled, "FEMA 
Flood Maps Some Standards and Processes in Place to Promote Map 
Accuracy and Outreach, But Opportunities Exist to Address 
Implementation Challenges." 

The Department of Homeland Security appreciates the opportunity to 
highlight current efforts that will not only comply with the 
recommendations, but will also improve our overall operational 
effectiveness. The recommendations and corrective actions to address 
the recommendations are described below. 

Recommendation 1: Establish separate measures and collect data needed 
to assess compliance with the Floodplain Boundary Standard for 
detailed and approximate flood studies. 

Response: Concur. FEMA agrees with this recommendation to establish 
tracking and reporting that will allow FEMA to report the level of 
precision by flood source. FEMA plans to implement this tracking as 
part of the Coordinated Needs Management System (CNMS) that will be 
fully implemented this fiscal year. The CNMS system will provide 
significantly improved national tracking and reporting on the flood 
hazard data inventory. 

Flooding sources with new and updated flood hazards must comply with 
the floodplain boundary standard and CNMS will track the study method 
for each flooding source. 

Recommendation 2: Establish uniform guidance for the validation of 
existing engineering data to help FEMA fully implement the New. 
Validated, or Updated Engineering (NVUE) standard and provide a basis 
for mapping partners to validate flood hazard data. 

Response: Concur. FEMA will finalize and issue guidance for validation 
and implement a full validation assessment of the flood map inventory 
this fiscal year. 

Recommendation 3: Implement probability sampling during the 
independent verification and validation (IV&V) audit process to the 
extent that the benefits outweigh the costs, to ensure that the 
results are generalizable for decision-making. 

Response: Concur. FEMA's current quality management process is 
designed to yield acceptable quality level based on current standards. 
FEMA will assess the additional costs to expand the scope of the IV&V 
compared to the expected benefits. 

Recommendation 4: Transfer independent verification and validation 
duties back to an independent entity to help ensure impartiality. 

Response: Non-concur. The Program Manager (PM) contractor is 
technically, managerially and financially independent of the flood 
hazard development process. The PM contractor is helping FEMA to 
integrate the program, monitor program performance, and implement a 
quality management process. FEMA believes that the quality audit 
function is more effective if it is integrated into the overall 
quality management process rather than performed externally to the 
quality management process. 

Recommendation 5: Adopt a systematic approach to IV&V data collection, 
so FEMA can better track map quality issues, more easily analyze the 
data, and adopt a corrective action plan. 

Response: Concur. FEMA will work with the contractor performing audits 
to redesign the reporting of map quality issues. 

Recommendation 6: Establish a mechanism to ensure compliance with the 
documentation requirements of public notification regulations. 

Response: Concur. FEMA will issue a procedure memorandum to reinforce 
the existing contract requirements to compile and archive this data. 
FEMA will also transition to fully digital storage of this data on the 
Mapping Information Platform (MIP) and incorporate a review of the 
required deliverables into the quality management process. 

Recommendation 7: Collect and analyze data on appeals and protests, 
including those on ineligible appeals, to the extent that the benefits 
outweigh the costs. 

Response: Concur. FEMA will issue guidance consistent with 
recommendation 8 (below), and implement changes to the current 
tracking systems to implement this recommendation. 

Recommendation 8: Issue guidance to mapping stakeholders to 
standardize the process for analyzing appeals and protests and 
submitting this data to FEMA. 

Response: Concur. FEMA will issue guidance to support the 
implementation of recommendation 7 (above). 

Recommendation 9: Establish performance goals and measures for 
promoting public acceptance of flood maps. 

Response: Concur. FEMA currently measures the community adoption rates 
for maps, which partially addresses acceptance, but has struggled to 
identify an effective measure for acceptance. FEMA will explore 
potential new measures, including the GAO's suggestion that measuring 
appeals and protests might effectively measure public acceptance. 

Recommendation 10: Develop a reporting structure for regions to use to 
identify resources needed to conduct flood mapping outreach 
activities, and implement a risk-based approach to allocate outreach 
resources. 

