ASFPM Update and NFIP
Reform
KAMM 10th Anniversary Conference
September 9, 2014
AND HE SAID
Floods are 'acts
of God,' but
flood losses are
largely acts of
man.
1945 PhD Dissertation
Human Adjustments to
Flood by Gilbert F.
White
ASFPM’s Mission
Mitigate the losses, costs, and human
suffering caused by flooding.
and…
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Protect the natural and beneficial
functions of floodplains.
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National CFM® Certification
State Chapter Services & Support
Legislative Activities
Work on National Policy Issues
Develop Publications & Resource Materials
for Floodplain Managers
No Adverse Impact (NAI)
Conferences & Events Continuing
Education Development (ASFPM Webinar
Series)
What does ASFPM do?
Flood Mapping for the Nation
• March 2013 ASFPM Report
• Cost Model developed to:– Complete mapping inventory for entire country
– $4.5 - $7.5 billion
– Steady state maintenance cost (of the mapping data
– $116 - $275 million
• Recommended all flood hazard areas in country be mapped
• Recommended nationwide LIDAR
• Fits well with the Congressional authorization
ASFPM Foundation: Holistic Coasts Report
• Resulting from 2013 ASFPM Foundation Forum
• 6 key recommendations for policy makers
• Focus is on resiliency, state and local leadership, investments in science and data, and self responsibility
Floodplains and Dam Risk Report
• Examines relationship between dams and floodplain management
• Several recommendations including prevent risk creep, mapping inundation areas, public availability of inundation areas, and strong dam safety programs
NAI How-To Guides
• 5 NAI level tools in each guide
• Based on 7 building blocks in NAI Toolkit
• Completed Mitigation and Infrastructure in 2013
• Will complete Planning and Education/Outreach by October 2014
• Two additional for 2015
Great Lakes Coastal Resilience Planning Guide
www.greatlakesresilience.org
http://www.greatlakesresilience.org/
National Policy Issues
The broad problem of flood-loss
reduction is that the rate at
which flood losses are being
eliminated by construction of
engineering or land-treatment
works is of about the same
magnitude as the rate at which
new property is being subjected
to damage. - GFW
FY 15 Budget
• FEMA – Flood Mapping. $84.4m. This is down from
$220m in '10, $181.6 m in FY '11, $97.7 in FY '12 and $100 m in FY '13, $95 FY ‘14
– Pre Disaster Mitigation. $0
– Flood Mitigation Assistance. $150 m. Up from $100 m in FY’ 14.
– EMPG. $350 million. About the same as previous years.
– NPGP being proposed again
NFIP Reforms 2012 and 2014
• BW-12
• Reauthorized the National Flood Insurance
Program (NFIP) for 5 years through
September 30, 2017
• Focus was fiscal solvency of program
• Signed July 6, 2012
• Homeowners Flood Insurance Affordability Act (HFIAA) of 2014
• Retreat from some BW-12 provisions, set
some longer glide paths to full risk rating
• Signed March 21, 2014
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Why the Changes?
