CSFI collaborated with Insurance for Good on a response to a proposed rule by HUD on the Federal Flood Risk Management Standard (FFRMS). The docket is FR-6527-P-01 Rescission of Floodplain Management and Protection of Wetlands; Minimum Property Standards for Flood Hazard Exposure; Building to the Federal Flood Risk Management Standard, with comments due on September 8.  The proposed rule would affect the process for determining the regulatory floodplain and elevation requirements.

CSFI’s comments underscored the importance of the longer-term insurability of communities. While expressing concern for to the potential additional costs for construction and disaster recovery of the previous rule, CSFI and Insurance for Good argued that “homes are not affordable if you cannot afford to insure them and if future disaster losses are greater.”  In the comment, CSFI and Insurance for Good opined that, without accounting for changes in HUD and NFIP expenditures caused by the proposed rule, “we do not believe that cost savings are complete.”

Furthermore, CSFI and Insurance for Good address outdated flood maps, which are tied to the 1 percent annual chance floodplain. Approximately 75% of the nation’s Flood Insurance Rate Maps (FIRMs) are now out of date.  In 2016, the Department of Homeland Security’s Office of Inspector General found that only 42% of the total flood map miles in FEMA’s inventory were updated and valid.

The full comment is available on Insurance for Good‘s website or on Regulations.gov.