[Senate Hearing 114-451]
[From the U.S. Government Publishing Office]
S. Hrg. 114-451
THE NATIONAL FLOOD INSURANCE PROGRAM: REVIEWING THE RECOMMENDATION OF
THE TECHNICAL MAPPING ADVISORY COUNCIL'S 2015 ANNUAL REPORT
=======================================================================
HEARING
before the
COMMITTEE ON
BANKING,HOUSING,AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED FOURTEENTH CONGRESS
SECOND SESSION
ON
EXAMINING THE TESTIMONY RELATED TO THE REAUTHORIZATION OF THE NATIONAL
FLOOD INSURANCE PROGRAM AS WELL AS THE RECOMMENDATIONS IN THE TECHNICAL
MAPPING ADVISORY COUNCIL'S ANNUAL REPORT
__________
SEPTEMBER 13, 2016
__________
Printed for the use of the Committee on Banking, Housing, and Urban
Affairs
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Available at: http://www.fdsys.gov/
______
U.S. GOVERNMENT PUBLISHING OFFICE
22-703 PDF WASHINGTON : 2017
-----------------------------------------------------------------------
For sale by the Superintendent of Documents, U.S. Government Publishing
Office Internet: bookstore.gpo.gov Phone: toll free (866) 512-1800;
DC area (202) 512-1800 Fax: (202) 512-2104 Mail: Stop IDCC,
Washington, DC 20402-0001
COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS
RICHARD C. SHELBY, Alabama, Chairman
MIKE CRAPO, Idaho SHERROD BROWN, Ohio
BOB CORKER, Tennessee JACK REED, Rhode Island
DAVID VITTER, Louisiana CHARLES E. SCHUMER, New York
PATRICK J. TOOMEY, Pennsylvania ROBERT MENENDEZ, New Jersey
MARK KIRK, Illinois JON TESTER, Montana
DEAN HELLER, Nevada MARK R. WARNER, Virginia
TIM SCOTT, South Carolina JEFF MERKLEY, Oregon
BEN SASSE, Nebraska ELIZABETH WARREN, Massachusetts
TOM COTTON, Arkansas HEIDI HEITKAMP, North Dakota
MIKE ROUNDS, South Dakota JOE DONNELLY, Indiana
JERRY MORAN, Kansas
William D. Duhnke III, Staff Director
Mark Powden, Democratic Staff Director
Jelena McWilliams, Deputy Staff Director and Chief Counsel
Shannon Hines, Professional Staff Member
Laura Swanson, Democratic Deputy Staff Director
Beth Cooper, Democratic Professional Staff Member
Dawn Ratliff, Chief Clerk
Troy Cornell, Hearing Clerk
Shelvin Simmons, IT Director
Jim Crowell, Editor
(ii)
C O N T E N T S
----------
TUESDAY, SEPTEMBER 13, 2016
Page
Opening statement of Chairman Shelby............................. 1
Opening statements, comments, or prepared statements of:
Senator Brown................................................ 2
WITNESSES
Roy E. Wright, Deputy Associate Administrator for Insurance and
Mitigation, Federal Emergency Management Agency................ 3
Prepared statement........................................... 27
Responses to written questions of:
Senator Toomey........................................... 36
Senator Menendez......................................... 36
Senator Warren........................................... 37
Senator Schumer.......................................... 37
Senator Kirk............................................. 38
John Dorman, Chair, Technical Mapping Advisory Council, and
Assistant State Emergency Management Director for Risk
Management, and Director, North Carolina Flood Risk Management
Program........................................................ 5
Prepared statement........................................... 30
Scott K. Edelman, Vice Chair, Technical Mapping Advisory Council,
and Senior Vice President, AECOM............................... 7
Prepared statement........................................... 34
Additional Material Supplied for the Record
FEMA--``Technical Mapping Advisory Council Overview''............ 41
Letter submitted by Tom Salomone, 2016 President, National
Association of REALTORS'............................ 47
Letter submitted by Chad Berginnis, Executive Director,
Association of State Floodplain Managers....................... 49
Letter submitted by Chad Berginnis, Executive Director,
Association of State Floodplain Managers and James M. Drinan,
JD, Executive Director, American Planning Association.......... 53
Joint letter submitted by American Bankers Association, American
Insurance Association, Council of Insurance Agents and Brokers,
Financial Services Roundtable, The Independent Insurance Agents
and Brokers of America, National Association of Mutual
Insurance Committees, National Association of Professional
Insurance Agents, and Property Casualty Insurers Association of
America regarding the Principles for Flood Insurance
Reauthorization................................................ 55
(iii)
THE NATIONAL FLOOD INSURANCE PROGRAM: REVIEWING THE RECOMMENDATION OF
THE TECHNICAL MAPPING ADVISORY COUNCIL'S 2015 ANNUAL REPORT
----------
TUESDAY, SEPTEMBER 13, 2016
U.S. Senate,
Committee on Banking, Housing, and Urban Affairs,
Washington, DC.
The Committee met at 10:32 a.m., in room SD-538, Dirksen
Senate Office Building, Hon. Richard C. Shelby, Chairman of the
Committee, presiding.
OPENING STATEMENT OF CHAIRMAN RICHARD C. SHELBY
Chairman Shelby. The hearing will come to order.
Today, we will hear testimony related to the upcoming
reauthorization of the National Flood Insurance Program, which
expires next year.
Today's witnesses will discuss the recommendations in the
Technical Mapping Advisory Council's annual report. The Council
was created by the Biggert-Waters Flood Insurance Reform Act.
Its job is to review matters related to the national flood
mapping program and make recommendations to FEMA.
This year's report includes recommendations on how FEMA can
better communicate flood risk which can form the basis for more
accurate flood insurance rates. Flood insurance not only helps
homeowners recover in the event of a flood; it also enables
communities to reduce flood risk through the adoption of
floodplain management standards. However, the program cannot be
successful without accurate mapping and flood risk modeling.
For years, right here I have advocated for a Flood
Insurance Program that uses the best science and data to map
properties so that both the Government and the homeowners fully
understand the risk of flooding.
Today, most homeowners do not understand the true flood
risk to their property. This is due in part to the fact that
FEMA's rate model was--and still is--based on limited data from
the early 1970s and nearly half of FEMA's maps remain out of
date.
The technology available today is better than ever before
and will enable us to produce very detailed maps. Such maps,
overlaid with historical flooding data and state-of-the-art
modeling, would allow the National Flood Insurance Program to
more accurately predict flooding risk and price flood insurance
policies accordingly.
The U.S. continues to experience repeated and devastating
flood disasters that have resulted in more than $51 billion in
payments from the National Flood Insurance Program. $51
billion. In fact, the recent flooding in Louisiana is
anticipated to cost more than $1 billion, making it the fourth
largest disaster in the history of the program.
These record-breaking disasters have required the program
to borrow $23 billion from the U.S. Treasury to pay claims. If
we want to ensure the long-term viability of the NFIP without
borrowing from the Treasury, flood insurance rates must
accurately reflect risk. The basic Flood Insurance Program has
not changed substantially since 1968.
I am hopeful that this report will spur the change that is
long overdue.
Senator Brown.
STATEMENT OF SENATOR SHERROD BROWN
Senator Brown. Thank you, Chairman Shelby, for calling this
hearing today and for your always prompt beginning of the
hearing.
Flooding is the most common and most costly natural
disaster facing our country. With a growing population and a
changing climate, our entire Nation--not just the coastal
States--will continue to grapple with this issue. It will have
a direct impact on Ohioans and other Americans who live in or
near floodplains. It will also have an indirect impact on all
taxpayers no matter where any of us live.
The people of Louisiana experienced historic, devastating
flooding in August from a storm that dumped as much as 2 feet
of rain in just about 48 hours. Thousands of homes and
businesses were destroyed; at least 13 people died. The cost is
so far very difficult to calculate.
Some homeowners and businesses had flood insurance policies
to help their recovery. Many others did not, possibly because
it was not required or because they assumed they were safe
outside of the 100-year floodplain.
I hope to get an update from Deputy Associate Administrator
Wright on how the NFIP is responding to the devastation in
Louisiana.
In addition, given the significant concerns that have been
raised around FEMA's claims process, I want to hear more about
FEMA's ``Transformation'' effort to improve the NFIP following
Superstorm Sandy and how that is working for policyholders in
Louisiana.
I also view today's hearing as the first step in a
comprehensive examination of the program leading up to its
reauthorization in 2017.
The National Flood Insurance Program seeks to combat the
effects of flooding through its three interrelated components:
One, flood insurance, to help property owners recover
quickly after a flood and reduce the need for Federal emergency
appropriations;
Two, floodplain management, to minimize damage to people
and property through mitigation and local ordinances;
And, three, floodplain mapping.
By identifying and mapping flood hazards, floodplain
mapping underpins both the insurance and the mitigation
components of the program.
The subject of today's hearing goes to the heart of
something both familiar and vital to us all: our homes and
communities.
Just ask the people of Louisiana.
We need to focus on ways to keep people and property out of
harm's way and help them bounce back when disaster does strike.
We also need to make smart investments in infrastructure
and mitigation to make our communities more resilient and to
save taxpayer dollars today and in the years ahead.
Accurate understanding and communication of the flood risks
we face is critical to those decisions.
Congress recognized the importance of accurate maps in our
2012 NFIP reauthorization, when we authorized increased funding
for FEMA's flood mapping and established the Technical Mapping
Advisory Committee to provide expert advice on improving
mapping for current and future conditions.
Our witnesses today will discuss TMAC's recommendations. I
hope to gain an understanding of the time, resources, and any
congressional actions that will be necessary to make them come
about. I hope this hearing brings that to us.
Mr. Wright, I understand that the short notice of today's
hearing did not permit you to submit advance written testimony
as is called for in the rules of the Committee. I hope you will
be submitting that testimony for the record.
Mr. Wright. I will, sir.
Senator Brown. Thank you.
With that, I welcome the witnesses, and I look forward to
hearing the testimony of all three of you on this important
topic.
Chairman Shelby. First, we will receive the testimony of
Mr. Roy Wright, Deputy Associate Administrator for Insurance
and Mitigation for the Federal Emergency Management Agency.
Next we will hear from Mr. John Dorman, who serves as the
Chair of the Technical Mapping Advisory Council. He is also the
assistant State emergency management director for risk
management for North Carolina.
Last, we will receive testimony from Mr. Scott Edelman, the
Vice Chair of the Technical Mapping Advisory Council. Mr.
Edelman is also the senior vice president for North America for
AECOM Water Resources. Is that right?
We welcome all of you today. Your written testimony will be
made part of the hearing record in its totality. We will start
with you, Mr. Wright.
STATEMENT OF ROY E. WRIGHT, DEPUTY ASSOCIATE ADMINISTRATOR FOR
INSURANCE AND MITIGATION, FEDERAL EMERGENCY MANAGEMENT AGENCY
Mr. Wright. Good morning, Chairman Shelby, Ranking Member
Brown, and Members of the Committee. I am Roy Wright, and I
serve as that Deputy Associate Administrator. Thank you for the
opportunity to testify about FEMA's Technical Mapping Advisory
Council--the ``TMAC,'' as we will call it--the recommendations
it has provided to FEMA, and our progress addressing those
recommendations.
As indicated by their name and clearly stated in the TMAC
charter, the Council is an advisory board established to advise
and make recommendations to the FEMA Administrator and the
flood mapping program. The Council's recommendations aid FEMA
in furthering our efforts to provide communities with the best
available data and tools to make better informed decisions that
reduce the risk and consequences of flooded across our Nation.
These recommendations in the mapping field complement our
endeavors elsewhere in the National Flood Insurance Program.
Mr. Brown asked about the transformation we are doing for the
customer, experienced policyholders, really a generational leap
forward that we are taking on our actuarial and claims
underwriting processes; ensuring that policyholders, like those
that we serve in Louisiana, get their claims paid accurately
and quickly.
We can talk more about this, but I will highlight inside of
the first 30 days, almost 29,000 claims have been filed, more
than $300 million in advance and early payments have moved out
to insured. This is a pace that has never been seen in the
history of National Flood.
To the TMAC, FEMA fundamentally agrees with the intent of
all 22 of the recommendations in the 2015 annual report. As I
look at those recommendations, I kind of see them in three
streams: there are those of a technical nature that can be
addressed through our normal policy updates; a second group
that are probably a stretch for our program, but they can be
accomplished with current science and resource levels; and,
third, a transformative set that requires the science to evolve
and resource levels that may not exactly be knowable today.
Over the last several months, we evaluated each and every
one of these recommendations to understand resource
requirements and impacts to inform implementation, priority
sequence, and investments.
