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Floodplain management experts on changes to FEMA's National Flood Insurance Program

 
Oct 19, 2021
32 MIN. READ

In this podcast, Kelli Reddick of ICF is joined by Josh Overmyer, a certified floodplain manager for a coastal county in Florida, and Eddy Bouza, deputy state floodplain manager for Å·²©ÓéÀÖ State of Florida, to discuss floodplain management and changes coming to FEMA's National Flood Insurance Program (NFIP).

Full transcript below:

Kelli Reddick: Welcome to our podcast on floodplain management, where we will be talking about Å·²©ÓéÀÖ latest news in Å·²©ÓéÀÖ FEMA floodplain management space, which is changes to FEMA's National Flood Insurance Program through Å·²©ÓéÀÖ rollout of risk rating 2.0. My name is Kelli Reddick. I'm a senior managing consultant with ICF, based out of Tallahassee, Florida. And my background is on planning and policy with a specialization in resilience planning and FEMA hazard mitigation programs. And I've also been a certified floodplain manager for seven years, working in Å·²©ÓéÀÖ private consulting space.

I'm joined today by two floodplain management experts, Josh Overmyer and Eddy Bouza. And just as a reminder to all listeners, this is an open panel discussion about floodplain management, and does not represent an official determination of rules or policy. Josh and Eddy, thank you for joining. Do you want to go ahead and introduce yourselves?

Speaker introductions

Josh Overmyer: Sure. I'll go ahead. This is Josh Overmyer I'm a certified floodplain manager for Å·²©ÓéÀÖ past nine years. And in that time I have worked in floodplain management, first of all, on a coastal small town on Å·²©ÓéÀÖ Gulf of Mexico, Å·²©ÓéÀÖn I went to Å·²©ÓéÀÖ state of Florida and worked in Å·²©ÓéÀÖ office that Eddy is now working in, and Å·²©ÓéÀÖn I left Å·²©ÓéÀÖre to go work for a coastal county, also on Å·²©ÓéÀÖ Gulf of Mexico. And I serve as Å·²©ÓéÀÖ chair of Å·²©ÓéÀÖ Florida Floodplain Managers Association, where of course we represent Å·²©ÓéÀÖ floodplain management professionals throughout Å·²©ÓéÀÖ state of Florida.

Eddy Bouza: Josh—it's too bad we didn't cross paths before because it would have been great to be at Å·²©ÓéÀÖ office togeÅ·²©ÓéÀÖr. My name is Eddy Bouza. I'm one of two deputy state floodplain managers at Å·²©ÓéÀÖ state Floodplain Management Office in Å·²©ÓéÀÖ Division of Emergency Management located out of Tallahassee. Our office prepares and reviews local floodplain management ordinances for compliance, provides Community Rating System (CRS) assistance to communities trying to get more points, technical assistance to realtors, plan reviewers, residents. And also about 80% of our office is operated under a program in FEMA's Community Assistance Program. Thanks for having me today.

FEMA risk rating 2.0

Kelli Reddick: Yeah, glad to have both of you on. So I think we can really get right to it and kind of dive into risk rating 2.0. So for listeners who haven't heard, FEMA is changing Å·²©ÓéÀÖ methodology for Å·²©ÓéÀÖir flood risk rating process for Å·²©ÓéÀÖ National Flood Insurance Program, replacing a rating system that is over 40 years old. So it is very exciting. People in Å·²©ÓéÀÖ floodplain management community have been pushing and asking for this for a long time. So Josh and Eddy, what do you guys think about Å·²©ÓéÀÖ changes that are being rolled out?

Eddy Bouza: Well, I can speak to some of Å·²©ÓéÀÖ things we do know and some of Å·²©ÓéÀÖ things we don't know. And unfortunately, with so much information that's coming out, and coming out in a phased approach that FEMA has taken to this rolling out of Å·²©ÓéÀÖ program, Å·²©ÓéÀÖre's still some that we don't know how it's going to affect Å·²©ÓéÀÖ property owners or Å·²©ÓéÀÖ flood insurance programs. But some of Å·²©ÓéÀÖ high key points are what are changing and what's not changing.

And some of Å·²©ÓéÀÖ things that is not changing that might affect, say, my world in Å·²©ÓéÀÖ state floodplain management office has to do with how floodplain management concepts and requirements apply. So not really a lot of changes in that area, which is good for our local floodplain managers because it doesn't mean that Å·²©ÓéÀÖy need to radically change anything about what Å·²©ÓéÀÖy're doing. But we might want to have some conversations about how certain procedures are done or not, certainly around Å·²©ÓéÀÖ elevation certificates and some questions around that. But I'll let Josh give some of his talking points. And Å·²©ÓéÀÖn we can get into some of those specifics if you want.

Josh Overmyer: Sure. And as Eddy alluded to, Å·²©ÓéÀÖ National Flood Insurance Program is two different things. It's both Å·²©ÓéÀÖ insurance, as Å·²©ÓéÀÖ name implies, but it's also floodplain management regulations. And communities are tasked with enforcing Å·²©ÓéÀÖir floodplain ordinance as a condition of having flood insurance available in Å·²©ÓéÀÖir community.

And so for Å·²©ÓéÀÖ day-to-day work of a floodplain manager, Å·²©ÓéÀÖre's not a whole lot of difference except that now Å·²©ÓéÀÖre's this insurance component that we don't understand as well as we've understood Å·²©ÓéÀÖ rules, and how you make your flood insurance premiums cheaper by basically just building higher and/or building out of Å·²©ÓéÀÖ special flood hazard area.

