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Authorize Chair/Vice Chair to sign Community Rating System Annual Recertification Document BEFORE THE BOARD OF COUNTY COMMISSIONERS LEWIS COUNTY, WASHINGTON IN THE MATTER OF: RESOLUTION NO. 21-365 AUTHORIZE THE CHAIR OR VICE CHAIR TO SIGN THE COMMUNITY RATING SYSTEM ANNUAL RECERTIFICATION DOCUMENT WHEREAS, for the County to remain in the Community Rating System (CRS) Program, which provides reduced costs for flood insurance within our community, the County must annually certify that it is continuing to implement the activities noted in the annual recertification document as credited under the CRS Program, and as described in the original application and subsequent modifications; and WHEREAS, County staff from multiple departments has reviewed and provided the requested documentation of continued implementation of the activities; and WHEREAS, the annual Program for Public Information (PPI) committee meeting was held to evaluate the PPI Plan, the committee does not have any recommended updates to the PPI Plan for this annual recertification and a copy of the PPI annual evaluation report is provided to the Board of County Commissioners (BOCC); and WHEREAS, a copy of the annual progress report for the floodplain management plan is provided to the BOCC; and WHEREAS, after review of the documentation, the County certifies it is continuing to implement the activities noted in the annual recertification document as credited under the CRS Program and as described in the original application and subsequent modifications; and WHEREAS, it appears to be in the public interest to approve this annual recertification document. NOW THEREFORE BE IT RESOLVED the BOCC hereby acknowledges receipt of the annual progress report for Activity 510, the floodplain management plan; receipt of the annual evaluation of the PPI Plan; and the annual recertification document; and NOW THEREFORE BE IT FURTHER RESOLVED that the Chair or Vice Chair of the BOCC is authorized to sign the annual recertification document. DONE IN OPEN SESSION this 12th day of October, 2021. Page 1 of 2 Res. 21-365 APPROVED AS TO FORM: BOARD OF COUNTY COMMISSIONERS Jonathan Meyer, Prosecuting Attorney LEWIS COUNTY, WASHINGTON Amber Smith By: Amber Smith, Vacant, Chair Deputy Prosecuting Attorney ATTEST: •'�°"NTY ks . Lindsey R. Pollock, DVM . p,RDOF .6? • ° C" Isey R. Pollock, DVM, Vice Chair C S�� 5 ,. ig4 Rieva Lester •' •//A 71, 'PN\ • Sean D. Swope Rieva Lester, Sean D. Swope, Commissioner Clerk of the Lewis County Board of County Commissioners Page 2 of 2 Res. 21-365 DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency CRSOMB Control Number: 1660-0022 COMMUNITY CERTIFICATIONS Expiration: 10/31/2023 Community Lewis County State WA CID 530102 (6-digit NFIP Community Identification Number) Note:Please cross out any incorrect items, below, as needed, and insert the updated information. CC-213 Recertification Recertification due date October 15, 2021 Chief Executive Officer CRS Coordinator Name Gary Stamper or Lindsey R. Pollock, DVM Karen Witherspoon Title Lewis County BOCC Chair or Vice Chair Senior Project Planner Address 351 W North Street 2025 NE Kresky Chehalis,WA 98532 Chehalis,WA 98532 Phone number (360)740-1120 (360)740-2637 E-mail address bocc@lewiscountywa.gov karen.witherspoon@lewiscountywa.gov I hereby certify that Lewis County [community name]is implementing the following activities on the attached pages as credited under the Community Rating System and described in our original application to the CRS and subsequent modifications. I hereby certify that, to the best of my knowledge and belief, we are in full compliance with the minimum requirements of the NFIP and we understand that we must remain in full compliance with the minimum requirements of the NFIP. We understand that at any time we are not to be in full compliance,we will retrograde to a CRS Class 10. I hereby certify that we will continue to maintain FEMA Elevation Certificates on all new buildings and substantial improvements constructed in the Special Flood Hazard Area following the date at which we joined the CRS. I hereby certify that if there are one or more repetitive loss properties in our community that we must take certain actions that include reviewing and updating the list of repetitive loss properties, mapping repetitive loss areas, describing the cause of the losses, and sending an outreach project to those areas each year, and if we have fifty (50)or more unmitigated repetitive loss properties we must earn credit under Activity 510(Floodplain Management Planning)for either a repetitive loss area analysis(RLAA)or a floodplain management plan(FMP). I hereby certify that, to the best of my knowledge and belief, we are maintaining in force flood insurance policies for insurable buildings owned by