1. Improve long-term
sustainability and
financial soundness
2. Respond to the rising
costs and consequences
of flooding
3. Encouraging private
market participation
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Washington Post 9-17-13
GW (HR 3370) TAKES THE OPPOSITE APPRAOCH CREATES NEW
SUBSIDIES AND LIABILITIES IN THE NFIP
Flood Mapping
• Establishes the National Flood Mapping Program– First time in legislation
– $400 million annually in authorization
– All maps must show 100-yr and 500-yr for:• All populated areas and areas of potential growth
• Residual risk (within 100-year FP) behind levees
• Residual risk (within 100-yr FP) below dams
• Mapping of non-structural mitigation features
– Flood data developed on watershed basis (already doing)
HR 3370 WAIVES MAP CHANGE PROCESSING FEES ASSOCIATED WITH FLOOD
MAP UDATES RESULTING FROM HABITAT RESTORATION PROJECTS
Flood Mapping
• Establishes the Technical Mapping Advisory Council to make recommendations to FEMA– Advises FEMA on mapping guidelines and map
update processes
– Improve accuracy, ease-of-use, distribution
– How to use best available climate science
• Requires notification of property owners who are included or excluded from areas where mandatory purchase is required
HR 3370 REQUIRES FEMA OBTAIN CERTIFICATION FROM TMAC THAT ITS
MAPPING PROCESS, WHEN APPLIED, RESULTS IN TECHNICALLY CREDIBLE
FLOOD HAZARD DATA
Flood Mapping
• Limits appeals to be based on the sole ground that the proposed data is scientifically or technically incorrect
• Establishes a Scientific Review Panel to hear certain appeals on flood mapping issues
• Mandatory property owner notification if new maps result in in our out of mandatory purchase area.HR 3370 PROVIDES FOR THE REIMBURSEMENT OF APPLICANT
COSTS (ENGINEERS, SURVEYORS, ETC. FOR SUCCESSFUL
APPEAL OF MAP ERRORS IN FEMA FLOOD MAPS
Mitigation Changes
• Combines NFIP mitigation grant programs into one.
• Makes demolish-rebuild an eligible item under all programs
• Allow some new flexibility to acquire or relocate SRL properties
• Establishes rational cost shares vs. existing programs– Severe Repetitive Loss up to 100% Federal
– Repetitive Loss up to 90% Federal
– All other up to 75% Federal
Mitigation Changes
• Establishes firm 5-year limitation on grant awards
• Limits grants under NFIP mitigation programs of 50K for state mitigation plans and 25K for local mitigation plan
• Establishes extra funds for states to provide additional technical assistance to communities
HR 3370 REQUIRES FEMA TO DEVELOP FLOOD MITIGATION GUIDELINES FOR
PROPERTY OWNERS FOR OPTIONS OTHER THAN ELEVATING
HFIAA Impact in Premiums
•Maximum annual increase is 15% annually generally speaking for NFIP policies. BW-12 had a maximum of 20%
•Pre-FIRM Subsidy Elimination Will now include all properties including primary residences that already have policies
Minimum 5% of total premium increase for subsidy elimination
Premiums for primary residences can go up a maximum of 18% annually
25% annual increase required (same as in 205 from BW-12) for non-primary residences, businesses, SD/SI, cumulative claims, SRLs
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HFIAA Impact in Premiums
•Grandfathering Subsidy Elimination
Yes, Section 207 was eliminated; however it was
replaced with new grandfathering section
Existing grandfathered policies seem to continue
to be grandfathered . . . but
New policies (after date of enactment of HFIAA)
for properties newly identified in SFHAs will be on
a glide path to full actuarial rates.
Year 1 . .PRP rates
Subsequent years . .follows rate increase path for
phase out of pre-FIRM subsidy
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Bad HFIAA Provisions
•All policies get a new ANNUAL surcharge $25 for primary residence properties
$250 for non-residential properties and non-primary residential properties.
Surcharges would be deposited in the NFIP Reserve Fund, which was established to ensure funds are available for meeting the expected future obligations of the NFIP
•New 1% goal FEMA is instructed to try and minimize the number of
policies with annual premiums that exceed one percent of the total coverage provided by the policy
Existing V-Zone rates already exceed this!
•Allows communities to be reimbursed for successful challenges of errors found in FEMA maps
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Good HFIAA Provisions
•Requires an Affordability Framework
•Restores substantial improvement to 50% (was changed to 30% in BW)
•Study of Voluntary Community-Based Flood Insurance Options
•Requires mapping of non-structural flood mitigation features such forests, marshlands, etc.
