An Evaluation of Compliance with the
National Flood Insurance Program Part B:
Are Minimum Building Requirements Being Met?


Margaret L. Mathis and Suzanne Nicholson 

Dewberry 

October 2006


Prepared under subcontract to the American Institutes for Research
as part of the 20012006 Evaluation of the National Flood Insurance Program



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An Evaluation of Compliance with the National Flood
Insurance Program Part B:


Are Minimum Building Requirements Being 
Met? 


Prepared as part of the 2001-2006 Evaluation of the National Flood Insurance Program 

Margaret L. Mathis and Suzanne Nicholson 

Dewberry
October 2006


Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program Part B:
Are Minimum Building Requirements Being Met?



REPORTS IN THE EVALUATION OF THE NATIONAL FLOOD 
INSURANCE PROGRAM 

This Evaluation is composed of a series of reports assessing questions identified and prioritized by a 
steering committee about the National Flood Insurance Program. The reports of the Evaluation will be 
posted on the FEMA website as they are finalized. The website URL is 
http://www.fema.gov/business/nfip/nfipeval.shtm. The reports in the Evaluation are: 

The Evaluation of the National Flood Insurance Program  Final Report 

American Institutes for Research and NFIP Evaluation Working Group 

Assessing the Adequacy of the National Flood 
Insurance Program's 1 Percent Flood Standard. 

Galloway, Baecher, Plasencia, Coulton, 
Louthain, and Bagha, Water Policy 
Collaborative, University of Maryland. 

Assessing the National Flood Insurance 
Programs Actuarial Soundness. Bingham, 
Charron, Kirschner, Messick, and Sabade, 
Deloitte Consulting. 

Costs and Consequences of Flooding and 
the Impact of the National Flood Insurance 
Program. Sarmiento and Miller, Pacific Institute 
of Research and Evaluation. 

Developmental and Environmental Impacts of 
the National Flood Insurance Program: A 
Review of Literature. Rosenbaum, American 
Institutes for Research. 

The Developmental and Environmental Impact 
of the National Flood Insurance Program: A 
Summary Research Report. Rosenbaum and 
Boulware, American Institutes for Research. 

An Evaluation of Compliance with the National 
Flood Insurance Program Part A: Achieving 
Community Compliance. Monday, Grill, 
Esformes, Eng, Kinney, and Shapiro, American 
Institutes for Research. 

An Evaluation of Compliance with the National 
Flood Insurance Program Part B: Are Minimum 
Building Requirements Being Met? Mathis and 
Nicholson, Dewberry. 

Evaluation of the National Flood Insurance 
Programs Building Standards. Jones, 
Coulbourne, Marshall, and Rogers, Christopher 
Jones and Associates. 

Managing Future Development Conditions in 
the National Flood Insurance Program. 

Blais, Nguyen, Tate, Dogan, and Petrow, ABSG 
Consulting; and Mifflin and Jones. 

The National Flood Insurance Programs 
Mandatory Purchase Requirement: Policies, 
Processes and Stakeholders. Tobin and Calfee, 
American Institutes for Research. 

The National Flood Insurance Programs 
Market Penetration Rate: Estimates and Policy 
Implications. Dixon, Clancy, Seabury, and 
Overton, RAND Corporation. 

Performance Assessment and Evaluation 
Measures for Periodic Use by the National 
Flood Insurance Program. Miller, Langston, 
and Nelkin, Pacific Institute of Research and 
Evaluation. 

State Roles and Responsibilities in the National 
Flood Insurance Program. Mittler, Morgan, 
Shapiro, and Grill, American Institutes for 
Research. 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program Part B:
Are Minimum Building Requirements Being Met?



The research described in this report was funded with Federal funds from the Federal 
Emergency Management Agency under contract # 282-98-0029 and under subcontract to the 
American Institutes for Research. The content of this publication does not necessarily reflect the 
views or policies of the Federal Emergency Management Agency, nor does mention of trade 
names, commercial products, or organizations imply endorsement by the U.S. Government. 

In designing and executing this study, Dewberry tapped its extensive floodplain 
management, flood hazard analysis and mapping, flood mitigation, and disaster response and 
recovery experience gained through 30 years supporting FEMA and its partners. This experience 
has provided Dewberry with an uncommon understanding of the programs, practices, and 
policies governing the National Flood Insurance Program (NFIP) and how they interrelate to 
activities conducted by state and local governments. 

This study contributes to the overall NFIP evaluation by developing estimates of the level 
of compliance with the NFIP minimum building requirements and increases our understanding of 
what are the most common violations and what factors explain the differences in levels of 
compliance between communities, flood zones, building types, and similar factors. 

For additional information about this study or Dewberrys NFIP experience, contact: 

Margaret L. Mathis, CFM
Dewberry
8401 Arlington Boulevard 
Fairfax, Virginia 22031-4666 
Phone: (703) 849-0330 
E-mail: mmathis@dewberry.com


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BIOGRAPHICAL INFORMATION ON REPORT AUTHORS 

Margaret L. Mathis is the Department Manager at Dewberry responsible for program 
support activities within Dewberrys Hazard Engineering Resources Department. She has in-depth 
knowledge of floodplain management regulations and procedures, gained through working on 
FEMAs flood hazard mapping program for over 20 years. Her experience has included a broad 
spectrum of assignments including flood study development; interpretation and implementation 
of NFIP floodplain regulations, policies, and procedures; and development of outreach strategies 
to improve dissemination of information to NFIP communities and property owners. She has 
also supported FEMA and its state partners in developing processes to improve map adoption 
and community compliance. Ms. Mathis also provides consulting services to clients on the 
Community Rating System and adoption of higher NFIP regulatory standards. She is a graduate of 
the University of Maryland, with a B.S. in Geography. 

