1. Building Codes and Floodplain Management
FEMA Region III National Flood Insurance Program Essentials and Best Practices
Laura Ghorbi, PE, CFM
RAMPP
Photo source: FEMA file photo

2. Objectives Familiarize floodplain administrators with building codes
Familiarize building code officials with floodplain ordinances
Identify where building codes and floodplain ordinances overlap and where the gaps are
Discuss the different approaches to adopting floodplain management provisions
Understand where higher standards may exist and how to coordinate with the building code
Flood provisions are included in the building codes, and also in floodplain ordinances. Officials tend to stick to what they know (building code officials look to building code, FPAs look to floodplain ordinances) but coordination between the two is important.
Familiarize floodplain administrators with building codes
Familiarize building code officials with floodplain ordinances
Understand where codes and ordinances interact
Understand where higher standards may exist

3. Meeting NFIP Requirements
NFIP participating municipalities must adopt and enforce floodplain management regulations that meet the minimum requirements of the NFIP.
The regulations must:
Be legally enforceable
Applied uniformly throughout the community
Floodplain regulations are usually found in one of, or a combination of, five types of regulations: “stand alone”, zoning ordinances, building codes, subdivision regulations and sanitary regulations.
Before floodplain administrators and building code officials can successfully coordinate to reduce flood risk- they have to understand one another’s language. Therefore, we are going to start with a high level overview of the minimum floodplain management requirements for participation in the NFIP.
The NFIP definition of “floodplain management regulations” is broad (includes zoning ordinances, subdivision regulations, building codes, health regulations, special purpose ordinances (such as a flood plain ordinance, grading ordinance and erosion control ordinance) and other applications of police power. The term describes such state or local regulations, in any combination thereof, which provide standards for the purpose of flood damage prevention and reduction.)

4. Permits Required for Development
ALL development in the SFHA requires a permit
Definition of development (as per 44 CFR 59):
Any manmade change to improved or unimproved real estate, including, but not limited to buildings or other structures, mining, dredging, filling, grading, paving, excavation or drilling operations, or storage of equipment or materials
The definition of development as established by the NFIP is a very inclusive term, including any manmade change or improved or unimproved real estate. This definition of development extends beyond building construction.
IBC Appendix G - DEVELOPMENT. Any manmade change to improved or unimproved real estate, including but not limited to, buildings or other structures, temporary structures, temporary or permanent storage of materials, mining, dredging, filling, grading, paving, excavations, operations and other land-disturbing activities.
Poquoson, VA (from FEMA Region III)
Ensure you have a process for capturing all floodplain development

5. Highlights of NFIP Requirements
Set forth in 44 CFR Section 60.3
Site reasonably safe from flooding
Construct to minimize flood damage
Use flood damage-resistant materials
Foundation and elevation requirements
Design to prevent flotation, collapse, lateral movement during flooding
Design or locate equipment to prevent water entry
Substantial Improvement/Substantial Damage requirements
In general, communities participating in the NFIP must require permits for all new development in the SFHA; elevate the lowest floor of all residential development in the SFHA to or above the base flood elevation and elevate or floodproof the lowest floor of nonresidential buildings to that elevation; restrict development in the regulatory floodway; ensure that construction materials and methods used will minimize future flood damage; and treat substantially improved structures as new buildings that must meet the minimum NFIP standards.