us and located in the Special Flood Hazard Area (SFHA) shown on our Flood Insurance Rate Map. I further understand that disaster assistance for any community-owned building located in the SFHA is reduced by the amount of National Flood Insurance Program (NFIP) flood insurance coverage (structure and contents)that a community should be carrying on the building, regardless of whether the community is carrying a policy. Signature . '0 , ,A (Chief Executive Officer) Date /0//212oz1 CC-213-1 [continued on next page] FEMA FORM 086-0-35A(10/23) Page 2 of 11 Community Lewis County State WA CID 530102 (6-digit NFIP Community Identification Number) B. In a regulated C. In the rest of the CRS Program Data Table A. In the SFHA floodplain outside community the SFHA 1. Last report's number of buildings in the SFHA(bSF)(line 6, last report) 2,130 2. Number of new buildings constructed since last report + 8 3. Number of buildings removed/demolished since last report - 0 4. Number of buildings affected by map revisions since last report(+or -) 0 5. Number of buildings affected by corporate limits changes(+or -) 0 6. Current total number of buildings in the SFHA(bSF)(total lines 1-5) 2,138 7. Number of substantial improvement/damage projects since last report 0 8. Number of repetitive loss properties mitigated since last report 0 9. Number of LOMRs and map revisions(not LOMAs)since last report 0 10.Acreage of the SFHA(aSFHA)as of the last report(line 13, last report) 55,796 11.Acreage of area(s)affected by map revisions since last report(+or -) 0 12.Acreage of area(s)affected by corporate limits changes(+or -) 0 13. Current acreage of the SFHA(total lines 10-12) 55,796 14. Primary source for building data: GIS parcel and Assessor's structural data+/-permit records 15. Primary source for area data: GIS data FEMA Q3+ DFIRM-(fed lands, 10ac water bodies, cities,tribes) 16. Period covered: as of October 1, 2021 Current FIRM date July 17, 2006 If available, the following data would be useful: 17. Number of new manufactured homes installed since last report 1 18. Number of other new 1 -4 family buildings constructed since last report 7 19. Number of all other buildings constructed/installed since last report 0 Comments: (Please note the number of the line to which the comment refers.) CC-213-2 [continued on next page] FEMA FORM 086-0-35A(10/23) Page 3 of 11 Community Lewis County State WA CID 530102 (6-digit NFIP Community Identification Number) Instructions At the first verification visit after the effective date of the 2013 CRS Coordinator's Manual, ONLY LINES 6 AND 13 NEED TO BE COMPLETED. These lines form the baseline data about the number of buildings and area of the SFHA for when the table is completed as part of the next annual recertification.The"period covered"entered in line 16 is the date that lines 6 and 13 are first completed. At all subsequent annual recertifications and cycle verification visits,the entire table is completed. The information in lines 6 and 13 from the last report is transferred to lines 1 and 10 in the next report. Instructions for the Columns Column A numbers are for the SFHA(the A and V Zones shown on the Flood Insurance Rate Map)(FIRM)). Use the FIRM currently in effect, not a draft or pending revision. Column B is completed only if the community receives CRS credit for regulating floodplain development outside the SFHA under Activity 410 (Floodplain Mapping)or Activity 430(Higher Regulatory Standards). Column C numbers help relate what happens in the floodplain to what is happening in the rest of the community. Enter"0"if there are no numbers to report for this period. Do not leave a cell blank. Do not fill in the shaded boxes. Instructions for the Lines Lines 1-7 deal with buildings. o Section 301.a of the CRS Coordinator's Manual defines what constitutes a"building"and lists examples of structures that are not counted as"buildings"by the CRS. o Section 302.a of the CRS Coordinator's Manual describes how the CRS counts buildings. For example, accessory structures are not counted. o As noted in Section 302.a,to determine building counts, communities may use any method that yields reasonably good estimates of the number of buildings. Examples of acceptable methods are listed in Section 302.a. Precision is less important for large numbers. For example,the impact of the numbers will not change much if there are 10,000 buildings or 10,100 buildings. o If a building is out of the SFHA, but in a parcel that is partly in the SFHA, it is not counted in column A--In the SFHA. o In line 14, note how the building counts were obtained or estimated. Use the comments area, if needed. Line 4 refers to map revisions.These include physical map revisions, Letters of Map Revision(LOMR), and Letters of Map Amendment (LOMA). If a building is removed from the SFHA by FEMA through a LOMA, but