Suzanne Nicholson is a Senior Technical Writer at Dewberry. She has over 11 years 
experience researching, writing, and editing reports in support of FEMA and the NFIP, including 
the Mitigation Assessment Team Report: Hurricane Ivan in Alabama and Florida (FEMA 489), 
FEMAs Project Impact Tool Kit, and many documents in support of FEMAs Map 
Modernization Plan. Prior to joining Dewberry, Ms. Nicholson was Rhetoric professor at 
Southern Methodist University and a professor of composition and developmental studies at 
Brookhaven College. She is a graduate of the University of Texas at Dallas with an M.A. in 
Humanities. 

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TABLE OF CONTENTS 

EXECUTIVE SUMMARY ..................................................................................................................................... IV


BACKGROUND.......................................................................................................................................................... V
METHOD ................................................................................................................................................................ VII
RESULTS AND CONCLUSIONS ................................................................................................................................ VIII
RECOMMENDATIONS.............................................................................................................................................. XII


1. INTRODUCTION ..................................................................................................................................................1


1.1. BACKGROUND AND PURPOSE OF REPORT............................................................................................................1


1.2. OVERVIEW OF THE NFIP ....................................................................................................................................2


1.3. NFIP REGULATIONS FOR CONSTRUCTION IN THE SFHA.....................................................................................4


1.4. SCOPE AND LIMITATIONS OF STUDY ...................................................................................................................6


1.5. ORGANIZATION OF THIS REPORT ........................................................................................................................8


2. METHOD................................................................................................................................................................9


2.1. COMMUNITY SELECTION PROCESS......................................................................................................................9


2.1.1. Cluster Selection Process........................................................................................................................9


2.1.2. Community Selection Process ................................................................................................................10


2.2. BUILDING SELECTION PROCESS ........................................................................................................................15


2.3. PREPARATION FOR SURVEY OF BUILDINGS .......................................................................................................15


2.3.1. Team Member Selection and Training ...................................................................................................16


2.3.2. Community Coordination......................................................................................................................16


2.3.3. Project Database...................................................................................................................................17


2.4. SURVEY APPROACH .........................................................................................................................................18


2.4.1. Administrative Survey ............................................................................................................................18


2.4.2. Elevation Surveys and Building Inspections ..........................................................................................18


2.5. LIMITATIONS ....................................................................................................................................................19


2.6. STUDY SAMPLE CHARACTERISTICS..................................................................................................................21


2.7. COMPLIANCE CLASSIFICATION CATEGORIES ....................................................................................................24


3. STUDY RESULTS ...............................................................................................................................................27


3.1. COMMUNITY RECORD KEEPING AND RETENTION .............................................................................................27


3.1.1. Permit Files...........................................................................................................................................28


3.1.2. Elevation Certificates............................................................................................................................30


3.2. ELEVATION SURVEY RESULTS ..........................................................................................................................31


3.2.1. Results by Compliance Classification Categories..................................................................................32


3.2.2. Results by Community and Building Characteristics .............................................................................38


3.2.3. Results Extrapolated to Community Clusters.........................................................................................48


4. SUMMARY AND CONCLUSIONS ....................................................................................................................51


5. RECOMMENDATIONS ....................................................................................................................................55


6. APPENDICES.......................................................................................................................................................59


APPENDIX A  PARTICIPATING COMMUNITIES WITH DETAILED SFHAS..........................................59


APPENDIX B  NATIONAL SURVEY RESULTS BY COMPLIANCE CATEGORY ....................................95


7. ACRONYMS.......................................................................................................................................................103


8. REFERENCES ...................................................................................................................................................105


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ACKNOWLEDGMENTS 

Appreciation is extended to the many professionals who took their time to review and 
provide insights and observations on earlier drafts of this report. Thanks are due in particular to 
Michael Robinson formerly of FEMA for his help in developing the compliance categories used 
in this report and for his review and comments on the findings. His thoughtful comments on the 
noncompliance with the NFIP building requirements found in this study and how it contributes to 
damages during the base flood formed the basis of much of the discussion included in the Results 
by Compliance Classification Categories section of this report. 

An immense amount of data was collected for this study, and the study would not have 
been successful without the hard work of the Dewberry project team including David 
Burkholder, Kelly Clemmensen, Lisa Turcios, John Graves, Scott Weber, Richard Nash, and 
Kaveh Zomorodi. 

A sincere thank you also goes out to Claudia Murphy of FEMA and Marc Shapiro, the 
current project director for the NFIP evaluation at AIR for their detailed comments on the report 
and for their help moving the study to completion. 

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EXECUTIVE SUMMARY 

Background 

In 2000, the Department of Homeland Securitys Federal Emergency Management 
Agency (FEMA) contracted with the American Institutes for Research (AIR) to perform a 
comprehensive evaluation of the National Flood Insurance Program (NFIP). As part of the 
evaluation, FEMA tasked AIR with conducting a comprehensive nationwide assessment of 
compliance with the NFIP minimum floodplain management regulations as set forth in Title 44, 
Section 60.3, of the Code of Federal Regulations (44 CFR 60.3). That assessment has been 
completed through two coordinated studies. 

Study Part A, prepared by AIR, assesses the processes for ensuring community 
compliance with NFIP regulations. The areas of inquiry include the NFIPs approach to training 
and technical assistance; the effectiveness of tools for monitoring community compliance, and 
defining and remedying violations; the roles of FEMAs headquarters and regional offices, and 
state floodplain management agencies in supporting the NFIP; the capabilities of communities to 
identify and address violations; and the appropriateness of sanctions for noncompliance. 

Study Part B, prepared by Dewberry under subcontract to AIR, quantitatively addresses 
the percentage of buildings located in FEMA designated Special Flood Hazard Areas (SFHAs)1 

 that are in compliance with the NFIPs floodplain management regulations, especially those 
regulations related to construction standards. Specifically, this study examined a subset of the 
buildings in SFHAs; notably recent2 construction that has occurred after the date FEMA had 
produced a Flood Insurance Rate Map (FIRM) for the area in which the building is located3. 
Study Part B seeks to identify those floodplain management regulations that have the highest and 
lowest rates of compliance and what factors explain the differences in levels of compliance 
between communities, flood zones, building types, and similar factors. 
Floodplain management regulations that meet minimum NFIP standards have been 
adopted by over 20,000 communities nationwide. These regulations are designed to prevent new 
development from increasing the flood threat and to protect new and existing buildings from 
anticipated flooding. In exchange for adoption and continued enforcement of the regulations, 
flood insurance is made available to communities, their property owners and renters. 