Perhaps the most transformative recommendation made in the
TMAC 2015 report is to transition from the 1-percent annual
chance as the basis for flood insurance ratings to a structure-
specific flood frequency determination. This recommendation
will require an entirely new approach to insurance rating and
underwriting, including new regulatory hazard and risk
products. It could also have cascading effects on floodplain
management standards in communities.
In January 2016, the TMAC also delivered its Future
Condition, Risk Assessment, and Modeling report looking beyond
today's risk. The recommendations there really have tried to
push us in ways that drive past what is currently practiced, so
putting our agency in a position to address and inform future
building in the country.
This summer, the TMAC submitted the 2016 Flood Mapping
Program Review as required under Section 17 of the Homeowners
Flood Insurance Affordability Act of 2014. This report included
a set of recommendations to further advance the program's
credible flood hazard data into the future. Based on the advice
from the TMAC and my recommendation, the Administrator has
certified the flood mapping program as credible.
We have already begun implementing the technical
recommendations that we can address through policy. We continue
to make strategic investments like high-resolution topography,
structure-specific data sets, and enhanced flood models; and
are laying out the planning that we need to lay the foundation
for this transformative work going forward.
Those transformative pieces, including the TMAC's
recommendation to transition away from the 1-percent annual
chance to provide the structure-specific risk information, will
necessitate additional research and planning, internally and
with our partners.
This said, to the Chairman's point, we need to meet these
transformations in flood hazard analysis with complementary
leaps forward in our actuarial and underwriting practices. I
consider this new approach to insurance rating and underwriting
crucial to the program. Simply, we need to set premiums that
best reflect the risk.
While the flood risk analysis is essential, nothing is more
powerful to communicate risk than a pricing signal. These
initiatives and investments will be critical as FEMA assesses
how we move away from being able to support kind of a big event
understood to understand the whole manifold of events that can
take place. We have got to move to structure-specific flood
frequencies, and eventually we need to actually see the
actuarial structure of the program fundamentally shift.
I appreciate the extraordinary time invested by the
Technical Mapping Advisory Council. Their hard work and
dedication will serve this program well. I am happy to address
your questions, and thank you, Mr. Chairman.
Chairman Shelby. Mr. Dorman.
STATEMENT OF JOHN DORMAN, CHAIR, TECHNICAL MAPPING ADVISORY
COUNCIL, AND ASSISTANT STATE EMERGENCY MANAGEMENT DIRECTOR FOR
RISK MANAGEMENT, AND DIRECTOR, NORTH CAROLINA FLOOD RISK
MANAGEMENT PROGRAM
Mr. Dorman. Thank you, Chairman Shelby, Senator Brown, and
Members of the Committee for the opportunity to come and
provide a perspective on the 2015 Technical Mapping Advisory
Council. As noted, I am John Dorman. I am the North Carolina
assistant State emergency management director for risk
management--that is a mouthful--and also the director of the
Flood Risk Management Program.
Necessity is the mother of all innovation. That is an
English proverb that speaks well to the overall tenet of the
TMAC recommendations. FEMA has diligently overseen the
generation of the current flood maps that focus more toward the
hazard. However, transformational strategies must be
implemented to address the needs of the country and the
program, such as insurance rates that reflect structure-
anticipated flood loss; communication that focuses on financial
loss as opposed to just an ``in and out''; and homeowners'
understanding of and confidence in the data used for flood
hazard determination and insurance premiums.
For North Carolina, Hurricanes Floyd, Francis, Ivan, and
Irene all demonstrated and compelled North Carolina to the need
for implementing transformational strategies. Thus, North
Carolina has successfully implemented the ability to generate
structure-based flood probability; structure-based flood risk
assessments; structure-based real-time impact and warning; and
structure-based, risk-based insurance rating. We are doing
that. Recent events across the country have again shown a lack
of accuracy and awareness of structure-specific flood risks
that both large storms and localized flash flooding can
present. With these needs ever apparent, I believe TMAC has
constructed recommendations that, if implemented, will
transform the program and improve the Nation's resiliency to
flooding. While there are 22 recommendations, I would like to
quickly speak to four of those that will be transformational.
First--and you have heard this before--fundamental to
accurate flood hazard identification and risk assessment is
accurate, high-resolution elevation data. Recent developments
in data collection technologies offer the most accurate and
efficient collection of ground elevation possible. Technology
such as Geiger LiDAR sensors collect data at both a higher
altitude and higher accuracy allowing for faster acquisition
and a lower cost of acquiring and processing the data. This
higher-resolution data also allows the opportunity to meet
other needs of other stakeholders--such as the Department of
Transportation and Utilities--that allow stakeholders to play a
part in sharing the cost.
Second, the transition from a 1-percent or 100-year flood
delineation and its elevation to a structure-specific annual
chance frequency with elevation is critical for the awareness
of every property that is in the flood zone, and it is, of
course, interesting to note that 26 percent of all flood claims
occur outside of the 100-year flood line. The recent events in
Louisiana demonstrate the importance of altering our Nation's
mentality that one is safe if they live outside of that line on
to a raised awareness of flood prevention at the structure
level.
Third, the transitioning to a focus of structure-based risk
assessment. This increased level of detail that calculate
structure-specific percent chance of flooding and estimated
annualized damage calculations can inform mitigation decisions
and create more accurate risk-based insurance premiums. This
will directly result in mitigation actions to reduce losses,
lessen the financial burden of the Federal Government to help
communities recover from disasters, and create a more
financially sound FIMA.
Finally, we must transition to a dynamic, queried display
of data, models, maps, and risk assessments. I will just say I
have seven children, and most of them are in the Millennial
generation, and as we have seen, the Nation has changed in how
it looks at and demands data. We must create a more robust
database that enables data to be dynamically queried and
displayed on the Web site. Floodplain modeling and mapping is
an ever changing science, based largely on the statistics and
the changes in land use and topography. We need to create an
efficient methodology to quickly and efficiently update flood
hazard and risk information and provide that at the fingertips
of the end users on all types of devices.
I want to point out that all or some of the four
recommendations I have just mentioned have been successfully
implemented in four States. These recommendations are not ideas
or pie-in-the-sky. They are proven concepts that are
operational today.
Thank you again for the opportunity to address the
Committee on this important topic. I would be willing and happy
to answer any questions you may have.
Chairman Shelby. Mr. Edelman.
STATEMENT OF SCOTT K. EDELMAN, VICE CHAIR, TECHNICAL MAPPING
ADVISORY COUNCIL, AND SENIOR VICE PRESIDENT, AECOM
Mr. Edelman. Good morning, Chairman Shelby and Members of
the Committee. I am Scott Edelman, senior vice president of
AECOM. I have spent my career solely focused on solving our
Nation's water-related opportunities and challenges. I
appreciate this opportunity to appear before the Committee on
Banking, Housing, and Urban Affairs.
I have been involved with creating maps for FEMA since
1981, and I am privileged serving as Vice Chair on the
Technical Mapping Advisory Committee established by the 112th
Congress. We as a Nation have simply endured too much pain and
suffering due to floods.
I believe that Roy Wright's strong support and
encouragement of the TMAC has resulted in two reports that show
a path to the next evolution of the NFIP. In the future, I
believe that if the recommendations of the TMAC reports are
supported by Congress and the Administration, we can make
significant strides to reduce both the pain and suffering that
our citizens are enduring at a record level and the burden
these unprecedented events continue to drain resources from our
U.S. Treasury.
Of the 29 recommendations contained in the TMAC 2015
reports, I believe that the three most important priorities and
potential benefits are:
First, the reintroduction of a 5-year rolling plan, to
allow leveraging of Federal dollars;
Second, the movement to structure-based risk assessments,
to create a safer Nation;
Third, preparing the Nation for future conditions, to stop
building new problems.
First, the reinstatement of the 5-year rolling plan allows
the leveraging of local and State dollars. FEMA cannot make the
Nation a safer place alone. The operating principles of FEMA's
Whole Community doctrine is critical as applied to flood-
related mitigation. Flood waters know no jurisdictional
boundaries as they devastate lives and property, and,
therefore, we need to fully engage local communities and make
these shared responsibilities more apparent to all. When
Congress funded Map Modernization in 2003, FEMA produced the
Multi-Year Flood Hazard Identification Plan, MHIP. MHIP
addressed every county in the Nation with when and how much
anticipated funding would be available. The result was an
enterprise-wide approach to maximize the return on Federal
investments in which FEMA served as the chief risk officer to
those investment in the studies, and communities felt strong
local ownership of the studies and results. This approach
better aligned FEMA with State and local efforts to reduce the
loss of life and property.
Second is structure-based risk assessments. We must change
the perception that if I am just on the other side of the 100-
year flood line I am safe. Too much time is spent trying to
justify the movement of the flood line by a few feet when in
actuality the risk of flooding of the structure only has
changed ever so slightly. Much of the problem is due to
uncertainty of the line itself.
To my knowledge, this is the only product that engineers
produce and communicate to the public that deals with averages
and not what is safe.
We also have a great deal of uncertainty within the
calculations. In all actuality, the current 100-year average
line shown on the flood maps is probably closer to a safe
design of a 10-year event.
Moving to a structure-based risk assessment begins to
change the conversation from one focused on ``in versus out''
to one that starts to communicate levels of risk. We must also
take into account affordability and grandfathering with sunset
clauses to take into account our most vulnerable communities
and constituents.
Third, we need to prepare the Nation for the future. GAO
asked FEMA to evaluate the impact of future conditions on the
National Flood Insurance Program. The report concluded that by
the year 2100 on average our floodplains are going to increase
by 45 percent, the number of polices we have are going to
increase by 80 percent, and the average loss per policy in
today's dollars will increase by 50 percent. This is an immense
challenge to our country. We need to encourage local
communities to adopt higher standards on a volunteer basis,
understanding that the higher standards results in less loss of
life. Many communities have done this, including Mecklenburg
County and the city of Charlotte. Based on their adoption of
future conditions elevations, Mecklenburg County has estimated
savings from flood damages from a single 100-year event to be
over $150 million. We need to stop building future problems so
we can fully concentrate on mitigation of existing problems.
My passion is not solely on the science but the need to
help the Nation with this longstanding challenge and the
billions of tax dollars that are unnecessarily wasted because
of poor land use decisions and the attempt to tame or ignore
Mother Nature.
I want to again thank the Committee for this opportunity. I
urge Members of the Committee to refer to the two TMAC reports
for more detail as a formal part of our testimony.
I would be happy to answer any questions you may have.
Chairman Shelby. I will ask all of you this: In your view,
does the Flood Insurance Program accurately map, price, and
communicate flood risk to homeowners in communities? Mr.
Wright, does it or does it not?
Mr. Dorman. I believe it does present it in a way that is
consistent. I would tell you that there is so much more
potential related to making it more precise. It can be
actuarially sound for the 80 percent of the policies that are
in that space, but there is significant ability for us to
improve.
Chairman Shelby. Mr. Dorman.
Mr. Dorman. Sir, I believe the guidelines and standards
that are being followed does allow for the making of
appropriate maps. I do believe that the relationship between
the individual and the insurance rater is the most important
component to that, and I would say that they would feel it is
not adequate. But for the level of data that they currently
have, I believe it is meeting its need.
Chairman Shelby. Mr. Edelman.
Mr. Edelman. We have two challenges with the 100-year flood
line, first as it deals with averages. As engineers, when we
communicate numbers to the public, we deal in what is safe. If
a 20-ton truck was going to go over a bridge that is supposed
to be safe for 20 tons, you expect to put thousands of trucks
over that every time and not have the bridge fail. The standard
that we are using on the maps, though, is that every other
truck would fail that bridge. So we are communicating that
wrong.
Second is uncertainty. We are a very young Nation. We have
gauge records of 20, 40, 60 years that are trying to predict
something that is 100 years out. If I was going to do the
engineering on the Nile River, I would probably have thousands
of years of records I could use. This uncertainty creates a
large unknown such that our elevations many times could be many
feet higher or lower than what is shown on the maps.
Chairman Shelby. The chance of flood determinations, Mr.
Edelman, the report recommends that the National Flood
Insurance Program move away from identifying the 1-percent
annual risk to a structure-specific flood frequency
determination and associated flood elevations. This 1-percent
determination has been in place since the creation of the
program. What are the specific differences between the two
approaches? And how would the program change under the
structure-specific determination methodology? And what is the
downside here? Because a lot of the stuff we have today is not
working.
