SmarteSafer Coalition Issues Public Comment on FEMA Notice

WASHINGTON, Sept. 24 (TNSCAPv) -- The SmarteSafer Coalition has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information: National Flood Insurance Program's Community Rating System". The comment was written and posted on Sept. 22, 2021:

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At SmarterSafer, a national coalition made up of a diverse chorus of voices, we collaborate to champion a united front for environmentally responsible and fiscally sound approaches to natural catastrophe policy that promotes public safety. As the nation continues through devastating flooding and wildfire events, it is important that we more seriously prioritize actionable adaptation and mitigation solutions to prevent further damage in the future.

SmarterSafer commends the Federal Emergency Management Agency (FEMA) for seeking input on the Community Rating System (CRS). We believe that the CRS is important and vital part of the National Flood Insurance Program (NFIP). We also believe that federal government agencies must be active agents in understanding, communicating, and helping communities mitigate risk to promote greater climate-resiliency.

It is important to recognize the effects flooding has on communities. Flooding is the most expensive type of natural disaster in the U.S. because of the damage it causes to individuals, property, economic activity, and government operations, not to mention the fatal effect it has on human life. Rising sea levels and increased extreme weather events continue to pose an increasing threat to the livelihoods of many individuals, most of whom do not know that their homes and personal property are at risk for flooding. As extreme and unpredictable weather patterns pursue, flood risks only increase. SmarterSafer believes that as the intensity and frequency of floods increase, national agencies should do everything in their power to help communities prepare for what is to come.

Flood insurance acts as a social safety net, encouraging people to participate in the economy and act on their full economic potential because they know that their investments and livelihoods, such as their homes and businesses, will be financially protected, in some form, by the NFIP. This behavior promotes long-term economic growth. Conversely, it is the only federal program that actively encourages people to live in harm's way, with the ultimate impact of pushing individuals and entire communities into poverty.

We appreciate the CRS and the incentives that it provides for communities to implement pre-disaster mitigation strategies. SmarterSafer believes that the CRS is a key initiative in ensuring the financial solvency of the NFIP. A 2017 GAO report found that the best way to cure premium increases is through mitigation strategies as they reduce future flood risk and fiscal exposure./1

We urge FEMA, when promoting CRS mitigation strategies, to reconsider how these strategies are rated. It is paramount that mitigation measures implemented by communities are proven to lower risk and should be rewarded as such. To help, SmarterSafer recommends FEMA use new updated maps to better understand the breadth of flood risk and to better communicate to individuals the risk they face and rely more on evidence-based and solution driven approaches to resiliency. Additionally, FEMA's CRS should look to green and nature-based infrastructure and its ability to simultaneously protect communities and promote environmental conservation. Finally, we believe that a thorough re-evaluation of CRS-related credit mechanisms should be more practical and facilitate the creation of a more inclusive program.

As true flood risks are revealed, FEMA should work with trusted community leaders to engage in rigorous outreach campaigns to spread awareness of the CRS and encourage community involvement. Special attention needs to be put on disadvantaged communities that may not have expertise to fully participate in this program. If the goal is to help minimize the effects of flood-based disasters, then FEMA programs, including the NFIP and CRS, must carefully examine financial access to flood insurance and incentives for those disadvantaged communities to engage in pre-disaster mitigation. Pairing CRS outreach campaigns with more mitigation, technical, and implementation assistance will help give these communities access to cost-saving mechanisms and drive down the future debt of NFIP.

SmarterSafer members remain united in our support for fiscally sound and environmentally responsible approaches to managing natural catastrophe in different communities. We stand ready to be a resource to FEMA as the agency continues to explore and incorporate the benefits of disaster mitigation into different communities.

Respectfully,

SmarterSafer Coalition

MEMBERS

Environmental Organizations

American Rivers

Center for Climate and Energy Solutions (C2ES)

ConservAmerica

Defenders of Wildlife

National Wildlife Federation

Natural Resources Defense Council (NRDC)

Surfrider Foundation

Consumer and Taxpayer Advocates

Coalition to Reduce Spending

National Taxpayers Union

R Street Institute

Taxpayers for Common Sense

Taxpayers Protection Alliance

Insurer and Reinsurer Interests

Association of Bermuda Insurers and Reinsurers (ABIR)

The Chubb Corporation

Liberty Mutual Group

National Association of Mutual Insurance Companies (NAMIC)

National Flood Association

Reinsurance Association of America

Swiss Re

USAA

Mitigation Interests

Natural Hazard Mitigation Association

Housing

Habitat for Humanity

National Housing Conference

National Leased Housing Association

ALLIED ORGANIZATIONS

Allianz of America

American Consumer Institute

American Property Casualty Insurance Association (APCIA)

Center for Clean Air Policy

CoreLogic

Friends of the Earth

Institute for Liberty

Zurich Insurance

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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0021-0001

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