1 

The SFHA is the area that is predicted to be inundated by the flood events having a 1-percent or greater chance of 
being equaled or exceeded in any given year. The SFHA, which is shown as either an A Zone or V Zone, is 
identified on a Flood Hazard Boundary Map or Flood Insurance Rate Map prepared by FEMA. 

2 

In this context, recent construction is defined as construction that has occurred since January 1, 1990. 

3 

Buildings constructed or substantially improved after the effective date of the initial FIRM for the area in which 
the building is located, or after December 31, 1974, whichever is later are referred to as Post-FIRM buildings. 

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In general, communities participating in the NFIP must require permits for all new 
development in the SFHA; elevate the lowest floor of all residential buildings4 in the SFHA to or 
above the Base Flood Elevation (BFE); restrict development in the regulatory floodway5; ensure 
that construction materials and methods used will minimize future flood damage; and treat 
substantially improved structures6 as new buildings that must meet the minimum NFIP 
standards. 

The success of the NFIP depends on communities ensuring that buildings and other 
development within their jurisdictions are constructed and maintained according to these 
standards so that flood losses will be minimized. If communities do not elect to participate in the 
program or if they do so but fail to adequately enforce the standards, then lives and property are 
placed in harms way; buildings will suffer unnecessary flood damage; the NFIPs actuarial 
soundness will be jeopardized; and the costs to society from future floods will be increased 
unnecessarily. The NFIP has an added dimension that encourages the thoughtful placement of 
new development and compliance with the NFIP regulations. Notably, flood insurance 
premiums are based on the flood zone in which the building is located and the elevation of the 
building in relation to the BFE. The effect of this differential rate structure is to provide an 
incentive to increase the level of safety of buildings beyond the minimum standards by giving 
significant financial benefits to building at higher elevations and in less hazardous flood zones. 

As discussed in Study Part A, there has never been a comprehensive nationwide 
assessment of compliance with the NFIP regulations. Although participating communities are 
monitored individually on a regular, though fairly infrequent basis, the question of how well the 
NFIP is being administered across the United States, and what proportion of flood prone 
buildings are built to the programs standards has been unanswered. The data collected through 
this study allow observations to be drawn about the level of compliance among a subset of NFIP 
communities, notably those located in areas where current and future floodplain development 
and flood risk is greatest and where success in achieving compliance with the NFIP regulations 
is most important. 

The summary that follows describes the research methods used in this evaluation, 
presents selected results and conclusions, and lists the recommendations growing out of this 
study. 

4 

In meeting the NFIP regulations, residential buildings are required to be elevated to or above the BFE, while nonresidential 
buildings have the option of being either elevated or floodproofed to the same level. 

5 

The regulatory floodway is the area identified on a FIRM or a Flood Boundary Floodway Map that represents the 
portion of the floodplain that carries the majority of the flood flow and often is associated with high velocity flows 
and debris impact. The floodway represents the channel of a river or watercourse and the adjacent land areas that 
must be reserved to discharge the one-percent annual chance flood without cumulatively increasing the water 
surface elevation more than a designated height, generally one foot. 

6 

Substantial improvement is defined in 44 CFR 59.1 as any reconstruction, rehabilitation, addition, or other 
improvement of a structure, the cost of which equals or exceeds 50 percent of the market value of the structure 
before the start of construction of the improvement. 

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Method 

The first stage of the sampling process used in this study included the purposive 
identification of geographic areas made up of either a metropolitan area or a group of closely 
located counties or communities (referred to herein as clusters) with large concentrations of 
post-FIRM buildings. This non-random approach to selection of the clusters was necessary to fit 
the available budget and ensure that the sample was representative of areas of the country where 
a preponderance of NFIP post-FIRM policies are found. Large, fast-growing communities as 
well as smaller tourist destinations along the coasts are represented in the sample frame because 
a high percentage of the post-FIRM construction is occurring in these areas. From an original 
sample frame that included eighteen cluster areas, ten clusters were chosen. These clusters 
represent the predominant types of flooding experienced by NFIP communities; in addition, they 
are geographically and economically diverse and include areas with high growth rates both in 
terms of population and the number of post-FIRM policies. A community selection process was 
used to develop a viable list of communities within each cluster, and from this list the 
communities to be studied were selected randomly. Fifty communities ultimately were included 
in Study Part B. 

All or most of the post-FIRM buildings constructed after January 1, 19907 (both insured 
and uninsured) located within SFHAs studied by detailed methods (i.e., for which FEMA had 
established BFEs or flood depths) of each candidate community were identified. From the 
comprehensive list of buildings, 35 to 45 candidate buildings suitable for survey in each 
community were selected randomly; ultimately, approximately 25 buildings in each community 
were physically surveyed. 

The data collection approach included an administrative survey  an inspection of the 
communitys permit files  and an elevation and building inspection survey. The objective of the 
administrative survey was to review community record keeping and retention as it relates to the 
construction of buildings in SFHAs, and the objective of the elevation and building inspection 
survey was to determine if buildings built within the surveyed communities had been built to 
minimum NFIP standards. 

The results should be considered suggestive of results that would be found among 
communities and buildings that fit the study criteria8. The presentation of results breaks down 
the compliance problems encountered to distinguish between different types of factors that may 
or may not put a buildings structure substantially at risk of damage in a 1-percent annual chance 
flood. 

7 

The January 1, 1990 date was set to ensure an adequate sample of buildings in most communities and allow 
comparison of changes in floodplain management practices over a 14-year time period. 

8 

The communities selected are predominantly rapidly-growing coastal communities on the Atlantic, Gulf, and West 
coasts and inland communities in the Southwest and along the Mississippi River. Buildings included in the study 
are post-FIRM buildings constructed after January 1, 1990 in detailed SFHAs. Buildings both insured and 
uninsured by a flood insurance policy are included. 