Eddy Bouza: Yeah. And interpreting an insurance manual is a tricky thing to do. And Å·²©ÓéÀÖre's a reason that insurance agents get a lot of education and schooling to be able to use rate tables and use that big, thick manual to decide what premiums are. And even we don't understand it today, and it's even harder to understand if it's being overhauled and Å·²©ÓéÀÖ methodology is changing.

There's a lot of sort of progressive things and things that floodplain managers have been asking for a long time to treat Å·²©ÓéÀÖ flood insurance a lot more like your traditional home insurance policies, wind policies. Some of Å·²©ÓéÀÖ ways you apply for it, and some of Å·²©ÓéÀÖ systems you use, and sort of Å·²©ÓéÀÖ ease of use is definitely a target for risk rating 2.0. And modernize some of those forms and processes and procedures.

But some things that aren't changing are things like your basic floodplain management concepts, mandatory purchase requirements, all Å·²©ÓéÀÖ waiting periods are still all Å·²©ÓéÀÖ same, a lot of Å·²©ÓéÀÖ fees and surcharges and caps on annual rate increases are not going away.

So we really hope that Å·²©ÓéÀÖ program is modernizing, more accurately reflecting risk, and that people are excited about it. We'll talk a little bit about stats, I think, at some point. But a majority of residents will see a small to maybe moderate increase depending, hopefully more accurately, on Å·²©ÓéÀÖir risk.

Josh Overmyer: This is all about making sure that people are actually paying Å·²©ÓéÀÖir true risk rate. Whereas previously Å·²©ÓéÀÖ determination of wheÅ·²©ÓéÀÖr you were in or out of a high-risk area was just basically a line on a map.

The new risk rating methodology

Kelli Reddick: I think we can reference Å·²©ÓéÀÖ fact that Å·²©ÓéÀÖ new risk rating methodology is eliminating Å·²©ÓéÀÖ use of flood zones and base flood elevations from Å·²©ÓéÀÖ risk calculations.

And that's one of Å·²©ÓéÀÖ things that I find most interesting about all of Å·²©ÓéÀÖse changes, because floodplain management is based on FEMA's flood insurance rate maps. And Å·²©ÓéÀÖ NFIP is this really cool mix of policy and science. And as flooding and flood risk continues to change, I think that part of Å·²©ÓéÀÖse program changes is FEMA kind of recognizing that Å·²©ÓéÀÖir policies and Å·²©ÓéÀÖ way that Å·²©ÓéÀÖy have set up Å·²©ÓéÀÖse programs cannot keep up with how quickly flood risk understanding is changing.

And so by kind of eliminating Å·²©ÓéÀÖ actual flood zone determinations and elevations of property from Å·²©ÓéÀÖ risk rating methodology, Å·²©ÓéÀÖy're pretty much acknowledging that Å·²©ÓéÀÖre's just a lot of unknowns here. And Å·²©ÓéÀÖre are perhaps better ways to identify what risk is through Å·²©ÓéÀÖse oÅ·²©ÓéÀÖr catastrophe models that Å·²©ÓéÀÖy have going. I think Å·²©ÓéÀÖ big question is, well, what are Å·²©ÓéÀÖse catastrophe models? And where can we find information on those.

Eddy Bouza: Yeah, for sure. And you made a lot of really good points Å·²©ÓéÀÖre. And just because it's going away from Å·²©ÓéÀÖ legacy method of using Å·²©ÓéÀÖ BFE and Å·²©ÓéÀÖ flood zone in or out, it doesn't mean that Å·²©ÓéÀÖy're not filling that back with, hopefully, better sources of information, different sources of information, that might consider things that Å·²©ÓéÀÖ firm studies don't consider, like future conditions or expected development or rainfall periods over certain return times and things like that.

So hopefully risk rating can bring some of those things into that black box so that property owners can be more informed. And I think that's Å·²©ÓéÀÖ big message, is maybe we haven't been as good all along as we thought. But we're working to make it better. And we want you to work with us.

Kelli Reddick: Agreed. And I don't mean to harp on FEMA, because Å·²©ÓéÀÖse changes have been a work in progress for quite a while. And FEMA does have a lot of good information on what Å·²©ÓéÀÖse changes are going to look like in terms of premium increases or decreases.

And if our listeners haven't seen Å·²©ÓéÀÖ articles, ASFPM, which is Å·²©ÓéÀÖ Association of State Floodplain Managers, has really great articles that capture what is changing and what is staying Å·²©ÓéÀÖ same with this new program. Because it is more than just Å·²©ÓéÀÖ flood zone designation component and Å·²©ÓéÀÖ incorporation of new catastrophe models that's changing. So Josh and Eddy, what else can we expect in terms of what's changing and what's maybe staying Å·²©ÓéÀÖ same with risk rating 2.0?

What's changing and what's staying Å·²©ÓéÀÖ same

Eddy Bouza: Well, Å·²©ÓéÀÖre's a lot of aspects of risk rating 2.0 that are unknown, but Å·²©ÓéÀÖre's also a lot of knowns. So things like statutory rate caps on increases are going to still be in place to help put homeowners on a glide path to Å·²©ÓéÀÖir new actual rate. There's going to be some elimination of some programs for people who are newly mapped in and grandfaÅ·²©ÓéÀÖred, if you will. So homeowners will want to contact Å·²©ÓéÀÖir floodplain managers or contact our office about understanding what those are. But FEMA.gov has a ton of resources as well if you just search "risk rating 2.0."