Response: Concur. A key component of the FEMA Risk Mapping, 
Assessment, and Planning (MAP) program is that it formalizes several 
outreach activities and products as part of a new standard project 
work flow. These new elements provide the structure to plan, track and 
report specific contract costs associated with flood mapping outreach. 
FEMA will make revisions to the MIP workflow to update and track new 
Risk MAP products and project level outreach and community engagements 
for earned value and other program management requirements. 

Additionally, FEMA will explore ways to analyze and allocate staff 
outreach resources based on risk. FEMA will also look for ways to 
quantify and track outreach activities that are integrated into map 
production activities that have historically been difficult to 
separate from production costs. 

FEMA will define a process for allocating resources to Risk MAP 
outreach based project risk, as well. FEMA anticipates that the risk 
factors for outreach may differ from the risk factors used to allocate 
engineering resources. 

Recommendation 11: Leverage, as appropriate, existing FloodSmart 
marketing resources and expertise to help increase public acceptance 
of flood maps. 

Response: Concur. As part of Risk MAP, the flood mapping program is 
actively engaged with FloodSmart to identify areas where their 
experience and work to date could increase our outreach effectiveness 
and deliver consistent messages across FEMA programs. 

Thank you for the opportunity to comment on this Draft Report. We look 
forward to working with you on future Homeland Security issues. 

Sincerely, 

Signed by: 

Jerald E. Levine: 
Director: 
Departmental Audit Liaison Office: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

William O. Jenkins Jr., (202) 512-8757 or jenkinswo@gao.gov. 

Staff Acknowledgments: 

In addition to the contact named above, Chris Keisling (Assistant 
Director), John Vocino (Analyst-in-Charge), Anthony Mercaldo, Justine 
Lazaro, Jamie Berryhill, C. Patrick Washington, Linda Miller, David 
Alexander, John Smale Jr, Jerome Sandau, Mark Ramage, Christine Davis, 
and Tracey King made key contributions to this report. 

[End of section] 

Footnotes: 

[1] According to FEMA, 20 to 25 percent of flood claims are to 
communities and properties outside of a “Special Flood Hazard Area” 
(SFHA), which are those areas that have an estimated 1 percent annual 
chance of flooding. 

[2] GAO’s High-Risk Series identifies federal programs and operations 
that, in some cases, are high risk due to their greater 
vulnerabilities to fraud, waste, abuse, and mismanagement. GAO, High-
Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-07-310] (Washington, D.C.: January 
2007). 

3] Pub. L. No. 111-83, 123 Stat. 2142, 2163 (2009); Pub. L. No. 110-
329, 122 Stat. 3574, 3675 (2008). 

[4] 42 U.S.C. § 4101(e). 

[5] For the purpose of this report, we will use the terms flood maps 
to describe FEMA’s flood insurance map products such as Flood 
Insurance Rate Maps (FIRM), Digital Flood Insurance Rate Maps (DFIRM), 
accompanying Flood Insurance Study and other supporting technical data. 

[6] Federal Emergency Management Agency, Risk Mapping, Assessment and 
Planning (Risk MAP): National Digital Elevation Acquisition and 
Utilization Plan for Floodplain Mapping (Aug. 9, 2010). 

[7] GAO, Flood Map Modernization: Program Strategy Shows Promise, but 
Challenges Remain, [hyperlink, http://www.gao.gov/products/GAO-04-417] 
(Washington, D.C.: Mar. 31, 2004). 

[8] The Technical Mapping Advisory Council was established by the 
National Flood Insurance Reform Act of 1994 to provide recommendations 
to FEMA on how to improve the accuracy, quality, distribution, 
dissemination, and ease of use of Flood Insurance Rate Maps, among 
other things. Pub. L. No. 103-325, §576, 108 Stat. 2255, 2280 (1994). 
The Council was created in November 1995 and it continued through 
November 2000. The Council submitted recommendations to the Director 
of FEMA in each of its Annual Reports. 