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Results and Conclusions 

This study addressed a series of research questions aimed at identifying the most 
common violations of the floodplain management regulations, where they were most common, 
and possible explanations for the differences in levels of compliance between communities, 
flood zones, building types, and similar factors. The results of those most salient questions 
follow. 

Overall rate of floodplain development compliance: 

Of the 1,253 buildings physically surveyed, 63 percent were found to be in full 
compliance with all of the building requirements of the NFIP. Generalizing up to what would be 
expected if all buildings in the clusters of communities meeting the selection criteria were 
surveyed, we estimate at a 95 percent confidence interval that between 58 and 70 percent of the 
buildings would be found to be in full compliance. These percentages, however, must be put 
into context. Of the buildings surveyed, few are at risk of suffering significant damage during 
base flood conditions; notably, because communities are generally successfully meeting the 
elevation requirements of the program. This success is illustrated by the fact that 89 percent of 
all buildings surveyed have their lowest floor at or above the BFE or within 6 inches of that 
elevation. In terms of damage reduction, ensuring that the lowest floor is elevated to or above 
the BFE is significant and results in minimizing flood insurance claims and federal disaster 
assistance. Again, generalizing up to what would be expected if all buildings meeting the 
selection criteria were surveyed across these clusters of communities, we estimate at a 95 percent 
confidence interval that between 86 and 94 percent of the buildings would have their lowest floor 
at or above the BFE or within 6 inches of that elevation. The 89 percent is comprised of the 
following: 

 63.1 percent of the buildings found to be in full compliance with all of the 
regulatory building requirements of the program 
 9.3 percent of the buildings with mechanical and utility equipment located below 
BFE but are fully compliant with the lowest floor elevation requirement 
 9.3 percent of buildings with openings that do not meet the openings requirement 
at 44 CFR 60.3(c)(5) but are otherwise fully compliant 
 3.8 percent with multiple noncompliance issues but are compliant with the 
elevation requirement 
 1.4 percent with their lowest floor within 6 inches of the BFE 
 1.9 percent with their lowest floor within 6 inches of the BFE and other instances 
of noncompliance 
Of further note, in addition to the 89 percent of buildings found to have been built to the 
BFE or within 6 inches of that elevation, an additional 4.3 percent have their main 
working\living floors above BFE but have finished enclosures or basements below the 
BFE. The buildings with noncompliant finished enclosures typically had the majority of the area 

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under the elevated floor reserved for parking but in each case had an enclosed finished room with 
non-flood resistant materials and furnishings. The noncompliant basements found were one to 
three feet below BFE and not likely to experience damages due to hydrostatic pressure9 during 
base flood conditions. For these reasons, as well as, limitations on flood insurance coverage for 
basements and noncompliant finished enclosures, the claims on these buildings would be much 
lower than for buildings with lowest floor violations at the same elevation. 

Most common violations found: 

The most common violations found were mechanical and utility equipment located below 
the BFE and openings that do not meet the openings requirement at 44 CFR 60.3(c)(5). 
Between them, these two types of violations account for 50.6 percent of the violations found 
within our sample. The regulations governing mechanical and utility equipment and openings 
are technically the most difficult to apply and enforce. Further, although these items can be 
compliant when a building is built, they can be modified later by the property owner without the 
community's knowledge. For these reasons, it is difficult to determine if the violations found are 
the result of misunderstandings concerning the requirements by local officials, willful disregard, 
less importance or focus placed on ensuring that the requirements are met, or lack of 
enforcement. 

Variation in compliance by geographic region: 

The results show that geography affects level of compliance only modestly. The analysis 
suggests that rates of compliance are better in the Southwest and lower on the West Coast of the 
US. It is speculated that some differences in rates of compliance are attributable to the 
prevailing building construction method found within the region. Generally higher rates of 
compliance were observed in communities with primarily slab-on-grade construction and lower 
rates in communities that use various types of elevated foundations. 

Effect of community size and economic resources on compliance: 

At the start of this study, it was anticipated that better levels of compliance would be 
found in larger communities with large areas of their community located within flood hazard 
areas and more economic resources. This assumption was based on the premise that more 
economic resources would be available within the community to support full-time floodplain 
management staff and more resources would be devoted to outreach and public education. It was 
further surmised that because FEMA and its state partners put the vast majority of their resources 
and effort into promotion of compliance within communities with the greatest number of flood 
insurance policies in an effort to protect the financial stability of the Flood Insurance Fund, better 
levels of compliance would be found in the larger communities within the sample. This study 
found little evidence of a strong relationship between the size or economic resources of the 
community and the number of compliant buildings. 

Solid walls can collapse if floodwaters get too deep. To prevent collapse the enclosure must have openings to 
allow floodwaters to enter and exist, thus automatically equalizing hydrostatic flood forces on the walls. 

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Compliance variation by the source of floodingcoastal or riverine: 

Generally, the analysis showed that no significant difference exists in the rate of 
compliance between buildings affected by coastal versus inland flooding10 . 

11

Compliance in Community Rating System (CRS) and non-CRS communities: 

Although one would expect to find better rates of compliance among communities 
participating in the CRS which is a voluntary incentive program that encourages communities to 
perform floodplain management activities that exceed the NFIPs minimum requirements in 
exchange for reduced flood insurance premiums, there is no evidence to support this expectation. 
The exception is that fewer lowest floor (Zone AE) and Lowest Horizontal Structural Member 
(Zone VE) violations are found in the CRS than non-CRS communities. 

Issuance of building permits, ensuring lowest floor and as-built elevations are at or above 
BFE, and document retention: 

In general, this study found problems with record keeping and retention by communities. 
As a result, it is unclear to what degree communities are meeting the 44 CFR 60.3 
requirement12 to issue building permits for all development in the SFHA, if they are commonly 
ensuring that the proposed lowest floor and as-built elevations (after construction has been 
completed) are at or above BFE, and if they obtain and retain documentation of design and 
construction methods. Although Elevation Certificates or equivalent data are available more 
widely among the CRS communities than NFIP communities not in the CRS, they nonetheless 
do not reach rates expected for CRS communities. 

