NFIP and The Community Rating SystemOur focus on the latter two affords us some creativity… CRS improves flood resiliency and reduces insurance costs Florida has integrated several

THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT

NFIP and The Community Rating System:

The Way Forward in Florida

Bryan Koon

Director


The National Flood Insurance Program (NFIP) was created by Congress through the National Flood Insurance Act of 1968.

Florida is a flood prone state and Floridians are encouraged to have flood insurance in the event a disaster happens they can recover more quickly.

Florida has 465 NFIP Participating Communities

The Community Rating System is a voluntary program in which NFIP policyholders can receive discounts on their premiums.

INTRODUCTION


BIGGERT-WATERS REFORM ACT 2012

• Signed into law on July 6, 2012, reauthorizing the National Flood Insurance Program for five (5) years.

• Brought sweeping changes to the insurance portion of the NFIP program including the establishment of an NFIP Disaster Fund.

• As flood risks continue, the costs and consequences of flooding increase. Artificially low rates and discounts are no longer sustainable.


House passed H.R. 3370 was signed into law on March 21, 2014 by President Obama.

Repeals the property-sales trigger requiring homebuyers to pay the full-risk rate for pre-FIRM subsidized properties.

Refunds policyholders who overpaid for premiums.

Restores the grandfathering of lower rates when new flood maps are issued and sets hard caps on how high premiums can increase annually.

GRIMM-WATERS NFIP REFORM ACT 2014


Over the last three years, the Division has taken on a number of statewide initiatives to increase CRS participation:

Hired dedicated CRS staff to assist communities entering the CRS and continuing to improve their class.

Identified activities at the state level in which every Florida community can count points toward the next level of discount

Started the process to acquire a new statewide notification system, which will provide communities with the potential of additional points for CRS.

Identify 100 new communities to enroll in CRS by October 2016

FLORIDA COMMUNITY RATING SYSTEM


NFIP key elements: Insurance, Mapping, Regulations and Mitigation

Our focus on the latter two affords us some creativity…

CRS improves flood resiliency and reduces insurance costs

Florida has integrated several key components: State Model Floodplain Ordinance coordinated with FBC

Community Assistance Visits or Field Community Assistance Contacts

Developing “Performance Measures” that ensure compliance with NFIP

Establishing streamlined participation for potential CRS communities

Danny Hinson, State CRS Coordinator and Steve Martin, NFIP Coordinator, and will walk us through the process.

THE WAY FORWARD IN FLORIDA


Benefits of The Community Rating

System Danny Hinson, CFM


A voluntary program within the National Flood Insurance Program

COMMUNITY RATING SYSTEM

Minimum NFIP requirements

CRS: Everything done

above and beyond minimum NFIP requirements

Reduced flood insurance premiums = more money in the policyholders pocket = more incentive for better

floodplain management.

Presenter

Presentation Notes

Stress CRS awards or recognizes better floodplain management above and beyond NFIP


CRS discounts on flood insurance premiums range from 5% up to 45%.

Communities can participate in some or all of the 19 public information and floodplain management activities to earn points which translate into flood insurance premium discounts!


Presenter

Presentation Notes

Going to see is Lida can create this graph with the % discounts at bottom of each column.


Community Rating System – National Goals

Reduce flood damage to insurable property.

Strengthen and support the insurance aspects of the NFIP.

Encourage comprehensive approach floodplain management


Presenter

Presentation Notes

CRS current goals – now what Florida is doing to increase CRS participation…..


In Florida, 47% of NFIP communities participate in the CRS program. Florida has 219 communities participating in the CRS.

Florida’s savings on insurance premiums is more than $183 million annually.

