Insurance Institute for Business & Home Safety Issues Public Comment to HUD

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WASHINGTON, March 4 -- The Insurance Institute for Business and Home Safety, Richburg, South Carolina, has issued a public comment to the U.S. Department of Housing and Urban Development. The comment was posted on Feb. 22, 2023.

The comment, on Docket No. HUD-2022-0083-0001, was sent to Secretary Marcia Fudge; and Marion McFadden, principal deputy assistant secretary of the Regulations Division in the Office of General Counsel.

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The Insurance Institute for Business & Home Safety (IBHS) is pleased to offer the following comments for your consideration in response to the Department of Housing and Urban Development's Request for Information for HUD's Community Development Block Grant Disaster Recovery (CDBG-DR) Rules, Waivers, and Alternative Requirements. IBHS is a 501(c)(3) organization enabled by the property insurance industry's investment to fund building safety research that leads to real-world solutions for home and business owners, helping to create more resilient communities.

Severe weather disrupts lives, displaces families, and drives financial loss. IBHS delivers top-tier science and translates it into action so we can prevent avoidable suffering, strengthen our homes and businesses, inform the insurance industry, and support thriving communities. The perils we study at IBHS are part of the natural world in which we live, but social and economic disasters occur when these perils meet human populations that live or work in harm's way. To break the cycle of destruction, it is essential to address all aspects of the building performance chain: where you build, how you design and construct, and how well you maintain and repair. As a building science institute, IBHS focuses on the ways that weather behaves, what makes homes and businesses vulnerable, and how our buildings can be more resilient. We exist to help ensure that the spaces where people live, learn, work, worship, and gather are safe, stable, and as strong as the best science can equip them to be.

One of the ways we translate our science into action is through FORTIFIED(TM), a voluntary construction and re-roofing program designed to strengthen homes and commercial buildings against specific types of severe weather such as high winds, hail, hurricanes, and even tornadoes. Based on decades of lab- and field-based research, FORTIFIED is available for single-family, multifamily, and commercial structures.

Traditionally, resilience has been treated in the United States as an emergency management and disaster response issue. Although resilience is a significant issue in that space, it also must be understood as a housing issue, which is why CDBG-DR is so critical. IBHS would welcome the opportunity to engage further with HUD to discuss how our building science research and the FORTIFIED program can be used by states receiving CDBG-DR funding to engage in resilient centric disaster recovery. Please contact Michael Newman, IBHS's General Counsel, at [email protected] with follow-up questions.

Specific Information Requested

IBHS has no comment on those questions it does not respond to directly.

1(h). Are there CDBG-DR rules, waivers, or alternative requirements that should be revised to better align with federal disaster relief programs implemented by the Federal Emergency Management Agency (FEMA), the U.S. Small Business Administration, the U.S. Army Corps of Engineers, or other Federal agencies? Are there CDBG-DR rules, waivers, or alternative requirements that should be adopted by other Federal disaster recovery agencies?

Federal investments in the built environment should fund projects that are built to withstand all knowable risks for a generation. Put another way, federal investments in housing and other structures should be built with sufficient resilience to withstand the natural perils expected to affect the location of the funded structure for the service-life of the building. IBHS applauds HUD's February 2022 requirement that CDBG-DR grantees funds incorporate "mitigation measures" when funding activities to construct, reconstruct, or rehabilitate residential or nonresidential structures with CDBG-DR funds. The Department's guidance regarding the meaning of mitigation measures -- "[w]hen determining which mitigation measures to incorporate, grantees should design and construct structures to withstand existing and future climate impacts expected to occur over the service life of the project" -- is particularly powerful.

Climate resilient retrofits to structures--sometimes called natural hazard mitigation--are a crucial way that homeowners can mitigate the risks of natural perils, including severe weather associated with climate change. Due to the research conducted at IBHS, actions to strengthen the resilience of residential structures are not just knowable but known. As noted above, the FORTIFIED program, developed by IBHS and based on decades of scientific research, is a set of voluntary, beyond-code construction upgrades that improve a building's resistance to the effects of severe weather. In January 2022, the FORTIFIED program expanded to serve multifamily properties. To date, more than 45,000 structures have been designated by the FORTIFIED program.

