"Chairwoman Waters, Ranking Member McHenry, and members of the Committee, thank you for inviting me to testify today. I am here on behalf of the
"Whether we are facing wildfire, earthquakes, hurricanes, or floods, it is clearer than ever before that our nation, states and communities must do more to prepare for known risk. Before I joined the
"The costs of weather-related disasters are on an upward trend, exacerbated by our warming climate, exceeding
"As I hope to convey in this testimony, a status quo approach to our disaster planning, preparation and response at a time of cascading hurricanes, typhoons, and inland flood impacts does not work. Given this reality, continuing on this same trajectory - including through additional extensions of the National Flood Insurance Program without meaningful reforms - will further jeopardize our natural environment and endanger human communities. As a nation we must confront and address the growing economic, environmental, societal, and cultural costs of disasters in a way that is just, equitable, and accounts for vulnerable populations. We encourage
"Of the 241 disaster events costing a billion dollars or more between 2000 and 2018, hurricanes and typhoons have caused the most damage, responsible for 55% of all losses, with flooding events responsible for another 7.4% of total losses.3 And these numbers can only be expected to grow. Projections under
"Unfortunately, the current National Flood Insurance Program (NFIP)-which has borrowed over
"Naturally functioning floodplains:
* Provide vital habitat for countless wildlife species. Healthy rivers, floodplains, and wetlands provide essential grounds for breeding, foraging, and other parts of the life cycles of innumerable species, and are crucial to the survival and recovery of many threatened and endangered species. Wetlands are some of the most biologically productive natural ecosystems in the world, and America's wetlands support millions of migratory birds and waterfowl. Although wetlands account for just about five percent of land area in the lower 48 states, those wetlands are the only habitat for more than one third of the nation's threatened and endangered species and support an additional 20 percent of the nation's threatened and endangered at some time in their life. These same wetlands are home to 31 percent of the nation's plant species.5
* Provide an array of resilience and public health benefits. Natural infrastructure, both alone and in conjunction with structural projects, provides important protection from storms and floods. Wetlands act as natural sponges, storing and slowly releasing floodwaters after peak flood flows have passed, and coastal wetlands buffer the onslaught of hurricanes and tropical storms. A single acre of wetland can store one million gallons of floodwaters.6 Just a one percent loss of a watershed's wetlands can increase total flood volume by almost seven percent.7 Restoring a river's natural flow and meandering channel, and giving at least some floodplain back to the river, slows down floodwaters and gives the river room to spread out without harming homes and businesses. Healthy floodplains also improve water quality and supply by fostering vegetation to limit non-point water pollution from storm water runoff, and allowing water to recharge in underground drinking water aquifers.
* Provide recreational value and buoy the outdoor economy. Protecting floodplains is also a way to protect the areas where members of the
"However, alterations to floodplains create multiple threats to wildlife and human communities through a range of impacts, including: changing the flow and hydrology of rivers; eliminating wetlands and side channels, destroying nesting and rearing areas and other important habitat; removing protective natural buffers; and causing siltation, nutrient, and other water quality problems. Unfortunately, decades of federal policies, with the National Flood Insurance Program as a key culprit, have led to increased development in floodplains that are no longer able to support the wildlife, ecological, and public safety benefits they once did.
Necessary Reforms to the NFIP
"We are pleased to see the Committee prioritizing the reauthorization and meaningful reform of the NFIP. Continuing the status quo in the flood program is not only a risky proposition for communities who rely on the indebted program to pay their claims, but it is poor practice from a longer-term planning perspective. NFIP has long masked risk by subsidizing rates, and
"SmarterSafer has detailed recommendations for comprehensive reform to NFIP which I have submitted for the record and attached to this testimony, and below I highlight several priority areas:
* increasing pre-flood mitigation to reduce risk and rates;
* improving the accuracy of
* ensuring continued movement toward risk-based rates, with targeted support for reducing risk;
* closing the protection gap including through private sector participation;
* and increasing overall transparency.
Increase investment in pre-flood mitigation, and incentivize natural infrastructure approaches
"By far, one of the best ways to reduce flood insurance rates and to mitigate against future disasters is to reduce risk. While
"Substantial new investments in mitigation, including through protecting, restoring, or enhancing natural infrastructure such as wetlands and dunes, can greatly reduce flood risks and save taxpayers from ballooning disaster payments. Proactive, preventative mitigation is the most cost effective investment the NFIP can make. According to a 2018 report from the
"However, not all mitigation is created equal. Community-wide, natural, and nature-based mitigation should be used and encouraged wherever possible. These are practices that protect, restore, or in some cases, even create natural features or processes that reduce erosion and flood impacts in coastal or riverine floodplains by dissipating floodwaters or wave energy, capturing sediment and debris, and building land elevation. Furthermore, with increased investments in mitigation - including nature-based mitigation - comes potential job opportunities, which should be steered toward vulnerable communities wherever possible. For example, the coastal restoration economy creates 30 jobs for each million dollars invested. 10
"Natural and nature-based mitigation practices may include but are not limited to:
* Planting or conserving native vegetation that increases floodwater infiltration, traps debris, slows erosion, and contributes to land building and elevation gain;
* Restoring, protecting, or constructing wetlands to attenuate floodwaters both along coastlines and in the upper reaches of a watershed, thereby delaying and reducing downstream flood peaks;
* Removal or modification of structures such as dams, levees (including setbacks), and culverts to restore natural hydrology and floodplain function to allow floodwaters to spread out across the landscape and slow down, thereby reducing downstream flood impacts;
* Managing sediment budgets to help build and maintain coastal ecosystems, helping them to keep pace with sea level rise;
* Implementing "living shorelines" that use site-appropriate, native biological materials to stabilize shorelines as an alternative to hard armoring;
* Open space protection and restoration (including via buyouts and easements) of floodplains and barrier islands that buffer communities from the full force of coastal storms.
