RisQ Issues Public Comment on FEMA Notice
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The executive summary points from a full publication can be found below. The full publication can be found here: https://risq-inc.medium.com/economic-and-racial-inequality-in-fema-sfha-flood-zone-designations-450b3019a78d - ~76% of Single-Family Residential flood risk in the US is not covered by the FEMA Special Flood Hazard Assessment (SFHA) 100-year flood zones that are also used to determine residential flood insurance requirements for government-backed home loans.
- Populations that spend the most relative income on housing are ~1.5x more likely than the least housing cost-burdened to be exposed to flood risk not covered by FEMA SFHAs. SFHAs in their current form are financially regressive with respect to flood risk and resilience.
- Even after accounting for housing cost-burden, non-white populations are significantly more likely to face flood risk that is not captured in FEMA SFHAs -- at every level of flood risk. Asian, Black, Native American, and Latino populations are only ~29%, ~65%, ~70%, and ~72%, respectively, as likely as white-alone populations to have flood risk accounted for by FEMA SFHAs.
- With no evidence for correlation between race/affluence and NFIP insurance policy take-up rates, SFHA disparities result in poorer people and communities of color bearing a disproportionate burden of uninsured flood risk and, all other things held equal, a disproportionate amount of mortgage delinquency and wealth destruction.
- Climate change without any change in SFHA approach is set to enhance inequality in the US, with a ~19% increase in expected annual losses to 2050 in inland areas, which are where the greatest SFHA inequality exists.
- Risk Rating 2.0 (RR2.0), which is designed in large part to make the NFIP more equitable, only addresses premium re-pricing in existing FEMA SFHAs. We clearly show that it will still fall short of achieving that goal given historical preferential investment in generally whiter and more affluent neighborhoods.
- Government Sponsored Entities (GSEs) --
- To build a more equitable and sustainable program,
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0011-0001
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