Mr. Edelman. You are absolutely correct, Mr. Chairman. The
problem that we have today is this in versus out mentality,
that if you are just a few feet outside the 100-year line you
are safe. What we are proposing is that all structures have
some level of risk. If you are built on the top of a hill, your
risk is going to be very low. But if you are just really close
to that line, you still have risk. And we need to have a
graduated system for moving through this.
The challenge that we are going to have is not so much on
the technology. We can do this today. We know how to do this.
The challenge will be with the implementation of how do we then
move the program from the current position to this new world,
and I believe we are going to have to do this with
grandfathering, with sunset clauses that may take 10 or 20
years to fade on out to make this accurate.
Chairman Shelby. Senator Brown.
Senator Brown. Thank you.
Mr. Edelman, you used the phrase in your testimony, ``We
must change the perception,'' and I want to ask you and Mr.
Dorman a couple of questions, and you can go first, about how
we communicate flood risk to consumers. When most people think
about flood risk, when they think about NFIP, they think about
whether they are in or out of the 100-year floodplain, assuming
they are not at risk if they are outside of that zone. You have
both intimated that. What exactly does the notion of the 100-
year floodplain obscure for consumers? And by that, you know,
how do we better communicate with people so that they
understand better their flood risk and insure their properties
appropriately? How do we communicate that? Mr. Edelman, if you
would start on that.
Mr. Edelman. OK. We can identify that by being structure-
specific. What people want to know is what is the risk of my
property, of my building, not so much what is generally
happening in my neighborhood or my town. So we have to be very
structure-specific to do that, and by allowing people to use
the latest technology to click on their individual house to see
what that risk is.
Senator Brown. Mr. Dorman.
Mr. Dorman. Well, I can speak for North Carolina. What we
have done is we have collected first-floor elevations for all
properties in the 100-year flood zone. And when there is a
flood and it starts flooding inside that property, there is a
financial cost to them. At the current pace we have, all we
know for homeowners is you are either in the 100-year or not,
whether you are going to flood more frequently or whether you
are not. So everyone at the current time sees either a 100-year
event, it is going to happen to me or not.
So what we have done in North Carolina and I believe what
the TMAC is proposing is that for each individual property we
determine at the 100-year or different levels of frequency what
the financial cost will be to the individual. That, from my
perspective, speaks very clearly to an individual what they
need to do to cover themselves.
Senator Brown. Specifically, what Mr. Edelman said, you
designate each structure with--attach the flood risk to each
structure.
Mr. Dorman. And the financial damage that will occur from
that.
Senator Brown. OK. Mr. Wright, NFIP came under fire for its
management of the Sandy claims process. You talked about the
good news of the unprecedented response to Louisiana. Tell me
what lessons you learned from Superstorm Sandy and your
response and what steps you have taken to improve it.
Mr. Wright. So, clearly, there was the scale of Sandy,
144,000 claims, $8.5 billion that was paid out initially. And
as this Committee's investigation pointed out, there were
plenty of stumbles in terms of how that is done, and part of
the charge that Administrator Fugate has given to me is to set
that back to right. At this point, 97 percent of those files
that requested review have been reviewed; 80 percent of those
offers have been made; and we are wrapping that up here in the
weeks to come.
But fundamentally for me, what it did was to force us to
step back and say the relic of this program, much of which you
can tie back to 1986 and 1999, had to change. So we saw this in
what we did in Louisiana. I was on the ground very early. I
have been down there twice. We have been in folks' homes.
Folks, where they have an insurance policy, want to know that
the money is coming. We push the money. Again, it does no
change the overall claim amount, but get those dollars so that
they can begin their own repairs, ensuring that they have an
off ramp when they get frustrated and confused.
So I have been out in the press, and we have been pushing
these things. If you are not getting the answer you want from
the insurance company, do not wait until the end. Come to us.
We have added a tremendous amount of oversight in terms of
quality control, tripled the amount that has historically been
done in the program, far more transparency, not only about from
the company's data but--in spite of the fact that the State
insurance commissioner does not regulate my program, I
volunteered to provide all of my information related to our
performance to the State insurance commissioner. So if you have
got problems, let us know.
Some of this is about simplification. This will be the
first event that will be able to fully avail itself of our new
appeals process. I think one of the big things I learned from
Sandy is if we would have had a robust and fair appeals
process, we could have addressed concerns as they came our way.
The prior regime that was in place just was not credible
enough. I could say more, but----
Senator Brown. What did you mean when you said make sure
that there is an off ramp when a homeowner is confused?
Mr. Wright. When someone files a claim, we tell them to
call their agent or their company, and we sell through 80
different companies that are out there, and that is the first
place to go to file your claim. But this program is
underwritten by the Federal Emergency Management Agency, and so
if I have a customer or a policyholder who has been frustrated
by their company, somehow something got dropped, this is my
program at the end of the day. And what we have done is said,
``You call me.'' And I am out there. You call 1-800-621-FEMA,
and you push number 2 for flood insurance, and you get to
someone so that we can resolve this. You should not have to
wait.
Senator Brown. Good. Thank you.
Thanks, Mr. Chairman.
Chairman Shelby. Senator Scott.
Senator Scott. Thank you, Mr. Chairman. Good morning to the
panel. Thank you all for being here. Mr. Wright, good seeing
you again.
Just one quick question on the Sandy crisis. What
percentage of homeowners had flood insurance in that area?
Mr. Wright. So I do not have great insight into that. Give
me a little moment to kind of explain. I know how many flood
insurance claims I have. No question about that. But FEMA does
not retain data on structures and properties across America. So
we have approximate pieces.
I know at a hearing with both you and Mr. Vitter in July,
we talked a bit about this, and one of the elements that I have
worked on since then is, as part of our broader affordability
work, we are going and doing some data matching with the Census
Bureau, where we are taking our 5.1 million policies and
bringing in some of the census data, because we need better
answers to this question about how many structures are in
versus out.
Senator Scott. So you have no clue on the percentage of
homeowners----
Mr. Wright. We have a series of studies that range----
Senator Scott. Mr. Wright, let me ask you a quick question.
Mr. Wright. I apologize.
Senator Scott. Because, unfortunately, 5 minutes is not as
long in Washington, DC, as it is other places. You do not have
a clue at this point, and perhaps you can provide that to me,
because here is my point: My answer--I spent, as you know, 20
years in the insurance business, and so my assumption is that
the answer is, ``Not many.'' And because the answer is like,
``Not many,'' when I look at my State and the flood insurance
mapping that is going on right now, when we look in Horry
County specifically--a 1,000-year flood just occurred in South
Carolina. We know that most of it was in the middle of the
State. Unfortunately, part of the consequences of the flood
mapping and using the 100-year model is that there are places
in Horry County that will now have to have flood insurance that
did not flood even during a 1,000-year flood. Perhaps an
additional 35,000 houses will need flood insurance even though
they are not, according to the 1,000-year flood, in real
danger, with an increased premium of around $6,000. Said
differently, for the homeowner who has a mortgage, that could
be about another $500-a-month in your mortgage premium. A
substantial increase.
I know that there is no way that FEMA takes into
consideration low-income houses and the impact that the mapping
would have on their ability to keep their homes. It is probably
impossible for that to be an expectation. What concerns me,
however, is knowing that one of the worst disasters from a
flood perspective occurred really outside of an area that
anyone would anticipate flood insurance, it does lead to a
logical conclusion that many folks who have flood insurance
will be absorbing the price and the responsibility of flooding
in places where you just cannot model it.
A part of that process has created much concern in Horry
County because, while it is a 10-year remapping process, it is
a 90-day appeal. And in those 90 days, you have to--according
to my friends in Horry County, the community has to develop
hydrology, hydrologic data and analysis, in order to appeal
what took 10 years on one side, you only get 90 days on the
other side. And, frankly, the information that we use to create
pricing, according to my folks who did not experience flooding,
is at best inconsistent with the realities that they have
experienced for the last couple hundred years.
Mr. Wright. So a couple of key points. All of the mapping
efforts that you are discussing have been in motion for a
number of years, most of them for less than 10 but for a number
of years, and the event from last fall, we did not go back and
redo the work, so it is based on the 1-percent annual chance
from a prior cycle.
To the point about the price, in every instance, given the
direction in the 2014 legislation that was passed and signed
into law, anyone who is coming in is not getting the $6,000
price. They are actually coming in at a newly mapped rate. That
average is between $300 and $500, depending on the level of
coverage. They do escalate over time, but they are coming in at
a much lower rate.
I think to the appeal question, I think it is very
important. What I will assure you of is we have been sharing
the data with the community throughout the process. They do not
just get it at the end. In fact, they have a number of
instances where the community gets a preview of it, and it
says, ``Do you want to give us additional information? Do you
have things that would change it?''
The 90 days per se related to that appeal period is set in
statute. And so what we have done very intentionally is work a
long way on the front side so there are no surprises, so that
when the 90 days starts that is set in statute, folks are
primed to play.
Senator Scott. I am out of time. I will just end my
comments with one comment as opposed to a question, and Mr.
Vitter made this point during our small business hearing when
you were there to testify. I recognize that the average price
of flood insurance is under $1,000. I have flood insurance at
my home, and I am 30 miles outside of Charleston. I will tell
you that in some areas--and I think one of the examples that
you used was the flood insurance premium was somewhere over
$25,000. So we are not talking about a $300 to $500 average
premium. We are talking about the outliers that are becoming
more of--less of an anomaly and more baked into the reality of
many homeowners. And I do not know many homeowners who can
afford what some will experience in Horry County--maybe not
all, but more than a few--a $6,000 premium, which is going to
be hard to absorb, and it would be great if we could find a way
to take that into perspective and context as we think about
flooding and disasters going forward.
Thank you.
Chairman Shelby. Senator Tester.
Senator Tester. Thank you, Mr. Chairman, and I want to
thank you and Senator Brown for holding this hearing.
Before I get to the witnesses, I want to speak about a
bill--and Senator Heller was here earlier--than Senator Heller
and I have. We have been working on it. It is called the
``Flood Insurance Market Parity and Modernization Act.'' It is
an important bill that will offer consumers flood insurance
options, and I think it will help NFIP remain viable over the
long haul. It will introduce private insurance into the
marketplace under the supervision of State insurance
commissioners. It was introduced in the House by Murphy and
Ross. It passed the House 419-0, which is an unusual thing for
the House to do. But the fact is I think it speaks of the
support of this bill, and I would love to see the Committee
take this up because I think it is something that could help. I
know that there are Members of this Committee who oppose it,
but that is what hearings are about, hammering out the
differences. And so I just bring that up because I think it is
important.
You know, this hearing should be held in front of the
Energy Committee. Things are changing. Here are some things
that I heard in the testimony: a pace never seen before in
National Flood, the growth; 26 percent of the claims are
outside the flood lines; in 83 years, our floodplains are going
to increase by 45 percent. And then I heard premiums need to
reflect risk; otherwise, the taxpayer pays for it.
And, quite frankly, this puts us in a conundrum because, as
Senator Scott said, we have--you know, we have got people who
cannot afford these kind of claims. By the same token, if we
want to talk about fiscal prudence, we cannot expect the
taxpayers, as we see these claims go up and up and up and up
and up and up and up, and billions and billions of dollars--I
think the Chairman said Sandy was a billion bucks. That is
probably going to be a cheap one next year. Who knows?
So I appreciate the work you do, and it puts us in a
difficult situation because I think most of us believe the
premiums need to reflect the risk, but we do not want to
premium people outside their homes, which means we need to come
to the realization that things are changing in our climate, and
they are changing quickly, and more quickly than we can adapt
to them in a reasonable way. And if we are going to continue in
this body of the U.S. Senate to have policies in this country
that promote climate change, we had better get the wallet out,
and we had better expect the taxpayers and our next generations
to pay a lot of money. That is my editorial comment.
Now I want to talk to you, Mr. Wright, about--by the way,
could you give me some figures on what is happening-- how long
have you been with the agency?
Mr. Wright. I have been with the agency for 8 years. I have
been in this role for 15 months.
Senator Tester. OK. So it would be unfair. I am going to
ask your agency to see what FEMA's budget has done over the
last 20 years. My guess is it has probably grown not just
double but a hell of a lot more than that.
Mr. Wright. There has been an up-and-down swing--we will
get you some numbers--in both the Disaster Relief Fund as well
as the base funding for the programs.
Senator Tester. OK. Thank you.
We have an issue in Montana on levees. It used to be that
the Army Corps would give FEMA information and--and correct me
if I am wrong--they would accredit those levees. The Army Corps
decided they were not going to do that anymore because they
said they do not have the budget capability of doing these
accreditations and, quite frankly, the liability is too high,
which puts the communities in a position where they cannot
afford to do the accreditation. And it puts you in a position
that you cannot afford to make the decision as to whether it is
a viable levee or not without that information.