6. Flood Damage-Resistant Materials
Required below the BFE
Withstand prolonged contact with floodwaters
FEMA guidance in Technical Bulletin 2
All construction below the BFE is susceptible to flooding and must consist of flood damage-resistant building materials.
“Flood [damage]-resistant material” is defined by the NFIP as “any building product [material, component or system] capable of withstanding direct and prolonged contact with floodwaters without sustaining significant damage.” The term “prolonged contact” means at least 72 hours, and the term “significant damage” means any damage requiring more than cosmetic repair. “Cosmetic repair” includes cleaning, sanitizing, and resurfacing (e.g., sanding, repair of joints, repainting) of the material. The cost of cosmetic repair should also be less than the cost of replacement of affected materials and systems. In addition to these requirements, individual materials that are considered flood damage-resistant must not cause degradation of adjacent materials or the systems of which the material is a part.
Floodwater is assumed to be considered “black” water; black water contains pollutants such as sewage, chemicals, heavy metals, or other toxic substances that are potentially hazardous to humans.
Image source: FEMA file photo

7. Foundation Requirements
A Zones
Slab-on-fill
Fully-enclosed foundation wall (flood openings required)
Open foundation on piers, posts, pilings, or columns
V Zones
Open foundation on columns or pilings
Designed by a registered design professional
All foundation types are allowed in Zone A, provided that they meet the performance requirements of the NFIP. Zone V buildings must have open foundations on pilings or columns, due to the high velocity wave forces. Water must be able to pass through the foundation.
Image source:
FEMA Quick Reference Guide: Comparison of Select NFIP & Building Code Requirements

8. Elevation Requirements
Elevation to or above the BFE is required in all flood zones. The reference point for Zone A is top of lowest floor, reference point for Zone V is bottom of lowest horizontal structural member. These are minimums and FEMA encourages higher elevations.
Floodproofing is an alternative for Zone A non-residential, will talk about that in a few slides.
A Zones:
top of lowest floor
to or above BFE
V Zones: bottom of lowest horizontal structural member to or above BFE
FEMA Region III, Poquoson, VA
FEMA Region III, Tinicum, PA

9. Elevate and Anchor Requirement
Structures and utilities must be anchored to resist the effects of flotation, collapse, and lateral movement
Foundation
NFIP requires that structures be designed (or modified) and adequately anchored to prevent flotation, collapse, or lateral movement of the structure resulting from hydrodynamic and hydrostatic loads, including the effects of buoyancy.
Appropriate foundation, proper anchoring, elevation or floodproofing help accomplish this. A continuous load path (shown in figure) helps transfer loads into the ground.
Lateral movement
Image source: FEMA file photo

10. Enclosures Below BFE A Zones V Zones
Limited to parking, building access, and limited storage
At least two openings no more than 1 foot above grade
One square inch of opening for each square foot of enclosed space
Engineered openings required certification
Limited to parking, building access, and limited storage
Space must be free of obstruction, or
Breakaway walls, open lattice, or louvers
Yardley Borough, PEMA
It is critical that flood waters be able to enter and exit. This is a requirement of the NFIP.
Zone A
Restricted to parking, building access, and storage
Minimum of two flood openings required
Flood openings no more than 1 foot above grade
Net area of 1 sq. in. for every sq. ft. enclosed or engineered
Zone V
Free of obstruction or
Breakaway walls, open lattice, or louvers
Compliant openings

11. Dry Floodproofing Requirements
Permitted only for non-residential structures in A Zone floodplains
Structure must be made watertight
To or above BFE (or BFE +1 foot for insurance purposes)
Requires certification by a registered design professional
Together with attendant utility and sanitary facilities, be designed so that below the base flood level the structure is watertight with walls substantially impermeable to the passage of water and with structural components having the capability of resisting hydrostatic and hydrodynamic loads and effects of buoyancy.
The figure above illustrates that floodproofing involves more than the building envelope—it also involves penetrations through the envelope and associated utility systems. Guidance on floodproofing utilities can be found in FEMA's Protecting Building Utilities from Flood Damage.
Image: Whole Building Design Guide, National Institute of Building Sciences