FORTIFIED provides property owners with the ability to achieve three increasing levels of resilience: FORTIFIED Roof(TM), FORTIFIED Silver(TM), and FORTIFIED Gold(TM). In the retrofit context, FORTIFIED Roof is usually the designation level achieved by property owners. IBHS has made the roof the foundation of FORTIFIED because an estimated 70 to 90 percent of catastrophic homeowners insurance claims include roof damage, and damaged roofs can lead to water intrusion that can significantly amplify damage to property. The technical standard for FORTIFIED Roof provides a three-tiered system that strengthens the roof through (i) more and stronger nails, (ii) locked-down edges, and (iii) a sealed roof deck, which work in concert to keep the wind and rain out. FORTIFIED Silver adds increased levels of resilience through requirements on windows, doors, and siding, and FORTIFIED Gold adds requirements related to a continuous load path from the roof to the foundation.

The value of the program was made clear in the aftermath of Hurricane Ida, when structures built to FORTIFIED's requirements survived the Category 4-strength winds. One project stands out. Les Maisons de Bayou Lafourche, an affordable housing project in Lockport, Louisiana, was approximately 90 percent complete when the eye of Hurricane Ida passed overhead. As demonstrated in the below photographs, the project escaped nearly unscathed, unlike neighboring properties destroyed by the hurricane. The Les Maisons project--which was funded in part by the Louisiana Land Trust, the Louisiana Housing Corporation, and the Louisiana Office of Community Development using HUD CDBG-DR grants--is now occupied, providing safe, resilient, and affordable homes to numerous families.

These results are confirmed by post-disaster studies of the effectiveness of FORTIFIED Home, which has a substantially similar set of requirements to the FORTIFIED Multifamily(TM) technical standard. Studies following Hurricane Sally (in Alabama) and Hurricanes Matthew, Florence, Dorian, and Isaias (in North Carolina) concluded that FORTIFIED designated homes were less likely to have an insurance claim and, for those homes with insurance claims, claims were smaller on average.

The FORTIFIED program is not only an effective means of reducing risk by increasing resilience--it is a cost-effective investment for multifamily property owners. A 2022 study from the University of Alabama's Culverhouse College of Business (attached hereto as Appendix A) concluded that building or retrofitting to FORTIFIED has relatively minimal costs and a strong rate of return. Regarding new construction, the study found that the additional cost of building a multifamily structure to FORTIFIED Gold ranged from approximately $12,000 to $43,000 for a hypothetical 30,000 square foot structure with 30 units (a marginal cost increase of no more than 1.5 percent of total cost of construction), depending on area of the country and the code requirements in place. This calculation includes both the cost of the retrofit and the third-party evaluation services that document compliance with the technical standard. In return, property owners could reduce annual insurance premiums by $1201 to $6549. For investments in FORTIFIED Gold, property owners could realize an 8.1 to 72 percent internal rate of return.

Regarding retrofits, the study found that the additional cost of retrofitting an existing multifamily property to FORTIFIED Roof in hurricane and high wind zones is about $9,000 for the same sized hypothetical structure, which includes both the cost of the retrofit and the third-party evaluation services, in hurricane and high wind zones; and approximately $19,000 in high wind and hail zones (with the additional cost arising from hail-resistant roof cover). On the other side of the equation, the study found that obtaining a FORTIFIED Roof designation could reduce annual insurance premiums by $791 to $1,533, depending on where the property is located. For investments in a FORTIFIED Roof designation, a property owner could realize an 8.3 to 35 percent internal rate of return on the investment for the property owner.

Additionally, resilience requirements in government programs like CDBG-DR have an important effect on workforce and skills development. We have observed in Alabama and Louisiana that references to the FORTIFIED program by government programs has facilitated opportunities to educate developers, builders, and contractors about FORTIFIED. Once these essential participants in the housing market build to FORTIFIED because of program or funding requirements, they develop a comfort level with the work and costs associated with FORTIFIED. This can result in voluntary take-up on other projects unconnected to government funding sources. In this way, CDBG-DR resilience requirements can have an even broader impact on the built environment than those projects funded by grantees.