Could you talk to me, is the relationship between FEMA and
the Army Corps when it comes to levees, is that over with? Or
are you still working with these guys? Can you work with them?
Are they offering you information? Give me an idea what is
going on.
Mr. Wright. So we work very closely with the Army Corps of
Engineers. I think if you go back 5, 6 years ago, I think that
that relationship needed a tremendous amount of work, and we
have repaired it in that period of time.
You point out their resourcing issues, so they have three
different kinds of analysis that they do of levees. Their top
tier one meets everything we need, but they do not do those
very often. Their bottom tier one, which they do all the time,
meets very little of the needs that we have.
And so under our regulations, the primary responsibility
for levee certification belongs to the levee owner. In many
instances, the Corps built them and then turned them over to
the local sponsor.
There are a few changes that I have put in place. One of
them is to work very closely with the local levee districts or
authorities so that we can give appropriate credit for however
much protection it does provide. Simply telling me that, you
know, this levee has done very well for the last 40 years is
not sufficient. In some instances, I have spoken with levee
board members, and I have said, ``Have you drilled a boring in
this in the last 40 years? Have you checked for safety?''
Senator Tester. Right.
Mr. Wright. And they go, ``No.'' You know, that is one of
those pieces that from a safety perspective is concerning to
me.
Senator Tester. Yes.
Mr. Wright. And so what I have got to do is find the best
kind of balance of how do we work with them, and we have made
partial credit more feasible in terms of how it reflects, but
there is a cost to that certification.
Senator Tester. Well, I appreciate your work, Mr. Wright,
and I appreciate the work of all the folks on this panel, and I
appreciate your testimony even though I was focused more on Mr.
Wright than the rest of you. But I would just say that if there
is stuff coming down the pipe where you need help to make this
happen--because it is not happening, and we are putting a lot
more folks in the floodplain because of that--not in all cases.
I should not make a blanket statement. You know what I mean,
Roy.
Mr. Wright. I do.
Senator Tester. Thank you very, very much.
Mr. Wright. Thank you.
Chairman Shelby. Senator Vitter.
Senator Vitter. Thank you, Mr. Chairman. Thanks to all of
you for your important work in this area.
I first want to underscore the significance of the recent
Louisiana flooding. I think it was really, unfortunately,
underreported in the national news for various reasons--a lot
of other things going on, the Olympics, the Presidential race.
And I think it is underappreciated in this body. We were away
on the August recess. But by any metric, it was the most
significant disaster since Sandy. Red Cross confirms that; FEMA
confirms that.
There have been over 138,000 individual FEMA claims. That
compares to flooding in northern and central Louisiana earlier
this year. That was very significant, under 40,000. Flooding in
South Carolina last year that was very significant, about
26,000. So it was literally a 1,000-year flood event. It was a
big event. And, unfortunately, only about 22 percent of those
flooded had flood insurance, not because they did not meet some
requirement or some notion of what was the prudent thing to do;
rather, they were way outside what was understood as any sort
of flood zone.
Mr. Wright, thank you for your work and for FEMA's work. Do
you want to make any quick comment on the significance of the
event and also the percentage of those uninsured?
Mr. Wright. Absolutely. As I look back at the last dozen
years, this one is number four on the list. I have got Katrina,
Sandy, and then Hurricane Ike from 2008. From a pure policy
count number, it is number four in line. It is in a riverine
area, more inland. And as I walked through some of the
neighborhoods, and particularly in areas inside the special
flood hazard area first, there were a tremendous number of
rental homes by which the landlord presumably had it paid off,
they did not carry flood insurance, and the renter did not
flood insurance. There was one block where only one out of
eight of those homes had flood insurance, yet they were all
inside.
I would then also speak to those beyond. So I look at some
of the things--I always get in trouble when you call out
parishes, but I looked particularly at East Baton Rouge and
Livingston parishes where we saw a tremendous amount outside.
Those folks clearly saw the 1,000-year event. And so as you see
that structure--I look at the counts particularly in East Baton
Rouge and the kind of concentration of that. This absolutely is
a devastating event.
Senator Vitter. Thank you. I just want to underscore that
because the Administration is going to properly make an
emergency request. But, again, 78 percent of those affected, no
flood insurance, not because they did something wrong but
because the great majority of them were way outside what was
identified as any sort of flood area.
To go to this mapping issue, Mr. Dorman, thank you for your
work. You point out in your testimony the good work of North
Carolina as well as Alabama and Virginia in their use to the
Flood Risk Information System, and there are similar ways of
going about obtaining that much greater level of clarity and
accuracy. In layman's terms, what do other States and the
Federal Government have to do to capture that level of real-
time and property-specific understanding?
Mr. Dorman. Well, I would say a couple things:
Efficient use of technology. This same set of LiDAR data
can give you building footprints. North Carolina collected 5.2
million building footprints to know where the buildings are
located. The LiDAR technology does that. It also gives you
first-floor elevation.
Partnerships--partnerships where North Carolina has worked
with our local governments to give us all the tax parcel
information that we tie to the buildings.
So, Senator, I would say the data is out there. For the
most part, the data is out there. It comes down to efficient
use of technology and the efficient use of partnerships. And
for North Carolina, we have been able to leverage up to $20
million of partnership leveraging with other entities in
sharing that set of data that they have a vested interest on. I
mentioned that a little bit. The Department of Transportation
needs information for their road centerlines. The LiDAR data
does that for them. Utilities need it for power lines, for
transmission and distribution.
So we have not gone out and collected it ourselves. We have
partnered and used technology to do that.
Senator Vitter. Great. Thank you.
Thank you, Mr. Chairman.
Chairman Shelby. Senator Reed.
Senator Reed. Well, thank you very much, Mr. Chairman, and
thank you for holding the hearing. I was very active with my
colleagues in trying to create this organization back a few
years ago, and thank you for your work, gentlemen, and
collectively your colleagues.
We have set you with the task of updating flood maps, but
that is a constant challenge, and it also requires resources.
And I wonder, Mr. Edelman, can you comment? Because the annual
report points out quite clearly how resources fell in 2011, and
they are not keeping up with the challenge, particularly as we
see some of these ocean effects and flooding effects getting
more dramatic. Can you comment on that?
Mr. Edelman. Yes, I can. It is really important for us to
have a stable program, and this is one of the reasons behind
trying to establish a 5-year plan. Perhaps if we could look at
something more toward the way that the Transportation
Improvement Program, the TIP, is done, it would allow for
easier planning of activities so we do not have these whipsaws
up and down and we can fully leverage everything.
The second part of your question there really goes down to
the heart that as a Nation we need to get out in front of this
problem and stop building new problems. What we really need to
do is draw that line in the sand such that let us not create
more problems. Let us put our hands around what we have, have
new development occur responsibly, and then let us come back,
and then we can start working away at our existing problems.
Senator Reed. Well, thank you.
Now let me turn to Mr. Wright, and this, I think, is a good
segue, because in Rhode Island we have a Coastal Resources
Management Council. There is a lot of good work in terms of use
of the seashore, and we have a lot of it. They are not formally
engaged in making the maps and revising the maps, but they are
a critical source of input for exactly the reason Mr. Edelman
referred to.
Can you describe how FEMA is conducting research with these
agencies, working with these agencies to provide a context for
the map making?
Mr. Wright. Absolutely. So I am looking for partners,
particularly at a State level, anytime I can find them. I know
that my staff met with some of the folks from the Rhode Island
Coastal Commission just here this past summer. As we look at
these pieces--because to John's point, there are plenty of
other State agencies that are doing pieces of this. But for me,
this more fundamentally gets down to the understanding of risk.
When we integrate these programs across a Federal, State,
and local level, I think we do a more effective job to
communicate the risk and bring the understanding that is
necessary. It is not that you get seven different flavors of
what is my flood risk from--the coastal commission has an
answer, the local town council has an opinion, FEMA has an
opinion. How do you bring those pieces together? That is what
is going to best inform that homeowner.
Senator Reed. Well, thank you very much. Again, I think
your response illustrates another aspect of this, whereas there
are generalized models of flooding that you have to use that
have been validated, et cetera. Then there are the very
localized conditions. And I wonder, and maybe Mr. Dorman can
comment on this. Is there a tension here? Is it being
effectively resolved between a generalized model versus some
very specific conditions in a State or a locality?
Mr. Dorman. Well, I think the generalized model should be
utilized across the board. The question is: What inputs do you
put into the model? If you put very specific localized inputs
into the model, it gives you a much higher resolution of
result, and that is why I believe the TMAC-- and what I would
suggest is going to the structural level. You can define the
100-year flood zone with that model. But if you use that same
model and apply the elevation of the building, you can actually
come up with when does the water intersect and enter the
building's foundation, and that is where that localized, more
specific data applies.
Senator Reed. Any other comments, Mr. Wright or Mr.
Edelman, on this point about localization versus the generic
model?
Mr. Edelman. Yes. Everything we need to do, we need to
adapt to the local conditions. There are some studies that we
work on that are more broad in general, and that is good to get
an understanding of what are the overall future use losses or
future expenses that the program may have. But when we are
talking with the homeowners and the communities, everything we
do has to be at the local individual level for it to be
personal to them and to have defendability with the results.
Senator Reed. Well, thank you very much, Mr. Wright, Mr.
Dorman, and Mr. Edelman. Thank you.
Chairman Shelby. Senator Menendez, finally. Thank you.
Senator Menendez. Thank you, Mr. Chairman. I want to thank
the panel. This is an incredibly important topic, but I want to
focus my comments elsewhere.
Mr. Wright, as you know, the handling of Sandy flood
insurance claims by FEMA and its contractors was an utter
disaster, resulting in untold thousands of survivors being
lowballed and unable to rebuild.
Now, I exposed this pattern of underpayment in hearings and
press conferences more than 2 years ago and subsequently worked
with your predecessor and with you to establish a virtually
unprecedented opportunity for all policyholders to have their
claims reviewed once again. And while FEMA should have gotten
it right the first time, I do appreciate FEMA's acknowledging
it made critical mistakes and attempting to remedy them.
Unfortunately, even the remedy has been fraught with
hurdles and delays, with many Sandy victims still waiting 200,
300, or 400 days beyond the 90-day timeframe FEMA initially
promised. But I want to focus on the present rather than the
past and get New Jerseyans the funds they need to rebuild as
quickly as possible.
On this front, I worked with you to speed the recovery by
establishing a pilot program to get Sandy survivors the funds
FEMA itself agreed it underpaid originally without jeopardizing
the homeowner's right to appeal to a third-party neutral. If it
taking so long to conclude the neutral hearings, why not pay
the undisputed amount up front and let people get going?
So let me take a moment to give the Committee a real-world
example of how this policy change made a tangible difference in
people's lives.
Ms. Donna Amon, a woman from Bayville, New Jersey, took
advantage of the pilot program and received her relatively
modest interim payment without having to waive her right to an
appeal. She had recently suffered an unimaginable tragedy when
her husband was killed in an accident while at work. After
working with her for several months, she wrote the following,
after receiving her interim payment:
``I cannot thank you all enough. I finally received about
$6,500 long-owed under my flood policy, and it could not have
come at a better time as I was in a very tight financial bind
after losing my husband as he was working on a boat that went
down near the Tappan Zee Bridge and went in to save the other
two crew members. First the Sandy storm, and then losing my
husband. You feel so alone, and I really felt no one cared. My
home was demolished in February, and 2 weeks after, I lost my
husband, then the finances. Getting the money up front was so
important for basic things. I am still pursuing the neutral
because I feel I was underpaid even after the review found I
should be owed $6,500. But I could not just wait 5 or 6 months
for the neutral to conclude. This helps the little people so
much. Please keep it going. Do not stop now. Other families
need the same help that I have received. Sincerely, Donna.''
Now, previously, Sandy survivors were faced with an almost
impossible choice: either accept the offer from FEMA and waive
your right to an appeal, or wait potentially for months on end
without any payments until the neutral issues a determination
and FEMA accepts it. Many survivors who know the FEMA offer was
still less than they deserve were all but forced to accept the
underpayment because they needed the funds immediately to keep
their heads above water.
Now, unfortunately, I understand that FEMA now claims it
does not have the authority to implement even these basic
common-sense fixes. And I do not want to go into the debate
over the Administrative Procedures Act or FEMA's regulatory
authority. You know, I can go through a list of things FEMA
refused to do at first but later their lawyer said, yes, you
know, allow Sandy survivors to appeal their claim outside of
the normal appeal process, outside of the court system, allow
Sandy survivors who survived their proof of loss to nonetheless
have their claim reviewed again, to have an independent third-
party neutral outside of FEMA established and able to overturn
a decision of FEMA. FEMA first said none of these things could
happen, and then subsequently they did.