12. Substantial Improvement/Damage
Cost to restore or improve the structure equals or exceeds 50% of its market value
If damaged, use the pre-damage market value
Must be brought into full compliance
Compliance means meet ALL FLOOD requirements for new construction.
Substantial damage means damage of any origin sustained by a structure whereby the cost of restoring the structure to its before damaged condition would equal or exceed 50 percent of the market value of the structure before the damage occurred.
Substantial improvement means any reconstruction, rehabilitation, addition, or other improvement of a structure, the cost of which equals or exceeds 50 percent of the market value of the structure before the “start of construction” of the improvement. This term includes structures which have incurred “substantial damage”, regardless of the actual repair work performed. The term does not, however, include either:
(1) Any project for improvement of a structure to correct existing violations of state or local health, sanitary, or safety code specifications which have been identified by the local code enforcement official and which are the minimum necessary to assure safe living conditions or
(2) Any alteration of a “historic structure”, provided that the alteration will not preclude the structure's continued designation as a “historic structure”.
This applies to damage of any origin: it is not just flood damage. It can be a combination of wind, wildfire, earthquake, soil settlement, termites, vandalism, deterioration, etc.
Cost of Improvement or Cost to Repair to Pre-Damage Condition
≥ 50%
Market Value of Building
Middletown Borough, Dauphin County, PA (from PEMA)
Town of Bloomsburg, Columbia County, PA (from PEMA)

13. Non-Building Development
Storage of materials
Paving and grading
Placement of fill
Recreational vehicles and temporary structures
Alteration of watercourse
Must have same or greater capacity
Must maintain capacity over time
Remember the definition of the development in the NFIP is a broader term- including any manmade change to improved or unimproved property. As a result there are many activities beyond building of a structure that require permitting in the SFHA, including storage of materials, placement of accessory structures, paving/grading, placement of fill, alteration of a watercourse and recreational vehicle or temporary structure placement.
These non-building requirements are typically located in Appendix G of the IBC, which we will address.
only cover these subjects briefly
If a development permit application proposes a stream alteration, the local official must notify adjacent communities, the State Coordinating Agency for the NFIP, and provide a copy to the FEMA Regional Office. If an adverse impact is suspected, the neighboring community will be able to voice its concerns prior to any modification. Federal and State permits will usually be required for any alteration or relocation.
Alterations are often made to the channels of rivers, stream, or drainageways, usually to improve drainage, relocate the channel, or to increase its flood carrying capacity. There are two requirements for maintaining the flood carrying capacity of an altered watercourse. The altered or relocated watercourse must have the same or greater capacity as the original watercourse. Additionally, once the alteration is made, the capacity of the altered or relocated watercourse must be maintained over time.
Image source: SC Quick Guide for Mapping

14. NFIP Technical Bulletins
NFIP requirements are performance-based
11 Technical Bulletins provide prescriptive guidance for compliance
The NFIP tells you what to do, but not necessarily how to do it.
There is a series of Technical Bulletins that FEMA has produced to provide guidance concerning the building performance requirements of the NFIP. These requirements are contained in Title 44 of the U.S. Code of Federal Regulations at Section The bulletins are intended for use by State and local officials responsible for interpreting and enforcing the requirements in their floodplain management regulations and building codes, and by members of the development community, such as design professionals and builders. New bulletins, as well as updates of existing bulletins, are issued periodically, as necessary. The bulletins do not create regulations; rather, they provide specific guidance for complying with the requirements of existing NFIP regulations.

