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