So I ask you, Mr. Wright, do you believe that Sandy
survivors or, for that fact, anyone who faces this in our
country should have to choose between exercising their right to
appeal from a third-party neutral or receiving the undisputed
amount FEMA acknowledges it owes them in a timely fashion? And
do you believe it is fair to say that Sandy survivors who have
waited nearly 4 years to get what they were entitled to have
suffered an emotional and financial hardship?
Mr. Wright. Mr. Menendez, I appreciate your leadership on
this, and I, like you, am entirely focused on getting everyone
the dollars that they are entitled to. And I think that I have
demonstrated to you and your team over the last 15 months, I
get to ``yes'' as much as anything. I have moved a lot of
barriers out of the way, and the struggle I have had on this
one, without going into particulars, the Administrative
Procedures Act, is now I am stumbling through these pieces. So
I have gone back to my team and said the outcome is speed to
get these answers, and so I have to find more ways to speed
this up, to get folks through the neutral, so we are at a point
where 97 percent of the files are reviewed and 80 percent of
the offers are made, which has not been fast enough for me or
for you. And so I have got to stay legal in these various
parameters I have under the laws and regulations. I will do
that and continue to push to get these payments done, because
they are entitled to closure and they are entitled to the
payments.
Senator Menendez. Well, I want to--my time has expired. If
the Chairman would indulge for another minute, here are the two
questions I asked you: Do you believe that Sandy survivors or,
for that fact, anyone else, should have to choose between
exercising their right to appeal from a third-party neutral or
receiving the undisputed amount FEMA acknowledges that it owes
them in a timely fashion? That is not whether it is the law or
not. Do you believe that as a proposition?
Mr. Wright. So I have to run a consistent process. I have
got more than 10,000 that have already been closed, and so as I
have worked this with the legal side, I have got to find a way
to hold that together so that I treat everyone----
Senator Menendez. OK. So I cannot get a simple straight
answer on a simple proposition. I am not talking about the
legalistics of it. I am talking about the value here. Is it
fair that someone has to ultimately give their right up for a
third-party neutral in order to be able to accept the payment
that is undisputed in the first place? Is that a fairness
question?
Mr. Wright. What I want to be able to do is give them the
option for their dollars and give them the option for getting
that neutral review if they choose to do that. We did agree to
add that piece, and we are speeding up the pace of it. It has
not gong fast enough.
I will continue to work to find a way to get payments in
people's hands.
Senator Menendez. Well, Mr. Chairman--and I know you have a
great concern about this program and certainly its financial
viability. But here is my point: If you for years--years--pay
your flood insurance policy, meet your obligations, and then,
God forbid, when the moment comes, the disaster comes, and you
find yourself being arbitrarily and capriciously lowballed,
contractors arranging to have lowballed amounts, and then you
are forced by virtue of a process that makes you accept what
you know is a lowball because you cannot wait to get your life
together again, something is wrong with that.
Chairman Shelby. I agree.
Senator Menendez. So as we think about fiduciary
responsibilities, which I share with the Chairman, I also think
we have to think about these types of program changes.
Thank you, Mr. Chairman.
Chairman Shelby. Senator Warren.
Senator Warren. Thank you, Mr. Chairman, and thank you for
holding this hearing. Many of us worked together to draft the
bipartisan Homeowner Flood Insurance Affordability Act, which
gave homeowners some relief on the dramatic increases for flood
insurance. And I was glad to be part of that process, but I am
still very concerned about the ongoing mapping.
Over 3 years ago, FEMA released many flood maps that our
cities and towns knew were not accurate, and those mistakes
have caused real problems for Massachusetts communities. The
city of Quincy, for example, was forced to appeal its flood
maps, and the city was successful, and it lowered or eliminated
the flood risk designation for nearly 2,000 properties. But
that appeal cost the city about $650,000. That is money that
Quincy could have used to hire more teachers or more
firefighters or upgrade roads or programs for seniors. But they
had to spend it on correcting FEMA's mistake.
And it is not just Quincy. Hull and Marshfield and Sitchuet
and Duxbury and communities all around Massachusetts have had
similar problems with flood maps. I understand it is a
difficult process and that FEMA needs more resources, but this
just is not working.
So, Mr. Wright, FEMA has acknowledged that there have been
costly errors because of inaccurate maps, and some communities,
like Quincy, can stretch their budgets and pay to have those
errors corrected. But I want to know what happens to a
community that cannot afford to hire costly engineering
consultants to review their maps. What happens to them?
Mr. Wright. So we work through a process that ultimately is
to engage the community at a series of intervals, because I
want to make sure that, to the degree that the community has
information or things that FEMA's map developers need to know,
we get that information. What I do see--and we will talk
generally as opposed to a specific community in Massachusetts--
is that there are times by which we have lower level people in
a community that are attending those meetings that do not
necessarily have the viewpoint that is broad. Key pieces in the
Massachusetts elements dealt, yes, with some data elements, but
also with alternative models that could be used to deal with
waive transformation.
Senator Warren. I am sorry, but the problem is the maps are
wrong, and they were able to prove that ultimately. It is just
that it cost them $650,000 for one town to prove that the maps
were wrong. And that helped ultimately nearly--that changed the
designation for nearly 2,000 properties. I am just asking the
question. If a town believes the maps are wrong and it does not
have the money to hire the very expensive engineering
consultants the way Quincy did, what happens to those towns?
Mr. Wright. What happens to those towns is we have to work
with them through that process so that I do get them that
piece. I understand the disconnect on this, ma'am. I truly do--
--
Senator Warren. You are telling me that you would fix it
and that Quincy did not need to spend $650,000 for the
independent engineering reviews?
Mr. Wright. So as we go through the mapping process, if
they get us the information and those inputs along the way, we
will change our products. In this instance--and there were some
of the appeals that were successful for communities, others
that were not successful along the Massachusetts----
Senator Warren. All right. Look, we are just going to--I am
going to keep saying the same thing. Challenging your maps is
expensive.
Mr. Wright. I understand.
Senator Warren. And when it turns out that you were wrong,
I want to know what happens to the people who cannot afford to
challenge, how they get reimbursement. Look, I pushed hard for
communities to be reimbursed when they successfully appealed
flood maps that turned out to be wrong. But, unfortunately,
that provision was not included in the final bill.
Let me ask a different question. Will FEMA support such a
provision in the upcoming reauthorization bill?
Mr. Wright. So, Senator, I will commit to work with you and
your office so that we can look at those specific elements as
it goes forward.
Senator Warren. All right. Look, I will just leave it there
then. The accuracy of flood maps should not be based on whether
a community can scrape together the money for a very expensive
independent review. Our cities and towns deserve a process that
is fair.
I want to ask about one other thing quickly, and that is, I
am concerned that we are not doing enough to utilize local
expertise. Cooperating technical partners, the CTPs, are
composed of State agencies, regional agencies, participating
communities that have the capability of becoming more active
participants in the FEMA flood mapping program. And the
Council's report indicates that FEMA is not bringing in
communities and local partners up front.
So, Mr. Dorman, let me just ask you, what steps should FEMA
take to collaborate with the cooperating technical partners and
ensure that local communities are brought into this process
earlier?
Mr. Dorman. Well, Senator Warren, I will say for the State
of North Carolina that partnership with FEMA has been very
positive. After Hurricane Floyd, we created a cooperating
technical partner relationship with FEMA. We created a
cooperating technical committee in the State of North Carolina
that brought all stakeholders to the table. And as we moved
across the State, we updated the maps and leveraged from all
agencies and local governments their information and data.
Senator Warren. So I am glad to hear that it worked, as you
put it, together. What I am really asking, though, is the
question about additional steps that need to be taken where it
is not--and I am out of time here, so I will just say the other
place I would go is I understand that you are very stressed for
resources to be able to do this and that this is a very
expensive process.
I will be submitting more questions for the record here,
and particularly questions on behalf of the towns of Marshfield
and Sitchuet and Duxbury. It is clear that we still have a lot
of work to do to verify the accuracy of the flood maps and not
force towns and homeowners to have to pay to correct maps when
they are erroneous, and that we also need to expand the role of
our communities in beginning the flood mapping process right
from the beginning.
Thank you, Mr. Chairman.
Mr. Dorman. Thank you.
Chairman Shelby. Mr. Wright, with all the new tools in
mapping that we have, we map the world, so to speak.
Mr. Wright. Right.
Chairman Shelby. Why can't we in the U.S. map the flood
zones? It is all based on identifying a risk, assessing the
risk, as you talked about, and so forth, maybe mitigating it.
But what is the problem? We have been working on this for
years. I have been on this Committee 30 years.
Mr. Wright. Yes, you have.
Chairman Shelby. And the Flood Insurance Program, we take a
step forward and then a step backward. A lot of good questions
have been asked here today. When somebody is not in a
floodplain, never been there, and they have to pay for risk.
Others do not. I understand all that. And there is mitigation
involved. I know FEMA has tried to get people out of harm's
way.
Mr. Wright. We have.
Chairman Shelby. But with the tools we have today of
mapping, it seems that this could be done. Is it easy? No, it
is not easy. But it could be done.
Mr. Wright. It can be, sir, and one of the key linchpins
for me on this, we mentioned the LiDAR, the elevation and
structural pieces that are there, that technology has continued
to evolve. The price points, while still very expensive--the
three-dimensional elevation program, which is the interagency
group across the civilian side of agencies that use elevation
data and contribute so we do not duplicate anything, estimates
that it would cost about $600 million to finish getting those
data across the Nation.
Chairman Shelby. Let me stop you a minute. But you have
paid out billions of dollars over time, billions and billions
of dollars.
Mr. Wright. We have, and so, sir, what we have done is we
are the largest contributor to that on an annual basis. This
year alone, we are putting $20 million into it. Today----
Chairman Shelby. But that is nothing compared to what you
need, $20 million.
Mr. Wright. I agree, and I think one of the game changers
on this is we must have an elevation data layer across the
Nation that is accurate and credible, and with that, we will
start dealing with risk in some different ways related to the
folks who are in versus out and some of the automated models. I
tell you, in the riverine area, we see as many structures move
in as move out each year. The people who move out do not sent
thank-you notes. The people who move in call their friends, and
they complain about, ``How dare you move me in?''
We look at the issue in Louisiana. Those maps were updated
in 2012 and 2014. The 100-year was marked, as well as the 500-
year. It is very interesting to actually look that most of East
Baton Rouge that was affected, outside the special flood hazard
area, was mapped as part of the----
Chairman Shelby. How long has it been since Baton Rouge
flooded like that?
Mr. Wright. I would always want to defer to locals on this,
but my understanding is 1983 was the last time they had
something of this magnitude. But the built environment was very
different in 1983. This is a point that, as we look at it, yes,
we have got to do the mapping, but Mr. Edelman referenced the
report we did in terms of the next, you know, 80-some-odd years
of our program. When they looked at it, climate variability has
an element related to it. But more than 30 percent of the
growth in our floodplain is because of new construction, new
construction that today is probably directly adjacent, but
because they put concrete and asphalt down, the water is no
longer absorbing, and it just conveys, and it is causing more
floods.
Chairman Shelby. Well, what is the answer? I mean, you
know, this Committee here has been involved in this, and it
seems like we are just treading water. You know, we are not
going anywhere. We play with the program, but we have not had a
comprehensive approach that will work, because what you are
doing, you want a program that is accurate, right?
Mr. Wright. Right.
Chairman Shelby. You cannot say that this program is
accurate, can you? Maybe in some areas.
Mr. Wright. So I will tell you that we credibly can lay out
the pieces of that, but there are levels of precision that are
there. So you referenced our 56 percent that meet our standards
today. That is resource-dependent. The standards are clear, and
those are credible. But, Mr. Chairman, I would assert to you
that the very point of this hearing today gets to the crux of
it. Of all the dimensions of the program, I do think that the
mapping element has a foundation of credibility and a clear way
that with the resources would allow us to absolutely show the
risk, and with that it must then become the launch point, and
as I described, I must transform how we actually show risk in
premiums then. I must look toward the future risk in this
country related to land use. And then we get to this fourth
dimension that is there, that, yes, it is about affordability
or grants and the like, but there are difficult questions for
those who cannot afford it.
While I am absolutely confident there is no silver bullet
on that, I look forward to bringing to this Committee next year
some framing as it relates to the data so that we can inform--
--
Chairman Shelby. They may not be able to afford the
premium. We understand some people just do not have the means.