We support HUD keeping this requirement as part of the CDBG-DR program, and encourage HUD, as well as other federal agencies and departments, to consider adoption of similar requirements across all federal spending on the built environment. This will allow our nation to better center resilience in disaster recovery and other federal investments in housing so that future natural disasters cause less suffering.

1(k). What types of technical assistance should HUD offer grantees to support a timely, equitable, resilient, and successful recovery? Are there phases of CDBG-DR grants (e.g., initial administrative work, action plan development, program implementation, etc.) where providing more intensive technical assistance would be more effective? What types of technical assistance should States offer local government subrecipients to support a timely, equitable, resilient, and successful recovery?

States have different capabilities, sophistication, and awareness of options for building with resilience to severe weather. As HUD continues to center resilience in CDBG-DR requirements, including the "mitigation measures" requirement from the February 2022 Consolidated Notice, some states may need additional technical assistance on how to meet this requirement, particularly in the development of their Action Plans. HUD technical assistance could help grant recipients find ways to build climate-resilient housing and programs, such as IBHS's FORTIFIED program, thereby making the process easier for grantees and subrecipients.

1(l). What types of technical assistance or other measures should HUD offer to better assist grantees in preventing and identifying potential contractor fraud and to strengthen the ability of grantees to assist beneficiaries when they are subject to contractor fraud?

Fraudulent and/or deceptive actions by unscrupulous contractors can contribute to the stress and displacement of property owners, particularly in the aftermath of natural disasters. The FORTIFIED program seeks to reduce the actual instances and likelihood of fraud among contractors who are building or retrofitting to FORTIFIED standards through an independent, third-party verification process by third party Evaluators. While not a replacement for building code enforcement, FORTIFIED Evaluators, who must complete an IBHS training program and pass an exam prior to conducting on-site inspections, verify and document that required FORTIFIED features have been designed and constructed properly. Evaluator reviews are done at critical stages in the construction process when visual verification is possible. Complete documentation on each structure is provided by the Evaluator and then subject to a quality assurance process by IBHS before a designation is provided. HUD technical assistance could help grant recipients identify programs, such as IBHS's FORTIFIED, that use third-party evaluators and auditors to inspect work done by contractors and reduce contractor fraud.

1(m). What mitigation techniques or requirements could HUD employ to enhance grantee capacity to comprehensively assess the likelihood of potential fraud risk and to otherwise detect and prevent fraud in grantee programs?

Through technical assistance and other measures, HUD can help grantees identify programs and investments that are designed to increase resilience while also identifying potential contactor fraud issues. For example, IBHS's FORTIFIED program is not limited to a technical standard; independent, third-party verification is an essential component of the program. In the multifamily context, property owners hire an independent evaluator to review project designs and document that the re-roofing or construction project is both designed and constructed to IBHS's program requirements. Such verification is particularly important considering the variation in building code adoption and enforcement around the country. In a 2022 analysis of building code quality throughout the nation, FEMA put 39 states in the lowest category, with 19 states receiving a score of 0 out of 100. Per the Biden-Harris Administration, "only about 35% of counties, cities, and towns [nationwide] have the latest codes in place, leaving millions of Americans more vulnerable to extreme weather and higher energy costs." While FORTIFIED is not intended to replace a strongly enforced, modern building code, the combination of the program's beyond-code technical standard and third-party verification process creates consistent resiliency across jurisdictions while also reducing the opportunity for contractor fraud.

2(a). Should CDBG-DR rules, waivers, or alternative requirements be written to 1) encourage or require grantees to first address disaster recovery housing needs prior to other recovery needs (e.g., infrastructure), or 2) encourage or require grantees to invest in whole community recovery in proportion to its unmet recovery need (e.g., housing, infrastructure, economic revitalization, and mitigation)?