the community still administers its floodplain management regulations on the property,the building should not be included in the line 4 count in column A--In the SFHA. However, communities that still regulate areas removed by LOMAs can receive credit under Activities 410 or 430. If the community is receiving such credit, the building should be counted under column B--In a regulated floodplain outside the SFHA. Line 7 is for the total number of buildings that were substantially improved plus the number of buildings that were substantially damaged during the period covered. Lines 10-13 deal with areas. o These areas are based on the areas shown on the community's FIRM including LOMRs or LOMAs. Section 403.b discusses those portions of the SFHA that are subtracted from the area of the SFHA to calculate the community's aSFHA used in credit calculations. o Section 403.e of the CRS Coordinator's Manual discusses calculating areas for CRS purposes. o Section 403.e notes that communities"should not spend an inordinate amount of time measuring areas."As with buildings, communities may use any method that yields reasonably good estimates. Examples of acceptable approaches are listed in Section 403.e. o Line 13 asks for the current acreage of the SFHA.The best source for this number is a GIS layer that shows the SFHA. If the community does not have GIS,the county, regional agency, or state NFIP mapping office may have SFHA layers and may be able to provide the data. If the community has a relatively recent FIRM,the study contractor or consulting engineer may have the data. o In line 15, note how the area calculations were obtained or estimated. Use the comments area, if needed. Lines 17-19 are voluntary, if the numbers are readily available. o Line 17 includes replacing an existing manufactured home with a new one. The newly placed manufactured home is counted as a new, post-FIRM, building. o The total of lines 17-19 should equal the value entered in line 2. CC-213-3 FEMA FORM 086-0-35A(10/23) Page 4 of 11 Community Lewis County State WA CID 530102 County Lewis COMMUNITY RATING SYSTEM ANNUAL RECERTIFICATION Your community has been verified as receiving CRS credit for the following Activities. • If your community is still implementing these activities the CRS coordinator is required to put his or her initials in the blank (do not use a checkmark or an "X") and attach the appropriate items. A blank with no initials indicates you are not implementing that Activity anymore, and will result in loss of points (and possible CRS Class). • If the word "attached" is used you must provide the requested documentation for that Activity. If no documentation has been acquired for that Activity, please explain why there is no documentation from the past year. /<09310 EC: We are maintaining Elevation Certificates, Floodproofing Certificates, Basement Floodproofing Certificates and V Zone design certificates on all new con- struction and substantially improved buildings in our Special Flood Hazard Area (SFHA) and make copies of all Certificates available at our present office location. 1 ] Initial here is you have had no new construction or substantial improvement in the SFHA in the last year. 702310 EC: Attached is the permit list for only new or substantially improved structures in the SFHA that have been completed in the last year. We have permitted 8 new building and substantial improvements in the SFHA during this reporting period. / w 310 EC: Attached are all the Certificates for new or substantially improved structures that have been completed during this reporting period that are in- cluded on the above permit list. (Note: The total number of Elevation and Flood- proofing certificates should match the number of permits issued and completed within the reporting period defined above. All permits issued for new construction or sub- stantial improvement within the V zone should have both an Elevation Certificate and a V Zone Certificate, and all buildings with basements within the basement exemp- tion communities should have both an Elevation Certificate and a Basement Flood- proofing Certificate). / (,1)320 MI 1: We are providing basic flood information to inquirers. We also continue to provide the following to inquirers: /<G_)MI 2 additional FIRM information /T7 MI 6 historical flood information MI 7 natural floodplain functions / 6(.2 320 MI: Attached is a copy of the publicity for the credited elements of this service this year. Community Certifications CC-213-1 Edition: 2017 Community Lewis County State WA CID 530102 County Lewis COMMUNITY RATING SYSTEM ANNUAL RECERTIFICATION / 6()320 MI: Attached is a copy of one page of the log, a letter, or other record that we kept on this service this year. K&320 MI: We are continuing to keep our FIRM updated and maintain old copies of our FIRM. / 6?