But, on the other hand, can they afford to continue to live
there? That is a risk, too.
Mr. Wright. So one of the things that was required in the
2014--there were elements of it in the 2012 bill, but it is
very clear in the 2014 bill, it requires us to do the clear
communication of risk. And so part of this evolution in my
underwriting practices, we are re-underwriting a whole set of
policies because my understanding of the direction in the
statute is I must tell folks what their true risk is. I intend
to do that with a pricing signal so that they understand the
gap between what they are paying and what their full premium
would be.
Chairman Shelby. As people continue to build in a known
flood area, prone to flooding, they have got to put a price,
when they start doing that, on the likelihood that there is
going to be a flood there.
Mr. Wright. And so I think part of what we are----
Chairman Shelby. How do you do that? Do you have to work
with the zoning people?
Mr. Wright. We do have to work with the zoning people on
that. What I find--and this may be too broad of a
generalization, but to the degree that someone is constructing
something today, 2016, in the high-hazard area, they are
building higher and stronger. They are required to do so. I
have got two places of concern: the area just outside the
special flood hazard area who maybe the flooding extends in
their direction, but far more problematic for me in an urban
context particularly is the water that used to absorb into the
water table upstream now is flowing down. The second piece of
that then is there is so much of the Nation's housing stock
that was built in the 1950s, 1960s, and 1970s. The homes that I
was at in Louisiana were all constructed before 1980.
Chairman Shelby. And a lot of them were built on slabs,
were they not?
Mr. Wright. Slab on grade.
Chairman Shelby. And if they flood, they do not have to
flood much to flood the house.
Mr. Wright. Exactly. And I grew up in a slab-on-grade,
1,100-square-foot home. That is what so many Americans--that is
what their experience is.
Chairman Shelby. It is cheaper to build.
Mr. Wright. It is much cheaper to build, and when someone
is trying to do this--trying to have their own home, and so I
look at the questions of understanding risk, how that evolves,
as well as how to make it affordable, and part of where I am
getting, Chairman Shelby, is: So how do we hold that against
affordable housing in this country in a way--and do it
explicitly? Because I think, unfortunately, in this program
over the last few decades, we have allowed folks to have
discounts and not know they had--and still complain about their
price because they think it was too high, and then not take
enough action to help people get out of harm's way. It has to
be in a way by which there is still a place for normal
Americans like my parents to live.
Chairman Shelby. Senator Brown, do you have any questions?
Senator Brown. Thank you. I thought that was a very good
conversation back and forth. Thank you, Mr. Chairman. I think
your initial question was: Can't the science figure this out?
And I think the science, after listening to that discussion,
clearly the science is simpler than the politics of people on
the Ohio River or wherever in my State thinking their insurance
is too high or that they should not have to buy it or why is
the Federal Government forcing me to do this at this price and
the difficulty of selling their house, who wants to buy that
house then, even though homes along the Ohio River are pretty
inexpensive. It is an area of the State, sparsely--depending on
where, of course--populated, and so low home prices and higher
insurance rates do not go together necessarily well. I think
that is the complexity of this.
Mr. Wright. And I would add one additional point to that.
To the degree that the prices may be a bit less, they are often
bought by a landlord who has the means to do so, and so we have
renters. So I look across the 5.1 million policies; only 1
percent of them, 50,000 of them, are contents only, essentially
a renter's policy. And so so many of those people that I
interacted with in East Baton Rouge may or may not have fully
understood their risk. They did not personally have a mandate.
They were not the homeowner. Yet they lost tens of thousands of
dollars worth of their life, and they have far less means
available to them to go put that back together again. That
policy is actually pretty reasonably priced.
Chairman Shelby. How do you communicate that?
Mr. Wright. Well, that goes to the point that Mr. Dorman
highlighted, that we have got to get ourselves--one of the
tools that we helped invest in, they have prototyped and proven
the concept, is you got to show them pictures. You have got to
show them three dimensions: here is my house, here is where the
water is going to go, and here is the price tag of what
happens.
Senator Brown. Give us a range of what the price--I mean
understanding you cannot be precise, but what the annual
insurance would be in a modest rental to ensure the contents.
Mr. Wright. Somewhere between--it depends on how some of
the surcharges play out. That set aside for a moment, somewhere
between $160 to $300. But $160 would be something that is a
very reasonable amount of coverage. Now, depending on your
means, that $160 could be still a substantial investment that
would be a difficult choice for someone to make.
Chairman Shelby. Is this a month or year?
Mr. Wright. Per year, sir.
Senator Brown. Per year.
Chairman Shelby. That is pretty cheap.
Mr. Wright. Right? And so I start----
Senator Brown. For us.
Mr. Wright. So I started looking at how then do we look at
getting--honestly, if I had to hypothesize a bit about
affordability, I think we are going to get a lot of some of
these conversations, the people who really need the coverage
that do not have, that may only need a few hundred dollars----
Senator Brown. You said at least in your visit to Baton
Rouge that it was 1 percent of renters that had that insurance?
Or what did you say exactly?
Mr. Wright. So nationwide, only 1 percent of my policies
are a contents-only policy for a renter. And I am sure that----
Senator Brown. Renters in floodplains or close to
floodplains.
Mr. Wright. Yeah.
Senator Brown. And that is flood insurance, 1 percent, or
content insurance generally? It is flood insurance?
Mr. Wright. So it is flood insurance to cover contents. If
you are a renter, you would not cover the structure, obviously.
Senator Brown. No, but not other kinds of rental
insurance----
Mr. Wright. Correct.
Senator Brown. ----to cover possessions. It is only--the
flood insurance part of that is 1 percent.
Mr. Wright. And, generally speaking, across the other
perils, flood is excluded. You can only come to National Flood
practically to get that coverage.
Thank you to both the Chairman and you.
I look forward to collaborating with the Committee as we
move forward.
Chairman Shelby. Thank you. The Committee is adjourned.
[Whereupon, at 11:55 a.m., the hearing was adjourned.]
[Prepared statements, responses to written questions, and
additional material supplied for the record follow:]
PREPARED STATEMENT OF ROY E. WRIGHT
Deputy Associate Administrator for Insurance and Mitigation, Federal
Emergency Management Agency
September 13, 2016
Introduction
Good morning Chairman Shelby, Ranking Member Brown, and Members of
the Committee. My name is Roy Wright, and I am the Deputy Associate
Administrator for Insurance and Mitigation, responsible for directing
FEMA's risk management, mitigation, and flood insurance programs. Thank
you for the opportunity to testify about FEMA's Technical Mapping
Advisory Council (TMAC).
Today, I will provide an overview of the TMAC and the reports and
recommendations it has provided to FEMA since it was established in
late 2014. I will also speak about FEMA's strategy for implementing the
recommendations, which vary in complexity and level of effort required
to address them, and well as the progress we have made to date. The
Council's recommendations will aid FEMA in furthering our efforts to
provide communities with the best available data and tools to make
better informed decisions that reduce the risk and consequences of
flooding nationwide.
TMAC Background
Under the Biggert-Waters Flood Insurance Reform Act of 2012 (BW-
12), Congress established the TMAC and authorized specific statutory
duties. The TMAC is tasked to provide recommendations on how to
improve, in a cost-effective manner, FEMA's flood mapping program to
ensure that Flood Insurance Rate Maps (FIRMs) reflect the best
available science and utilize the best available methodologies for
considering the impact of future development on flood risk. Consisting
of Government and private sector experts from across the country and a
diverse group of flood map stakeholders, in September 2014, the TMAC
convened for its first public meeting. During its first year, the TMAC
developed recommendations that it provided to FEMA through two reports
in January 2016: a 2015 Annual Report and a Future Conditions Risk
Assessment and Modeling Report. The TMAC annual report describe the
Council's activities, evaluate FIRM activities, and summarize the
Council's recommendations.
The Homeowner Flood Insurance Affordability Act of 2014 (HFIAA)
requires FEMA to implement a flood mapping program, after a review by
the TMAC. When the program is applied, it will result in technically
credible flood hazard data in all areas where flood maps are prepared
or updated. In July 2016, the TMAC submitted the TMAC 2016 Flood
Mapping Program Review as required. This report included 14
recommendations to assist the agency to provide technically credible
flood hazard data into the future. Based on this advice and my
recommendation, the Administrator has certified the flood mapping
program as credible.
Composition of the TMAC is defined in BW-12 and includes four
designated members and 16 appointed members. The four designated
members of the Council serve as regular Government employees (or the
designees thereof) and consist of the FEMA Administrator, the Secretary
of the Interior, the Secretary of Agriculture, and the Under Secretary
of Commerce for Oceans and Atmosphere. The additional 16 members are
appointed based on their demonstrated knowledge regarding surveying,
cartography, remote sensing, geographic information systems, or the
technical aspects of preparing and using FIRMs. To the extent possible,
membership of the TMAC is balanced between Federal, State, local,
tribal, and private sector members. There is also geographic diversity
including representation from areas with coastline on the Gulf of
Mexico, and from other areas identified by the FEMA Administrator as
having a high risk for flooding.
I would like to thank the members of the TMAC for their hard work
and dedication over the past 2 years. The Council formulated
recommendations to improve the quality of flood mapping and to ensure
that the best available science and methodologies are used when
considering the impacts of sea level rise and future development on
flood risk. I appreciate the tremendous amount of professional
expertise and personal commitment that each member invested to convene
as a council, conduct subcommittee discussions, and research and
produce the Council's reports and recommendations. The Council's
recommendations will aid FEMA in furthering our efforts to provide
communities with the best available data and tools to make better
informed decisions that reduce the risks and consequences of flooding
nationwide.
As indicated by their name and clearly stated in the TMAC charter,
the Council is an advisory board established to advise and make
recommendations to the FEMA Administrator and the flood mapping
program. Informed by the TMAC's reports and recommendations, FEMA will
determine the appropriate path forward as we evolve based on changes in
customer needs, advances in technology, and the National Flood
Insurance Program (NFIP) reform requirements.
TMAC's Reports and Recommendations
The TMAC's 2015 Annual Report contains 22 recommendations for
FEMA's flood mapping program. The recommendations generally fall into
three key themes: credible flood data, digital inventory and delivery,
and customer-oriented products (including structure-level risk, and
more options for targeted products and engagement). FEMA fundamentally
agrees with all 22 of the recommendations in the 2015 Annual Report.
Over the last several months, the Agency has been working to evaluate
each recommendation to understand resource requirements and impacts to
inform implementation priorities, sequencing, and investments.
Perhaps the most transformative recommendation made by the TMAC in
2015 is to transition from one percent (1 percent) annual chance as the
basis for flood insurance ratings to a structure-specific flood
frequency determination. This recommendation will require an entirely
new approach to insurance rating and underwriting, including new
regulatory hazard and risk products and potential impacts on floodplain
management standards.
In January 2016, the TMAC delivered its Future Conditions Risk
Assessment and Modeling Report. This statutorily mandated report
includes seven overarching recommendations and numerous sub-
recommendations. The first recommendation calls for providing future
conditions flood risk products, tools, and information for coastal,
Great Lakes, and riverine areas. It is the most substantial of the
recommendations and the remaining recommendations are largely related
to the details of how this could be achieved, with sub-recommendations
providing even more details. By recommending that FEMA add future
conditions assessments, modeling and mapping, TMAC is recommending that
FEMA drive forward both the state of the science and the state of
application of the science on a broad scale. Transitioning from an
applied science agency, to an agency that also performs scientific
research, is significant.
In July 2016, the TMAC submitted the TMAC 2016 Flood Mapping
Program Review to FEMA. This report includes 14 recommendations to
assist the agency to provide technically credible flood hazard data
into the future. The report focuses on the findings of the TMAC's
review of the flood mapping program, as required by HFIAA. The TMAC
reviewed the mapping program's structure, process, outputs, quality
management, and metrics and concluded that FEMA's mapping program, when
applied as designed, results in technically credible flood hazard data
in areas where flood insurance rate maps are prepared or updated.
The TMAC is currently working on its 2016 Annual Report. We
anticipate that the TMAC will submit this report to FEMA in early 2017,
and that it will include additional recommendations, as well as further
guidance and insight into its previous report recommendations.
FEMA's Implementation Strategy
Addressing the TMAC recommendations has been and will continue to
be one of the top priorities for the National Flood Mapping Program.
Today, I want to summarize for you our strategy for implementation, and
talk about some of the priorities and investments the Agency focused on
this year. Our implementation strategy can generally be summarized as
follows:
1. Address several technical recommendations through FEMA's
consistent, routine approach to maintain and enhance national
mapping policies.