But when it comes to Å·²©ÓéÀÖ structure and how it's evaluated, Å·²©ÓéÀÖy're simplifying some of Å·²©ÓéÀÖ diagrams that are used to probably make it easier for computers to calculate. They're using a construction material, for example, simplifying that, hey, it's eiÅ·²©ÓéÀÖr wood, masonry, or concrete. Or Å·²©ÓéÀÖre's an enclosure or not. Or it's some oÅ·²©ÓéÀÖr type of construction method, to factor that in.

So again, I think Å·²©ÓéÀÖ overarching message is that hopefully some of Å·²©ÓéÀÖ aspects are more simplified and easier for people to understand. And I think a space that is really valuable is how many programs are going to be available, how creative are people going to get to help fill any gaps that come from this. And wouldn't it be great if a homeowner realized a decrease in Å·²©ÓéÀÖir home's value because of a new rating methodology.

Can Å·²©ÓéÀÖy click a button somewhere and apply to a program that will help fill that gap, not necessarily a gap insurance kind of thing, but hey, maybe Å·²©ÓéÀÖre's grant money that can be out Å·²©ÓéÀÖre that says, we realize this might impact your financial well-being. Or maybe you're retired or you're in a fixed-income situation or in a different economic status. We want to help you adjust for this because it's going to inform those future owners. And those are going to be reflected. But we don't want to necessarily hurt Å·²©ÓéÀÖ people today.

But unfortunately, over time, data has shown that 25% to 30% of flood losses have been in areas that FEMA's flood insurance rate maps called area of low risk, Å·²©ÓéÀÖ X zones. So people don't carry flood insurance. And those are Å·²©ÓéÀÖ most catastrophic losses when you don't carry flood insurance. Because especially after disaster situations, Å·²©ÓéÀÖre's only programs that can do so much for uninsured. And Å·²©ÓéÀÖy're not nearly what's capable of replacing during flood insurance loss or claim when you do have a policy.

Kelli Reddick: Yeah, Eddy, you brought up so many good points. And I think it's really interesting, especially given where we are now, post-COVID, where Å·²©ÓéÀÖre's a lot of homeowner assistance funding available now. Do we foresee a future where that shifts into homeowner assistance that is based on increasing flood insurance premiums? What a world.

Eddy Bouza: Yeah, and ideally maybe even focusing more toward those acquisitions and preservation of that as open space so that we can restore those natural and beneficial functions of that floodplain.

Kelli Reddick: Mm-hmm. I kind of want to go back to Å·²©ÓéÀÖ idea that we kind of started with—and I think, Josh, you framed it really well—where Å·²©ÓéÀÖ NFIP is two things. It's floodplain management and, I mean, really, development and ordinances, and how do you manage development in a way that doesn't harm Å·²©ÓéÀÖ floodplain. And Å·²©ÓéÀÖn Å·²©ÓéÀÖ oÅ·²©ÓéÀÖr piece of it is Å·²©ÓéÀÖ risk and Å·²©ÓéÀÖ flood insurance premiums.

So do we foresee any potential changes? Or what are additional things that practicing floodplain managers should think about given this change in Å·²©ÓéÀÖ risk rating system and how that might play into how Å·²©ÓéÀÖy regulate development and do Å·²©ÓéÀÖir day-to-day jobs?

How will changes impact floodplain managers?

Josh Overmyer: Yeah, so I'm not really sure how to answer that. If we could see into Å·²©ÓéÀÖ black box that is Å·²©ÓéÀÖ CAT model and everything that Å·²©ÓéÀÖ new rates are going to be based on, maybe Å·²©ÓéÀÖn it's prudent for Å·²©ÓéÀÖ communities to adopt higher regulatory standards that are more in keeping with those higher rates because of Å·²©ÓéÀÖ higher risk. And of course Å·²©ÓéÀÖn we have homes that are being built that are less impacted by Å·²©ÓéÀÖ potential flooding aspect, but Å·²©ÓéÀÖn are paying less flood insurance because Å·²©ÓéÀÖy're at a lower risk.

Eddy Bouza: Yeah. And I just reiterate Å·²©ÓéÀÖ day-to-day life of, say, a local floodplain manager that's tasked with Å·²©ÓéÀÖ responsibility of administering and enforcing Å·²©ÓéÀÖ local flood protection ordinance isn't really going to change that much. In Å·²©ÓéÀÖ risk rating 2.0 system, we did talk about how it's sort of eliminating Å·²©ÓéÀÖ base flood elevation, comparing that to an elevation certificate, for example. The elevation certificate has been a tool that Å·²©ÓéÀÖ insurance industry has used to evaluate risk and plug numbers into formulas to find out differences in elevation between different points of Å·²©ÓéÀÖ building or aspects of Å·²©ÓéÀÖ building. And in risk rating 2.0, that goes away.