Compliance variation by flood zone: 

Generally our analysis showed a significantly better rate of compliance in Zone AO than 
in other flood zones. Elevations associated with Zone AO are represented on the FIRM as whole 
foot elevations. It is theorized that the existence of a whole foot flood depth or elevation that is 
clearly identified on the FIRM may increase the accuracy of the flood elevation determined and 
placement of fill or the lowest floor. While on a whole there is no evidence of significant 
differences in rates of compliance other than in AO Zones, there is mild evidence to suggest that 

10 

Coastal flooding includes flooding from any body of water subject to tidal fluctuations. Coastal communities 
may or may not include V flood zones. V Zones are areas that are inundated by tidal floods with velocity waters 
and breaking waves. 

11 

Any community participating in the NFIP may join the CRS provided that the community is in full compliance 
with the NFIPs minimum requirements and that it makes a commitment to perform a minimum number of 
additional floodplain management activities. As a basic requirement, CRS communities must keep permit files that 
include Elevation Certificates for all structures built, substantially damaged, or substantially improved in the SFHA 
since the community entered the CRS. 

12 

Communities participating in the NFIP must require permits for all new development in the SFHA. Further they 
must ensure the lowest floor of residential buildings be at or above BFE and that the building be constructed to 
withstand flood damage. Standard documentation including a development permit, FEMA Elevation Certificate or 
equivalent as-built elevation data, and information regarding the construction methods are to be retained by the 
community indefinitely. 

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VE Zone has a higher fraction of buildings where the elevation requirements of the program 
have not been met than found in the other flood zones. 

Variation in compliance between buildings uninsured and insured by the NFIP: 

Buildings carrying and not carrying NFIP flood insurance (insured and uninsured 
buildings) were included in this study to help ascertain if flood insurance may have been dropped 
for structures where serious violations may have resulted in high flood insurance premiums. 
Marginally significant evidence was found of a relationship between lower compliance and 
uninsured buildings. 

Compliance over time: 

Study B compares results by compliance category for three segments of time: 1990 to 
1995, 1996 to 2000, and 2001 to 2004. The analysis shows a significant increase in the 
percentage of fully compliant buildings from the earliest to the most recent time period. 

Method of construction of buildings and compliance: 

In general, there are higher rates of compliance in communities with primarily slab-ongrade 
construction (construction on a concrete slab that is installed on compacted or natural soil) 
and lower rates in communities that use various types of elevated foundations. 

Building type (commercial, manufactured homes, or other residential structures) and 
compliance: 

Higher levels of compliance were observed in townhomes/rowhouses and in public 
buildings. Poor compliance was found in manufactured homes. Within the manufactured 
buildings, there was a high occurrence of electrical and mechanical below the BFE. These were 
primarily air conditioning condensers found at grade. 

In conclusion, as discussed in Part A of this study, Achieving Community Compliance, 
(Monday et al., 2006) and in latter sections of this report , the NFIPs success is based on two 
conditions. The first is that communities will choose to participate in the program and, therefore, 
will adopt and agree to enforce floodplain management ordinances established under authority of 
the National Flood Insurance Act, as amended. The incentive for such participation, and all that 
it entails, is the availability of flood insurance for the community and its property owners. 

Second, once a community begins participating in the NFIP, it is assumed that it 
administers and enforces its ordinance in such a way that development in its floodprone areas 
meets the local (and NFIP) standards and, thus, is protected from future flood damage. If either 
condition is not metif communities do not elect to participate in the program or if they do so 
but fail to adequately enforce the standards  lives and property are placed in harms way; 
buildings will suffer unnecessary flood damage; the NFIPs actuarial soundness is jeopardized; 
public policies and regulations in floodplains may be based on unreliable data; and the costs to 
society from future floods will be increased unnecessarily. In short, a high level of continuous 
compliance with the NFIP standards is crucial to the programs success. Thus, the question of 
the extent and nature of compliance and noncompliance is an important element of any 
assessment of the NFIP and must be continually monitored. 

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Recommendations 

The $1.1 billion in estimated flood damages prevented annually due to reduced frequency 
and severity of losses13 resulting from enforcement of floodplain management regulations 
provides testament to the successful implementation of many of the NFIPs floodplain 
management measures. However, the data gathered through this study point to the need for 
greater focus on enforcement and additional training and technical guidance in several areas. In 
addition, this study identified widespread problems with community record keeping and 
retention related to construction of buildings in the nations SFHAs. 

Recommendations for improving the specific deficiencies identified through Part B of the 
Evaluation of Community Compliance follow. These recommendations include specific actions 
that communities can take to improve compliance as well as actions FEMA and its state partners 
can take to promote improved compliance. 

Community Compliance Part B Recommendation #1 (CCB1): Adoption of freeboard should 
be strongly promoted 

The prevalence of lowest floor (Zone AE) and LHSM (Zone VE) violations, and 
noncompliant buildings found to be within 6 inches of the BFE, reinforces the advisability of 
communities or states adding a requirement for freeboard rather than meeting the minimum 
requirement that the top of the floor be built at BFE. Freeboard is the additional height 
requirement above the BFE that provides a factor of safety against flooding and wave run-up. 
The benefits of adopting freeboard should be widely promoted through training, FEMA and 
community websites, and in technical publications. Communities should be strongly encouraged 
to codify the requirement in their local ordinances. 

CCB#2: Promote frequent verification inspections during construction 

One of the most effective ways to ensure compliance with the NFIP building standards, 
as well as higher standards such as freeboard requirements that a community may have adopted, 
is to inspect the site frequently during construction. Errors in the elevation of the lowest floor are 
most easily found and corrected in earlier phases of construction, while detection of errors in the 
placement of electrical and mechanical equipment is not possible until later in the construction 
process. An inspection program also puts builders, developers, and property owners on notice 
that the community will insist that projects are completed in compliance with the regulations. 