-2330 OP: We continue to conduct or provide all credited outreach projects. ____330 PPI: Attached is a copy of the annual evaluation of our program for public information, along with minutes of the meeting, sign in sheets, or other docu- mentation of the committee members' participation. We have included a pro- gress report template for you to use (in the email notification) if you don't have one of your own. / 02340 ODR: People looking to purchase flood prone property are being advised of the flood hazard through our credited hazard disclosure measures. / 6!)350 LIB/LPD: Our public library continues to maintain flood protection materials. X'61)350 WEB: We continue to conduct an annual review and update of the information and links in our flood protection website. /<61)360 PPA: We continue to provide flood protection advice to inquirers. /q1}360 PPV: We continue to provide on-site flood protection assistance to inquirers. /q' 360 PPA/PPV: Attached is a copy of one page of the log, up to three letters, or other records that we kept on this service this year. /<0}360 PPA/PPV: Attached is a copy of the document that told others about this / these service(s) this year. / 6(9370 CP: Attached is a copy of the evaluation of the coverage improvement plan, and documentation that it was submitted to the governing body. / 0-)370 CP: Attached is a copy of the outreach to the community regarding implementation of the coverage improvement plan and technical assistance on flood insurance. A'a)410 MAP: We continue to use our additional regulatory flood data before a new development can proceed in our floodplain. / 0)420 OSP: We continue to preserve our open space in the floodplain. Community Certifications CC-213-2 Edition: 2017 Community Lewis County State WA CID 530102 County Lewis COMMUNITY RATING SYSTEM ANNUAL RECERTIFICATION /(f1430: We continue to enforce the floodplain management provisions of our zoning, subdivision and building code ordinances for which we are receiving credit. (KGl Initial here if you have amended your floodplain regulations. Attach a copy of the amended regulations, provide a summary of the changes and mark up the regulations indicating what's been changed. 7 0 430 RA: We continue to enforce our procedures for administering our floodplain management regulations. If applicable, we also continue to employ CFMs and staff who took credited training courses. We currently have 1 CFMs on staff. ( U 440 AMD: We continue to use and update our flood data maintenance system on an annual basis as needed. /qt)440 BMM: We continue to maintain our system of Benchmarks. [ ) Initial here if any Benchmarks were found to be missing or inaccurate. Attach a copy of the correct elevation or a description of the missing Benchmark(s). /q�440 FM: We continue to maintain our historical Flood Hazard Boundary Map, FIRMs and Flood Insurance Studies. k((_ 450 SMR: We continue to enforce the stormwater management and low impact development provisions of our zoning, subdivision and building code ordinances for new developments in the watershed. 1 ) Initial here if you have amended your stormwater management regulations that will impact your CRS program. Attach a copy of the amended regulations, provide a summary of the changes and mark up the regulations indicating what's been changed. /c(1)450 ESC/WQ: We continue to enforce the provisions of our zoning, subdivision and building codes as they pertain to erosion and sediment control and water quality. A'(t9502 RL: We currently have 36 repetitive loss properties and send our notice to 630 properties in the repetitive loss areas. __ 502 RL: Attached is a copy of this year's notice on property protection, flood insurance and financial assistance that we sent to our repetitive loss areas. /q19510 FMP: Attached is a copy of our floodplain management plan's annual progress report for the action items contained in the plan. We have included a progress report template for you to use (in the email notification) if you don't have one of your own. /qf)510 FMP: We have provided copies of this/these progress report(s) to our governing board and local media. Community Certifications CC-213-3 Edition: 2017 Community Lewis County State WA CID 530102 County Lewis COMMUNITY RATING SYSTEM ANNUAL RECERTIFICATION K6? 