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· The federal manuals should be expanded to include nonstructural flood loss reduction techniques and ecosystem restoration and thereby foster their use by all engineers, planners, and biologists, Review of Risk-based Analysis Engineers have long used the concept of freeboard to account for uncertainty in design. But freeboard is being eliminated under the Corps of Engineers' recently adopted risk-based design approach, which determines a design size optimized by project benefits. This means that a Corps of Engineers structure estimated to provide I % chance flood protection would be missing the three feet of freeboard now added to most designs. The project economics may dictate a structure larger or smaller than a 1% chance standard, but considering that many proposed federal projects are not justified today because the costs exceed the benefits, a reduction in cost (by choosing a structure that provides lower protection) would lead to construction of more projects, · A multi-agency review and an independent scientific assessment of risk-based design should be undertaken to consider, among other questions, whether this technique leads to a proliferation of smaller levees, thus increasing exposure for catastrophic flood losses. The risk-based method tends to move away from the concept of designing to a minimum standard, With its use, the potential exists for the erosion of the minimum standard of I % chance flood protection. A cornmittee was assembled by the National Research Council's Water Science and Technology Board in late 1998 to conduct an 18-month review of the Corps' use of risk-based analysis, · Guidelines reaff1I1lling confonnance with a minimum design standard should be explicit in the design method, PARTNERSHIPS AND INCENTIVES Flood damage is a direct consequence of floodplain investment actions, both public and private. Those who occupy and use the floodplain should be responsible for the consequences of their actions, The federal government is clearly responsible for federal activities that invade the floodplain, But the authority and responsibility for guiding and controlling other land use lies exclusively with non-federal entities. To the degree that state and local governments sanction unfettered floodplain development, including new construction of public facilities, they share responsibility for excessive flood damage. · The roles, responsibilities, and capabilities of the public, the various levels of government, and the private sector should be clarified and strengthened, Citizens, businesses, and local and state legislators need to better understand that the federal government will not always bail them out after a flood, They must bear their fair share of the risk. FEDERAL ROLE In its concern for the general welfare, the federal government has a proper interest in measures to hold flood damage to an economic minimum, It has a responsibility to discourage floodplain development that would impose a later burden upon federal taxpayers, that would benefit a few at the expense of others, or that would victimize unsuspecting citizens. It does not follow, however, that Association of State Floodplain Managers -27- National Flood Programs in Review 2000