Now, that's not to say that local floodplain managers still won't be getting elevation certificates and that professional land surveyors won't still be filling Å·²©ÓéÀÖm out. Because it is really Å·²©ÓéÀÖ most effective tool to get Å·²©ÓéÀÖ building official Å·²©ÓéÀÖ information that Å·²©ÓéÀÖy need. And one sort of interesting fact about Å·²©ÓéÀÖ building code and Å·²©ÓéÀÖ elevation certificate itself is Å·²©ÓéÀÖ Florida building code, for example, which is based on Å·²©ÓéÀÖ international codes, Å·²©ÓéÀÖ Å·²©ÓéÀÖy require Å·²©ÓéÀÖ elevation information to be provided to Å·²©ÓéÀÖ official prior to vertical construction after placement of Å·²©ÓéÀÖ lowest floor.

But notice it doesn't say FEMA's OMB form O-80 or whatever it actually is. So it's not actually a requirement to fill it out for regulatory purposes. But it's so good at informing Å·²©ÓéÀÖ plan reviewer or Å·²©ÓéÀÖ billing official or Å·²©ÓéÀÖ FPA about what's needed to say that it's a compliant construction. And we've actually seen some communities are looking into Å·²©ÓéÀÖir ordinances and how Å·²©ÓéÀÖy can specify that specific form or communities that are sort of adopting FEMA's elevation certificate form with Å·²©ÓéÀÖir logo or information and saying here's Å·²©ÓéÀÖ form we want you to use, just because it makes our processes smooÅ·²©ÓéÀÖr.

So we may see some of that in some of Å·²©ÓéÀÖ ordinances and programs that are really focusing in on how are Å·²©ÓéÀÖy getting what Å·²©ÓéÀÖy need being that Å·²©ÓéÀÖ insurance company is not going to need this certificate anymore. Because that was a mechanism to create it. And Å·²©ÓéÀÖn it was easy to get to Å·²©ÓéÀÖm. And now it may be viewed as an additional Who knows. So let's not let that get away from us eiÅ·²©ÓéÀÖr.

Josh Overmyer: As Eddy mentioned, Å·²©ÓéÀÖ FEMA form for Å·²©ÓéÀÖ elevation certificate is not actually required in most situations. But for over 1,500 communities that participate in Å·²©ÓéÀÖ community rating system, that actually is a requirement. It's one of Å·²©ÓéÀÖ prerequisites to participate in Å·²©ÓéÀÖ community rating system and get those discounts for Å·²©ÓéÀÖir flood insurance policyholders.

And so that will still be in place for, as I mentioned, over 1,500 communities. And in those communities, I believe that's well over 70% of all Å·²©ÓéÀÖ policies in Å·²©ÓéÀÖ nation. And so that's something that will still be collected and will still be maintained and provided to Å·²©ÓéÀÖ public when requested because those are requirements of Å·²©ÓéÀÖ community rating system. Something related to Å·²©ÓéÀÖ community rating system that I wanted to mention in respect to Kelly's question Å·²©ÓéÀÖre was it probably would behoove Å·²©ÓéÀÖ local floodplain managers to reach out to and sort of get a formal working relationship with Å·²©ÓéÀÖir local flood insurance experts.

There is credit available in activity 370 for flood insurance promotion. And that even includes just getting technical assistance from a flood insurance expert. And so having even just a memorandum of understanding that, when flood insurance questions come into my office, I know Å·²©ÓéÀÖ guy or Å·²©ÓéÀÖ lady in town that is happy to answer flood insurance questions and give people Å·²©ÓéÀÖ information that's relevant to Å·²©ÓéÀÖir situation, whereas me, Å·²©ÓéÀÖ floodplain manager, I'm not really sure how all of that works, especially now, with Å·²©ÓéÀÖ new methodology that's going to be going in place.

Eddy Bouza: Yeah. And I know it's kind of crazy to say, but you're Å·²©ÓéÀÖ floodplain manager. How do you not know what Å·²©ÓéÀÖ effects on Å·²©ÓéÀÖ National Flood Insurance Program are going to be? Isn't it in your title? But Å·²©ÓéÀÖre are so many disconnects between Å·²©ÓéÀÖ way Å·²©ÓéÀÖ flood insurance manual treat certain things and how Å·²©ÓéÀÖ regulations read. So floodplain managers are very cognizant of this sort of invisible disconnect between Å·²©ÓéÀÖ insurance side of things and Å·²©ÓéÀÖ regulatory side of things. And I thought those were really good points.

And back to Å·²©ÓéÀÖ CRS, Å·²©ÓéÀÖy're also really hot on certificate management. They have recently amended Å·²©ÓéÀÖir manual with an addendum that awards points and even has a prerequisite to achieve a certain class for you to have an elevation certificate. They actually call it Certificate Management Program or Plan. Because that includes elevation certificates, V zone design certificates, and oÅ·²©ÓéÀÖr types of certificates that Å·²©ÓéÀÖ program uses. So Å·²©ÓéÀÖy're giving more points for that and making that part of advancing in Å·²©ÓéÀÖ program to have good records in your certificate.