Nationally 6% of NFIP communities participate in the CRS program with savings on insurance premiums of $360 million annually



FLORIDA CRS COMMUNITIES

COMPARISON: FL VS. US

US CRS COMMUNITIES

0

10

20

30

40

50

60

70

80

90

Class 9 Class 8 Class 7 Class 6 Class 5 Class 4 orbetter

0

50

100

150

200

250

300

350

400

450

Class 9 Class 8 Class 7 Class 6 Class 5 Class 4 orbetter

Florida has a higher percentage of communities participating, and higher levels of achievement, than rest of US meaning more resilient communities.


Our State CRS Program is aimed at informing communities:

Components of the program

Requirements for implementing a successful local program

Documenting accomplishments to get credit for points

Networking with other communities through User Groups

Advancing to next CRS Class levels

Next major challenge is encouraging participation in CRS…



Floodplain Management

and the Florida Building Code

Steve Martin, CFM, State NFIP Coordinator

Presenter

Presentation Notes

Bryan has set the stage for why Florida is so committed to encouraging communities to become more flood resilient and to join the Community Rating System. Staff needed to consider the elements of the NFIP that could provide the tools to further this important commitment. One of the more obvious tools, taking a cue from the Insurance industry itself that stimulated development of the universal Building Codes, we first looked at the relationship between the NFIP and the Building Codes. FEMA has long been a driving force to get the flood building provisions of the NFIP into the International Building Codes.


THE CODES

• IBC 2000 included flood building provisions • FBC 2010 included flood building provisions • FBC 2010 references the ASCE 24-05 Flood Resistant Design and Construction standards applicable to Code. • Florida floodplain ordinance coordinated with the FBC.

Presenter

Presentation Notes

Florida’s Building Code like many states, is based on the IBC. Therefore, Florida’s quest for more flood resilient communities starts with incorporating the NFIP flood building provisions in the Florida Building Codes. Florida developed a model floodplain ordinance coordinated with the FBC based on FEMA’s draft model ordinance that is also coordinated with the IBC. The State model floodplain ordinance removes duplicative flood provisions now contained in the Florida Building Code, but, Florida’s model incorporates many of the guidance documents provided in dozens of technical documents produced by FEMA which is otherwise recommended but not required.

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCMPl1Nm_vccCFUyegAod59EM2A&url=http://www.suncoastboaf.net/?p%3D43&ei=TNfYVcOPJ8y8ggTno7PADQ&psig=AFQjCNH_z4X_GoUn8vmSjShbH9YiP5Kl3Q&ust=1440360197743975

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCJiAxIjAvccCFQiLDQodAsACSA&url=http://www.amazon.com/2015-International-Building-Code-Council/dp/1609834682&ei=rtfYVZjxOIiWNoKAi8AE&psig=AFQjCNGzJ5zQu2IMQIBHpQg7VR8MVZtsIQ&ust=1440360695855912

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCMP_teLBvccCFQOsgAodep4Mjg&url=http://shop.iccsafe.org/flood-resistant-design-and-construction-asce-sei-24-05.html&ei=d9nYVYPoNYPYggT6vLLwCA&psig=AFQjCNEBxao77CL4K_lOSbYz_5DsQ-qiTQ&ust=1440360897250668


STATE MODEL FPM ORDINANCE More specific administrative provisions

Formatting, definitions and provisions consistent with FBC

Recaptures buildings exempt from the FBC

Establishes coordination between the Building Official and Floodplain Administrator

NFIP Flood Provisions for Buildings

Florida Building Code

Local Ordinance

Presenter

Presentation Notes

Examples of more specific administrative provision: determining BFEs where none on FIRM; making SI/SD determinations; setting minimum heights for Manufactured homes at the bottom of the frame instead of the finished floor, and the like. FEMA requires all buildings in flood zones to be regulated for flood – the ordinance simply says buildings exempt from the FBC have to comply with ASCE 24 (the same standard that the FBC, Building references for specific requirements for buildings). FEMA requires all development to be regulated, including buildings exempt from the FBC such as farm buildings on farms. Local FPM regulations were always intended to regulate all buildings. The BO and the FPA may be the same person/office. FAQ: Must the community’s Building Official also be designated the Floodplain Administrator? No. Communities should designate the position of a qualified staff member who is knowledgeable about floodplain management to fulfill the broad range of responsibilities of the Floodplain Administrator. It is common to designate a department head, planning manager, building official, or a town manager, who then delegates functions. By law, the building official is responsible for enforcing the building code. If designated as the Floodplain Administrator, the building official functions under the authority of the FPM regulations.