520 AR: We continue to maintain as open space the lots where buildings were acquired or relocated out of the floodplain. I ] Initial here if there have been any changes (additions or deletions) to the parcels credited as open space. Attach a description of those changes. / 6t)530 FP: We continue to encourage property owners interested in elevating or retrofitting their buildings to protect them from flood damage. [ ] Initial here if there have been any changes (additions or deletions) to the buildings credited as being flood protected. Attach a description of those changes. Additional Comments: Attachments: 310 Permit List 310 Elevation Certificates 320 Publicity documents for credited elements 320 One page of log 330 Annual evaluation on PPI 360 One page of log 360 Documents that describe service 370 Verification that evaluation for 330 was transmitted to BOCC 370 Copy of outreach 430 Amendment to Floodplain Development regulations 502 Copy of repetitive loss letter 510 Annual progress report Community Certifications CC-213-4 Edition: 2017 CRS Activity 330 & 370 CRS Activity 330/370 Program for Public Information (PPI) Annual Evaluation Report — 2021 Community(s): Lewis County, Chehalis, Centralia Name of PPI: Program for Public Information — Lewis County, Chehalis and Centralia Submitted by: Karen Witherspoon, CRS Coordinator (Lewis County) Email: karen.witherspoon@lewiscountywa.gov Date of Report: August 31, 2021 Date Report sent to Governing Body(s): September 30, 2021 1. Date of the annual PPI committee meeting for this evaluation: August 19, 2021 by Zoom link. 2. List of committee members that attended the annual PPI committee meeting above: Doyle Sanford, CFM Lewis County Building Official/ Fire Marshal Trevor Elliott Insurance agency Celest Wilder, CFM City of Chehalis Floodplain Manager Amelia Schwartz City of Chehalis Planner Ken Frazier Surveyor, floodplain business owner, floodplain resident Hillary Hoke, CFM City of Centralia, Community Development Assistant Director 3. List the Priority audiences for your community: The priority audiences are listed in Table 9 from the PPI plan. Table 9.Priority Audiences Audience Topics of Information Insurance agents The flood hazard,flood insurance,FEMA Elevation Certificates Lenders The flood hazard,flood insurance,construction regulations PPI Annual Evaluation Report—Lewis County Page 1 Real estate The flood hazard,flood insurance,construction regulations agents Builders Construction regulations,building protection measures,financial assistance for mitigation projects Permit applicants Construction regulations,building protection measures,financial assistance for mitigation projects Surveyors Construction regulations, FEMA Elevation Certificates Rental properties The flood hazard,flood insurance,construction regulations Flooded Safety precautions after a flood,construction regulations,building protection measures,financial assistance for properties mitigation 4. List the Topics and associated messages with the desired outcomes for each message: Table 11 of the PPI Plan lists the ten (10) annual messages and desired outcomes for the messages. Topics: 1. Know your flood hazard 2. Insure your property for your flood hazard 3. Protect people from the hazard 4. Protect your property from the hazard 5. Build Responsibly 6. Protect natural floodplain functions PPI#1 Keep your flood insurance policy PPI#2 Sign up for Lewis County Alert notices PPI#3 Use the river gage websites to learn more about your flood threat. PPI#4 Get funding help for mitigation Desired Outcomes: 1. People contact the map information service and are advised of their flood hazard and appropriate protection measures 2. 80% of the floodplain properties are covered by a flood insurance policy 3. No one drives into a flooded area 4. Property owners retrofit their buildings to reduce exposure to flood damage 5. All development projects in the floodplain are compliant with the regulations 6. Measurements show improvement in water quality PPI#1 Everyone keeps their flood insurance policies —there is no drop in total coverage PPI#2 Everyone is aware when a flood is coming PPI#3 Everyone is aware when a flood is coming and if it will impact their property PPI#4 Property owners apply for financial assistance to retrofit their buildings 5. List the projects in the PPI used to convey the above messages: Table 12 of the PPI Plan lists the projects used to convey the messages. PPI Annual Evaluation Report—Lewis County Page 2 Projects listed in PPI Plan Table 12: OP#1. Mailer to SFHA OP#2. Mailer to repetitive loss areas OP#3. Mailer to lenders, insurance agents, real estate agents OP#4. Utility bill insert OP#5. Mailer to Channel Migration Zones OP#6. Mailer to surveyors OP#7. Facebook OP#8. Red Cross booth at annual events OP#9. Real estate brochure OP#10. Permit office handouts OP#11. Public lobby brochure rack OP#12. Real estate presentations OP#13. All Hazards Guide OP#14. "Do you have streams..." brochure OP#15. "Flooding" brochure OP#16. Emergency Management booths OP#17. Public service announcements OP#18. Mailer to other flood hazard areas Map information service (CRS Activity 320) Website (CRS Activity 350) Flood protection assistance (CRS Activity 360) 6. List which projects were implemented for this reporting period: OP#1. Mailer to SFHA OP#2. Mailer to repetitive loss areas OP#3. Mailer to lenders, insurance agents, real estate