[9] Department of Homeland Security Office of the Inspector General, 
Challenges in FEMA’s Flood Map Modernization Program, OIG-05-44 
(Washington, D.C.: September 2005). 

[10] National Research Council (U.S.), and United States. 2009 Mapping 
the Zone: Improving Flood Map Accuracy. Washington, D.C.: National 
Academies Press. [hyperlink, 
http://www.nap.edu/catalog.php?record_id=12573] May 2009; National 
Research Council (U.S.). 2007. Elevation Data for Floodplain Mapping. 
Washington, D.C.: National Academies Press. [hyperlink, 
http://books.nap.edu/catalog.php?record_id=11829] August 2007. 

[11] FEMA created the Mapping Information Platform in 2004, to enable 
the management, production, and sharing of flood hazard data and maps 
and related information in a digital environment. In March 2006, FEMA 
developed a Mid-Course Adjustment to its Map Modernization Initiative. 

[12] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[13] Riverine flooding is flooding related to or caused by a river, 
stream, or tributary overflowing its banks due to excessive rainfall, 
snowmelt, or ice. 

[14] The maximum margin of error for estimates of percentages from our 
sample of flood mapping projects is plus or minus 9 percentage points 
at the 95 percent level of statistical confidence. 

[15] FEMA’s requirement to maintain a flood elevation determination 
docket (FEDD) is found at 44 C.F.R. § 67.3. 

[16] See GAO Combating Terrorism: Evaluation of Selected 
Characteristics in National Strategies Related to Terrorism, 
[hyperlink, http://www.gao.gov/products/GAO-04-408T] (Washington, 
D.C., Feb. 3, 2004), and GAO Financial Literacy and Education 
Commission: Further Progress Needed to Ensure an Effective National 
Strategy, [hyperlink, http://www.gao.gov/products/GAO-07-100] 
(Washington, D.C., Dec. 4, 2006). 

[17] Pub. L. No. 90-448, tit. XIII, 82 Stat. 572 (1968). 

[18] Also included are Puerto Rico and the Virgin Islands. 

[19] FEMA’s Risk Reduction Division performs floodplain management 
activities to reduce risk to life and property through the use of land 
use controls, building practices and other tools, in both pre- and 
post-disaster environments. FEMA’s Risk Insurance Division provides 
flood insurance for property owners and encourages communities to 
adopt and enforces floodplain management regulations that mitigate the 
effects of flooding on new and improved structures. 

[20] [hyperlink, http://www.gao.gov/products/GAO-04-417]. 

[21] According to FEMA officials, the term "field survey" within FEMA 
usually means actual survey measurements made by a crew on the ground, 
and the term "field reconnaissance" is usually used within FEMA to 
distinguish site visits to get an overall understanding of the area to 
be studied and collect information other than survey measurements. In 
addition, topographic data is mostly produced by aerial surveys, 
although certain key features are often measured by field survey 
because the aerial survey technology may not produce accurate results 
in some situations. 

[22] A Flood Insurance Study (FIS) is a book that contains information 
regarding flooding in a community and is developed in conjunction with 
the flood insurance rate map. The FIS, also known as a flood elevation 
study, frequently contains a narrative of the flood history of a 
community and discusses the engineering methods used to develop the 
maps. The study also contains flood profiles for studied flooding 
sources and can be used to determine Base Flood Elevations for some 
areas. 

[23] FEMA is required to contact community stakeholders, such as the 
state coordinating agency and other appropriate community officials, 
to discuss the intent and nature of the proposed flood map study. 44 
C.F.R. § 66.5. 

[24] FEMA is required to publish the proposed flood elevations in a 
prominent local newspaper at least twice during the 10-day period 
following the notification of the community chief executive officer. 
Property owners have 90 days from the second newspaper publication to 
appeal the proposed flood elevations. 44 C.F.R. §§ 67.4, 67.5. 

[25] Final flood elevations must be published in the Federal Register 
and copies sent to the community chief executive officer, all 
individual appellants, and the state-coordinating agency. 44 C.F.R. § 
67.11. 

