Cancelling the Flood: Increasing FEMA Community Rating System Participation in Flood-Prone Communities

– Executive Summary

According to the Federal Emergency Management Agency (FEMA), “Flooding is the most frequent severe weather threat and the costliest natural disaster facing the nation.”[1] In 1968, Congress created the National Flood Insurance Program (NFIP) to provide flood insurance protection to homeowners.[2] Three decades later, Congress amended it to include the Community Rating System (CRS) that rewards flood-prone communities for efforts to improve floodplain management, enhance community preparedness, and mitigate flood risk.[3] CRS monetized the preparedness activities of communities before flooding, resulting in reduced flood damages and insurance claims, thereby saving the federal treasury taxpayer dollars. Participating communities receive NFIP discounts of up to 45 percent for their residents.[4] Congress created the CRS to help meet the two competing goals of the NFIP: financial solvency of the program and affordable flood insurance premiums.

This thesis explores methods for FEMA to increase Community Rating System participation in flood-prone communities. It employs appreciative inquiry as part of a comparative analysis of CRS success in the three most flood-prone states—Florida, Texas, and Louisiana. Since most of the CRS initiatives focus on the local level, this thesis examines the critical successes and essential failures of populous coastal and fluvial communities, too.

This research provides the findings of the comparative analysis including state promotion of the CRS program, the consequential impact of repetitive loss properties on NFIP’s solvency, and the unrealized opportunities to earn significant CRS credits for reducing such properties across the nation. By using the appreciative inquiry (AI) framework, this thesis identifies effective and unique mitigation opportunities to build resiliency into flood-prone communities, including advanced design solutions, along with grant funding solutions. By studying the CRS success of the three most flood-prone states and selected communities, this research provides roadmaps and blueprints for other communities to enhance and sustain their community resiliency, thereby providing flood insurance premium reductions for homeowners and improved financial solvency for the NFIP.

The three most flood-prone states share comprehensive floodplain management planning across all four CRS series, helping them attain CRS success. Executing a plan of public outreach, open space preservation, and an effective mitigation program leads to CRS success and reduced flood insurance premiums for homeowners.[5] Further, within the three most flood-prone states, urban centers have significantly greater participation, especially those with recent natural disasters, such as Houston and Austin.[6] Reviewing the state-by-state performance reveals a trend—performance varies significantly by community and depends more on local factors than broader state performance. State success in the CRS program depends on its promotion to communities. Further, developing a comprehensive floodplain management plan must account for the context. For example, Louisiana not only faces hurricanes from the Gulf, but also the confluence of two-thirds of the nation’s stormwater runoff.[7]

Sea Bright, NJ succeeded largely because of Superstorm Sandy upgrades that most coastal flood communities could replicate.[8] The One NYC plan provides a great foundation for CRS success since it covers all facets of life in New York City. Wilkes-Barre and Scranton, Pennsylvania are similar fluvial communities, having attained Fire Insurance Service Office (ISO) scores of two, which is outstanding.[9] Even though Scranton has fewer floodplain properties, its success with Fire ISO signals leadership commitment to emergency preparedness. Successful CRS communities have a commitment to the foundation of CRS—Floodplain Management Planning, Community Outreach, Mitigation Planning focusing on repetitive and severe repetitive loss properties and unique challenges to the specific community.[10]

A surprising finding of this research is the substantial flood risk of repetitive loss properties and their crucial role in the overall success of the CRS program. According to FEMA, “NFIP actuaries have reported that repetitive loss is the single most important factor that affects the stability of the National Flood Insurance Fund.”[11] Additionally, NFIP expects the costs of these properties to grow in the future. As FEMA notes, although only 1.3 percent of insured properties qualify as repetitive loss (RL) or severe repetitive loss (SRL), those properties may well account for 15 to 20 percent of future NFIP losses in the future.[12] Since RL and SRL pose exponentially greater financial risk to FEMA, reducing the number of these high hazard properties eliminates repeated flood claims and improves the NFIP’s solvency.[13] Hence, FEMA awards the most CRS points for activities that collectively reduce RL and SRL risk.[14]

The Community Rating System (CRS) bridges the gap. between fiscal solvency and citizen flood protection by encouraging local governments to execute proven floodplain management practices that reduce the risk to the federal government, which it rebates to homeowners through policy discounts. CRS rewards communities with policy discounts for additional floodplain management activities that reduce the overall risk to the federal treasury, a win-win for all.

For the CRS program to be effective and efficient, the federal, state, and local levels must have a strong partnership. It begins with leadership and a commitment to enhance and sustain the core capabilities of the National Preparedness Goal.[15] This effort starts with a comprehensive floodplain management plan developed with community stakeholders and partners, and then incorporates this plan into a longer-term state mitigation plan with community resiliency as the cornerstone.