agents OP#4. Utility bill insert (The County does not send out monthly utility bills, but the cities' utilities serve unincorporated areas in their urban growth boundaries.) OP#7. Facebook (used by Emergency Management during public service announcements) OP#8. Red Cross booth at annual events OP#10. Permit office handouts OP#11. Public lobby brochure rack OP#12. Real estate presentations OP#13. All Hazards Guide OP#14. "Do you have streams..."brochure OP#15. "Flooding" brochure OP#16. Emergency Management booths OP#17. Public service announcements OP#18. Mailer to other flood hazard areas Map information service (CRS Activity 320) Website (CRS Activity 350) Flood protection assistance (CRS Activity 360) PPI Annual Evaluation Report-Lewis County Page 3 7. List why some projects were not implemented (if any): The mailer to properties in the Channel Migration Zones (OP#5), elevation certificate mailer to surveyors (OP#6), and the real estate brochure (OP#9) have not been designed and implemented at this time. 8. List what should be changed (if anything). This should include what messages, outcomes and projects should be revised or dropped and what new ones should be initiated. No changes to the PPI plan were recommended by the PPI Committee during this annual review. PPI Annual Evaluation Report—Lewis County Page 4 CRS Activity 510 CRS Activity 510 Progress Report on Implementation of Credited Plan Date this Report was Prepared: September 27, 2021 (for the October 1, 2020 — Sept 30, 2021 Annual Recertification — 2nd recertification since cycle visit) Name of Community: Lewis County Name of Plan: 2016 Lewis County Multi-Jurisdictional Hazard Mitigation Plan Date of Adoption of Plan: January 25, 2016 by Resolution Number: Res 16-029 5 Year CRS Expiration Date: September 30, 2022 (Next 5 Year Cycle Visit— approximately March 2023) 1. How can a copy of the original plan or area analysis report be obtained: The plan is available on the Lewis County Community Development Department webpage at https://lewiscountywa.gov/departments/community- development/multi-jurisdictional-hazard-mitigation-plan/ or by contacting the Lewis County Community Development Department. 2. Describe how this evaluation report was prepared and how it was submitted to the governing body, released to the media, and made available to the public: The evaluation report was prepared and copies provided to the Board of County Commissioners (BOCC) at a meeting open to the public. Electronic audio and video recordings are available to the media and the public. The BOCC was briefed about the evaluation report during the annual CRS update report. 3. Provide a description of the implementation of each recommendation or action item in the action plan or area analysis report, including a statement on how the project was implemented or not implemented during the previous year: • Continue to enforce the flood damage prevention code: This is an on-going effort and the action item is met each year. • Keep building codes current as per Washington State requirements: The building codes are current with Washington State requirements. • Conduct annual review of the mitigation strategies: This is an on-going effort and the action item is met each year. • Monitor flooding and take action to move equipment during an event: This is an on-going effort using the flood warning system and other monitoring efforts; this action item is met each year. The Lewis County webpage for the Emergency Management Department has links to several applications for flood warnings, road conditions, river gauges and monitoring overall flooding during prior to and during an event. httos://lewiscountvwa.gov/departments/emergency- management/emergencv-preparedness/ • Review critical area ordinances to update flood zones, seismic zones, and landslides: Lewis County critical area codes were updated to current Washington State standards in 2018. 4. Discuss why any objectives were not reached or why implementation is behind schedule: The action items were met and implementation is not behind schedule. 5. What are the recommendations for new projects or revised recommendations? The 2016 Lewis County Multi-Jurisdictional Hazard Mitigation Plan contains the on-going recommendations and mitigation strategies. BOCC AGENDA ITEM SUMMARY Resolution: BOCC Meeting Date: Oct. 12, 2021 Suggested Wording for Agenda Item: Agenda Type: Deliberation Authorize the Chair or Vice Chair to sign the Community Rating System Annual Recertification Document Contact: Karen Witherspoon Phone: 2637 Department: CD - Community Development Description: Authorize the Chair or Vice Chair to sign the Community Rating System Annual Recertification document Approvals: Publication Requirements: Publications: User Status PA's Office Pending Additional Copies: Cover Letter To: Karen Witherspoon, Lee Napier