Community Assistance Visit (CAV)
CAV is a visit to a community by a FEMA staff member(s) that serves the dual purpose of providing technical assistance to the community and assuring that the community is adequately enforcing its floodplain management regulations. The CAV consists of a tour of the floodplain, an inspection of the permit files, and meetings with local appointed and elected officials. If any administrative problems, violations or enforcement procedures are identified during a CAV the community will be placed on notice and be given the opportunity to correct those deficiencies within established deadlines. FEMA will work with the community and assist in establishing mechanisms to bring their program into compliance and in those cases where the community does not establish a plan and initiate action to bring itself into compliance or fail to meet the mandates outlined in the CAV report, FEMA will initiate enforcement action against the community that may result in the loss of Federal Disaster Funding for the community and could also lead to the loss of insurance for all township properties that have flood insurance. That would mean that residences who are required to have flood insurance per their mortgage could lose their mortgage and be forced into private mortgage markets with exceedingly high mortgage rates.
Londonderry Township was selected for a Community Assistance Visit (CAV) since it is classified as a Tier-1 Community on FEMA’s list of high risk communities having a higher risk of experiencing losses due to the concentrated development in the floodway of a Special Flood Hazard Area that currently exist throughout the Susquehanna River islands.
Many potential violations were identified during the course of the floodplain tour and the Township was directed to establish an action plan supported by a comprehensive compliance tracking spreadsheet that lists addresses and / or parcel level information with a description of potential violations and to proactively implement systematic processes to correct administrative deficiencies that have resulted in building and development violations.
Londonderry Township Action Plan
Following receipt of the Community Assistance Visit (CAV) report Londonderry Township scheduled a meeting to inform the island stakeholders that the Township was mandated to commence a comprehensive enforcement of the floodplain ordinance requirements.
For complete details of that meeting go to the following link: Floodplain Ordinance Enforcement Meeting
The initial part of the action plan involved creating property files, conducting field trips to the islands, inventory existing development to establish a baseline of existing structures, document their condition, and identify potential violations.
Using the information gathered during the field trips, the Township’s consultant engineer completed a series of studies utilizing FEMA’s Substantial Damage Estimator program, commonly referred to as an SDE report, to make substantial damage determinations for those structures that were damaged as a result of the flooding in 2011.
As an action item listed in the CAV report the floodplain development permit application was updated to include sufficient information for a floodplain determination, substantial improvement determination, floodway compliance documents and a means to assure that all other necessary government permits required by state and federal laws have been obtained as specified in the Floodplain Development Ordinance. The floodplain development permit application serves as the mechanism to assure that this CAV requirement is enforced.
As part of the action plan Londonderry Township established a systematic process to conduct field trips to the islands every year, document findings, and make comparisons to the previous yearly visits to identify potential violations including work without a permit resulting in a stop work order. Where potential violations of the Floodplain Development Ordinance as well as the International Property Maintenance Code are observed, pre-enforcement notices are sent to the owner of record and in those cases involving lease agreements notices are sent to both the owner and lease holder of record with an opportunity to mitigate the violation prior to issuing an official Notice of Violation.
The CAV report serves as the basis for the Township’s methodology to assure compliance with all applicable ordinances, codes and associated regulations including but not limited to the Floodplain Development Ordinance, On-Lot Sewage Disposal System Ordinance, International Property Maintenance Code including Manufactured / Mobile Homes Chapter 14 and the Uniform Construction Code.
For a full copy of the CAV report go to the following link: Community Assistance Visit CAV