January 11, 2012 FAQ: Are all communities required to adopt Compensatory Storage requirements? Inundated floodplains provide refuge areas for juvenile salmon. The continued loss of flood storage to fill and development decreases access to these floodplains for juvenile salmon and lessens their probability for survival and fitness during floods. When providing compensatory storage designed for fish use, local governments can help preserve these fish species. The requirement in the Reasonable and Prudent Alternative is to “provide compensation for any effects to floodwater storage and fish habitat function within the 100-year floodplain.” Communities may avoid this requirement by prohibiting fill in the floodplain. Unless fill is prohibited in the floodplain, communities must provide compensatory storage for any loss in floodwater storage. Flood storage areas created for compensation must also be planted with native vegetation to allow good refugia during a flood event, and must not create fish stranding sites. Compensation sites must be within the same hydraulic reach as the fill/development. In “Door 3” communities, compensatory flood storage is required prior to the next flood season in order to avoid loss of storage and its corollary fish-refuge function. Door 2 jurisdictions may propose a restoration package(s) for those watersheds where other proposed actions would result in an incremental loss of floodplain storage over the short-term (1-3 years), but the net outcome of all actions would be required to demonstrate beneficial effects (see separate FAQ regarding Habitat Analysis at an Appropriate Scale). Compensatory Storage may not be required in some areas where fill will have a negligible effect on storage. An example would be coastal floodplains (where fill is generally prohibited for structural support 44CFR 60.3(e)(6))or a wide riverine delta where there is coastal influence. Filling areas behind a levee may also have a negligible effect on habitat function depending on the ability for fish to be present during a flood; however, the effects on functions other than flood storage will also need to be taken into account prior to issuance of any floodplain development/ fill permit. For more information on incorporating compensatory storage into your local ordinances please visit the following websites: CRS Credit for Higher Regulatory Standards, page 31 http://www.fema.gov/library/viewRecord.do?id=2411 ASFPM NAI Toolkit, page 21 http://www.floods.org/NoAdverseImpact/NAI_Toolkit_2003.pdf U.S. Department of Homeland Security Region X 130 228th Street SW Bothell, WA 98021-9796 www.fema.gov