State floodplain model ordinance, instructions and notes

PowerPoint presentation encouraging adoption of ordinance

6 Higher Standards (optional to enhance flood resiliency)

Sample Forms to implement ordinance provisions

Online training for Flood Provisions in the Building Code

Visit website:

http://www.floridadisaster.org/Mitigation/SFMP/lobc_resources.htm

FLORIDA’S WEBSITE ON FPM ORDINANCE

Presenter

Presentation Notes

We make it easy for communities to adopt the State’s model FBC-coordinated model floodplain management ordinance. On our website, you will find a do-it-yourself process: downloadable ordinance for A Zones or A and V zones, Frequently Asked Questions, A PPT that explains the value in communities to adopt the FBC-coordinated model floodplain ordinance Six higher standards Sample forms: SI/SD Sample Notice, Zone V Engineer’s Design Certificate, Non-conversion Agreement, Agreement to Submit ECs

http://www.floridadisaster.org/Mitigation/SFMP/lobc_resources.htm


CODES, HIGHER STANDARDS, & REALITY

Presenter

Presentation Notes

Even with the Codes, and the model floodplain ordinance adopted by local governments, the reality is that structures may not be fully compliant. In many cases, communities do the best they can to approve conforming development but the reality is that site conditions and public needs may dictate otherwise. The basis for deviation from the regulations, usually in the form of variances, should be documented to ensure that non-conforming structures are not considered to be noncompliant and a possible threat to joining CRS or maintaining CRS class levels.


FIELD COMMUNITY ASSISTANCE CONTACTS Tour floodplains and flood zones, meet with Floodplain staff

Ensure floodplain ordinance is compliant, guidance docs

Assess Floodplain Program Effectiveness Identify threats, challenges and opportunities facing FPMs Verify enforcement of regulations consistent with NFIP & FBC Provide technical assistance Encourage training and provide educational materials

Resolve procedural and compliance concerns

Discuss CRS-CAV Pilot Program, schedule for participating

Presenter

Presentation Notes

Field Community Assistance Contacts are a way to ensure compliance with the NFIP and reach out to communities that otherwise may have limited contact with other floodplain management programs. Folks not completely familiar with our process have referred to the visits as “audits”, but many times they are an opportunity to provide one-on-one technical assistance, and some meetings become a mini-workshop where local staff can discuss program concerns with State floodplain staff, obtain advice on handling delicate floodplain issues, or learn about successful solutions implemented by other communities. Most importantly in the Pilot Program, FCACs provide an opportunity for communities to learn about how they can participate in CRS and start down a path for improved flood resiliency. State CRS staff are able to conduct a CRS Quick Check to estimate the likely class level that a community may achieve when first participating in the CRS program


NFIP: INCENTIVE / DISINCENTIVE BASED NFIP is a voluntary program, with quid pro quo requirements…

Federally required regulations / communities must enforce.

Compliance is expected / non-compliance impacts membership.

Adopting higher and better standards / improves resiliency.

Implementing resiliency measures / reduces risk.

Reduced risk / opportunity to join CRS is available.

Biggert-Waters 2012 set actuarially higher rates / Florida creates “CRS-CAV Pilot Program” with FEMA HQ support.

Presenter

Presentation Notes

Discuss the dichotomy between the incentives and dis-incentives, and how this relates to the CRS-CAV pilot Program.


NFIP-CRS Eligibility – The Past

Decades-old compliance issues must be resolved to join CRS.

Floodplain staff must pay for mistakes of previous employees.