15. I-Codes and Floodplain Management Requirements
The flood provisions of the 2012 and 2009 I-Codes meet or exceed National Flood Insurance Program minimum requirements for buildings and structures.
I-Codes do not meet the minimum NFIP requirements for other development unless adopting:
In their entirety,
Appendix G of the IBC,
Chapter 1 (administration), AND
No limiting amendments
We are now going to switch gears to talk about the I Codes and where the NFIP minimum requirements are covered within the I codes.
Important consideration is that all of the requirements for other types of development (beyond the requirements for buildings and structures) live within the IBC Appendix G, which is not automatically adopted when a community adopts the I codes. Additionally, some of the administrative requirements require adoption of Chapter 1 of the I codes and a community cannot pass any limiting amendments. A community must be deliberate in the way they adopt the I codes if they intend to rely on the I codes to fulfill all of the minimum NFIP requirements.
Meet or exceed the NFIP requirements – meaning that all minimums in NFIP are covered (for buildings and structures) and there are no conflicts – only more specificity or higher standards.
For buildings and structures – not all development
Communities that participate in the NFIP adopt regulations and codes that govern development in special flood hazard areas, and enforce those requirements through the issuance of permits. The International Residential Code (IRC) and International Building Code (IBC), by reference to ASCE 24, include requirements that govern the design and construction of buildings and structures in flood hazard areas. FEMA has determined that the flood provisions of the I-Codes are consistent with the requirements of the NFIP (the I-Code requirements shown either meet or exceed NFIP requirements). ASCE 24, a design standard developed by the American Society of Civil Engineers, expands on the minimum NFIP requirements with more specificity, additional requirements, and some limitations.
Adopt IBC Appendix G, with mandatory enforcement. In these States, communities are required to enforce Appendix G. Most communities are likely to also have a “standalone” floodplain management ordinance that contains both requirements for buildings and requirements similar to those in Appendix G. NFIP State Coordinators need to determine how communities should resolve differences. One option is to encourage communities to adopt regulations that are similar to Model Ordinance BB, which is specifically written to coordinate with the I-Codes and Appendix G. This approach is likely to be most effective when floodplain management responsibilities are assigned to the community’s building department, although Appendix G may be modified to assign it to another department.
• Make IBC Appendix G available for adoption by communities. Some States do not mandate enforcement of Appendix G, but allow its adoption by communities. When communities have this option, they should examine Appendix G and Model Ordinance AA and Model Ordinance BB (Appendix XX) and determine which approach is most effective.
• Not adopt or make IBC Appendix G available. In these States, communities have no choice. Adopting local floodplain management regulations that contain the provisions in Appendix G results in consistency with the NFIP. Model Ordinance AA is specifically written for this purpose (see Appendix XX).
Model codes are “consensus” and are developed to establish minimum design and construction requirements. Similar to the development of laws, the ICC code development follows a governmental consensus process that includes open forums of debate and refinement.
The system ensures fairness in the process, controls against conflicts of interest, and prevents vested economic interests from determining the outcome of all code change proposals.
Buildings and structures are to resist anticipated forces that may lead to structural failure: dead loads, live loads, roof loads, flood loads, snow load, wind loads, and seismic loads.

16. Prescriptive vs. Performance
Prescriptive Code via IRC
Performance Code via IBC
The more prescriptive the code, the more engineering is behind the requirements – and the less individual design is required
Details the specifications for construction standards
Design professional only required where proposal is outside of the specifications of the code
Leave it to the designer and engineer to decide how to achieve that performance
Need a technical professional
References other prescriptive standards (like ASCE 24)
Prescriptive Code
Provides solutions that achieve a certain outcome
The more prescriptive the code, the more engineering is behind the requirements – and the less individual design is required
Design professional required for locations/sites or houses that don’t fit within the limitations of the prescriptive code (e.g., in V Zones)
Performance Code
Identifies and quantifies the level of performance and leaves it to the designer and engineer to decide how to achieve that performance
Creates a framework that both clearly defines the intent of the code and provides a process to understand quantitatively what the code is trying to achieve
IRC:
Detached 1-2 family dwellings and townhomes (3 stories or less)
Prescriptive
Flood provisions established in Sections 301 and 322
Administrative provisions in Chapter 1
IBC:
All buildings not covered by IRC
Performance-based
Flood provisions established in Section 1612
Administrative provisions in Chapter 1 and Appendix G
References ASCE 7 (flood loads) and ASCE 24 (flood-resistant design and construction)

