More than one engineer has told me that sand mine dikes appear as though they are designed to fail. Part of the problem is that the State sets no standards for their construction; the State simply says they must be “effective.” But there are only minor penalties if they prove ineffective.
How Sand Mines Use Water
Mines use water to separate sand from silt by spinning the mixture through a centrifuge. The large sand particles go to a stockpile. The smaller silt particles return to a settling pond. If left long enough, the water clarifies and can safely be released.
Water and silt go one way, sand the other. The constant inflow of silty water in the settling pond creates a deltathat raises the water level.
Constant Battle Against Silt and Water
The problem, however, is the buildup of silt and water over time.
The fine sediment often does not have enough time to drop out of suspension before water in the settling pond begins to overflow. That’s when dikes often break and sediment laden water is released into the river.
Sadly, this is not an isolated problem. I have documented breaches in most San Jacinto River mines.
Road Disappears as Dike Gets Higher
Since then, aerial photos show that LMI is building dikes higher to prevent future releases. But as the thin dikes made out of sand/silt get higher, they also get narrower. They seem designed to fail at some point.
Process waste water leaks through them into surrounding wetlands and the West Fork. To keep the dikes from failing, the mine even appears to be pumping water out of its pit into the wetlands.
A large rain could easily overwhelm these dikes and cause another failure. As a starting point, review the satellite photo below from Google Earth. It was taken about a month after a major breach from another part of the mine. Note the perimeter road around the entire pond. It disappears in aerial photos taken a few months later.
Satellite photo from 12/1/2019 shows a drivable road around the entire eastern perimeter (right) of the LMI Moorhead mine.
Now compare that to this series of helicopter photos taken on 4/21/2020. The series starts in the upper right of the satellite photo and heads south (toward the bottom of the satellite image). This area of the mine is far from public view, except from a helicopter..
Note the difference in elevation between the pond in the mine and the pond outside of it.Note the partially buried pipe between the two ponds. A siphon?Looking south along the eastern perimeter. you can see how the road now disappears and the wall of the dike gets thinner. Zooming out, you can see how the far this condition existsand why I ask the question, “Are these dikes designed to fail?”Tracking south to the next grove of trees, you can see water leaking through the narrow dike as it approaches the top. Comparing the dike to nearby tree trunks, I estimate the dike is no more than 2-3 feet wide.
Where 56 Million Gallons Allegedly Entered River
The same condition exists on another pit at the same mine. The dike shown in the foreground is the one that the TCEQ says failed last year. Note water ponding on the narrow road. See photo below.
Note the difference in the color of the water in the pond and in the river in the photo below. The pond color has not changed during the eight months I have been documenting these sand mining operations from the air.
Same dike, photographed from a different angle, looking north. West Fork is in foreground. A newArtavia drainage ditch in the background now funnels water from more than 2000 acres straight toward mine.The mine blames Artavia for the November discharge.
No Texas Regulations Govern Dike Construction
Unfortunately, the State of Texas has no regulations that address construction of dikes.
No standards exist for height, width, composition, compaction, or reinforcement.
I asked Ramiro Garcia, head of enforcement for the TCEQ, this question. “Does Texas have regulations for sand mines that affect the width, height, slope, compaction, and materials used in perimeter dikes or barriers?“
His reply: “The Industrial Stormwater Multi-Sector General Permit requires the use of pollution prevention practices that can effectively protect the water quality in receiving waters, or that are necessary for remaining in compliance with the general permit. The GP states that “the permittee shall evaluate and use appropriate measures and controls to reduce soil erosion and sedimentation in areas of the facility with demonstrated or potential soil erosion and sedimentation” (Part III.A.4(c)). There are no specific requirements for width, height, slope, compaction, or materials for dikes or barriers.“
So the permittee gets to determine what’s “appropriate”!
Designed to Fail?
The lack of regulation is how we get strips of sand a couple feet wide holding back hundreds of millions of gallons of waste water. One big rain, a flood, and the wastewater buildup is gone. Conveniently!