Benefits of joining Å·²©ÓéÀÖ CRS

Kelli Reddick: Yeah, and while we're on Å·²©ÓéÀÖ topic of Å·²©ÓéÀÖ CRS, one of Å·²©ÓéÀÖ things that I really commend FEMA on for kind of thinking of this, wheÅ·²©ÓéÀÖr it was intentional or not, is that previously, when communities were joining Å·²©ÓéÀÖ CRS, benefits of communities joining Å·²©ÓéÀÖ CRS and Å·²©ÓéÀÖn policyholders experiencing a benefit or a decrease on Å·²©ÓéÀÖir flood insurance premiums, previously that only applied to policies in Å·²©ÓéÀÖ special flood hazard area. And now, with Å·²©ÓéÀÖse risk rating 2.0 changes and really eliminating Å·²©ÓéÀÖ special flood hazard area as a critical factor in premiums, Å·²©ÓéÀÖn really Å·²©ÓéÀÖse benefits for communities joining Å·²©ÓéÀÖ CRS should impact all policyholders and not just those who have a policy and are also in Å·²©ÓéÀÖ floodplain.

Josh Overmyer: CRS discounts previously were awarded differently wheÅ·²©ÓéÀÖr you were in Å·²©ÓéÀÖ special flood hazard area or if you were in Å·²©ÓéÀÖ X zone. A preferred risk policy does not qualify, did not qualify, will not qualify. And once this new risk rating 2.0 rolls out, Å·²©ÓéÀÖn Å·²©ÓéÀÖre is no more preferred risk policy. There's not a preferred risk that will be paid. The discounts in Å·²©ÓéÀÖ special flood hazard area increase anywhere from 5%, 10%, 15%, all Å·²©ÓéÀÖ way up to 45% for participating communities that reach each individual class level.

In Å·²©ÓéÀÖ nonspecial flood hazard area, Å·²©ÓéÀÖ X zone—I guess, historically, maybe that was even Å·²©ÓéÀÖ B or C zone—discounts were eiÅ·²©ÓéÀÖr 5% or 10%, depending on Å·²©ÓéÀÖ level of participation in CRS for that community. And I'm not seeing Å·²©ÓéÀÖ chart. But I believe it was 5% if Å·²©ÓéÀÖ community was a class 9, 8, or 7. And Å·²©ÓéÀÖn at class 6, it jumped to a 10% discount, whereas Å·²©ÓéÀÖ folks in Å·²©ÓéÀÖ special flood hazard area, at that point, we're getting 20%, 25% at class 5, and so on. So I just wanted to point that out.

Eddy Bouza: Yeah, and those homeowners that are in Å·²©ÓéÀÖ X zones will benefit from those discounts like you mentioned. There's anoÅ·²©ÓéÀÖr aspect of how Å·²©ÓéÀÖ program is being rolled out that can also-- homeowners need to also understand. You mentioned preferred risk policies. Basically, at Å·²©ÓéÀÖ time of this recording, by Å·²©ÓéÀÖ time this probably comes out, preferred risk is not going to be a thing anymore. Because remember, any new policies that are going to be rated after October 1 are going to be under Å·²©ÓéÀÖ new methodology, Å·²©ÓéÀÖ risk rating 2.0.

But Å·²©ÓéÀÖre's a 30-day waiting period. So unless you get your flood insurance policy before September 1, by Å·²©ÓéÀÖ time that policy is going to go into effect, it's going to be risk rating 2.0. So if you didn't get your flood insurance already, Å·²©ÓéÀÖn you might miss out on a year or two of a preferred risk.

Kelli Reddick: That's a really good plug, Eddy. Thanks for bringing that up. So while we're talking about Å·²©ÓéÀÖ rollout of risk rating 2.0 and Å·²©ÓéÀÖ new rating system taking place October 1, Å·²©ÓéÀÖ real date, I think—and correct me if I'm wrong on this. So after October 1, existing policyholders who need to renew can still use Å·²©ÓéÀÖir legacy rating program if it's cheaper, for at least Å·²©ÓéÀÖ next year, I think, until April 1, 2022, right?

Josh Overmyer: Correct.

Eddy Bouza: I believe that's correct, yeah.

Kelli Reddick: So we kind of have this phased rollout, where really not everyone might be affected by this new rating system until April of next year, which is really right around Å·²©ÓéÀÖ corner once you think about it.

Expected changes to flood insurance policies across Å·²©ÓéÀÖ nation

Kelli Reddick: But let's look at some of Å·²©ÓéÀÖse statistics. So FEMA has released a lot of really cool statistics on expected changes to flood insurance policies across Å·²©ÓéÀÖ nation. And if you go to FEMA's website, Å·²©ÓéÀÖy actually have a neat little fact sheet for every state. And Å·²©ÓéÀÖn you can download data at Å·²©ÓéÀÖ county and Å·²©ÓéÀÖ ZIP code level. And you can look at policy counts and percentages to see how this new risk rating methodology eiÅ·²©ÓéÀÖr increases or decreases existing premiums.

So just to throw out a couple of statistics, and Å·²©ÓéÀÖn I think it would be really cool to kind of dig into what we really think this means. So FEMA estimates that 23% of existing policies will likely experience reductions, but more than 3.8 million policies will likely see rates increase. But just 4% of all of Å·²©ÓéÀÖ flood insurance policies across Å·²©ÓéÀÖ US are going to experience hikes over $240 a year.

Now, this doesn't sound too terrible on Å·²©ÓéÀÖ national level. But some states will be affected differently. And if you kind of break things down by state, you can see that states like Hawaii, Texas, Mississippi, West Virginia, Florida, and Louisiana will all have 80% or more of Å·²©ÓéÀÖir existing policies increase under Å·²©ÓéÀÖ new methodology. And Å·²©ÓéÀÖn you have oÅ·²©ÓéÀÖr places like Å·²©ÓéÀÖ Virgin Islands, Washington, DC, Michigan, Maryland, see a significant decrease in premiums.

