Without question, flooding is the most common and costly natural disaster in the United States. When federal flood protection standards were updated last year, it was a long overdue step towards safeguarding our Nation against an environmentally and fiscally irresponsible future marked by increased sea level rise, coastal storms, and inland flooding caused by climate change. But opponents have surfaced, including an unlikely bunch of largely quasi-governmental groups operating under the name of “Floodplain Alliance for Insurance Reform” from Texas and Mississippi (two states that have received a combined $7.2 billion in public assistance money from FEMA in the wake of floods, in part to rebuild public buildings infrastructure).
The opposition is hard to fathom. Most of their concerns have little to do with the how the flood protection standards actually work. What’s even more confusing, if not outright concerning, is that some of the groups opposing flood protection standards are currently underwater….due to flooding.
One of the opponents is the Fort Bend Flood Management Association of Fort Bend County, Texas. Ironically, the Brazos River, which runs through their territory, recently crested at nearly 54 feet and much of the area under the association’s protection is flooded. Additionally, from 1998 to 2014, Fort Bend County received $24 million in flood disaster aid from FEMA. It’s precisely these kinds of disasters and this kind of federal assistance the flood protection standards are intended to address. We need to protect the land we call home by ensuring that when federal taxpayer dollars are spent to build new public buildings or repair old ones from floods, we think long and hard about how best to protect against future damages.
Direct average annual flood damages have almost doubled since the 1990s, increasing from approximately $5.6 billion per year in the 1990s to nearly $10 billion per year in the 2000s. The indirect costs of flooding, such as business closings, supply-line interruptions, and lost wages, are far greater. Unfortunately, this trend shows no sign of abating. Sea level rise and more intense storms, resulting from climate change, will exacerbate our Nation’s flood risk.
To counter this growing problem, more than a year ago the Obama administration updated the flood protection standards. The updated standards require all Federal taxpayer-funded buildings, facilities, and infrastructure to be built with an additional margin of safety.
The standards require, whenever practicable, to avoid locating taxpayer funded infrastructure like schools, hospitals, fire stations, and water and sewage treatment plants, in a floodplain. And if you have to build them in a floodplain, then take some common sense steps to make sure they can survive a flood. Seems pretty straightforward, right?
These common sense flood protection standards have been supported by respected leaders in the arena like Smarter Safer, the Association of Federal Floodplain Managers, and a broad spectrum of organizations including fiscal conservatives, professional floodplain managers, environmental groups, and insurance interests. But for all the support the standards have received, there have been those who oppose building better.
In materials the Floodplain Alliance for Insurance Reform recently sent to Congress, they make many complaints that just don’t hold up to scrutiny. Below, we set the record straight on some of their incorrect claims.
Opponents claim, wrongly, that there has been no public input on the flood protection standards.
Following President Obama signing an executive order in January 2015 that updated the standards, there was a 90-day public comment period and eight public meetings held across the country and one public webinar.
Moreover, as federal agencies move to implement the standards, each agency is required by federal law to hold a public comment period on any proposed regulations they may issue. Some agencies have even requested public input in advance of proposing new regulations.
Opponents claim, wrongly, that the flood protection standards will increase the size of floodplains that appear on FEMA’s official flood maps.
Nothing could be further from the truth.
Under the flood protection standards, federally funded projects should be built outside the area that would be inundated by a flood with a depth equal to the 100-year flood plus 2 feet (3 feet for critical infrastructure). Alternatively, the depth of the 500-year flood can be used as the benchmark. The 100-year and 500-year flood elevations are already mapped by FEMA. Far from expanding how FEMA maps floodplains, applying the standard can rely on that information to make better decisions about what to build and where to build.
But don’t take my word for it, here’s what FEMA says about the standards:
“The FFRMS [Federal Flood Risk Management Standards] will not change the minimum floodplain management criteria in 44 CFR Part 60 that communities must adopt in order to participate in the NFIP for flood prone areas, FEMA’s flood mapping standards, or the rating and claims practices of the NFIP. This means that the FFRMS will have no effect on the cost or availability of Federal flood insurance for policyholders. FEMA will continue to identify and map flood prone areas and designate flood risk zones based on the 1-percent-annual chance floodplain using available engineering methods and depict these zones on Flood Insurance Rate Maps (FIRMs).”
Opponents claim, wrongly, that there needs to be a cost-benefit analysis before flood protection standards are put in place.
Multiple requirements already exist for such a process when a proposed rule is being developed. For example, Executive Order 12866 and OMB Circular A-4 impose a process for analyzing a proposed regulations fiscal impact. In addition, Executive Order 13563 incorporates the requirements of Executive Order 12866 and specifically directs agencies “to use the best available techniques to quantify anticipated present and future benefits and costs as accurately as possible.” Asking for an additional analysis of the costs and benefits is redundant and only wastes time and money.
The time has come to stop squabbling about whether we need updated flood protection standards. We clearly do. We’re wasting billions of dollars a year to repair and rebuild in the wake of floods. It is environmentally and fiscally irresponsible. It’s time to take a tougher stance on defending our Nation by joining our political leaders, taxpayer advocates, professional floodplain managers, and environmental groups in support of common sense reforms.