If the TCEQ discovers an unauthorized discharge, the mine pays a “slap on the wrist” fine. They average about $800. That’s why I ask, “Are sand mine dikes designed to fail?” It seems cheaper and easier to pay the fine than build earthworks that protect the source of drinking water for 2 million people.
State Rep. Dan Huberty tried to implement effective sand mining regulations during the last legislative session. Unfortunately, most of the mining bills he sponsored died in committee. I’m using the time before the next session to document mining practices on the San Jacinto. Hopefully, we’ll be able to make a better case next year.
Posted by Bob Rehak on 5/4/2020
979 Days after Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/05/20200421-RJR_0878.jpg?fit=1200%2C800&ssl=18001200adminadmin2020-05-04 13:04:422020-05-04 13:23:31Are Sand Mine Dikes Designed to Fail? State Sets No Standards
Here’s an update to last week’s watchlist. It includes seven Lake Houston Area developments – four from last week and three new.
Perry Homes’ Woodridge Village
On April 28, 2020, Harris County Commissioners approved the purchase of Woodridge Village from Perry Homes with two conditions: 1) that the City of Houston would defray half the cost by contributing $7mm worth of land that HCFCD needed for other flood control costs, 2) that the City would adopt new Atlas-14 rainfall statistics.
The next day, Houston Mayor Pro Tem Dave Martin discussed the deal on a Facebook live “virtual lunch” with the Lake Houston Area Chamber. At about 26:20 into the video, he said that the stipulations had already been agreed to. He said the City had already identified 11 pieces of property, 6 of which were presented to the County during its consideration of the deal in executive session the previous night. He also said the City would divert water from Taylor Gully to the Kingwood Diversion Ditch and build a barrier between Elm Grove and Woodridge, while the county built a regional detention facility.
Perry contractors went back to work the next day before Martin spoke. They continued working all week. They worked near Mace in Porter, on N2 (the large detention pond in the middle of the western border), and N3 (another detention pond on the eastern border).
A reliable source who needs to remain anonymous told me that the work was at the request of Perry’s lawyers. The source said that Perry and its contractors were simply complying with their contract.
This week marks the anniversary of the first storm (May 7th) that landed Perry in hot water. And forecasters predict an above-average hurricane season, which starts in four weeks. The lawyers may have had that on their minds, too. As they say in legal circles, “The third time is the pen.” Woodridge contributed to flooding Elm Grove twice last year, in May and September.
Excavator working near Mace in Porter on April 29, 2020.
Romerica’s “Orchard Seeded Ranches”
This is the 331-acre project formerly known as the Heron’s Kingwood. It wound around the Barrington and River Grove Park. Romerica is now trying to develop the same land under a different name, “Orchard Seeded Ranches.”
However, on Thursday, 4/30/2020, the Houston Planning Commission deferred approval of the developer’s General Plan.
General Plan of Orchard Seeded Ranches in Kingwood Texas
The Commission then asked the developer to consult with the City Engineer; the Planning and Development Department; and Harris County Flood Control before bringing further requests back to the Commission.
That should send a strong signal to the developer that rough waters lie ahead. Any proposal will likely be debated publicly when/if the developer returns.
The development is still listed in CoH’s PlatTracker. So we will continue to watch this one.
Holley’s Kingwood Cove Golf Course Redevelopment
A review of the City of Houston’s PlatTracker Plus Map indicates that Holley has not yet applied for any permits on the golf course in Forest Cove. City of Houston confirmed that via a FOIA request (Freedom of Information Act).
Note how golf course on left is unshaded. That indicates no activity with the Planning Commission. Compare that to the purple area on the right for Romerica’s property. That indicates approval of a General Plan is still pending.
A review of the Harris County Appraisal District website indicates a limited liability company in Pittsburgh, PA, actually owns the golf course.