[26] 44 C.F.R. §§ 66.3, 67.3. 

[27] Federal law provides that FEMA must encourage local officials to 
disseminate information concerning a flood mapping study widely within 
the community, so that interested persons will have an opportunity to 
bring all relevant facts and technical data concerning the local flood 
hazard to the attention of the agency during the course of the study. 
42 U.S.C. § 4107. 

[28] According to FEMA officials, production of these 2008 projects 
under Map Modernization continued through 2010, and some of these 
projects were still in progress at the time of our review. 

[29] The total number of stream miles includes approximately 4.2 
million miles of channels (waterways and rivers) and 600,000 miles of 
coastline shorelines (open ocean, lakes, and ponds) in the United 
States, according to the National Research Council, Committee on 
Floodplain Mapping Technologies. 

[30] GAO, Best Practices: Commercial Quality Assurance Practices Offer 
Improvements for DOD, [hyperlink, 
http://www.gao.gov/products/NSIAD-96-162] (Washington, D.C.: Aug. 26, 
1996). 

[31] The National Elevation Dataset is the primary elevation data 
product of the U.S. Geological Service that contains the best 
available elevation data of the United States. According to the 
Service, the data set is updated on a two month cycle to integrate any 
newly available, improved elevation source data that are processed to 
a common coordinate system and unit of vertical measure. 

[32] The limited circumstances under which FEMA would historically 
provide funding for topographic data are detailed in FEMA’s Geospatial 
Data Coordination Implementation Guide (v2.2), (March 2008) p. 68. 
Generally, FEMA only provides funding when existing elevation data are 
inadequate, i.e., do not meet the minimum accuracy required in FEMA 
flood mapping standards. 

[33] Flood insurance purchase is mandatory for all federally backed 
mortgages for properties in special flood hazard areas. 

[34] For approximate studies, FEMA may include a BFE, but it not 
considered a regulatory standard. 

[35] See GAO Tax Administration: IRS Needs to Further Refine Its Tax 
Filing Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22, 
2002). GAO reported on nine key attributes of successful performance 
measures. Linkage is defined as measure that is aligned with division 
and agencywide goals and mission and clearly communicated throughout 
the organization. Clarity is defined as a measure that is clearly 
stated and the name and definition are consistent with the methodology 
used to calculate it. 

[36] Metadata is a concept that applies mainly to electronically 
archived data and is used to describe the definition, structure, and 
administration of data files with all contents in context to ease the 
use of the captured and archived data for further use. 

[37] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[38] Federal Emergency Management Agency, Risk Mapping, Assessment and 
Planning (Risk MAP): National Digital Elevation Acquisition and 
Utilization Plan for Floodplain Mapping, (Washington, D.C.: Aug. 9, 
2010). 

[39] Apptis, IV&V Audit Report (April 2010). 

[40] GAO, Financial Management Systems: DHS Faces Challenges to 
Successfully Consolidating its Existing Disparate Systems, [hyperlink, 
http://www.gao.gov/products/GAO-10-210T] (Washington, D.C.: Oct. 29, 
2009). 

[41] GAO, [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[42] GAO, Firearms Trafficking: U.S. Efforts to Combat Arms 
Trafficking to Mexico Face Planning and Coordination Challenges, 
[hyperlink, http://www.gao.gov/products/GAO-09-709] (Washington, D.C.: 
June 18, 2009). 

[43] USA.gov introduces Web 2.0 and social media as umbrella terms 
that define the various activities that integrate technology, social 
interaction, and content creation. USA.gov cites FEMA as an example of 
an agency that is using online content and technology to achieve its 
mission and goals. 

[44] 44 C.F.R. § 67.3. 

[45] The maximum margin of error for estimates of percentages from our 
sample counties is plus or minus 9 percentage points at the 95 percent 
level of statistical confidence. 

[46] 44 C.F.R. § 67.5. 

[47] GAO, 2010 Census: Cost and Design Issues Need to Be Addressed 
Soon, [hyperlink, http://www.gao.gov/products/GAO-04-37] (Washington, 
D.C.: Jan. 15, 2004). 