We encourage HUD to address disaster recovery housing needs with resilience and natural hazard mitigation centered as a critical component of that response. This approach has several benefits that further HUD's core mission of creating "strong, sustainable, inclusive communities and quality affordable homes for all." Put simply, homes are not "quality" unless they are sufficiently resilient to withstand knowable risk from severe weather. Further, they are not "affordable" unless they provide savings to the resident not just on the day of purchase (or lease signing), but on an ongoing basis as well. Just as investment in energy efficiency and renewable energy sources is good for the environment and residents' operational costs, so too do investments in resilience provide ongoing savings to residents. As a general principle, risk reduction results in avoided damages from severe weather and reduced insurance premiums that reflect the reduction in risk. Given the state regulation of insurance, these savings vary from state to state. By way of example, homeowners can obtain discounts up to 42 percent (Oklahoma), 55 percent (Mississippi), or 55 percent (Alabama). In the multifamily space, a 2022 study from the University of Alabama's Culverhouse College of Business (attached hereto as Appendix A) concluded that building or retrofitting to FORTIFIED has relatively minimal costs and a strong internal rate of return of 8.1-72 percent for investments in FORTIFID Gold and 8.3 to 35 percent for investments in FORTIFIED Roof.

Using CDBG-DR grants to build and retrofit resilient housing helps ensure that people are not only housed, but that they remain housed following natural disasters. In addition, quality housing that withstands severe weather allows working families to return home following natural disasters, which in turn supports local economies and economic revitalization by preventing businesses from closing from low demand and want of workers, protecting the local tax base. Whole community recovery requires support across multiple lanes, and quality housing is a foundational element, without which the other factors are much harder to achieve.

2(g). How can CDBG-DR rules, waivers, or alternative requirements be modified or eliminated to better address the unmet recovery and mitigation needs of affordable rental housing, public housing, and housing for vulnerable populations?

According to sociological research, people who are disabled, elderly, low income, and otherwise vulnerable are less likely to prepare for natural disasters, evacuate safely, avoid physical or psychological trauma, or recover quickly and fully. Residents with low incomes account for a meaningful percentage of the population in many coastal communities and other areas that face climate risk, often living in the most vulnerable types of housing.

In this context, HUD's February 2022 requirement that grantees of CDBG-DR funds incorporate "mitigation measures" when carrying out activities to construct, reconstruct, or rehabilitate residential or non-residential structures with CDBG-DR funds was a critical reform that should be maintained in future CDBG-DR notices, and hopefully expanded to include other funding from HUD and other federal agencies and departments.

Applying beyond code construction standards for new housing construction and climate resilience-enhancing retrofits to existing housing are crucial ways that the owners of affordable rental housing, public housing, and housing for vulnerable populations can better serve residents and advance HUD's mission of providing "quality" housing, while also reducing operating costs by reducing risk of loss and, relatedly, possibly reducing the cost of insurance, thus meeting HUD's mission of providing "affordable" housing.

A 2022 study (https://alabama.app.box.com/s/4w8bahzwqgettjzayw9zo9989h9k95wm) from the University of Alabama's Culverhouse College of Business (attached hereto as Appendix A) concluded that building or retrofitting to FORTIFIED has relatively minimal costs and a strong rate of return. Regarding new construction, the study found that the additional cost of building a multifamily structure to FORTIFIED Gold ranged from approximately $12,000 to $43,000 (a marginal cost increase of no more than 1.5 percent of total cost of construction), depending on area of the country and the code requirements in place. This calculation includes both the cost of the retrofit and the third-party evaluation services that document compliance with the technical standard. In return, property owners could reduce annual insurance premiums by $1201 to $6549. For investments in FORTIFIED Gold, property owners could realize an 8.1 to 72 percent internal rate of return.

Regarding retrofits, the study found that the additional cost of retrofitting an existing multifamily property to FORTIFIED Roof in hurricane and high wind zones is about $9,000, which includes both the cost of the retrofit and the third-party evaluation services, in hurricane and high wind zones; and approximately $19,000 in high wind and hail zones (with the additional cost arising from hail-resistant roof cover). On the other side of the equation, the study found that obtaining a FORTIFIED Roof designation could reduce annual insurance premiums by $791 to $1,533, depending on where the property is located. For investments in a FORTIFIED Roof designation, a property owner could realize an 8.3 to 35 percent internal rate of return on the investment for the property owner.

5(a). What CDBG-DR rules, waivers, or alternative requirements, if any, should be modified or eliminated to ensure grantees equitably allocate resources and adequately address disaster-related needs of the most impacted, vulnerable, and underserved communities?