Harris County Appraisal District info for property at 805 Hamblen, aka Kingwood Cove Golf Course.
It’s not unusual for developers to use other people’s money. I shall continue to watch this. Holley says his engineer is reworking plans based on input from people surrounding the course.
Ryko Property Near Confluence of Spring Creek and West Fork
This property is in Montgomery County and the City of Houston’s Extra Territorial Jurisdiction. The Montgomery County Engineers office says the company has not yet filed any plans that have been approved. The City of Houston PlatTracker Plus Map also shows the owner has not yet filed any applications.
US FWS Wetlands Map shows wetlands throughout the Ryko property between Spring Creek and the West Fork.
New Caney ISD High School #3
Dark green area in center between Sorters Rd. and 59 is future home of New Caney ISD High School #3.
The New Caney Independed School District plans to build a third high school south of the HCA Kingwood Medical Center and behind the car dealerships that front US59. I don’t know much more about this except that they plan to extend roads into the area that is now forest. High schools usually have large parking lots. And that means rapid drainage. It is unclear at this time whether MoCo will require detention ponds.
Northpark Woods
Looking northwest at Northpark Woods from over Sorters/McClellan Road. The drainage ditch on the left parallels Northpark Drive. Sand mines and the West Fork are in the background.Photo 4/21/2020.
This high-density development along the West Fork San Jacinto River in Montgomery County is now about one-third to one-half built. Construction continues.
The Colonies in Plum Grove
North of SH99 in Plum Grove and east of the East Fork in Liberty County, lies one of the largest developments in the Houston region without detention ponds.
Formally known as Colony Ridge, some locals call it “The Colonies.” Colony Ridge bills itself as a “master-planned” community with six major subdivisions: Sante Fe, Camino Real, Grand San Jacinto, Rancho San Vincente, Montebello, and Bella Vista. Together they comprise 30,478 lots on approximately 10,000 acres at present. And they’re still growing!
The Colonies currently cover an area almost as large as Kingwood. Photo 4/21/2020.Drainage empties into the East Fork San Jacinto. While flying over the area, I did not see one detention pond. Mobil homes make up most of the housing stock.Note open-ditch drainage.
Colony Ridge advertises itself as “an escape from the city, land on which to grow and build a home, no restrictions and easy credit.” Aerial photos reveal people scratching out hardscrabble lives on barren lots.
This is a blue collar neighborhood. The developer says his target market is poor Latino laborers. They see this as a step up from apartment living and a chance to own a part of the American dream.
But while flying over it, I did not see one detention pond.
As SH99, the Grand Parkway, pushes east from 59, this area will boom. Without better drainage regulations, Liberty County and Plum Grove will heap their drainage problems on those downstream.
FEMA’s National Flood Hazard Layer Viewer shows East Fork Flood Plains relative to Colony Ridge (right).
The good news is that Liberty County has joined with seven other counties to form a Southeast Texas Drainage District. The bad news is that Harris County is not one of the seven.
Posted by Bob Rehak on 5/3/2020
978 Days after Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/05/20200421-RJR_1204.jpg?fit=1200%2C800&ssl=18001200adminadmin2020-05-03 10:41:082020-05-03 11:00:12Development Watchlist: Perry, Romerica, Colony Ridge and More
Since the National Flood Insurance Plan’s (NFIP) inception in 1968, additional legislation has been enacted to strengthen the program, ensure its fiscal soundness, create better maps, and tie rates closer to risk. Next year, FEMA will transform the NFIP with something called Risk Rating 2.0, a major change.
FEMA says that with Risk Rating 2.0, NFIP is leveraging industry best practices and current technology to deliver rates that are fairer, easier to understand, and better reflect a property’s unique flood risk.
That last part is code for “we lost a lot of money.”
Unsustainable NFIP Losses
NFIP continues to pay claims in excess of revenues, and borrows increasingly from the U.S. Treasury.