17. IBC Appendix G - Flood-Resistant Construction
Addresses flood-related administrative requirements
The only place in the I-Code that addresses development other than buildings
G101 Administration
G102 Applicability
G103 Powers and Duties
G104 Permits
G105 Variances
G201 Definitions
G301 Subdivisions
G401 Site Improvement
G501 Manufactured Homes
G601 Recreational Vehicles
G701 Tanks
G801 Other Building Work
G901 Temp Structures & Temp Storage
G1001 Utility & Miscellaneous Group U
IBC Appendix G addresses flood-related administrative requirements and development other than buildings. Even if IBC is adopted, IBC Appendix G must be explicitly adopted separately (not automatic with IBC adoption).

18. American Society of Civil Engineers (ASCE) Publications
ASCE 7, Minimum Design Loads for Buildings and Other Structures
ASCE 24, Flood Resistant Design and Construction
Cited by IBC
Flood loads include:
Hydrostatic loads
Hydrodynamic loads
Wave loads
Impact loads (from debris and ice)
Cited by IBC and IRC
Specific limitations, minimum requirements, and performance standards for the design and construction of buildings and structures in flood hazard areas
Because the I Codes can be performance based, ASCE 7 and 24 are referenced in the IBC and the IRC (LIMWA and Zone V) to provide the prescriptive standards.
ASCE 24 is a reference standard that IBC refers to for flood resistant design and construction. IRC allows it as an alternative to the provisions in the IRC and requires it for residential buildings in the floodway.

19. Administrative Provisions
How are administrative provisions of the codes handled?
Many States modify or rewrite
Some States allow communities to write their own
Some States use a single chapter for all codes
Duties and powers of the building official
Granting modifications
Content of construction documents and plans
Inspections
Many States modify or rewrite the administrative provisions in the building code.
Some States allow communities to write their own administrative provisions to suit their community needs
Some States use a single chapter for all codes. Instead of having an administrative chapter in each code (residential, building, etc.)
The codes include administrative provisions related to flooding including:
Duties and powers of the building official
Granting modifications
Content of construction documents and plans
Inspections

20. Inspections
The Floodplain Administrator and the Building Code Official are both responsible for ensuring compliance and confirming as-built conditions
I-Codes call for at least:
Lowest floor or footer inspection to be conducted to allow for correction of possible violation prior to further vertical construction
Survey before final inspection
Final as-built inspection
NFIP:
Under the NFIP, communities are required to ensure that all new construction and Substantial Improvement of buildings meet or exceed the minimum floodplain management requirements of the NFIP. The most effective way to ensure compliance is to inspect the site frequently during construction. The NFIP regulations require communities to obtain and retain documentation of the elevations of new construction and Substantial Improvements.
I-Codes:
The I-Codes include sections that list a series of inspections, including “lowest floor inspections” (IBC) and “floodplain inspections” (IRC) upon placement of the lowest floor and prior to further vertical construction. At that time, the permittee is to submit elevation documentation. Unlike many aspects of a building under construction that can be checked visually, elevation above a datum is not readily verified. Obtaining the elevation information at this stage in construction allows both the builder and the local official to check that the lowest floor elevation is correct. It is easier and less expensive to catch an error during construction than to discover it when the as-built elevation certificate is completed. The 2012 I-Codes specify another inspection that requires another submission of elevation
documentation prior to the final inspection. The FEMA Elevation Certificate provides more than just the surveyed elevation of the lowest floor—it documents the elevation of the lowest equipment and information about openings in the walls of enclosures. Having the Elevation Certificate in hand before the final inspection helps the local official verify compliance with flood requirements.
ASCE 24:
ASCE 24 includes the technical provisions that apply to the design and construction of buildings and structures in flood hazard areas. Administrative functions of communities, such as the type and scheduling of inspections, are set in building codes or local regulations, not in design standards.

