Here's our plan and breakdown of key lessons and considerations for developing a storm response plan, particularly drawing from the experiences of St. Pete Beach and Treasure Island:

1. Pre-Storm Planning & Preparation:

• Develop and Document Procedures: Communities should decide in advance how they will handle significant flood events, developing written procedures for making consistent Substantial Improvement/Substantial Damage (SI/SD) determinations. Consistency in applying these procedures is crucial, especially when many buildings are damaged.

• Resource Mechanisms: Establish resource mechanisms before a disaster to meet funding limits like the 180-day period for the DRRA 1206 program.

• Inter-agency coordination: Successful implementation of the DRRA 1206 policy requires close collaboration between federal, state, tribal, territorial, and local partners. Local officials should coordinate with the community staff member who typically works directly with the FEMA Program Delivery Manager (PDMG) or State Public Assistance official.

• Mutual Aid Agreements: Develop mutual aid agreements or other mechanisms to facilitate post-disaster support from other communities, state associations, or organizations.

• GIS for Tracking: Keep records in a format that allows plotting by a geographic information system (GIS) to easily document the status of each damaged building. This can include tracking inspections, permits, and substantial damage determinations.

• Review and Update Disaster Recovery Plans: Ensure that permitting requirements are clearly outlined in disaster recovery plans, specifically within the flood plain management section of city codes. Cities can amend these codes to proactively address potential issues.

2. Initial Response & Damage Assessment:

• Impact Surveys: Deploy code officers and building inspectors to perform impact surveys immediately after a storm.

• FEMA 1206 Mission: Submit a 1206 request mission through the County to the State for substantial damage inspections and flood plane reviews. Have someone regularly check on the status of the mission.

• Two Options for Compliance: Be aware of the two options for National Flood Insurance Program (NFIP) compliance: 1) proactively conduct substantial damage inspections or 2) wait for permit applications and then perform substantial damage estimates. Cape Coral opted to wait for permit submissions initially, which led to issues with FEMA.

• Initial Assessments: The initial assessments are not definitive, but are a way to identify properties that may be substantially damaged. A more detailed review of damage and costs will be required for a final determination.

• County Involvement: Work with the county for coordinated damage assessments.

• Data Collection: Gather data on damaged properties, including photos and high water marks, which can help with damage assessments.

3. Permitting Process & Substantial Damage Determinations:

• Permits for all repairs: Require permits for all repairs beyond temporary muck-out, roof tarping, or window blocking, even those that are minor. This is a point of conflict with community desires to repair homes quickly.

• Prioritize Repair Permits: Focus on issuing repair permits for specific project types rather than issuing all permit types at once.

• Electronic and Paper Permits: Be prepared for a high volume of permit applications both electronic and paper.

• Substantial Damage Documentation: When reviewing permits, ensure that substantial damage documentation, including invoices and estimates, is submitted.

• Total Cost of Repair: Look at the total cost of repair, not just the cost of the permit being issued.

• Include all costs: The cost of repairs for substantial damage determinations includes all work, volunteer labor, owner-builder work, donated materials, and invoices from contractors. Anything attached to the structure, such as painting and faucets, is included in the cost, while ancillary structures like sheds, seawalls, and docks are not.

• Consistent Methodology: Use a consistent methodology for calculating market value of repairs and labor. Consider resources like RS Means or online websites.

• Document all determinations: Clearly document how substantial damage determinations are made.

• Communicate with Residents: Ensure that residents are aware of the permitting requirements, the need to submit FEMA packets, and the substantial damage rules.

• Provide Clear Guidance: Clearly communicate to residents what is needed for permit applications, including sketches of floor plans, appraisal guidelines, and cost breakdowns.

• Offer Assistance: Set up special service centers or dedicated staff to assist residents with the permitting process.

• Address Conflicting Codes: Be prepared to address conflicting information and confusion arising from building codes vs. flood plain ordinances and the NFIP requirements.

• One or two options: Be aware of FEMA's two options for substantial damage determinations: (1) proactive inspections or (2) waiting for permit applications. Treasure Island initially used both and later decided to follow option 2.

4. Community Engagement & Communication:

• Designated Webpage: Create a designated webpage for all storm-related messaging.

• Consistent Messaging: Maintain consistent messaging throughout the city and county, aligning with FEMA requirements.

• Multiple Communication Channels: Use various communication channels like social media and videos to share information.

• One-on-One Meetings: Schedule time for one-on-one meetings with residents to discuss their individual situations, show empathy, and explain the process.

• Town Halls: Conduct town halls to provide information but avoid open mic sessions. Use QR codes or other methods for people to submit questions.

• Transparency: Be transparent about the processes and challenges in post-storm recovery.

• Communicate FEMA requirements: Explain to residents why certain requirements from FEMA are being enforced. This is often not what the community wants to hear, but is necessary for compliance.

• Address Concerns: Address concerns about the potential loss of NFIP participation and increased insurance rates that result from non-compliance with FEMA rules.

• Manage Expectations: Manage community expectations regarding the pace of recovery and the time required for permitting and inspections.

5. Addressing Specific Issues:

• 50% Rule: Be aware of the 50% rule, which states that if the cost of repairs exceeds 50% of the market value of the structure, the building must be brought into compliance with current flood regulations, which may include elevation.

• Look-back Periods: Be aware that look-back periods can affect the 50% rule. A longer look-back period can increase compliance points with the Community Rating System (CRS) but may also delay property owners from making improvements.

• Private Appraisals: Accept private appraisals that meet specific guidelines.

• FEMA Letter: Be aware of the FEMA wind loss mitigation letter available on the property appraiser's website.

• Pre-Storm Building Value Reconsideration: Utilize the opportunity for pre-storm building value reconsideration.

• Substantial Damage Action Plans: Prepare and submit a substantial damage action plan to FEMA.

• Non-Compliant Owners: Have a plan for dealing with property owners who refuse to comply with NFIP requirements, which may include moving to remove them from the program.

• Sanitary Sewer System: Have a plan for addressing storm surge and wind impacts on the sanitary sewer system. This can include bypass pump systems, backup generators, and measures to mitigate system overload from water flowing into toilets and showers.

• Debris Removal: Establish a debris management site and follow regulations for debris removal and disposal.

• Key Takeaways from Cape Coral: 1206 Program: The biggest failure for Cape Coral was their 1206 mission request that went unfulfilled. Requesting 1206 assistance can allow a community to have FEMA pay for substantial damage inspections early in the process.

• Proactive Inspections: FEMA prefers communities to proactively inspect every home for damage.

• Resource Needs: Performing damage inspections on a large scale is an enormous undertaking and requires substantial resources.

• FEMA Audits: Be prepared for extensive audits by FEMA, sometimes years after the storm.

• NFIP Compliance: Be aware of the consequences for not following FEMA rules, which include potential probation, increased insurance rates, and loss of NFIP eligibility.

• Holistic Approach: Consider a holistic approach to building a more resilient community that includes partnerships between local governments, the Department of Economic Commerce, the legislature, and the federal government.

By implementing these strategies, our city will better navigate the complexities of post-storm recovery, minimize disruption to our residents, and comply with federal requirements.