Last October, Michael D. Berman wrote an article titled “Flood Risk and Structural Adaptation of markets: An Outline for Action” in the Federal Reserve Board’s Community Development Innovation Review. In it, he says, “On September 22, 2017, after borrowing $5.825 billion to fund claims from Hurricanes Harvey, Irma and Maria, the NFIP had reached its maximum U.S. Treasury borrowing authority of $30.425 billion in program debt. On October 26, 2017, Congress cancelled $16 billion of NFIP debt—the first time in the history of the NFIP that has occurred. Then on November 9, 2017, the NFIP borrowed another $6.1 billion to fund additional 2017 losses, including additional losses from Hurricanes Harvey, Irma and Maria.”
Rating Flood Risk at Property Level
Berman claims, “The NFIP is clearly not properly pricing flood risk, nor is it adequately influencing prudent behavior by property owners and municipalities to sufficiently reduce or otherwise mitigate this risk…This new rating system, known as Risk Rating 2.0, is expected to include repricing of premiums based on flood risk at the property level.”
What Risk Rating 2.0 Involves
FEMA says its current risk-rating methodology has not fundamentally changed since the 1970s. It is now heavily dependent on the 1-percent-annual-chance-event (100-year floodplain).
Risk Rating 2.0 will incorporate a broader range of flood frequencies, new mapping data, and new technologies, more individual rating characteristics, such as:
• Distance to the coast or another flooding source; • Different types of flood risk; and • The cost to rebuild a home.
By reflecting the cost to rebuild, the new rating plan will also aim to deliver fairer rates for owners of lower-value homes.
Rates that Promote Mitigation Efforts
FEMA also plans to offer mitigation credits to help incentivize risk-reduction efforts and reduce the cost of future flood events. Risk Rating 2.0 will initially provide credits for three mitigation actions:
Installing flood openings;
Elevating onto posts, piles, and piers; and
Elevating machinery and equipment above the lowest floor.
FEMA is not yet saying how many premiums will increase or decrease, or by how much. Two things ARE clear though.
6:1 Payback on Flood Mitigation Investments
First, the old system is broken and unsustainable. Flood maps were outdated and based on data decades old in many cases. They contained many unmapped areas and the mapped areas were strongly influenced by local politicians and developers. Maps also did not reflect the effects of upstream development or more intense, frequent storms.
Second, the new system has a chance to incentivize risk-reduction. The old system encouraged people and communities to rebuild things the way they were after a disaster. We need a new system that encourages more prudent behavior.
FEMA cites a recent study by the National Institute of Building Sciences. Looking back over 23 years of data, the study found that for every dollar that the federal government invests in flood hazard mitigation, taxpayers save an average of six dollars of future disaster recovery spending.
Rebuild to Fail or Rebuild to Adapt?
The current federal flood insurance program promotes rebuilding in flood prone areas. Hopefully, the new system will promote adaptation to help mitigate increased risk.
Flood insurance rates that better reflect risk may promote more prudent behavior by developers, lending institutions, property owners, buyers, and real estate agents who will all “follow the money.”
Are Sand Mine Dikes Designed to Fail? State Sets No Standards
More than one engineer has told me that sand mine dikes appear as though they are designed to fail. Part of the problem is that the State sets no standards for their construction; the State simply says they must be “effective.” But there are only minor penalties if they prove ineffective.
How Sand Mines Use Water
Mines use water to separate sand from silt by spinning the mixture through a centrifuge. The large sand particles go to a stockpile. The smaller silt particles return to a settling pond. If left long enough, the water clarifies and can safely be released.
The constant inflow of silty water in the settling pond creates a delta that raises the water level.
Constant Battle Against Silt and Water
The problem, however, is the buildup of silt and water over time.
Last November, the Texas Commission on Environmental Quality cited the LMI Moorhead mine for the unauthorized discharge of 56 million gallons of white goop into the San Jacinto West Fork. It had 25X more suspended solids than water from upstream.