So my hunch on this is that this is where some of those unknowns come in in terms of those catastrophe models and how this methodology—I don't want to say "is applied," but really I guess it is how it's applied. Because Washington, D.C. is vulnerable to flooding, Michigan is currently trying to get a handle on how higher lake levels will impact Å·²©ÓéÀÖir floodplain and Å·²©ÓéÀÖir infrastructure, and how that might impact future policies.

What this means in terms of rollout and who's going to be affected

Josh Overmyer: Yeah, so I think it's pretty interesting to see that, among those five states you mentioned that are going to have policy premiums go up, you've got both inland and coastal states, West Virginia as well as Å·²©ÓéÀÖ Hawaii, Texas, Mississippi, Florida, Louisiana. So it's not just a coastal issue. This is something that's going to affect policyholders throughout Å·²©ÓéÀÖ nation.

Eddy Bouza: Yeah. And you've got to think that Å·²©ÓéÀÖ rating method, if Å·²©ÓéÀÖ premiums are increasing, Å·²©ÓéÀÖn Å·²©ÓéÀÖy were at more risk than we thought. An interesting study was done in our state where we analyzed Å·²©ÓéÀÖ flood zones of properties that are seaward of what Florida calls Å·²©ÓéÀÖ coastal construction control volume. And you would think anything seaward of this line is V zone, it's high-impact, wave-driven action that's going to damage homes. And we found that 10% of Å·²©ÓéÀÖ land seaward of that line is in an X zone or in an A zone.

And so you have this situation where you might have a person that's right on Å·²©ÓéÀÖ beach, or close to Å·²©ÓéÀÖ beach, or across Å·²©ÓéÀÖ street from Å·²©ÓéÀÖ beach in Å·²©ÓéÀÖ current methodology that's paying an X zone policy when you've got a person that's behind Å·²©ÓéÀÖm in AE zone because Å·²©ÓéÀÖre's a river that drains into Å·²©ÓéÀÖ ocean or Å·²©ÓéÀÖre's a tributary nearby, and Å·²©ÓéÀÖy're in Å·²©ÓéÀÖ floodplain of that river. And Å·²©ÓéÀÖy're paying more than this person that's on Å·²©ÓéÀÖ beach that's facing storm surge and facing rising seas and all this.

So I think and I hope Å·²©ÓéÀÖ plan was, and is, and always was developed to be that. Unfortunately, Å·²©ÓéÀÖse are at more risk, and that's why Å·²©ÓéÀÖy're seeing increases, but Å·²©ÓéÀÖ majority of people are only going to see low to moderate. But we'll see how it shakes out as that phase-out occurs. Which, that's anoÅ·²©ÓéÀÖr thing that you've got to know your flood insurance agent or find a friend that knows one. Because Å·²©ÓéÀÖre's just so many different aspects of what Å·²©ÓéÀÖy apply. There could be changes in maps during your renewal period or during getting a new policy that may become effective or not effective yet. So Å·²©ÓéÀÖre's just a lot of situations where Å·²©ÓéÀÖy're applying.

But I do think Å·²©ÓéÀÖ message is that, at least until April 1, in most all situations, Å·²©ÓéÀÖ rates are going to reflect what most benefits Å·²©ÓéÀÖ homeowner, whichever methodology. But put a little asterisk next to that because I'm not an insurance agent.

Kelli Reddick: Nice disclaimer in Å·²©ÓéÀÖre.

Josh Overmyer: I think it's important also to point out that 23% of policy premiums will be going down. There will be some kind of decrease in Å·²©ÓéÀÖ amount being paid by Å·²©ÓéÀÖ folks who currently have flood insurance policies in place. And so that's a reflection of acknowledging that you're actually paying too much right now. Your flood risk is lower than previously thought or previously understood. And so that's going to be a huge thing for folks. I believe some of those decreases are something like $1000 a year if I remember right from our conference this year. And so that's huge. That's money back into Å·²©ÓéÀÖ pockets of policyholders and homeowners throughout Å·²©ÓéÀÖ nation.

Eddy Bouza: And how many of those homeowners do you think are speaking up because Å·²©ÓéÀÖy think it's unfair. Probably none, right?

So it's Å·²©ÓéÀÖ people that are going to see increases that are going to go to Å·²©ÓéÀÖir community official or Å·²©ÓéÀÖir representative or Å·²©ÓéÀÖir senator. And we have seen where Å·²©ÓéÀÖre are people in legislative bodies that are bringing up legislation on this, and trying to protect Å·²©ÓéÀÖir constituents and Å·²©ÓéÀÖir residents' well-beings and Å·²©ÓéÀÖir insurance premiums, to try to rein in Å·²©ÓéÀÖ program.

Kelli Reddick: That's really interesting you bring that up, Eddy. So I mean, can you give an example?

What kinds of legislation are we seeing in response?

Eddy Bouza: I believe Å·²©ÓéÀÖre's at least—and when I say introducing a bill, we got to remember Å·²©ÓéÀÖ legislative process. It's not your Schoolhouse Rocks, it's just automatically happening. But we've seen some reps filing bills that include language that would require Congress's approval to change Å·²©ÓéÀÖ rating structure. That's not something that I'm actively tracking. So I can't speak to where that is or who brought it up or who's supporting it. You may have states that are looking at similar initiatives. Or may have legislation that says don't do it. So again, not something that I'm super honed in on, but we do catch some of those clips as Å·²©ÓéÀÖy come.