"Floodplain forests, wetlands, wide beaches, vegetated dunes, tidal marshes, coastal forests, shrublands, mangroves, and oyster reefs all have a role to play as a form of natural infrastructure that can be even more resilient than hard armoring, like bulkheads, create less erosion, and can be cheaper to maintain over the long-term.11 These natural features serve not only as vital fish and wildlife habitat and help to boost the lucrative outdoor economy, but also to keep communities safe by dissipating floodwaters and wave energy, while helping to maintain and, in places, gain land elevation.
"Taking this into account, the
"We are supportive of supplying communities with a diversity of tools to fund mitigation efforts, including the revolving loan fund for flood mitigation in Chairwoman Waters' proposal, and appreciate the priority given to severe repetitive loss properties and low-income homeowners, as well as the inclusion of environmental restoration activities as an eligible use of that fund. But loans alone are not enough to upgrade America's resilience to flooding. We also applaud the additional authorization of pre-disaster mitigation funds, as well as the proposed increase to Cost of Compliance (ICC) coverage up to
"We also encourage the Committee to look at other investments and programs to help mitigate risk, both within and beyond
"Additionally, per provisions in the 2018 Disaster Recovery Reform Act,
Ensure accurate mapping
"Flood maps are a critical component of the National Flood Insurance Program. These maps define the Special Flood Hazard Areas--the '100 year flood plain'--within which the purchase of flood insurance is required to obtain a federally backed mortgage. Because of this, it is essential that these maps accurately reflect risk. However, most of the flood maps
"We are very supportive of the discussion draft proposals to reauthorize the flood mapping program and provide funding to support flood mapping, as well as the requirement for
Continued movement toward risk-based rates, with support for reducing risk
"For too long, the federal government has masked true risk through subsidized rates, resulting in a program deeply in debt to taxpayers and contributing to or enabling coastal and riverine development, which has in turn contributed to the loss of functioning floodplains and natural features that reduce flood damages.
"We are not recommending a move to immediate actuarial rates; however, the current system is not transparent and incentivizes further development in vulnerable and ecologically sensitive floodplains and coastal areas. We recommend that all properties should either begin or continue to move towards risk-based rates, especially second residences, with annual increases capped to some percentage of current premiums to make the increases predictable. We also recommend that NFIP communication to policyholders-- particularly premium statements--contain what the property's risk-based rate is, as well as the current rate the policyholder is paying, to ensure property owners understand their risks.
"At the same time, we appreciate the Committee's attention to the significant equity issues related to affordability and the need to provide targeted assistance for low-income homeowners, vulnerable, frontline communities, and subsistence communities. We urge the committee to focus their affordability efforts on these at-risk communities, especially individuals who face higher flood threats due to land use decisions made by the federal and state governments and for whom full risk-based rates in a short time horizon would be unaffordable. This includes at-risk historic communities around the nation such as those in
"We also urge the Committee to consider that the best way to help vulnerable communities with affordability concerns is to invest in upfront mitigation assistance wherever possible and cost-effective, and focus premium support where needed for those who truly cannot afford their insurance rates.
"We were pleased to see the attention to affordability in the draft proposals, and look forward to working with the committee on those provisions once we have an opportunity to more fully analyze the proposal. However, as a coalition we are opposed to proposals to increase coverage limits, as this increases tax-payer risk.
Closing the Protection Gap
"People in harm's way need to understand their risks and purchase insurance. However, consumers should not only be able to access flood insurance through the National Flood Insurance Program, but should also have choice amongst private sector policies. Greater choice and competition will ensure over time that more people at risk get the flood coverage they need. As private insurers write flood coverage and become more comfortable and more familiar with the products, they will offer it more widely, helping to close the protection gap. SmarterSafer believes a functioning, financially stable NFIP is critical, and that we need NFIP along with a private market.
"Not only will additional insurance options help close the protection gap, but it will help on an issue of critical importance to those in harm's way and to this Committee--affordability. A recent study found that in the three states with over half of all flood insurance policies, even in the highest risk areas - V zones - between 62 and 88 percent of all homeowners could potentially access more affordable flood options in the private sector.18
"It is also important that the increased involvement of the private sector works in concert with the NFIP's broader program goals and responsibilities. Currently, mapping and floodplain management are partially funded through a fee on all NFIP policies. If policies move from NFIP to the private sector, it is critical that mapping and floodplain management funds must not be reduced--these funds benefit everyone in communities, not just those who purchase flood insurance.
"We applaud the Committee for releasing discussion drafts that take strides toward improving the National Flood Insurance Program. We are pleased to see updates to mapping as well as plans to address affordability and mitigation, and we hope to work with the Committee to strengthen and pass meaningful NFIP reauthorization. Thank you again for the opportunity to testify today."
* * *
1 Value of Coastal Wetlands for Flood Damage Reduction in
2 NOAA National
3 NOAA National
7 Demissie, M. and
8 OIA 2017. The Outdoor Recreation Economy. https://outdoorindustry.org/wp-content/uploads/2017/04/OIA_RecEconomy_FINAL_Single.pdf
10 Natural Infrastructure Report. Audubon. 2018. https://www.audubon.org/sites/default/files/audubon_infrastructure_jan192018.pdf
11 Sutton-Grier AE, Gittman RK, et al. Investing in Natural and Nature-Based Infrastructure: Building Better Along Our Coasts. Sustainability. 2018; 10(2):523.
18 Milliman. Could private flood insurance be more affordable than the NFIP? 2017. http://www.milliman.com/insight/2017/Could-private-flood-insurance-be-cheaper-than-the-NFIP/