According to sociological research, people who are disabled, elderly, low income, and otherwise vulnerable are less likely to prepare for natural disasters, evacuate safely, avoid physical or psychological trauma, or recover quickly and fully. Low-income residents account for a meaningful percentage of the population in many coastal communities and other areas that face climate risk, often living in the most vulnerable types of housing. In this context, resilience is a critical element of equitably allocating resources and addressing disaster-related needs of the most impacted, vulnerable, and historically marginalized communities.

Voluntary organizations active in disasters (VOADs) and government agencies that engage in disaster recovery are too familiar with a common calculation conducted when addressing disasters with finite resources: every additional dollar directed toward beyond-code resilience reduces the number of projects that can be touched. However, with the increase in severe weather and attendant loss - of the 341 weather and climate disasters since 1980 where overall damages/costs reached or exceeded $1 billion (as analyzed by NOAA), over a quarter (89) have occurred in the past five years - resilience must become a foundational element of equitable disaster recovery. Many property owners are finding that they must "build it right or build it twice." Across many hazards, we know how to build and retrofit more resilient structures. Through requirements, incentives, technical assistance, HUD can continue to make CDBG-DR funded disaster recovery equitable and resilient centric, thus furthering its mission of creating "strong, sustainable, inclusive communities and quality affordable homes".

6(a). Are there CDBG-DR rules, waivers, or alternative requirements, and/or policies that prevent or limit grantees' focus on mitigating the impacts of climate change, particularly for those areas disproportionately impacted by climate change? If so, please describe.

Although HUD's February 2022 requirement that grantees of CDBG-DR funds incorporate "mitigation measures" when carrying out activities to construct, reconstruct, or rehabilitate residential or non-residential structures with CDBG-DR funds was critical, grantees and subrecipients need additional support to identify ways to meet this requirement in a verifiable way. States have different capabilities, sophistication and awareness of options for building with resilience to severe weather. HUD policies prioritizing education, training, and technical assistance on climate-resilient housing and programs, such as IBHS's FORTIFIED program, could facilitate easier compliance with resilience requirements in the CDBG-DR program.

6(b). How can CDBG-DR's rules, waivers, or alternative requirements or policies be modified or eliminated to encourage grantees to use CDBG-DR funds to invest in activities that incorporate resilience and mitigate the impacts of climate change?

HUD's February 2022 requirement that grantees of CDBG-DR funds incorporate "mitigation measures" when carrying out activities to construct, reconstruct, or rehabilitate residential or non-residential structures with CDBG-DR funds was a critical reform thatshould be maintained in future CDBG-DR notices. This requirement will help CDBG-DR grantees and subrecipients identify and implementsolutions that mitigate the impacts of climate change by increasing the resilience of the built environment.

The Consolidated Notice included an additional requirement regarding Green and resilient building standard for new construction and reconstruction of housing, which "requires that all [construction and reconstruction of housing and residential buildings] and assisted with CDBGDR funds meet an industry-recognized standard that has achieved certification under (i) Enterprise Green Communities; (ii) LEED (New Construction, Homes, Midrise, Existing Buildings Operations and Maintenance, or Neighborhood Development); (iii) ICC-700 National Green Building Standard Green+Resilience; Living Building Challenge; or (v) any other equivalent comprehensive green building program acceptable to HUD." While framed as a green and resilient building standard requirement, this requirement is far more focused on the "green and sustainable" part of that issue. Moreover, by including green and resilient standards as options for grantees to choose from, a standard focused on green construction practices could meet the requirement at the expense of resilience, and vice versa. We encourage HUD to make separate requirements for green building standards and resilient building standards. Unlike green standards, which are generally applicable across all regions of the United States, resilient building standards are risk-specific, and so any resilient building standard would have to be responsive to the risks within the grantee's region. One tool for identifying such risks is FEMA's National Risk Index. Resilient construction standards that HUD could consider include IBHS's FORTIFIED program for coastal and inland wind risk and IBHS's Wildfire Prepared Home program for wildfire risk. Wildfire Prepared Home is a voluntary, research-based mitigation program designed to meaningfully reduce risk of damage from wildfire. Owners of single-family homes can achieve a designation by undertaking and verifying a set of requisite mitigation actions concerning their home's roof, structure, and defensible space. The program is currently available to California residents.