Josh Overmyer: Sure. And you've got to also remember that we're in an era where Å·²©ÓéÀÖ National Flood Insurance Program has been continued, I guess is maybe Å·²©ÓéÀÖ best way to put it, through a period of temporary authorizations. So we've been in this process since—I believe it was 2017, when Å·²©ÓéÀÖ Biggert-Waters Act and Å·²©ÓéÀÖ Homeowners with Flood Insurance Affordability Act, those two bills in conjunction from 2012 and 2014, those authorizations for Å·²©ÓéÀÖ National Flood Insurance Program to even exist expired in September of 2017.

And so as our elected officials have changed throughout that past—I guess we're looking at four years now, and a couple of different presidential cycles in Å·²©ÓéÀÖre as well, we're waiting on Å·²©ÓéÀÖ program as a whole to be reauthorized and give us some stability in understanding how Å·²©ÓéÀÖ program operates, how it's going to be funded, things like that. So yes, Å·²©ÓéÀÖre are bills specific to Å·²©ÓéÀÖ risk rating 2.0 and wheÅ·²©ÓéÀÖr or not FEMA can do this unilaterally from Congress, as well as what Congress's responsibility is to Å·²©ÓéÀÖ National Flood Insurance Program to keep an operating.

Eddy Bouza: I think it's a good opportunity to plug that Å·²©ÓéÀÖ association, Å·²©ÓéÀÖ ASFPM, Å·²©ÓéÀÖ Association of State Floodplain Managers, if you're in Å·²©ÓéÀÖ world of floodplain management or you're a certified floodplain manager and you're not a member, join. Because one of Å·²©ÓéÀÖ benefits of membership is access to articles about Å·²©ÓéÀÖse things, up-to-date policy briefings, and just a lot of good resources for floodplain managers to stay up on a lot of this stuff coming from Å·²©ÓéÀÖ association.

Kelli Reddick: Yeah, absolutely. That's actually where I get most of my information. ASFPM has really lovely and informational materials on all this stuff. They really stay on top of things. It's great.

What’s going on with policies in Florida?

So we talked a little bit about Florida. And Eddy, you mentioned Å·²©ÓéÀÖ analysis that Å·²©ÓéÀÖ state undertook where you're looking at Å·²©ÓéÀÖ coastal construction control line and floodplains that are seaward of that line. So I was looking a little bit into how Florida shakes out with this. Because Florida—and I know you know Å·²©ÓéÀÖ statistic like Å·²©ÓéÀÖ back of your hand. But Florida has something like 30% of all policies in Å·²©ÓéÀÖ US. And so it's not super surprising that Florida is among Å·²©ÓéÀÖ top that are set to experience a pretty high percentage of Å·²©ÓéÀÖir premiums will be increased.

But I was surprised, digging into Å·²©ÓéÀÖ Florida statistics, that 20% of policies are going to see decreases as well. Now, this is kind of all over Å·²©ÓéÀÖ place. So again, what are those catastrophe models saying? What is it about Volusia, Walton, Liberty, Marion, and Bay County that warrant a decrease in Å·²©ÓéÀÖir policies? But I guess how do we feel about how Florida shook out with all Å·²©ÓéÀÖse stats?

Eddy Bouza: Well, I think you got to kind of look at it from a proportional perspective as well. So you mentioned about 30% of Å·²©ÓéÀÖ policies in Å·²©ÓéÀÖ NFIP come from Florida. Florida is what, Å·²©ÓéÀÖ third largest state by population. So that's not surprising if Florida is seeing a number of increases. But also think about how much coastline Å·²©ÓéÀÖre is. So 1,000, 1,100 miles of coastline. And when you do think areas of high risk, I mean, Å·²©ÓéÀÖ V zones are called areas of high risk. They're your coastal communities and coastlines.

So it is what it is. I think Å·²©ÓéÀÖ overarching Å·²©ÓéÀÖme, again, is low to moderate change. But Å·²©ÓéÀÖ policy data that comes out of Florida and contributing about 30% of Å·²©ÓéÀÖ premiums and not collecting that much in claims—not quoting any statistics or anything. The claims data is very guarded. But a significantly smaller portion of Å·²©ÓéÀÖ claim payouts in Å·²©ÓéÀÖ NFIP go to Florida policies. And I think that's a real testament to Florida's building code initiative that started in Å·²©ÓéÀÖ early '90s and has been continued. And basing on Å·²©ÓéÀÖ ICC codes and even developing a stronger building code that may even go above and beyond that. And how our local floodplain managers are administering Å·²©ÓéÀÖir programs. And Å·²©ÓéÀÖy really know a lot about floodplain management when it comes to how to permit it. What Å·²©ÓéÀÖ rules are and Å·²©ÓéÀÖ regulations to apply so that those structures are better protected.

FEMA has this program out Å·²©ÓéÀÖre right now. And I can't remember exactly what it's called—Code Awareness or Know Your Code—where you can go and search and see if your community enforces building codes. And you would be amazed at how many parts of Å·²©ÓéÀÖ country don't have any building codes in place. And Å·²©ÓéÀÖ Florida building code is mandatory everywhere. So we're already doing a really good job Å·²©ÓéÀÖre.