2. Engage internal and external stakeholders and partners as FEMA
determines the appropriate sequence of program changes that
will support the implementation of the transformative mapping
reforms recommended by the TMAC.
3. Continue to make strategic investments (e.g., high resolution
topography, structure-specific datasets, enhanced flood models)
while engaging in strategic, long-term planning to lay the
foundation for transformative new mapping polices, products and
regulations.
The reports submitted by the TMAC include some technical
recommendations that address our ongoing program delivery, seeking
refinements or improvements to what we already do and how we operate.
Just as we did with the BW-12 legislative mandates for the mapping
program, we are using existing program mechanisms to implement those
changes to the extent possible. Through our regular Guidelines and
Standards cycle, several of the TMAC's 2015 recommendations will be
implemented in November 2016, and an additional set of TMAC
recommendations are scheduled for implementation in November 2017.
Over the last few years, the Agency has continued to enhance the
Cooperating Technical Partners (CTP) program within the flood mapping
program. We are using established CTP coordination mechanisms to
address the TMAC's CTP-related recommendations. In many ways, the work
we've been doing to enhance the CTP program is already addressing much
of what is in the recommendations. Similarly, we are using our Flood
Risk Products Integrated Project Team (IPT) to start addressing the
recommendations from the 2015 Annual Report about understanding user
needs for our flood risk products.
Other recommendations are transformative and can't simply be
assigned to an existing team or process to address. Those include the
TMAC's recommendations for transitioning away from mapping the one
percent (1 percent) annual chance flood hazard, providing structure-
specific risk information, digital delivery of our products, and most
of the future conditions recommendations. These recommendations
necessitate extensive research, planning, and strategizing, both
internally and with our partners.
These engagements are ongoing, but in the meantime we know what
some of the foundational elements are to enable delivery on these
recommendations in the future. In FY17, one of our focus areas in Risk
Management is to deliver flood risk data that is useful for risk-based
decisions. This year we will continue to make targeted investments, in
coordination with the United States Geological Society (USGS) and the
3DEP program, that continue to move the Nation toward a national high-
resolution topographic dataset. We will continue to invest in enhanced
modeling and multi-frequency returns. Being able to evaluate the
frequency of flooding at a structural level using high resolution
topographic data is an essential step toward structure-specific risk
rating and delivery of a redesigned risk rating for the NFIP. We are
also making strategic technological investments and changes, not just
to improve digital delivery of the mapping products, but to ensure that
enhancements of FEMA mapping products are interoperable with insurance
rating mechanisms, mitigation planning initiatives, and floodplain
management.
FEMA is also exploring a more comprehensive approach to addressing
future conditions mapping and the future conditions recommendations
provided by the TMAC. The TMAC's Future Conditions Recommendation 6,
which directs the completion of pilot studies, provides a way to plan
for and develop an initiative that can accomplish the objectives set
forth in the future conditions recommendations and can be performed in
a way that addresses the majority of the other recommendations and sub-
recommendations found in the Future Conditions report.
Addressing the research, development, program planning, and
implementation questions through a series of demonstration projects
will lead to an efficient and effective strategy to provide future
conditions flood risk products, tools, and information. The TMAC was
clear in its future conditions recommendations to FEMA that future
conditions should be reflected in non-regulatory products at this time,
and not on the regulatory Flood Insurance Rate Maps (FIRM).
FEMA has already been conducting sea level rise pilot studies. We
are working to identify the specific remaining research gaps to be able
to design additional future conditions demonstration and pilot projects
to address those gaps and inform how FEMA establishes and resources
future conditions mapping initiatives.
FEMA has emerging efforts that complement and are informed by the
TMAC's recommendations, such as an ongoing initiative to redesign risk
rating for the NFIP. FEMA considers a new approach to insurance rating
and underwriting crucial for the program, and has already started
identifying the technical considerations for implementation. FEMA
leadership has incorporated progress on this recommendation into
performance plans. FEMA is currently assessing this recommendation in
conjunction with the ongoing initiative to analyze technologies, data
sources, and trends for flood risk quantification toward a long-term
goal of developing a redesigned risk rating system for the program.
These initiatives and investments will be critical as FEMA assesses how
to move from being able to support the assessment of structure-specific
flood frequencies, to eventually delivering actuarial structure-
specific flood insurance ratings in the future.
To support a mindful, meaningful transformation, in FY17 we will
begin implementation of the 2015 Annual Report's Recommendation 2 which
calls for a national 5-year operations plan. Our national plan will be
informed by Regional 5-year plans to support appropriate flexibility
and variance at the regional level while providing consistency at the
national level. This 5-year plan will become a rolling plan that will
help us bridge operations from our current status to where we want to
go as we transform. The development of a 5-year operations plan will be
supported by the implementation of Annual Report's Recommendation 3,
which calls for the development of program goals and metrics that will
help drive investments and behaviors needed to transform the delivery
of our flood mapping program.
The timing is right for the transformation of the National Flood
Mapping Program, however we need to account for and learn from the
investments we've already made--especially in the program's evolution
to Risk Mapping, Assessment, and Planning (Risk MAP). The status of the
mapping inventory currently varies from Region to Region. FEMA's
Regional offices flood mapping investments each reflect unique
circumstances, and accordingly, the Regions have varying degrees of
readiness for implementing TMAC recommendations. We also have a
significant number of projects already in process that utilize current
policies and standards, so we need to take those projects into account
as we plan our implementation of and investments in the
transformational changes.
Conclusion
We value the work of the TMAC, and will continue to work with the
TMAC and Congress to continually evolve the flood mapping program to
meet the needs of individuals and communities to understand their flood
risk and provide the foundation for actuarial rate setting in the NFIP.
Again, thank you for the opportunity to testify today. I look
forward to any questions the Committee may have.
______
PREPARED STATEMENT OF JOHN DORMAN
Chair, Technical Mapping Advisory Council, and Assistant State
Emergency Management Director for Risk Management, and Director, North
Carolina Flood Risk Management Program
September 13, 2016
Chairman Shelby, Ranking Member Brown, and Members of the Committee
on Banking, Housing, and Urban Affairs; good morning and thank you for
the opportunity to appear before you and provide my perspective on the
2015 Technical Mapping Advisory Council (TMAC) recommendations. I am
John Dorman, North Carolina Assistant State Emergency Management
Director for Risk Management, and Director of the North Carolina Flood
Risk Management Program. I am currently serving as the Chair on the
Technical Mapping Advisory Council.
The English proverb ``Necessity is the mother of all innovation''
speaks well to the overall tenet of TMAC recommendations. FEMA has
diligently overseen the generation of current flood hazard focused data
and products. However, transformative strategies must be implemented to
address needs of the program: insurance rates that reflect structure-
anticipated flood loss; communication focused on financial loss as
opposed to an ``in or out'' focus; and, homeowner's understanding of
and confidence in the data used for flood hazard determination and
insurance premiums.
For North Carolina, Hurricanes Floyd, Francis, Ivan, and Irene all
demonstrated and compelled the need to implement these transformative
strategies. Thus, North Carolina has successfully implemented the
ability to generate structure-based flood probability; structure-based
risk assessments; real-time structure-based flood impact and alert;
and, structure-specific risk-based insurance rating. Recent events
across the Country have again shown a lack of accuracy and awareness of
structure-specific flood risks that both large storms and more
localized flash flooding can present. With these needs ever apparent, I
believe TMAC has constructed recommendations that, if implemented, will
transform the program and improve our Nation's resiliency to flooding.
Below are four recommendations of the TMAC that I believe are key to
transformative improvements:
First, fundamental to accurate flood hazard identification and risk
assessment, is accurate, high-resolution ground elevation data. Recent
developments in data collection technologies offer the more accurate
and efficient collection of ground elevation data. Technology like the
Geiger LiDAR sensors collect data at both a higher altitude and higher
accuracy allowing for faster acquisition time and reduced costs of
acquiring and processing LiDAR data. This higher resolution data also
allows the opportunity to meet the needs of other stakeholders so that
cost sharing objectives can be achieved.
Second, the transition from a 100-year floodplain delineation and
flood elevation to a structure-specific annual chance flood frequency
is critical to raise awareness that every property has some level of
flood risk--26 percent of flood damages are on properties outside the
100-year floodplain delineation. The recent events in Louisiana
demonstrate the importance of altering our Nation's mentality that one
is safe if they live outside of the line depicted on a map and raise
awareness of flood probability at the structure level.
Third, the transitioning focus to structure-based risk assessment.
This increased level of detail that calculates structure-specific per
cent annual chance of flooding and estimated annualized damage
calculations can inform mitigation decisions and create more accurate
risk-based insurance premiums. This will directly result in mitigation
actions to reduce losses, lessen the financial burden on the Federal
Government to help communities recover from disasters and create a more
fiscally sound FIMA.
Finally, we must transition to a dynamic, queried display of data,
models, maps, and risk assessments. The way we communicate as a Nation
is changing, and we need to create a more robust database that enables
data to be dynamically queried and displayed on a Web page. Floodplain
modeling and mapping is an ever changing science, based largely on
statistics and changes in land use and topography. We need to create an
efficient method to quickly and efficiently update flood hazard and
risk information and provide that information at the fingertips of end
users on all types of digital devices.
It is important to note that all or some of the four transformative
recommendations have been successfully implemented in four States.
These recommendations are not just ideas but proven concepts in
production today.
Thank you again for the opportunity to address this Committee on
this important topic. I am honored to be able to provide testimony
based on our experience with the FEMA and with the NFIP as the
Committee considers the most efficient methods to prevent or reduce
flooding losses.
I would be happy to answer any questions that you may have.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
PREPARED STATEMENT OF SCOTT K. EDELMAN
Vice Chair, Technical Mapping Advisory Council, and Senior Vice
President, AECOM
September 13, 2016
Good morning Chairman Shelby, and Members of the Subcommittee. I am
Scott Edelman, Senior Vice President of AECOM. I have spent my career
solely focused on solving our Nation's water related opportunities and
challenges. I appreciate this opportunity to appear today before the
Committee on Banking, Housing, and Urban Affairs.
I have been involved with creating maps for FEMA since 1981, and am
privileged to be serving as Vice Chair on the Technical Mapping
Advisory Committee established by the 112th Congress.
We, as a Nation, have simply endured too much pain and suffering
due to floods.
I believe that Roy Wright's strong support and encouragement of the
TMAC has resulted in two reports that show a path to the next evolution
of the NFIP. In the future, I believe that if the recommendations of
the TMAC reports are supported by Congress and the Administration, we
can make significant strides to reduce both the pain and suffering that
our citizens are enduring at a record level, and the burden these
unprecedented events continue to drain resources from our United States
Treasury.
Of the 29 recommendations contained in the TMAC 2015 reports, I
believe that the three most important priorities and potential benefits
are:
1. The reintroduction of a 5-year rolling plan--to allow leveraging
of Federal dollars;
2. The movement to structure-based risk assessments--to create a
safer Nation; and
3. Preparing the Nation for future conditions--to stop building new
problems.
First, the reinstatement of a 5-year rolling plan allows the
leveraging of local and State dollars. FEMA cannot make the Nation a
safe place alone. The operating principals of FEMA's Whole Community
doctrine is critical as applied to flood-related mitigation. Flood
waters know no jurisdictional boundaries as they devastate lives and
property, and therefore we need to fully engage local communities and
make these shared responsibilities more apparent to all. When Congress
funded Map Modernization in 2003, FEMA produced the Multi-Year Flood
Hazard Identification Plan, MHIP. MHIP addressed every county in the
Nation with when and how much anticipated funding would be available.
The result was an enterprise-wide approach to maximize the return on
Federal investments in which FEMA served as the Chief Risk Officer to
those investment in the studies, and communities felt strong local
ownership of the studies and results. This approach better aligned FEMA
with State and local efforts to reduce losses of life and property.
Second is structure-based risk assessments. We must change the
perception that if I am just on the other side of the 100-year flood
line I am safe. Too much time is spent trying to justify the movement
of the flood line by a few feet when in actuality the risk of flooding
the structure only has changed ever so slightly. Much of the problem is
due to uncertainty of the flood line itself.
To my knowledge, this is the only product that engineers
produce and communicate to the public that deals with averages
and not what is safe.
We also have a great deal of uncertainty within the
calculations. In all actuality, the current 100-year average
line shown on the flood insurance maps is perhaps closer to a
safe design level of a 10-year event.
Moving to a structure-based risk assessment begins to change the
conversation from one focused on ``in vs. out'' to one that starts to
communicate levels of risk. We must also take affordability and
grandfathering with sunset clauses into account for our most vulnerable
communities and constituents.