Sadly, this is not an isolated problem. I have documented breaches in most San Jacinto River mines.
Road Disappears as Dike Gets Higher
Since then, aerial photos show that LMI is building dikes higher to prevent future releases. But as the thin dikes made out of sand/silt get higher, they also get narrower. They seem designed to fail at some point.
Process waste water leaks through them into surrounding wetlands and the West Fork. To keep the dikes from failing, the mine even appears to be pumping water out of its pit into the wetlands.
A large rain could easily overwhelm these dikes and cause another failure. As a starting point, review the satellite photo below from Google Earth. It was taken about a month after a major breach from another part of the mine. Note the perimeter road around the entire pond. It disappears in aerial photos taken a few months later.
Now compare that to this series of helicopter photos taken on 4/21/2020. The series starts in the upper right of the satellite photo and heads south (toward the bottom of the satellite image). This area of the mine is far from public view, except from a helicopter..
Where 56 Million Gallons Allegedly Entered River
Note the difference in the color of the water in the pond and in the river in the photo below. The pond color has not changed during the eight months I have been documenting these sand mining operations from the air.
No Texas Regulations Govern Dike Construction
Unfortunately, the State of Texas has no regulations that address construction of dikes.
I asked Ramiro Garcia, head of enforcement for the TCEQ, this question. “Does Texas have regulations for sand mines that affect the width, height, slope, compaction, and materials used in perimeter dikes or barriers?“
His reply: “The Industrial Stormwater Multi-Sector General Permit requires the use of pollution prevention practices that can effectively protect the water quality in receiving waters, or that are necessary for remaining in compliance with the general permit. The GP states that “the permittee shall evaluate and use appropriate measures and controls to reduce soil erosion and sedimentation in areas of the facility with demonstrated or potential soil erosion and sedimentation” (Part III.A.4(c)). There are no specific requirements for width, height, slope, compaction, or materials for dikes or barriers.“
So the permittee gets to determine what’s “appropriate”!
Designed to Fail?
The lack of regulation is how we get strips of sand a couple feet wide holding back hundreds of millions of gallons of waste water. One big rain, a flood, and the wastewater buildup is gone. Conveniently!
If the TCEQ discovers an unauthorized discharge, the mine pays a “slap on the wrist” fine. They average about $800. That’s why I ask, “Are sand mine dikes designed to fail?” It seems cheaper and easier to pay the fine than build earthworks that protect the source of drinking water for 2 million people.
State Rep. Dan Huberty tried to implement effective sand mining regulations during the last legislative session. Unfortunately, most of the mining bills he sponsored died in committee. I’m using the time before the next session to document mining practices on the San Jacinto. Hopefully, we’ll be able to make a better case next year.
Posted by Bob Rehak on 5/4/2020
979 Days after Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
Development Watchlist: Perry, Romerica, Colony Ridge and More
Here’s an update to last week’s watchlist. It includes seven Lake Houston Area developments – four from last week and three new.
Perry Homes’ Woodridge Village
On April 28, 2020, Harris County Commissioners approved the purchase of Woodridge Village from Perry Homes with two conditions: 1) that the City of Houston would defray half the cost by contributing $7mm worth of land that HCFCD needed for other flood control costs, 2) that the City would adopt new Atlas-14 rainfall statistics.
The next day, Houston Mayor Pro Tem Dave Martin discussed the deal on a Facebook live “virtual lunch” with the Lake Houston Area Chamber. At about 26:20 into the video, he said that the stipulations had already been agreed to. He said the City had already identified 11 pieces of property, 6 of which were presented to the County during its consideration of the deal in executive session the previous night. He also said the City would divert water from Taylor Gully to the Kingwood Diversion Ditch and build a barrier between Elm Grove and Woodridge, while the county built a regional detention facility.
Perry contractors went back to work the next day before Martin spoke. They continued working all week. They worked near Mace in Porter, on N2 (the large detention pond in the middle of the western border), and N3 (another detention pond on the eastern border).