RECOMMENDATIONS

  1. Public Official Training
    For lasting impact, all partners and stakeholders must have a basic understanding of the serious threat of flooding to the nation, the basic principles of the NFIP, and the value of the CRS. Based on the comparative analysis and findings, this thesis advances the following short term, medium term, and long-term training options for any community leader to be more effective and efficient in floodplain management and CRS success.[16]
  1. Planning for CRS Communities
    For communities participating in the CRS program, using a return on investment (ROI) template, found in Appendix C, would provide a roadmap to effectively improve their CRS ratings. This Alternative CRS Strategy organizes projects by ROI rather than activity, providing a roadmap to quickly focus on easy to achieve projects. By using the current CRS community achievement levels, communities could reorganize each element by high ROI (points earned with limited effort required), medium ROI (moderate effort required), low ROI (significant effort required), and de minimis ROI (exhaustive effort required).[17]
  1. THIRA Planning for Communities with Repetitive Loss Properties 
    Finally, for NFIP participating communities that have either RL or SRL properties, those communities should integrate the required NFIP Repetitive Loss Analysis plan into the required NPG Threat and Hazard Identification and Risk Assessment (THIRA).[18] Both federal programs separately require this assessment of flood risk so the ROI of working in partnership improves the chances of increasing mitigation grant funding.
  1. Future Research
    How can other states replicate Florida’s CRS program success? Florida’s overall CRS participation rates and the number of advanced communities far exceed the rest of the nation. What can be duplicated from the success of Miami, Houston, and New Orleans, in cities like Hoboken, New York, Philadelphia, and others? Lessons learned from these communities can become best practices for others to implement.

[1] Federal Emergency Management Agency, Flooding – Our Nation’s Most Frequent and Costly Natural Disaster (Washington, DC: Federal Emergency Management Agency, March 2010).

[2] Congress recognized that it could not be both profitable for private insurance companies and affordable for homeowners without financial support and commitment from the federal government. Federal Emergency Management Agency, Floodplain Management Requirements: A Study Guide and Desk Reference for Local Officials, FEMA 480, Washington, DC: Federal Emergency Management Agency, 2005, 2–3, https://www.fema.gov/sites/default/files/documents/fema-480_floodplain-management-study-guide_local-officials.pdf.

[3] Federal Emergency Management Agency, Floodplain Management Requirements, 2–4.

[4] Diane P. Horn, Introduction to the National Flood Insurance Program, CRS Report R44593 (Washington, DC: Congressional Research Service, January 6, 2023), 19.

[5] “Federal Emergency Management Agency, National Flood Insurance Program Community Rating System Newsletter,” Federal Emergency Management Agency, February 2023), 4.

[6] Federal Emergency Management Agency, Texas: Top 50 National Flood Insurance Program (NFIP) Policy Count Communities and Community Rating System (CRS) Participation (Washington, DC: Federal Emergency Management Agency, October 1, 2021), https://crsresources.org/files/100/maps/states/texas_crs_map_october_2021.pdf.

[7] Promoting Mitigation: FEMA and the State of Louisiana Press Release (Washington, DC: Federal Emergency Management Agency, February 11, 2011), 1.

[8] Sea Bright, CRS Activity 510: Progress Report on Implementation of Credited Plan, (Sea Bright, NJ: 2019), 2–6.

[9] “Community Rating System Factsheet,” Federal Emergency Management Agency, 2017, 1.

[10] Katherine H. Norris, “Inequity in Action: A Quantitative Analysis of the Implementation of State Hazard Mitigation Plans,” (master’s thesis, Naval Postgraduate School, March 2023), 25, http://hdl.handle.net/10945/72063.

[11] Federal Emergency Management Agency, National Flood Insurance Program Community Rating System: Coordinator’s Manual. FIA -15 /2017 (Washington, DC: Federal Emergency Management Agency, 2017), 110–6. https://www.fema.gov/sites/default/files/documents/fema_community-rating-system_coordinators-manual_2017.pdf.

[12] Federal Emergency Management Agency, 500–3.

[13] Laura Lightbody and Brian Watts, “Repeatedly Flooded Properties Will Continue to Cost Taxpayers Billions of Dollars,” Pew, October 1, 2020, https://www.pewtrusts.org/en/research-and-analysis/articles/2020/10/01/repeatedly-flooded-properties-will-continue-to-cost-taxpayers-billions-of-dollars

[14] Federal Emergency Management Agency, Coordinator’s Manual, 110–6.

[15] William L. Painter, The Department of Homeland Security: A Primer. CRS Report No. R47446 (Washington, DC: Congressional Research Service, March 21, 2023), 1

[16] Federal Emergency Management Agency. The Importance of Floodplain Management for Elected Officials (Washington, DC: Federal Emergency Management Agency, 2023)

[17] Michael-Kerjan Erwann, Ajita Atreyna and Jeffrey Czajkowski, Learning over Time from FEMA’s Community Rating System (CRS) and Its Link to Flood Resilience Measurement (Philadelphia: The Wharton School, University of Pennsylvania, 2016), 21.

[18] Department of Homeland Security, Federal Emergency Management Agency, Local Mitigation Planning Policy Guide, FP 206–21-0002 (Washington, DC: Department of Homeland Security, Federal Emergency Management Agency, April 19, 2023), 17.

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