21. Any exemptions within I-Codes or State amendments are superseded by the NFIP minimum requirement to regulate all development in the SFHA.
There is a common misconception that exemptions in the building code or state amendments to the building code permit less restrictive development to occur within the SFHA. This is not true.
While development, such as recreational cabins, may be exempt from your building code standards, if this development is located within your SFHA it must still comply with the minimum NFIP requirements. NOTE for local officials: Read the language contained within any exemption in question directly and they will find in the fine print that the exemption doesn’t apply within the SFHA.
IBC and IRC R105.2 have list of specific activities that are exempt from a building permit (and some States add to the list).
Exemption does not authorize “any work to be done in any manner in violation of the provisions of the code or any other laws or ordinances.” [must still comply]
Examples:
I-Codes exempt recreational cabins from permit requirement
PA Exemptions that are commonly misunderstood –
- For 1- and 2-family dwellings do not require a permit if there are no changes to means of egress or structural change.
PA Act 16 – permit expiration act
Read the fine print on every amendment or exception, because these activities are actually not exempt from the permit requirement when in the SFHA
Allows enforcement if such activities are not consistent with the code.

22. BFE vs. DFE
Base Flood Elevation (BFE) and Design Flood Elevation (DFE)
DFE is always BFE or higher
In most communities, DFE = BFE
DFE is greater than BFE if a community regulates beyond the SFHA on the effective FIRM
DFE is NOT BFE + freeboard
Freeboard is typically included as an additional height above the BFE or DFE in lowest floor elevation requirements
EXPLAIN WHY IT IS NOT THE BFE + FREEBOARD
Base flood elevation – elevation of base flood (one percent annual chance)
Design flood elevation– allows a community with more current or more extensive flood hazard mapping to adopt it, but it must at a minimum be SFHA/BFE
The map clip is from NC where state negotiated with FEMA to put Zone X to reflect future SFHA on some FIRMs.

23. Coastal A Zone Delineated using LiMWA
Flood hazards can be much greater than in riverine Zone A:
Waves 1.5 to 3 feet high are capable of causing structural damage and erosion
Older FIRMs may fail to reflect changing site conditions as a result of long-term erosion
Higher Standard: IBC places Zone V requirements in the Coastal A Zone where delineated
Higher Standard: IRC requires 1 foot of freeboard in the Coastal A Zone where delineated
EXPLAIN WHY THIS IS IMPORTANT AND THE RISKS BUIDINGS IN COASTAL A ZONES FACE FROM WAVE ACTION, SCOUR, ETC. EXPLAIN HOW FEMA HAS INCLUDED THE LIMWA ON NEW MAPS AND HOW ADMINISTERING THE COASTAL A ZONE HAS BEEN MADE EASIER BY ITS INCLUSION. IN THE ABSENCE OF ITS DELINEATION ON THEIR MAP HOW DO THEY ADMINISTER THE PROVISION?
The NFIP regulations do not have provisions for Coastal A Zone (CAZ), but the I-Codes do (see map on right). The IBC, by reference to ASCE 24, requires CAZ buildings to be treated like Zone V buildings. The IRC permits the use of ASCE 24 in the CAZ as an alternative to its flood provisions, which allows CAZ buildings to be treated like Zone V buildings. Starting in 2008, revised and new coastal digital Flood Insurance Rate Maps (FIRMs) show the Limit of Moderate Wave Action (LiMWA), which delineates the landward limit of the CAZ.
Image source: FEMA P-55

24. Critical Facilities
Higher elevation requirements for critical and essential facilities, depending on occupancy and purpose of building
The i-codes treat certain categories of structures like critical facilities.
Category III and Category IV include facilities that FEMA and emergency managers consider to be “critical facilities.”
Category III structures represent a substantial hazard to human life in the event of failure; examples of buildings with specific occupancy loads (number of people) such as schools and healthcare facilities, and buildings such as water treatment facilities and waste water treatment facilities, that should be assigned this category; and
Category IV structures are essential facilities, which the code defines as “buildings and other structures that are intended to remain operational in the event of extreme environmental loading from flood, wind, snow or earthquake.” As with Category III, examples of buildings that should be assigned this category are provided, such as fire, rescue, ambulance and police stations.
Image source: FEMA file photo
Image source: stock photo