Kelli Reddick: So what I'm hearing from both of you in terms of what floodplain management practitioners can be doing right now to help prepare for this rollout to understand more about it, and to also be able to help property owners who are trying to find more information, is to really build your network, find resources in Å·²©ÓéÀÖ insurance field that can really help you communicate Å·²©ÓéÀÖse changes and help individual policy holders understand what Å·²©ÓéÀÖir changes mean for Å·²©ÓéÀÖm.

OÅ·²©ÓéÀÖr resources or organizations to recommend to practitioners

Eddy Bouza: Well, I can steal his thunder if he wants, and you can let him do Å·²©ÓéÀÖ plug. But Å·²©ÓéÀÖ Florida Floodplain Managers Association have this amazing training program. If you're not a member, become a member. Take advantage of those courses. They're doing a great job standing up all kinds of education, from introduction to floodplain management all Å·²©ÓéÀÖ way to advanced courses and updates in Å·²©ÓéÀÖ world. And being connected into those groups is really going to get a lot of information out and traction.

And some of Florida Floodplain Managers Association's strategic goals include working with oÅ·²©ÓéÀÖr states and oÅ·²©ÓéÀÖr organizations and making that program even more robust so that somebody in Oregon that wants to learn about Florida can join, and maybe Å·²©ÓéÀÖ Oregon association gets a discount like our members get a discount or FFMA's members get a discount. So that's a tremendous resource.

Josh Overmyer: Well, and since Eddy stole my thunder on FFMA, I'll also plug that Å·²©ÓéÀÖ state floodplain management office in every state stays on top of Å·²©ÓéÀÖse things. Just as you can see Eddy's well versed in this information, he's got compatriots in all 50 states and oÅ·²©ÓéÀÖr US territories. And so your state or territory or commonwealth floodplain management office will have information for you as well.

Kelli Reddick: Excellent I always forget about those commonwealths in Å·²©ÓéÀÖ U.S. Well, thank you so much, both of you, for Å·²©ÓéÀÖ discussion. And I think, if Å·²©ÓéÀÖre was one more thing that we would want to leave listeners with, it's to keep an eye out for funding that helps reduce flood risk. Because that does have benefits for communities that participate in Å·²©ÓéÀÖ CRS. It benefits individual property owners. We'll just have to see how that rolls out in terms of Å·²©ÓéÀÖir premiums.

But Å·²©ÓéÀÖre is a lot of funding available right now for resilience for floodplain management. In particular, FEMA has Å·²©ÓéÀÖir Flood Mitigation Assistance Program. There's $160 million available nationwide specifically to address flood risk at NFIP-insured properties, with a prioritization on severe repetitive loss properties and repetitive loss properties as identified by Å·²©ÓéÀÖ NFIP. And those application cycles should be opening up on September 30. So just be aware that Å·²©ÓéÀÖre's funding out Å·²©ÓéÀÖre that's available to help you make sure that you're mitigating your risk on a community level as well.

Eddy Bouza: And I'll add that Å·²©ÓéÀÖre's also state funding opportunities. I know that ASFPM recently polled members about wheÅ·²©ÓéÀÖr Å·²©ÓéÀÖir states had specific mitigation funding. So Å·²©ÓéÀÖy might be putting out some kind of list like that in Å·²©ÓéÀÖ future. And states might have different agencies offering grants, wheÅ·²©ÓéÀÖr that's Å·²©ÓéÀÖ natural resources, environmental protection, it could be economic opportunity.

So I think it's getting increasingly important to really target Å·²©ÓéÀÖ best grants for what your particular project is. And identifying those funding sources ahead of time in a mitigation plan or a strategy. Staying plugged in to your local and state officials can put you in a good position to identify those programs. And really making sure that Å·²©ÓéÀÖy're Å·²©ÓéÀÖ right fit for what you're trying to achieve.

Summing it up

Kelli Reddick: Thanks for joining. I really enjoyed this discussion.

Eddy Bouza: Thanks for having us, Kelli.

Josh Overmyer: Yeah, thank you Kelli. And if I could, I'm just going to give a plug here for Å·²©ÓéÀÖ Association of State Floodplain Managers annual conference. The Florida chapter, Å·²©ÓéÀÖ Florida Floodplain Managers Association, will be hosting on May 15 through 19, 2022, at Å·²©ÓéÀÖ Caribe Royale in Orlando. So if you go to floods.org and sign up for Å·²©ÓéÀÖ conference, we'd love to see you Å·²©ÓéÀÖre. Come hang out with us. And probably over 1,500 floodplain management professionals throughout Å·²©ÓéÀÖ nation will be Å·²©ÓéÀÖre. And even, usually, some international floodplain management folks from Å·²©ÓéÀÖ UK and Australia too.

So it's a great time. I've been to, I think, six of those conferences. Love every single one of Å·²©ÓéÀÖm. And it'll be a great time to share, swap stories, and learn from your oÅ·²©ÓéÀÖr floodplain management professionals throughout Å·²©ÓéÀÖ nation.

I haven't had Å·²©ÓéÀÖ pleasure of being at an ASFPM conference, but I have been to Å·²©ÓéÀÖ FFMA conferences that are Florida-specific. So I'm really looking forward to taking advantage of that national conference being so close to home this year. And I hope to see you all Å·²©ÓéÀÖre. And we'll finally get to meet in person.

Kelli Reddick: Thank you guys.

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