7(a). How can CDBG-DR rules, waivers, or alternative requirements be modified or eliminated to ensure that grantees are mitigating natural hazard risks (e.g., sea level rise, high winds, storm surge, flooding, volcanic eruption, and wildfire risk), while also minimizing displacement of members of families, individuals, or entities such as businesses, farms, or nonprofit organizations from their homes and neighborhoods?

Weather events become natural disasters by devastating communities, damaging property, disrupting local economies, and dislocating families. This need not be the case. In many respects, scientific study - such as the kind conducted at IBHS's Research Center - has resulted in design and construction practices and standards that allow the built environment to withstand severe weather. The way to strengthen our nation's housing stock is not just knowable, it is known. By requiring that CDBG-DR grantees construct and rehabilitate housing and other structures to a level of resilience that can withstand knowable risks, HUD can help reduce and, in some cases, eliminate the damage, disruption and dislocation too often associated with natural disasters. HUD's inclusion of the "mitigation measures" requirement in the 2022 Consolidated Notice was an important step in centering resilience in construction funded with CDBG-DR grants.

8(a). Should the Department impose construction standards that require the use of CDBG- DR funds to adhere to current editions of the International Building Code (IBC), International Existing Building Code (IEBC), International Residential Code (IRC), International Wildland-Urban Interface Code (IWUIC), International Plumbing Code (IPC), International Mechanical Code (IMC), International Fuel Gas Code (IFGC), International Fire Code (IFC), ICC 500-14, ICC/NSSA Standard on the Design and Construction of Storm Shelters, and ICC 600-14 Standard for Residential Construction in High-wind Regions?

Yes. In a 2022 analysis of building code quality throughout the nation, FEMA put 39 states in the lowest category, with 19 states receiving a score of 0 out of 100. Per the Biden-Harris Administration, "only about 35% of counties, cities, and towns [nationwide] have the latest codes in place, leaving millions of Americans more vulnerable to extreme weather and higher energy costs." Housing or other structures built outside the 35 percent of jurisdictions with modern, enforced codes do not reflect advances in building science and construction practices and cannot be considered "quality". Additionally, having to rebuild or substantially repair homes after natural disasters because they were not built using know resiliency factors cuts against the housing also being "affordable." Requiring that CDBG-DR funded structures be built to - at a minimum - modern codes and standards is a necessary step. However, building codes are only useful if they are enforced as well as adopted. HUD requirements that CDBG-funded buildings be constructed to modern codes will be difficult to enforce without state or local code officials who are educated and authorized to inspect and enforce those iterations of codes and standards.

While FORTIFIED does not replace a strongly enforced, modern building code, the combination of the program's beyond-code technical standard and third-party verification process creates consistent resiliency across jurisdictions that lack enforcement mechanisms.

b. Should HUD better align its building code requirements for CDBG-DR and CDBG-MIT with those required by FEMA or other Federal agencies? If so, how?

In 2022, the Biden-Harris Administration announced the launch of a National Initiative to Advance Building Codes. The Initiative calls for a "comprehensive review of federal funding and financing of building construction, to ensure federally-supported housing and other building projects follow modern building codes and standards to the greatest extent feasible." The Initiative also calls for providing "incentives and support for communities to adopt current building codes and standards by providing technical assistance, implementing proven strategies and best practices--such as those in the new Federal Emergency Management Agency (FEMA) Building Codes Strategy--across all relevant agencies in the federal government, and using mapping tools that help track code adoption based on energy efficiency and local hazards such as flood, earthquake, tornado, and hurricane risk." Consistent with this Initiative, HUD should align its requirements for CDBG-DR and CDBG-MIT with modern building codes and standards and respond to local hazards such as flood, earthquake, tornado, and hurricane risk. It can do so by requiring modern codes as a minimum standard, maintaining its 2022 requirement for "mitigation measures," expanding its list of acceptable green and resilient building standards, and requiring that housing projects meet both green and resilient building standards, rather than just one or the other.

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Thank you for the opportunity to contribute to this critical issue. If you have any questions, please do not hesitate to contact me at [email protected].

Sincerely,

Michael Newman

General Counsel

Insurance Institute for Business & Home Safety

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Original text here: https://downloads.regulations.gov/HUD-2022-0083-0024/attachment_1.pdf

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com