25. Local Officials Need to Know
What edition of the code was adopted and who is the agency?
How is the code adopted? (at the State level, etc.)
Are there amendments or modifications?
The regulations in the building codes and local floodplain management ordinance to meet or exceed the requirements of the NFIP
How to enforce all floodplain management requirements across all codes and ordinances
Most of the floodplain requirements for structures are ALREADY INCLUDED in the building codes that communities have adopted. Ensure that building code officials or anyone administering and enforcing the requirements are aware of this.
Local officials need to know:
What edition of the code was adopted?
How is the code adopted? (at the State level, etc.)
Are there amendments or modifications?
Do the building code requirements meet the NFIP?
How to coordinate building codes and local floodplain management regulations to meet or exceed the requirements of the NFIP
Make sure third-party code inspectors are following floodplain management ordinances
Third party codes inspectors 
NFIP minimums for buildings and structures exist in the building code
Make sure to share the community ordinance with the inspectors
Ultimately, the community is still responsible for meeting the requirements of the program. Make sure your third-party inspectors are aware of all building regulations.

26. State Building Code Adoption
Washington, D.C.
Department of Consumer and Regulatory Affairs
N/A
Delaware
No state-wide codes
Adopted at a local or county level
Maryland
Department of Housing and Community Development
State-wide code
Municipalities can adopt higher standards
Pennsylvania
Department of Labor and Industry
Virginia
Municipalities can adopt higher floodplain standards
West Virginia
Fire Commission, Office of State Fire Marshall
Include agency references
Must know how it works in each state – most important to know who to talk to and understand how it is adopted
State Building Code Approaches to Adoption and Enforcement
Adopt State code based on I-Codes and mandate local enforcement
Do not mandate enforcement, but specify code that local jurisdictions must adopt if they elect to adopt a code
Adopt and enforce State code only for certain buildings (State buildings, schools, hospitals, etc.)
Adopt only IRC or IBC
Allow local jurisdictions to decide whether to adopt, and which code to adopt
Here is a snapshot of how these various approaches to adoption and enforcement of the state building code are applied in Region III.
Many States that adopt the I-Codes at the State level do not allow local amendments. One of the primary justifications for a statewide building code is uniformity, and many States consider that rationale is weakened if communities are permitted to make amendments, even amendments that make the code more restrictive to address local conditions.
States that allow local amendments usually explicitly state that amendments may not weaken the code and usually require that local amendments be justified based on local conditions. Many specify that local amendments are to be reported to the State, and some States post local amendments online for ready access by the public. States handle local amendments in a number of ways; the most common are:
Prohibit amendments or modifications
Allow amendments or modifications only if they strengthen code
Allow any amendments or modifications (can weaken code)
Example: Virginia does not allow communities to amend the code. However, State statute specifies that the building code shall not supersede local floodplain regulations, thus allowing locally adopted higher standards. The statute and building code are clear that while farm buildings and structures do not require a building permit, they are still subject to local floodplain management regulations.

27. Adoption and Enforcement of the NFIP Minimum Requirements
Three main approaches to adoption and enforcement
Stand-alone ordinances
Companion or Wrap-around ordinances
I-Codes: in their entirety, with Appendix G of the IBC, Chapter 1, AND no limiting amendments
Adoption of the local floodplain ordinance requirements can also take a number of forms and it is important that local building officials and floodplain administrations understand where the requirements are found as well as the imp

28. Stand Alone Ordinances
Might be easier to administer and enforce
One ordinance contains all NFIP requirements for development standards
Developers and officials can easily see the requirements in one place
Ensure that all offices/agencies are aware of floodplain standards when inconsistent
May not be coordinated with other regulations or codes – regulations could be in conflict
This is the Region III recommended approach to adoption of floodplain management requirements.