[48] In addition to contracting with ASFPM to review appeals process, 
FEMA officials said that, beginning in November 2010, they planned to 
implement an additional process for appeals resolution. Specifically, 
FEMA has created an independent Scientific Resolution Panel that can 
be convened when deemed necessary by FEMA or by a joint agreement 
between FEMA and an appellant. The Scientific Resolution Panel is to 
review and resolve conflicting data related to proposed BFEs as 
provided for in the National Flood Insurance Act, as amended. 

[49] For example, see GAO, Managing for Results: Enhancing Agency Use 
of Performance Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: Sept. 9, 
2005); GAO, Program Evaluation: Studies Helped Agencies Measure or 
Explain Program Performance, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-00-204] (Washington, D.C.: Sept. 
29, 2000); GAO, Agency Performance Plans: Examples of Practices That 
Can Improve Usefulness to Decisionmakers, [hyperlink, 
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.: 
Feb. 26, 1999); and GAO, Managing for Results: Strengthening 
Regulatory Agencies’ Performance Management Practices, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-00-10] (Washington, D.C.: Oct. 28, 
1999). 

[50] According to the CTP program guidance, if a CTP has agreed to 
perform outreach activities, FEMA may match funds from CTPs for 
outreach activities up to 10 percent. 

[51] Pub. L. No. 103-62, 107 Stat. 285 (1993). 

[52] GAO, Performance Budgeting: OMB's Performance Rating Tool 
Presents Opportunities and Challenges For Evaluating Program 
Performance, [hyperlink, http://www.gao.gov/products/GAO-04-550T] 
(Washington, D.C.: Mar. 11, 2004). 

[53] In 2011, we plan to respond to a congressional mandate to review 
FEMA’s management of national levee systems. 

[54] GAO, Risk Management: Further Refinements Needed to Assess Risks 
and Prioritize Protective Measures at Ports and Other Critical 
Infrastructure, [hyperlink, http://www.gao.gov/products/GAO-06-91] 
(Washington, D.C.: Dec. 15, 2006). 

[55] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[56] Riverine flooding is flooding related to or caused by a river, 
stream, or tributary overflowing its banks due to excessive rainfall, 
snowmelt or ice. 

[57] National Research Council (U.S.), and United States. 2009. 
Mapping the Zone: Improving Flood Map Accuracy. Washington, D.C.: 
National Academies Press. [hyperlink, 
http://www.nap.edu/catalog.php?record_id=12573] May 2009. 

[58] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[59] GAO, Best Practices: Commercial Quality Assurance Practices Offer 
Improvements for DOD, [hyperlink, 
http://www.gao.gov/products/NSIAD-96-162] (Washington, D.C.: Aug. 26, 
1996). 

[60] See GAO, Combating Terrorism: Evaluation of Selected 
Characteristics in National Strategies Related to Terrorism, 
[hyperlink, http://www.gao.gov/products/GAO-04-408T] (Washington, 
D.C.: Feb. 3, 2004), and GAO, Financial Literacy and Education 
Commission: Further Progress Needed to Ensure an Effective National 
Strategy, [hyperlink, http://www.gao.gov/products/GAO-07-100] 
(Washington, D.C.: Dec. 4, 2006). 

[61] [hyperlink, http://www.gao.gov/products/GAO-04-417]. 

[62] GAO, Flood Map Modernization: Program Strategy Shows Promise, but 
Challenges Remain, [hyperlink, http://www.gao.gov/products/GAO-04-417] 
(Washington, D.C., Mar. 31, 2004). 

[63] National Research Council (U.S.), and United States. 2009. 
Mapping the Zone: Improving Flood Map Accuracy. Washington, D.C.: 
National Academies Press. [hyperlink, 
http://www.nap.edu/catalog.php?record_id=12573] May 2009. 

[64] Federal Emergency Management Agency, Modernizing FEMA’s Flood 
Hazard Mapping Program: A Progress Report (May 2001). 

[End of section] 

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