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.

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.”

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

Preliminary Engineering Starts for Adding More Gates to Lake Houston Dam

In early April, the Coastal Water Authority (CWA) quietly finalized the scope of work for engineers working on adding more gates to the Lake Houston Dam. Engineering firm Black & Veatch’s contract was approved. And their work has now begun. Here’s what it involves.

Looking upstream at the Lake Houston Dam. Photo taken 11/4/2019.

Background: Why More Gates?

After Hurricane Harvey, a pilot study by HCFCD and Freese & Nichols showed additional gates could have helped lower floodwaters.

The current gates on Lake Houston’s dam have one fifteenth the discharge capacity of Lake Conroe’s – 10,000 cfs vs. 150,000 cfs.

Additional gates could help synchronize the release rates of the two dams and thus reduce flood risk. More/bigger gates could lower the Lake Houston faster in advance of a storm and add width to the spillway during a storm. Both help reduce flooding.

Avoiding Unnecessary Releases

Currently, it takes several days to lower Lake Houston enough to significantly reduce flood risk. During that time, approaching storms can veer away or dissipate. So a conservation angle exists here, too. More gates release water faster. That lets CWA wait until weather-forecast certainty is higher before lowering the lake. And that, in turn, helps avoid unnecessary discharges and conserve water.

18-Month Project Starting from April 8th

The addition of gates is a three-year project broken into two 18-month phases.

Phase 1 involves preliminary design of conceptual alternatives, selecting the “best” based on criteria described below, and permitting.

The clock for Phase 1 started ticking on April 8, 2020, the day Black and Veatch’s contract was approved. Phase 1 should conclude in September 2021.

Phase 2 involves final design and construction. Assuming all goes well, we could have more discharge capacity at the Lake Houston dam by March 2023 at the earliest. However, there will be an evaluation period between the two phases that could push the completion date out further. Also…

Phase 2 Depends on Outcome of Phase 1

One objective of Phase 1 is to prove up the concept, the budget, and the benefit/cost ratio.

Proceeding to construction in Phase 2 will depend on the outcome of Phase 1. In Phase 1, engineers will examine several possible designs to determine the most effective alternative. They will consider flood reduction benefits, downstream impacts, cost, environmental impact, constructibility and more.

Then FEMA will evaluate the benefit/cost ratio of the winning design to ensure it meets or beats initial projections in the grant request.

  • If it does, FEMA will release money for Phase 2, the final design and construction.
  • If it doesn’t, the whole project could die.

FEMA does not guarantee Phase 2 funding at this time.

What Happens Now?

The scope of work document reveals who will do what in the next 18 months on the Lake Houston Spillway Improvement Project (LHSIP).

Objective: To relieve upstream flooding by increased discharge capacity that supports pre-releases.

Modifications could include (but are not limited to):

  • Additional crest gates on or adjacent to the existing dam or…
  • New, as-yet-unspecified hydraulic structures that provide for releases elsewhere on the embankment

Unlike tainter gates which swing up from a radial arm, crest gates swing down from a bottom hinge.

The project will consider both upstream benefits and downstream impacts.

Looking downstream over the Lake Houston Dam in foreground gives you some idea of the courage that it requires to live or work below a dam.

After defining alternatives and constraints, the contractor, Black & Veatch, will analyze the alternatives to quantify and compare costs and benefits of each configuration.

Five Major Tasks in Phase 1

Preliminary engineering involves five major tasks:

  • Management plans
  • Hydrology and Hydraulic Modelling
  • Permitting
  • Field Investigation
  • Development of alternative concepts

Let’s look at each.

Management Plans

Black & Veatch will begin Phase 1 by developing project-, quality-, and risk-management plans.

H&H Studies

Hydrology and hydraulics (H&H) studies will evaluate the ability of the various concepts to reduce upstream flooding and downstream impacts. Black & Veatch will develop H&H models that combine both the San Jacinto River and Buffalo Bayou basins to evaluate downstream impacts of any dam.

The combined model will extend all the way to Galveston Bay and evaluate design alternatives for up to nine events:

  • 2-, 10-, 50-, 100-, and 500-year storms
  • Extreme historic events (e.g. Harvey, Ike or Memorial Day), including at least one with storm-surge effects
  • A hypothetical Probable Maximum Precipitation event.

The process includes collecting, reviewing, adjusting and validating existing models before performing simulations.

Permitting Gauntlet

To save time, permitting will begin concurrently with design. The permitting schedule is aggressive and may spill over into Phase 2 as details are refined. Permitting includes (but is not limited to) coordination with federal, state and local agencies for:

  • Environmental Assessment
  • Environmental Impact Statement
  • Wetland delineations
  • Threatened and endangered (T&E) habitat assessment
  • T&E species-specific surveys
  • Migratory Bird Treaty Act (MBTA) surveys
  • Freshwater Mussel survey
  • Stormwater pollution prevention
  • Clean Water Act
  • Flood Plain Construction

The environmental team will also consider:

  • Topography and Soils Construction Impacts
  • Land Use
  • Indirect and Cumulative Impacts
  • Geology, Hydrology and Drainage
  • Sediment Quality
  • Vegetation
  • Air Quality
  • Invasive Species
  • Coastal Zone Management Wildlife and Endangered Species
  • Essential Fish Habitat
  • Existing Facilities and Utilities
  • Noise Quality
  • Socioeconomics
  • Traffic and Circulation
  • Waters of the U.S., including Wetlands
  • Environmental Justice
  • Cultural Resources (historical and archaeological)
  • Recreation
  • Floodplains
  • Visual/ Aesthetic Appeal
  • Water Quality
  • Hazardous Materials

Field Investigations

Black & Veatch will also conduct site surveys and a geotechnical investigation, complete with borings, to evaluate soil conditions, depth-to-water, permeability, and seepage control.