CCB#3: Perform periodic checks to ensure that the property continues to remain in 
compliance 

Communities should periodically check to ensure that the property continues to remain in 
compliance over time. Later inspections are particularly important when a building has an 
enclosure below the lowest floor. Such areas can be easily modified into habitable fully 
furnished space in violation of the NFIP regulations creating safety hazards. This study 

Source: FEMA website http://www.fema.gov/plan/prevent/floodplain/How_the_NFIP_works.shtm. 

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identified 30 noncompliant finished enclosures. Many are surmised to have been converted to 
habitable fully finished living space without community consent. 

CCB#4: A concerted effort is needed to focus greater attention on community permit file 
record keeping and retention 

Strong adherence to a floodplain management program that requires permits for all 
floodplain development, monitors construction as it takes place as well as periodically over time 
to ensure continued compliance with the NFIP requirements or the communitys own higher 
standards, and ensures adequate documentation of those activities, benefits the NFIP compliance 
program in two ways. First, it allows FEMA and its state partners involved in community 
monitoring activities to quickly assess the adequacy of the communitys program and direct 
limited resources towards communities with the greatest needs. Second, good records show 
what was approved, forming a paper trail needed for administrative or legal proceedings when 
buildings are found to be in violation of the communitys ordinance. Improvements in this area 
may be brought about by having FEMA regional offices, FEMA state partners, and Insurance 
Services Office, Inc. (ISO)14/CRS personnel focus greater attention on the record keeping 
requirements of the program during contacts with communities. 

CCB#5: FEMA should consider revising the opening requirements found in 44 CFR 60.3 
(c)(5) for buildings in coastal AE zones with non supporting breakaway walls. 

The FEMA 2000 Coastal Construction Manual recommends that buildings in Coastal AE 
zones 15 be constructed to be more resistant to coastal flood forces. Further, the nations private 
sector building code organizations and consensus standards groups (i.e., IBC, IRC, NFPA 5000, 
ASCE 7, ASCE 24) recognize the Coastal AE zone hazard and require appropriate design and 
construction requirements similar to those established for VE zones under the NFIP. 
Nonetheless, the Coastal AE zone, has yet to be included in the NFIP regulations. At present, 
buildings in Coastal AE zones constructed to Zone VE standards that include non supporting 
breakaway walls below the lowest floor and do not also have openings that meet the openings 
requirements of 44 CFR 60.3(c)(5) are considered noncompliant. Thirteen of the noncompliant 
buildings identified by this study as having insufficient openings are pile and column buildings 
that appear to be built to Zone VE standards in Zone AE. It is recognized that a regulatory 
change does not happen without great deliberation. Until such time as a regulatory change might 
be implemented, FEMA should issue clear guidance regarding the opening requirement in 
breakaway walls in coastal AE zones. 

14 

The CRS is administered jointly by FEMA and ISO personnel. On behalf of FEMA, ISO reviews and scores 
community applications and conducts regular visits with communities to verify activities are being implemented as 
described in their application. 

15 

The Coastal Construction Manual identifies a new hazard zone called a Coastal A zone, that is not included in the 
NFIP regulations. Coastal A zones are those areas located landward of an open coast with or without mapped V 
Zones where the principal sources of flooding are tides, storm surges, seiches or tsunamis instead of riverine 
sources. Coastal A Zones are subject to wave effects, velocity flows, erosion, scour, and all combinations of the 
above. These areas are expected to receive 1 -3 foot breaking waves during a 100-year event. 

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CCB#6: FEMA should continue its support of training for local staff, state training 
requirements, and certification of local floodplain managers. 

It is impossible to know if the instances of noncompliance found in this study are the 
result of misunderstandings concerning NFIP requirements by local officials, willful disregard, 
less importance or focus placed on ensuring that certain requirements are met, or lack of 
enforcement once violations are found. Nonetheless, it is widely believed that most communities 
and individuals are willing to abide by technical standards set for the program and that public 
servants are interested in protecting people and their property. With the latter premise in mind, it 
is surmised that community compliance could be improved by making more resources available 
for both FEMA and the states to increase staff levels and travel support, and to produce and 
deliver more workshop and training materials. This recommendation is also found in Part A of 
the evaluation of community compliance. 

CCB#7: FEMA and ISO/CRS personnel should monitor compliance in communities participating in 
CRS more closely and take decisive action to bring communities into compliance or retrograde their 
CRS class. 

Part A of the evaluation of community compliance found monitoring and enforcement in 
CRS communities to be deficient. Shortcomings are perceived to be the result of poor 
recordkeeping and retention, confusion about roles and responsibilities and communication gaps 
between FEMA, FEMAs state partners, and ISO/CRS personnel. Study B found further 
evidence of noncompliant programs in CRS communities in the areas of both recordkeeping and 
retention and noncompliant buildings. 

CRS communities typically have large amounts of development in the floodplain and 
serious flooding problems and, hence it is not surprising that they are faced with serious 
challenges in ensuring compliance. However, FEMA recognizes and rewards CRS communities 
for having better floodplain management programs by reducing the cost of flood insurance 
premiums within the community; the effect is to reduce the communitys contribution to the 
National Flood Insurance Fund. Thus, noncompliance in CRS communities increases the overall 
costs of the NFIP and affects the viability of the flood insurance fund even more than 
noncompliance in other communities. A concerted effort is needed to remedy the deficiencies in 
this program. 

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1. INTRODUCTION 
1.1. Background and Purpose of Report 
In 2000, the Department of Homeland Securitys Federal Emergency Management 
Agency (FEMA) initiated a comprehensive evaluation of the National Flood Insurance Program 
(NFIP)the first since Congress established the NFIP with the passage of the National Flood 
Insurance Act of 1968. The purpose of the evaluation is to gather data and information to 
formulate policies for future floodplain management, risk assessment, and flood insurance and to 
support long-term planning and policy making for the NFIP. 