A reliable source who needs to remain anonymous told me that the work was at the request of Perry’s lawyers. The source said that Perry and its contractors were simply complying with their contract.
This week marks the anniversary of the first storm (May 7th) that landed Perry in hot water. And forecasters predict an above-average hurricane season, which starts in four weeks. The lawyers may have had that on their minds, too. As they say in legal circles, “The third time is the pen.” Woodridge contributed to flooding Elm Grove twice last year, in May and September.
Romerica’s “Orchard Seeded Ranches”
This is the 331-acre project formerly known as the Heron’s Kingwood. It wound around the Barrington and River Grove Park. Romerica is now trying to develop the same land under a different name, “Orchard Seeded Ranches.”
However, on Thursday, 4/30/2020, the Houston Planning Commission deferred approval of the developer’s General Plan.
The Commission then asked the developer to consult with the City Engineer; the Planning and Development Department; and Harris County Flood Control before bringing further requests back to the Commission.
That should send a strong signal to the developer that rough waters lie ahead. Any proposal will likely be debated publicly when/if the developer returns.
The development is still listed in CoH’s PlatTracker. So we will continue to watch this one.
Holley’s Kingwood Cove Golf Course Redevelopment
A review of the City of Houston’s PlatTracker Plus Map indicates that Holley has not yet applied for any permits on the golf course in Forest Cove. City of Houston confirmed that via a FOIA request (Freedom of Information Act).
A review of the Harris County Appraisal District website indicates a limited liability company in Pittsburgh, PA, actually owns the golf course.
It’s not unusual for developers to use other people’s money. I shall continue to watch this. Holley says his engineer is reworking plans based on input from people surrounding the course.
Ryko Property Near Confluence of Spring Creek and West Fork
This property is in Montgomery County and the City of Houston’s Extra Territorial Jurisdiction. The Montgomery County Engineers office says the company has not yet filed any plans that have been approved. The City of Houston PlatTracker Plus Map also shows the owner has not yet filed any applications.
New Caney ISD High School #3
The New Caney Independed School District plans to build a third high school south of the HCA Kingwood Medical Center and behind the car dealerships that front US59. I don’t know much more about this except that they plan to extend roads into the area that is now forest. High schools usually have large parking lots. And that means rapid drainage. It is unclear at this time whether MoCo will require detention ponds.
Northpark Woods
This high-density development along the West Fork San Jacinto River in Montgomery County is now about one-third to one-half built. Construction continues.
The Colonies in Plum Grove
North of SH99 in Plum Grove and east of the East Fork in Liberty County, lies one of the largest developments in the Houston region without detention ponds.
In January of 2017, the Houston Chronicle wrote about how La Colonia was transforming Plum Grove. They interviewed local residents who lamented the loss of forests. ABC13 ran a story about the squalid living conditions. Yet the area continues to expand.
Formally known as Colony Ridge, some locals call it “The Colonies.” Colony Ridge bills itself as a “master-planned” community with six major subdivisions: Sante Fe, Camino Real, Grand San Jacinto, Rancho San Vincente, Montebello, and Bella Vista. Together they comprise 30,478 lots on approximately 10,000 acres at present. And they’re still growing!
Colony Ridge advertises itself as “an escape from the city, land on which to grow and build a home, no restrictions and easy credit.” Aerial photos reveal people scratching out hardscrabble lives on barren lots.
This is a blue collar neighborhood. The developer says his target market is poor Latino laborers. They see this as a step up from apartment living and a chance to own a part of the American dream.
As SH99, the Grand Parkway, pushes east from 59, this area will boom. Without better drainage regulations, Liberty County and Plum Grove will heap their drainage problems on those downstream.
The good news is that Liberty County has joined with seven other counties to form a Southeast Texas Drainage District. The bad news is that Harris County is not one of the seven.
