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Will a local plan be approved if it does not address the “shoulds” sections of the local planning requirements?

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Will a local plan be approved if it does not address the “shoulds” sections of the local planning requirements?

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Yes, since these sections are recommended but not required under 44 C.F.R. 201.6. It should be noted that the information described in the “shoulds” can significantly strengthen and improve the risk assessment as well as assumptions made in the plan (including the mitigation strategy). Nonetheless, a plan that does not address these components can be approved if it meets all the mandatory requirements. FEMA strongly encourages that plans without a fully developed risk assessment make this a priority for the 5-year update, since a more complete risk assessment will provide a stronger foundation for the mitigation plan and program. This will aid not only the jurisdiction, but the State as it incorporates local risk assessments into its mitigation plan. From: http://www.fema.gov/plan/mitplanning/faqs.

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