FEMA selected the American Institutes for Research (AIR) to perform the evaluation of 
the NFIP. In September 2002, as part of the evaluation, FEMA tasked AIR with conducting a 
comprehensive nationwide assessment of the level of compliance with the NFIP minimum 
floodplain management standards as set forth in Title 44, Section 60.3, of the Code of Federal 
Regulations (44 CFR 60.3). That assessment has been completed through two coordinated 
studies: Study Part A, An Evaluation of Compliance with the National Flood Insurance 
Program Part A: Achieving Community Compliance, Monday et al., 2006, prepared by AIR 
assesses the processes for ensuring community compliance with NFIP regulations. The areas of 
inquiry include the NFIPs approach to training and technical assistance; the effectiveness of 
tools for monitoring community compliance and defining and remedying violations; the roles of 
FEMAs headquarters and regional offices as well as state floodplain management agencies in 
supporting the NFIP; the capabilities of communities to identify and address violations; and the 
appropriateness of sanctions for noncompliance. 

This study, hereafter referred to as Study Part B, prepared by Dewberry under 
subcontract to AIR, quantitatively addresses the percentage of post-Flood Insurance Rate Map 
(FIRM) buildings16  both insured and uninsured in Special Flood Hazard Areas (SFHAs)17  
that are in compliance with the NFIPs floodplain management regulations, especially those 
regulations related to construction standards. Study Part B estimates, within the areas selected, 
which floodplain management regulations have the highest and lowest rates of compliance and 
characterizes levels of compliance by type and size of community, geographical area, foundation 
type, occupancy, building type, and similar factors. 

16 

Post-FIRM buildings are those buildings constructed or substantially improved after the effective date of the 
FIRM on which the building is shown. A FIRM typically includes BFEs and other hazard information needed to 
better protect new construction from flood damage. The flood hazards presented on the FIRM determine the NFIP 
minimum floodplain management regulations applicable to the construction of the building. Flood insurance 
premiums for post-FIRM buildings are based on actuarial rates, i.e., rates based on the true risk the building is 
exposed to. 
17 

The SFHA is the area that is predicted to be inundated by the flood events having a 1-percent or greater chance of 
being equaled or exceeded in any given year. The SFHA, which is shown as either an A Zone or V Zone, is 
identified on a Flood Hazard Boundary Map or Flood Insurance Rate Map prepared by FEMA. 

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Knowledge of compliance is a crucial element of any assessment of the NFIP; without 
compliance, lives and property may be at risk, and the actuarial soundness of the NFIP 
jeopardized. By dividing the topic of compliance into two interrelated studies, AIR 
distinguished between the processes and organizations that support and enforce compliance with 
NFIP regulations and the actual compliance of buildings with NFIP construction standards. 
Although the two studies require different forms of analysis, they have not been considered in 
isolation. References to Study Part A can be found throughout this report. 

1.2. Overview of the NFIP 
The NFIP is a federal program enabling property owners in participating communities to 
purchase insurance as a protection against property losses caused by flooding. Participation in 
the NFIP is based on an agreement between communities and the federal government: if a 
community adopts and enforces a floodplain management ordinance to reduce future flood risk 
to new construction in floodplains, the federal government will make flood insurance available 
within the community as a financial protection against flood losses. 

Many federal, state, and local agencies and non-governmental organizations are involved 
in different components of the NFIP. FEMA, which is responsible for administering much of the 
NFIP, conducts flood studies, publishes the NFIP maps, and makes flood insurance available 
within communities participating in the NFIP. The objectives of the NFIP are to 1) decrease risk 
of flood losses, 2) reduce costs and adverse consequences of flooding, 3) reduce demands and 
expectations for federal disaster assistance after floods, and 4) restore and preserve natural and 
beneficial values of floodplains.18 

In cooperation with states and communities, FEMA has produced FIRMs depicting 
SFHAs for over 20,000 communities nationwide. The SFHA represents the flood that has a 1percent 
annual chance of occurring in any given year (base flood). The base flood is the national 
standard used by the NFIP and all federal agencies for the purposes of regulating development 
and requiring the purchase of flood insurance. All FIRMs include SFHAs, but the SFHAs (also 
referred to as flood zones) reflect varying degrees of analyzes. Rural communities or areas 
within communities with limited existing or potential development are typically mapped by 
approximate methods. Areas studied by approximate methods show the approximate outline of 
the SFHA and carry a Zone A flood hazard designation. While the elevation of the 1-percent 
annual chance flood is represented by the approximate Zone A boundary, the exact BFE is not 
shown in Zone A areas and is typically unknown to communities and property owners. In 
contrast, areas studied by detailed methods reflect complex hydrologic and hydraulic studies that 

These goals were reached by a consensus of FEMA and the NFIP Evaluation team in 2002 Design for the 
Evaluation of the National Flood Insurance Program. The Fourth goal is not included in statute, however. The 
primary legislatively stated purposes of the 1968 Act creating the NFIP were to Through insurance, better 
indemnify individuals for flood losses that created personal hardships and economic distress; reduce future flood 
damages through State and community floodplain management regulations; and reduce Federal expenditures for 
disaster assistance and flood control, 

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analyze flood duration, drainage area, structures, the amount of impermeable surface, and other


factors that affect flood hazards. These 
studies assign statistical probabilities to 
different size floods. This is done to 
understand what might be a common or 
ordinary flood for a particular area versus 
a less likely or severe flood for that same 
river or coastline. Flood studies 
developed using detailed methods include 
the computed elevation to which 
floodwaters are anticipated to rise during 
the base flood. 

Detailed flood studies are a vital 
part of a floodplain management program 
and provide the necessary flood 
elevations, flood velocities, and floodway 
dimensions to ensure newly constructed 
buildings are built to reduce flood 
damages to acceptable levels. This study 
focused solely on areas studied by 
detailed methods (Zones AE, VE, AH 
and AO). These areas are more 
developed and, thus, have more buildings 
at risk than in Zone A areas. In addition, 
the buildings are subject to the elevation 
requirements and more stringent 
floodplain management requirements 
than are applicable in Zone A areas. The 
detailed flood zones relevant to Study 
Part B are defined in the box on the right. 