Posted by Bob Rehak on 5/3/2020
978 Days after Hurricane Harvey
FEMA Reforming Flood Insurance Risk, Rate Structure
Since the National Flood Insurance Plan’s (NFIP) inception in 1968, additional legislation has been enacted to strengthen the program, ensure its fiscal soundness, create better maps, and tie rates closer to risk. Next year, FEMA will transform the NFIP with something called Risk Rating 2.0, a major change.
FEMA says that with Risk Rating 2.0, NFIP is leveraging industry best practices and current technology to deliver rates that are fairer, easier to understand, and better reflect a property’s unique flood risk.
Unsustainable NFIP Losses
NFIP continues to pay claims in excess of revenues, and borrows increasingly from the U.S. Treasury.
Last October, Michael D. Berman wrote an article titled “Flood Risk and Structural Adaptation of markets: An Outline for Action” in the Federal Reserve Board’s Community Development Innovation Review. In it, he says, “On September 22, 2017, after borrowing $5.825 billion to fund claims from Hurricanes Harvey, Irma and Maria, the NFIP had reached its maximum U.S. Treasury borrowing authority of $30.425 billion in program debt. On October 26, 2017, Congress cancelled $16 billion of NFIP debt—the first time in the history of the NFIP that has occurred. Then on November 9, 2017, the NFIP borrowed another $6.1 billion to fund additional 2017 losses, including additional losses from Hurricanes Harvey, Irma and Maria.”
Rating Flood Risk at Property Level
Berman claims, “The NFIP is clearly not properly pricing flood risk, nor is it adequately influencing prudent behavior by property owners and municipalities to sufficiently reduce or otherwise mitigate this risk…This new rating system, known as Risk Rating 2.0, is expected to include repricing of premiums based on flood risk at the property level.”
What Risk Rating 2.0 Involves
FEMA says its current risk-rating methodology has not fundamentally changed since the 1970s. It is now heavily dependent on the 1-percent-annual-chance-event (100-year floodplain).
Risk Rating 2.0 will incorporate a broader range of flood frequencies, new mapping data, and new technologies, more individual rating characteristics, such as:
• Distance to the coast or another flooding source;
• Different types of flood risk; and
• The cost to rebuild a home.
Rates that Promote Mitigation Efforts
FEMA also plans to offer mitigation credits to help incentivize risk-reduction efforts and reduce the cost of future flood events. Risk Rating 2.0 will initially provide credits for three mitigation actions:
FEMA is not yet saying how many premiums will increase or decrease, or by how much. Two things ARE clear though.
6:1 Payback on Flood Mitigation Investments
First, the old system is broken and unsustainable. Flood maps were outdated and based on data decades old in many cases. They contained many unmapped areas and the mapped areas were strongly influenced by local politicians and developers. Maps also did not reflect the effects of upstream development or more intense, frequent storms.
Second, the new system has a chance to incentivize risk-reduction. The old system encouraged people and communities to rebuild things the way they were after a disaster. We need a new system that encourages more prudent behavior.
Rebuild to Fail or Rebuild to Adapt?
The current federal flood insurance program promotes rebuilding in flood prone areas. Hopefully, the new system will promote adaptation to help mitigate increased risk.
Flood insurance rates that better reflect risk may promote more prudent behavior by developers, lending institutions, property owners, buyers, and real estate agents who will all “follow the money.”
For More Information
For more information, see:
Risk Rating 2.0 FAQs
Federal Reserve Board Community Development Innovation Review
Cheaper Flood Insurance: Five Ways to Lower the Cost of Your Flood Insurance Premium
NFIP Community Rating System: A Local Official’s Guide to Saving Lives, Preventing Property Damage, and Reducing the Cost of Flood Insurance
FEMA Discussion of Property Insurance Reform
FEMA Discussion about Reducing Risks and Rates
National Institute of Building Sciences 2019 Report on Mitigation
Posted by Bob Rehak on 4/2/2020
977 Days since Hurricane Harvey