•Requires FEMA to clearly communicate full flood risk determinations to individual property owners regardless of whether their premium rates are full actuarial rates
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HFIAA Bottom Line
•Preserves basic structure of BW-12, does not repeal most of it
•It modifies some annual increases and generally increases glide path to full actuarial rates
•Contrary to the name, it did not do much to address flood insurance affordability–Addressed immediately going to full risk rates upon sale or
new policy .. . Good
–Some provisions nibble around the edges
–Lots of studies . . .no implementation or even pilots
–Some peoples total policy costs will be higher under HFIAA than under BW-12!
All subject to FEMA’s final interpretation!24
Options and Actions to Address Flood Insurance Affordability
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Options & Action
• Property Owners
– Identify what full-risk rate is; get an EC
– Look into effect of higher deductibles
– Look into rate-reducing mitigation actions; e.g.
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• Add vents
• Use Breakaway walls
• Fill in/up enclosures
• Elevate
Options & Action
• Property Owners
– FHA 203K Loan
• FHA's primary program for the rehabilitation and
repair of single family properties
• Combines financing for purchase or refinance and
repairs into one loan
• Can be used in cases where property owner finds
flood insurance too expensive
• Must be done by a FHA approved lender – they
already exist throughout the country
• Competitive mortgage rates although mortgage
insurance is required for five years after loan27
Options & Action
• Communities and States
– Join CRS/Increase CRS Rating
– Be aware of potential mitigation grants
– Provide technical advice and build capacity to
do so
• Have Certified Floodplain Managers on staff
• Elevation Certificates
• Building/Rebuilding to reduce flood risk
• Redouble focus on mitigation planning and
develop sound actions to mitigate risk
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Options & Action
• Communities and States
– Create state and local mitigation programs
• Mitigation Rebate Programs
• Grant programs that provide local match to federal
programs
• Duplicate underfunded federal programs
– Implement higher standards
• Freeboard (not just one foot anymore)
• Standards for areas outside FEMA 100-year
floodplain but where flood losses occur
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Pawleys Island, South Carolina
Pawleys Island: Raising new buildings isonly first step for townJuly 31, 2014
By Charles SwensonCoastal Observer
When Pawleys Island Town Council held a public hearing this month on a proposal that will require new and remodeled homes to be elevated an extra 3 feet there was only one comment against it. And that was offered second hand.
Council Member Mike Adams got a call from a property owner concerned that the higher buildings would change the look of the island. He passed along the objection during the council’s discussion, but added, “I don’t necessarily subscribe to that.”
The measure passed unanimously and will gain the town points under a federal flood insurance program that reduces premiums for policyholders in participating communities.
Odessa, Texas
The city map on this brochure approximates
the location the Special Flood Hazard Areas
(SFHA). You can view this map in a larger format
on City of Odessa’s web- site in webMAPS at
www.odessa- tx.gov. You can request an
Elevation Certificate for any residential or
commercial structure in the flood plain from the
City Engineering Division for a fee and take it to
your insurance agent for an accurate flood
insurance premium quote. The City’s
engineering division can be contacted at
432-335-3242.
South Holland, Illinois
State of Colorado
State of Connecticut
• Shore-Up Connecticut
is a state established
low interest mitigation
loan program
established in July
2014
• For coastal shoreline
A and V zone
properties only
• Eligible properties
also include owner
occupied rentals and
small businesses
Reform Legislation Resources
www.FEMA.gov/Flood-Insurance-Reform
www.NFIPiService.com
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Reform Legislation Resources
www.Floods.org
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Other Resources
http://floodinsurancetraining.com/theory-of-elevation-rating/
http://floodinsurancetraining.com/ec-made-ez-online/ 37
Conclusion
As floodplain management professionals, we have a responsibility to be educated
and help citizens understand options
www.floods.org
http://www.floods.org/
Thank You
The present status of floodplain management does not
encourage complacency ... On balance, progress has
been far short of what is desirable or possible, or what
was envisaged at times when the current policies and
activities were initiated - GFW
Credit given to the Natural Hazards
Observer and Rob Pudim for all
illustrations in this presentation