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Please find our comments below on changes to the NFIP. These comments are limited to riverine flooding as we do not have coastal areas. We also generally do not have levees.
The FIRMS in the region are outdated. Virtually all
Now we come to whether the standards need updating. The short answer is, yes.
As seen above, the maps, and the accompanying base flood elevations are not highly accurate. But they are meant to be used to elevate homes and businesses to an exact height to avoid flood damage. The maps say the 1% chance flood (commonly thought of as the 100-year flood) will only go so high, and one inch above that is safe enough that insurance is not required. As
Floodways are special areas within flood zones that typically carry greater heights and velocities. To distinguish these areas when talking with lay audiences that can easily conflate 'flood fringe', 'flood hazard area', 'floodplain', and 'floodway', we refer to areas mapped as floodway as the 'death zone'. That may be a bit dramatic for
With the above changes,
Properties that are primary residences that flood disastrously once, such that the building is a 100% loss, should be automatically offered a 100% buyout. This buyout offer must be quickly made as owners make decisions about whether to repair or rebuild within days. To do this,
Properties that flood repeatedly are obviously an indication that the map is wrong in that spot (if they are post-FIRM properties), since they would have been built to theoretically be above the base flood. Pre-firm properties that flood repeatedly are understandable, but should have high premiums to reflect that risk. In both cases, those properties that become severe repetitive loss (SRL) properties need to stop being a drain on the NIFP program, a source of trauma for families, a source of pollution to waterways, and a risk to responders in rescues. SRL properties that have cumulative damage exceeding twice the value of the structure and are primary residences should be offered a choice between a 100% buyout, or permanent removal from the NFIP upon the expiration of the current policy and a prohibition on future Individual Assistance benefits. Secondary residences should go to full actuarial rates at the next policy period and be offered a 75% buyout. For owners that choose to stay, the loss of insurance and future benefits must be recorded in the land records. As above, case managers may be needed for some residents. For SRL rental properties where tenants will be displaced, Uniform Relocation Assistance (URA) funding should be provided.
Local hazard mitigation planning can play a critical role in lessening future disaster damage. However, lack of data from
Thank you for your consideration.
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The notice can be viewed at: https://www.regulations.gov/document/FEMA-2021-0024-0001
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