A non-compliant community today would always be non-compliant unless all past compliance issues are resolved.

FLORIDA’S CRS – CAV PILOT PROGRAM

Presenter

Presentation Notes

Many communities joined CRS years ago after meeting rigorous tests to ensure they were qualified to join by resolving all compliance issues. Other communities fond themselves in a bind where they could not get owners to correct violations, even though these communities were improving their programs, were completely compliant from a programmatic standpoint and adopting and abiding by higher standards. They were always being held back by past compliance issues or previous NFIP program procedural problems associated with former staff.


Joining the CRS Under the New Pilot Program-- Staff of communities that adopt FBC-coordinated ordinance are

more engaged.

Non-CRS communities have benefit of Field Community Assistance Contacts.

New procedures for communities to join CRS means increased success for overall NFIP program.

Communities’ adopted “Performance Measures” renews communities’ commitment to the NFIP.

CRS stimulates opportunities for improved resiliency.

FLORIDA’S CRS – CAV PILOT PROGRAM

Presenter

Presentation Notes

Ordinance creates closer ties between FPA and floodplain administrator, or they are one in the same. Under annual scopes of work with FEMA, State visits mostly larger communities with greater development pressure, the Pilot Program enables the State to visit communities not in CRS many of which have not had a visit in 10 to 20 years and have very outdated floodplain ordinances. State assisting smaller communities helps them not only meet minimum NFIP requirements, but encourages them to become more resilient with CRS as the reward. Once in CRS, communities have a clear path for adopting higher standards, conducting more outreach, mitigating more structures, or preserving more open space.


1. Adopt FEMA-approved Florida Model Floodplain Ordinance.

2. Conduct annual inspections in flood zones to identify compliance issues that must be mitigated.

3. Adopt/implement flood zone permit application & checklist.

4. Verify accurate completion of FEMA Elevation Certificates before vertical construction and prior to issuance of C.O.

5. Annually send letters to utility companies concerning installation of tanks and HVAC equipment.

6. Develop/implement Substantial Improvement/Substantial Damage determination procedures and permanent maintenance of documentation.

7. Provide Elevation Certificates and link to Digital FIRMs on local website.

SEVEN PERFORMANCE MEASURES

Presenter

Presentation Notes

These are the seven Performance Measures that help a community become recognized as eligible for CRS consideration. The Performance Measures are contained within a package of materials developed by the State Floodplain Management Office and are required to be adopted by Resolution, much like the Resolution communities had to adopt in order to join the NFIP. Florida CRS Staff conducts a CRS evaluation to verify the community can earn at least 500 points, and most are found to be eligible for a class 8 resulting in a 10% savings on flood insurance policy premiums.


FLORIDA CRS INITIATIVE CRS-CAV Pilot Program

Enrolling Communities in the Community Rating System

SEVEN PERFORMANCE MEASURES

Bureau of Mitigation Florida Division of Emergency Management


NEXT STEPS

Florida will continue to lead the way in improving the National Flood Insurance Program and the Community Rating System

CRS-CAV Pilot Program – appreciates FEMAs support

Lessons Learned

CRS – how other states can implement changes

Future of flood insurance

Presenter

Presentation Notes

Bryan Koon closing slide


Florida Floodplain Management Office Steve Martin, CFM

State NFIP Coordinator 850.922.5269

[email protected]

http://www.floridadisaster.org/Mitigation/SFMP/Index.htm

Florida Community Rating System Office Danny Hinson, CFM, FPEM

Florida CRS Initiative 850-544-8383

[email protected]

http://www.floridadisaster.org/mitigation/CRS

CONTACT INFORMATION

mailto:[email protected]

http://www.floridadisaster.org/Mitigation/SFMP/Index.htm

mailto:[email protected]



Documents

NFIP and The Community Rating SystemOur focus on the latter two affords us some creativity… CRS improves flood resiliency and reduces insurance costs Florida has integrated several