29. Companion/Wrap-around Ordinance
Use the building code for design and construction of buildings and structures
Use a companion ordinance for administrative provisions:
Adoption of effective maps (and map revisions)
Floodway encroachment analyses
SI/SD determinations
Variances/modifications
Use a companion ordinance for development activities that are not regulated by the building code
At this point in time we are not aware of any community in Region III that has taken this approach.

30. I-Codes Only Must have both IBC and IRC, with flood provisions intact
Must capture existing buildings
Must retain administrative provisions (flood)
Must capture buildings exempt from the code
Must adopt Appendix G (administrative and development other than buildings)
Must understand where each NFIP requirement is met
Amendments must not weaken the code
At this point in time we are not aware of any community in Region III that has taken this approach.

31. Resolving Conflicts in Regulations
If the community has both floodplain management ordinances and the I-Codes in effect:
The more restrictive prevails
Understand which office is responsible for each requirement
Go through coordination process to identify differences and gaps
Decide how best to resolve those differences and eliminate the gaps (change code, change ordinance, rely on case-by-case application of “more restrictive prevails”)
Third party codes inspectors 
NFIP minimums for buildings and structures exist in the building code
Make sure to share the community ordinance with the inspectors
Ultimately, the community is still responsible for meeting the requirements of the program. Make sure your third-party inspectors are aware of all building regulations.

32. Flood Resistant Buildings and Development
NFIP Regulations (44 CFR Parts 59 & 60)
ASCE 7
ASCE 24
Building Code
Local Floodplain Management Regulations* or
IBC Appendix G*
Visual summary of how the various components we have discussed today relate helps to reinforce why coordination is critical as well as how all the pieces relate to one another.

33. Coordinating the I-Codes and NFIP
Worksheets to help ensure communities meet all NFIP requirements
Helps to identify what to capture in a companion ordinance
Crosswalks of I-Codes to NFIP regulations
Sample plan review and inspection checklists
FEMA publication “Reducing Flood Losses Through the International Codes” is a great resource to help communities coordinate their codes and ordinances to meet or exceed the NFIP, and includes:
Worksheets to help ensure communities meet all NFIP requirements
Helps to identify what to capture in a companion ordinance
Crosswalks of I-Codes to NFIP regulations
Sample plan review and inspection checklists
Currently being updated – 4th Edition coming in Summer 2014

34. Coordination Matters
The NFIP minimums regulate all development in the SFHA
Remember, nearly all of the NFIP minimum requirements for buildings and structures are ALREADY found in the building code
But, other forms of development may not be captured in the building code (for instance, placement of fill)
Higher standards likely exist in local floodplain management ordinances
Building Code Officials and Floodplain Administrators must work together on administration and enforcement
Uncoordinated enforcement results in non-compliance, higher insurance premiums, and increased risk to life and property.

35. Resources and Assistance
FEMA Building Science Homepage: science
Click on Building Code Resources
Flood Resistant Provisions of the 2012 and 2009 I-Codes
Highlights of ASCE 24-05, Flood Resistant Design and Construction
Provisions of the I-Codes and ASCE 24 Compared to the NFIP
I-Codes vs. NFIP checklists
Building Science Helpline: 1(866) or FEMA-
For further questions on the NFIP, contact your State Floodplain Manager
Here are some can you find resources and technical support.

36. FEMA Region III Contacts
- FEMA Region III Floodplain Management and Insurance Branch
Washington, D.C.
Phetmano Phannavong, P.E., CFM
Delaware
Michael Powell, CFM
Maryland
David Guignet, P.E., CFM
Pennsylvania
Daniel Fitzpatrick, CFM
Virginia
Charley Banks, CFM
West Virginia
Kevin Sneed, CFM