A bathymetry team will measure water depth and develop contour maps for an area that extends 500 feet upstream from the dam.

Preliminary Engineering/Conceptual Design

Finally, preliminary engineering will develop conceptual layouts and site plans for several alternatives.

This exercise will also evaluate areas of impact, site access and utilities, staging and borrow areas, dewatering extents, existing structure tie-in, general facilities layout, and downstream channel alignment.

These site plans will be used for costing and evaluating the feasibility for each alternative.

Criteria for Choosing Best Alternatives

The engineers will also develop an evaluation matrix that includes, but is not limited to:

  • Ability to meet project goals
  • Environmental clearance
  • Construction costs, including any environmental mitigation
  • Long-term operation and maintenance costs
  • Benefit/cost analysis
  • Risks in design, construction, and operation.

From all the feasible options, engineers will then chose the three best based on:

  • Cost
  • Upstream impact
  • Downstream impact
  • Environmental impact
  • Permitting requirements
  • Constructibility

Timing on Phase 2

Assuming we get to Phase 2, the second 18 months may not start immediately. FEMA will need time to evaluate Phase 1 results. And the CWA will need to develop bid specs, bid the job, select a winner, and develop a contract with a scope of work, just as they did for Phase 1. That could talk several months and push completion well into 2023.

For More Information

All that, just to figure out what to do! To read the full 27-page Scope of Work, click here. I will also post this document for future reference in the Reports page of this web site under a new tab titled Lake Houston Dam Spillway Improvement Project.

Posted by Bob Rehak on 5/1/2020

976 Days after Hurricane Harvey

Tools to Track Permit Applications for Developments Near You

Have you ever been flooded by a new development? Did you learn about the development AFTER bulldozers started knocking down trees? There’s a much better way. The City of Houston offers several tools to help you track applications for new developments long before the bulldozers start belching diesel fumes.

GIS PlatTracker Map

The first is an interactive, color coded GIS map that shows the status of all permit applications in the City and its ETJ (extra-territorial jurisdiction). The ETJ extends well beyond the boundaries of the City. Going up 45, it extends to 242. Going up 59, it extends to Roman Forest.

City of Houston PlatTracker map for Northeast Houston and Lake Houston Area as of 4/30/2020

If someone has applied for a permit to develop a piece of land, it will show up on the map. Notice the purple areas along the West Fork west of the Kingwood Country Club. That’s how I learned about the reactivation of Romerica’s plans.

The color of the parcels corresponds to the stage of the application. Clicking on the parcel pulls up an information panel that gives you more history including the date the developer submitted the application, when it will be reviewed, the review stage, and more.

Zoom in and out as wide as you want. Just be aware that the wider you zoom, the longer it takes the screen to refill with all the plat information. There’s a lot more of it!

As I zoomed out around Kingwood, the number of new developments that I was unaware of shocked me. If you want to see humongous changes, look south of Humble, east to Huffman, west to Spring, and north to Porter and New Caney. Kingwood is a relative island of quiet in a sea of change.

Other Related Interactive Maps

The PlatTracker Plat Map is just one of thirty other interactive maps that you can use to explore and monitor the City around you. They include, but are not limited to:

  • Land use
  • Water flood hazards
  • Governmental boundaries
  • Demographics
  • Annexation history
  • Address and Permit Information

PlatTracker Agenda/Spreadsheet

Once you have identified a development you are interested in, another site can help you learn more about when the Houston Planning Commission will consider applications related to the site. It will also give you:

  • Subdivision plat name
  • Application Number
  • Date Submitted
  • Subdivision type
  • Variance requests
  • Location on the Commission’s agenda
  • County
  • Council district
  • Precinct
  • Census Tract
  • Zip Code
  • School district
  • TIRZ (tax increment reinvestment zone) if any
  • Superneighborhood Council
  • Land Use
  • Number of Lots
  • Acreage
  • Appraisal district numbers
  • Developer Name
  • Applicant Company
  • Applicants Name
  • Phone Number

You can even download the latest documents related to the application.

For Planning Commission meeting dates and agendas, click here.

Situational Awareness for Concerned Citizens

Wow. Everything you need to put your mind at ease. Or stage a protest. All at your fingertips.

These are great tools for concerned residents and citizen activists.

I’m sure a lot of Elm Grove residents wish they had known about these tools before the bulldozers started knocking down trees in Woodridge Village.

For future reference, I’ve added links for these sites within ReduceFlooding’s Links Page under the Community heading.

Posted by Bob Rehak on 4/30/2020

975 Days since Hurricane Harvey