Third, we need to prepare the Nation for the future. GAO asked FEMA
to evaluate the impact of future conditions on the National Flood
Insurance Program. The report concluded that by the year 2100 on
average our floodplains will increase by 45 percent nationally, the
number of polices will increase by 80 percent and our average loss per
policy will increase by 50 percent based on today's dollars. This is an
immense challenge to our country. We need to encourage local
communities to adopt higher standards on a volunteer basis
understanding that the higher standards results in less loss of life.
Many communities have done this including Mecklenburg County and the
City of Charlotte, NC. Based on their adoption of future conditions
flood elevations, Mecklenburg County has estimated savings from flood
damages from a single 100-year event to be over $150 Million. We need
to stop building future problems so we can finally concentrate on
mitigation of existing problems.
My passion is not solely on the science but the need to help the
Nation with this long-standing challenge and the billions of tax
dollars that are unnecessarily wasted because of poor land use
decisions and the attempt to tame or ignore Mother Nature. I want to
again thank the Committee for this opportunity. I urge Members of the
Committee to refer to the two TMAC reports for more details as a formal
part of our testimony.
I would be happy to answer any questions that you may have.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR TOOMEY
FROM ROY E. WRIGHT
Q.1. In July 2013, FEMA issued new mapping procedures for non-
accredited levees. I was pleased to see that some non-
accredited levee systems would be recognized as reducing flood
hazard. Unfortunately, I still hear from frustrated
Pennsylvanians who feel that local flood control structures are
either completely ignored or treated unfairly by FEMA.
What progress has FEMA made on including non-accredited
levees in its FIRMs?
How has FEMA informed communities of its new policies
towards non-accredited levees?
How can communities protected by non-accredited levees
ensure that FIRMs accurately reflect the flood hazard reduction
those levees offer?
A.1. Answer not received in time for publication.
Q.2. I understand that FEMA is in process of updating its
claims appeals process.
Can you provide an update on where that stands?
A.2. Answer not received in time for publication.
Q.3. Besides claims appeals, my office receives a steady volume
of request for help in appealing FIRMs. This may be because the
highly technical nature of the appeals process can be difficult
and confusing.
Are any efforts underway to improve mapping appeals? If so,
what issues are being considered, and when can we expect to see
changes implemented?
A.3. Answer not received in time for publication.
------
RESPONSES TO WRITTEN QUESTIONS OF
SENATOR MENENDEZ FROM ROY E. WRIGHT
Q.1. As I mentioned above, FEMA's systems and oversight over
its Write Your Own insurance companies and other contracts were
severely lacking in the aftermath of Superstorm Sandy. From
insurance companies lowballing Sandy survivors, to a broken
appeal process that was a virtual black hole for policyholders,
the claims process after Sandy exposed fundamental problems
with the NFIP that demand a comprehensive overhaul.
As you know, I've worked for the past several years to
first expose and then address the most egregious shortcomings.
Can you give the Committee a sense of the reforms that have
been made since the aftermath of Sandy and if they are adequate
to prevent another debacle like we saw after Sandy?
Should the people of New Jersey be confident that they
won't have to go through the same ordeal they did after Sandy
when the next storm strikes?
A.1. Answer not received in time for publication.
------
RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARREN
FROM ROY E. WRIGHT
Q.1. Will FEMA allow attenuation of wave setup in back-bay or
inland areas to be guided through the use of high water marks
(HWMs) that are available for the Blizzard of 1978 storm in the
Towns of Scituate, Marshfield, and Duxbury? This historical
storm has been shown to produce storm surge levels at or above
the 1 percent-annual-chance stillwater level for these areas.
The HWMs would be used (with judgment) to assess the
hydrodynamics and propagation of surge into the enclosed
estuarine areas. This is the same method that was used for the
successful appeals of the Preliminary 2013 FIS study for the
Towns of Scituate, Marshfield, and Duxbury.
A.1. Answer not received in time for publication.
Q.2. The U.S. Army Corps of Engineers (USACE) was authorized by
Congress in January 2013 in the Disaster Relief Appropriations
Act of 2013 (Public Law 113-2) to conduct the North Atlantic
Coast Comprehensive Study (NACCS). A core component of the
NACCS study was a numerical modeling effort that produced
updated storm surge and wave annual-exceedance probabilities
for extreme coastal storm events for the Mid- to North-Atlantic
region, from Virginia to Maine. The NACCS study provides a
characterization of both synthetic tropical storms and
historical extratropical storms that can contribute to probable
coastal flood hazards in the New England area. The NACCS study
also makes use of two-dimensional (2-D) hydrodynamics and wave
models to capture the spatial variability in storm surge and
wave conditions along the complex coastline of Massachusetts.
Modeled 1 percent annual chance water levels and wave heights
from the NACCS study represent an improvement to the
methodologies used by FEMA to produce the Nov. 4, 2016 Flood
Insurance Rate Maps (FIRMs) for the Towns of Scituate and
Marshfield, and the Cape Cod Bay shoreline of Duxbury. Will
FEMA allow the use of 1 percent annual chance SWELs and
significant wave heights from the NACCs study to be used as
input conditions for the WHAFIS and wave run-up analyses?
A.2. Answer not received in time for publication.
------
RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER
FROM ROY E. WRIGHT
Q.1. Mr. Wright, as you are aware, New York City has submitted
a technical appeal disputing FEMA's Preliminary maps and I know
that--FEMA has set up an independent review board to review the
City's appeal.
First, can you provide an update on the status of the
independent review board's analysis? Where do things stand and
when do you expect to for the board to make a determination?
Second, is FEMA prepared to revise the New York City maps
accordingly if it is determined by the board that the
preliminary maps are not as accurate as they should have been?
A.1. Answer not received in time for publication.
Q.2. Mr. Wright, I have asked that you take steps to ensure
that FEMA has and exercises the necessary authority to properly
oversee the WYO carriers, third-party service providers and any
firms that they may all hire.
I was pleased to see that you acted quickly in responding
to the New York AG's investigation and recommended that the
engineering firm HiRise be disbarred from participating in the
program.
However, do you plan to seek to disbar any WYOs or firms
they may have hired based on their actions in the aftermath of
Sandy?
What information or developments are necessary for FEMA to
take such action?
What is the timeframe for making such a determination with
regard to seeking disbarment of WYOs or other firms?
Further, what about the legal counsel hired by the WYOs to
represent their interests in cases filed by Sandy victims? Do
you plan to seek to prohibit any of these firms from being able
to handle future litigation matters on behalf of the WYOs based
on their actions in handling cases that arose from Sandy?
A.2. Answer not received in time for publication.
Q.3. Mr. Wright, can you provide me an update on the Sandy
Claims Review Process?
Additionally, I'd like to know more about one specific
piece of the process. It has been raised with my office that
FEMA adjusters in the Sandy Claims Review Process are relying
on the original engineering reports from suspect engineering
firms, like HiRise, as a basis for determining what homeowners
should be paid through this re-review process.
First, is that true?
Second, has FEMA gone back to see if these engineering
reports were ever changed or manipulated to alter the
conclusions made regarding the actual damage sustained in
Sandy?
Third, can you tell me what is FEMA doing to ensure that
the engineering reports used as a basis for making
determinations in the Sandy Claims Review Process are based on
accurate reviews of the damage to these homes? Finally, have
any of the WYOs that hired these suspect engineering firms been
asked to or required to pay for new engineering reports to be
filed? Are any of them doing so?
A.3. Answer not received in time for publication.
------
RESPONSES TO WRITTEN QUESTIONS OF SENATOR KIRK
FROM ROY E. WRIGHT
Q.1. The NFIP rate plan is outmoded and does not reflect
insurance industry best practices. For example, the Institute
for Business and Home Safety (IBHS), as well as catastrophe
modelers, have pointed out the differences between riverine
flooding and storm surge. Since riverine flooding is generally
inland and storm surge is generally coastal, most experts
believe there is an unjustified disparity in the rates charged
to policyholders in the 30 zones across the country, not to
mention the disparity created by the significant subsidization
of premiums charged to many policyholders.
Are some policyholders paying too much while others are
paying too little, independent of the subsidies built into the
program?
How do your propose modernizing the NFIP rate plan to
eliminate this disparity?
A.1. Answer not received in time for publication.
Q.2. Reinsuring NFIP exposure can transfer risk from taxpayers
to the private market, provide financial stability, and
facilitate private market competition. There has been much
discussion about how robust and competitively priced the
catastrophe risk market is at this time, but the price and
availability of reinsurance changes with the weather and other
market conditions, resulting in year-to-year volatility. This
volatility could place the NFIP in jeopardy, and private
carriers could be discouraged from entering the market. Longer-
term reinsurance arrangements not only limit volatility, but
can also facilitate more robust data analytics and pricing
sophistication for the flood events that are most challenging
for the private market.
How do you perceive the role of reinsurance as a tool to
reduce the Federal Government's exposure to loss, and to
encourage private insurers to write direct flood coverage?
I understand that you are currently negotiating reinsurance
coverage for the coming year. Are you investigating the
availability and potential benefits of longer term reinsurance
coverage?
A.2. Answer not received in time for publication.
Q.3. Presumably Congress will reauthorize the NFIP next year
and the NFIP will continue to be the primary flood insurance
market for homeowners and businesses. In the meantime, FEMA can
take important steps to improve the program with its existing
authority. For example, FEMA should look to industry best
practices to improve customer communications so there is better
public understanding of the underwriting and rating processes,
and up-front clarity on which losses are covered and which
losses are not. FEMA also has the authority to issue bulletins
and other guidance so that FEMA's claim handling and
engineering investigation requirements are objective and
transparent. By meeting customer needs and expectations, and by
providing clear guidance to insurance companies participating
in the NFIP, there will be less policyholder frustration, fewer
complaints and less litigation.
What is FEMA doing to make the program more customer-
centric and how is FEMA communicating with the Write Your Own
carriers to improve the customer experience?
A.3. Answer not received in time for publication.
Q.4. FEMA recently proposed removing the Write Your Own (WYO)
Financial Assistance/Subsidy Arrangement from the Code of
Federal Regulations (CFR) so FEMA can negotiate individual
contracts with the insurance companies that serve as FEMA' s
agents for the sale and administration of flood insurance
policies.
Do you believe that some WYO companies perform better than
others and, if so, what measures will you take when negotiating
new contracts to make sure that better performing companies
remain in the program?
Since you will be negotiating individual contracts, are you
concerned that contracts with different companies on different
terms could create competitive imbalances?
A.4. Answer not received in time for publication.
Q.5. You have stated that the Arrangement would be removed from
the CFR, but will continue to be available on the FEMA website.
Your WYO partner companies currently rely on the fact that
their contractual relationship with FEMA under the Arrangement
conforms to Federal law, which makes clear that the Federal
Government assumes liability for losses under NFIP policies.
Why would the Arrangement continue to be accessible if a
new and presumably different contract is to be negotiated with
each WYO carrier? Will the current Arrangement apply in any way
to the new individualized contracts and, if so, are there any
legislative or regulatory changes necessary to ensure that the
new contracts conform to federal law so the essential nature of
the WYO relationship is not disrupted?
A.5. Answer not received in time for publication.
Additional Material Supplied for the Record
FEMA--``TECHNICAL MAPPING ADVISORY COUNCIL OVERVIEW''
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
LETTER SUBMITTED BY TOM SALOMONE, 2016 PRESIDENT, NATIONAL ASSOCIATION
OF REALTORS
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
LETTER SUBMITTED BY CHAD BERGINNIS, EXECUTIVE DIRECTOR, ASSOCIATION OF
STATE FLOODPLAIN MANAGERS
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
LETTER SUBMITTED BY CHAD BERGINNIS, EXECUTIVE DIRECTOR, ASSOCIATION OF
STATE FLOODPLAIN MANAGERS AND JAMES M. DRINAN, JD, EXECUTIVE DIRECTOR,
AMERICAN PLANNING ASSOCIATION
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
JOINT LETTER SUBMITTED BY AMERICAN BANKERS ASSOCIATION, AMERICAN
INSURANCE ASSOCIATION, COUNCIL OF INSURANCE AGENTS AND BROKERS,
FINANCIAL SERVICES ROUNDTABLE, THE INDEPENDENT INSURANCE AGENTS AND
BROKERS OF AMERICA, NATIONAL ASSOCIATION OF MUTUAL INSURANCE
COMMITTEES, NATIONAL ASSOCIATION OF PROFESSIONAL INSURANCE AGENTS, AND
PROPERTY CASUALTY INSURERS ASSOCIATION OF AMERICA REGARDING THE
PRINCIPLES FOR FLOOD INSURANCE REAUTHORIZATION
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]