Flood Mitigation Industry Association Issues Public Comment on FEMA Notice

WASHINGTON, Jan. 29 -- Roderick Scott, board chair of the Flood Mitigation Industry Association, Mandeville, Louisiana, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on the National Flood Insurance Program's Floodplain Management Standards for Land Management and Use, and an Assessment of the Program's Impact on Threatened and Endangered Species and Their Habitats". The comment was written on Jan. 1, 2022, and posted on Jan. 26, 2022:

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1. 44 CFR 6.6 Flood Plain Variance - FEMA needs to expand the types of buildings/uses for a flood plain variance to include Aquariums and sea food industry buildings located adjacent to the water. When created the US did not have the almost 2 dozen large salt water aquariums built. The US had a flurry of these massive aquariums built in the 1980-1990's time line, in a time where sea level rise was not an issue like it is now.

These aquariums will need to be flood proofed to be flood resilient. The addition of salt and fresh water aquariums to the list of water dependent buildings under the CFR is essential. In addition, fishing industry buildings are extremely water dependent but not included in the list of buildings that can be granted a variance.

Fishing industry buildings adjacent to the water, on the docks must also be allowed to get a variance and wet/dry flood proofed in order to increase their flood resilience and not a NFIP compliance liability for the community.

2. NFIP 2.0 must offer substantial policy premium discounting for retro fit elevation and certified dry flood proofing. As currently proposed, the difference of policy premium rates has a minor rate reduction for bringing the building into compliance with minimum flood map elevation requirements. Under NFIP 1.0 substantial rate reductions were realized after the mitigation projects were completed, there by providing a return on investment for the property owners for the not inexpensive projects. There may be as many as 3-4 million pre-FIRM buildings in US flood zones that the banks estimate have a value of $1.5 trillion.

3. The method for determining the value of a building for cost benefits relating to various grant programs for flood hazard mitigation must be changed. The current system of using a pre-flood assessed value favors higher value properties and disadvantages lower value buildings, the ones owned by lower income families. The building value should be the cost to replace the building at current labor/materials format not depreciated value. This would increase the value of the lower end buildings. This would be in line with the FEMA/NFIP 2.0 building "replacement cost" value format.

4. The mandatory demolition of buildings on acquired properties for permanent green spacing is outdated and not environmentally responsible. Any acquired building that is in "re-useable" condition should be allowed to be acquired for $1.00 and relocated for in fill housing outside of the 1% FEMA flood zone and on a NFIP compliant foundation with 2 ft freeboard. The US currently has a 5 million housing unit deficit. Every thousand square feet of wood frame building has an estimated 200 trees utilized in the materials for construction. In addition construction debris already takes up over 65% of our landfills and masonry/concrete materials do not bio degrade, leaving multiple future generations to inherit these materials in the landfills. The importance of this new direction will become more and more important as the nation works through the issues and begins to implement the relocation of millions of people and hopefully several million buildings as the sea level continues to rise.

5. Non-structural flood hazard mitigation funding programs must be streamlined. All mitigation programs of acquisition, elevation, wet and dry floodproofing projects take several years from the actual application deadline to notification take years, often after buildings are rebuilt the same as they were, vulnerable to flooding. All mitigation project funding types should be streamlined.

Roderick Scott, CFM

Board Chair

Flood Mitigation Industry Association

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The notice can be viewed at https://www.regulations.gov/document/FEMA-2021-0024-0001

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