Development may take place 
within the SFHA provided that the 
development complies with local 
floodplain management ordinances, 
which must meet the minimum federal 
requirements. Communities participating 
in the NFIP must adopt legally 
enforceable floodplain management 

DESCRIPTION OF FLOOD ZONES INCLUDED IN 
THIS STUDY 

All SFHAs are subject to inundation by the 1 percent 
annual chance flood event. 

Zone AE: Zone AE represents riverine and lacustrine 
(lake) floodplains and coastal floodplains landward of 
Zone VE. These areas have been studied by detailed 
methods including the use of hydrologic and hydraulic 
analyses to develop Base (1% annual chance) Flood 
Elevations (BFEs), accurate floodplain boundaries, and, 
at times, regulatory floodway boundaries. (Zone AE is 
used on new and revised maps in place of Zones A1A30.) 


Zone VE: Also known as coastal high hazard areas, 
these zones are mapped along the nations coastlines and 
include areas subject to additional hazards due to storm-
induced velocity wave action. BFEs derived from 
detailed hydraulic analyses are shown within these zones. 
(Zone VE is used on new and revised maps in place of 
Zones V1-V30.) NFIP regulations contain specific 
elevation and structural performance requirements for 
buildings constructed in Zone VE. 

Zone AH: SFHAs subject to shallow flooding (usually 
areas of ponding) where average depths are between one 
and three feet. BFEs derived from detailed hydraulic 
analyses are shown in this zone. 

Zone AO: SFHAs subject to shallow flooding (usually 
sheet flow on sloping terrain or ponding) where average 
depths are between one and three feet. Average flood 
depths derived from detailed hydraulic analyses are 
shown within this zone. 

Mandatory flood insurance purchase requirements apply 
as a condition of federal or federally related financial 
assistance for acquisition and/or construction of buildings 
in SFHAs of any community. 

For more detailed NFIP flood zone definitions, refer to 
44 CFR 60.3. 

measures that are compliant with 44 CFR 60.3 of the NFIP regulations. Requirements in 44 
CFR 60.3 are based on the level of mapping that FEMA has provided to the community, that is, 
whether FEMA has designated SFHAs, BFEs, a regulatory floodway, and/or coastal high 
hazards on the communitys FIRM. The regulatory floodway is the area identified on a FIRM or 

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a Flood Boundary Floodway Map19 that represents the portion of the floodplain that carries the 
majority of the flood flow and often is associated with high velocity flows and debris impact. 
The specific requirements in 44 CFR 60.3 associated with the construction in the flood zones 
relevant to Study Part B are discussed in section 1.3 below. 

1.3. NFIP Regulations for Construction in the SFHA 
Study Part B, addresses buildings located within SFHAs designated as Zones AE, VE, 
AO, or AH. The zone designation and the BFE are critical factors in determining what 
requirements apply to a building and, as a result, how it is built. Minimum federal requirements 
for Zones AE, AH, and AO are found in 44 CFR 60.3(c) of the NFIP regulations. For Zone 
VE, the minimum requirements are found in 44 CFR 60.3(e). NFIP regulations governing 
construction in the regulatory floodway are found in 44 CFR 60.3(d). The requirements for 
each of the zones and the regulatory floodway are summarized below. 

Zones AE and AH: In Zones AE and AH, all new construction and substantial 
improvements20 of residential buildings must have the lowest floor (including the basement, if 
any) elevated to or above the BFE. Nonresidential buildings in Zones AE and AH must either be 
elevated to the BFE or dry floodproofed to the BFE so that their walls are substantially 
impermeable to the passage of floodwaters. Manufactured homes must 1) be elevated on a 
permanent foundation such that the lowest floor of the manufactured home is elevated to or 
above the BFE and 2) be secured to an adequately anchored foundation system to resist 
floatation collapse and lateral movement. An adequately anchored manufactured home typically 
includes over-the-top or frame tie-downs in addition to standard connections to the foundation 
that will withstand flood and wind forces.21 

Zone AO: In Zone AO, all new construction and substantial improvements of residential 
buildings must have the lowest floor (including the basement, if any) elevated above the highest 
adjacent grade at least as high as the depth number specified in feet on the communitys FIRM 
(at least two feet if no depth number is specified). Nonresidential buildings in Zone AO must 
either be elevated or dry floodproofed to the BFE. 

Zone VE: In Zone VE (Coastal High Hazard Areas), there are four NFIP minimum 
requirements for new construction and substantial improvements (both residential and 
commercial): 1) the building must be elevated on pile, post, pier, or column foundations; 2) the 

19 

A Flood Boundary Floodway Map (FBFM) is an official FEMA map that depicts the regulatory floodway. In the 
late 1980s, FEMA began combining the FIRM and FBFM into one map, but, prior to that time, the FIRM and 
FBFM were published as two separately published products. FBFMs remain in effect in a limited number of 
communities around the country. 

20 

Substantial improvement is defined in 44 CFR 59.1 as any reconstruction, rehabilitation, addition, or other 
improvement of a structure, the cost of which equals or exceeds 50 percent of the market value of the structure 
before the start of construction of the improvement. This term includes structures which have incurred substantial 
damage, regardless of the actual repair work performed. 

21 

For more on regulations governing placement of manufactured homes, see 44 CFR 60.3[c] and [e]. 

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building must be adequately anchored to the foundation; 3) the building must have the bottom of 
the lowest horizontal structural member (LHSM) at or above the BFE; and 4) the building design 
and method of construction must be certified by a design professional. The area below the BFE 
must be built of flood-resistant materials and be free of obstructions; if enclosed, the enclosure 
must be made of lightweight wood lattice, insect screening, or breakaway walls. Use of the 
space below BFE must be confined to parking of vehicles, building access, or storage. Materials 
such as carpeting, paneling, drywall, or sheet rock are not allowed. The requirements for 
manufactured homes in VE Zones are the same as for Zone AE. 

In each of the above flood zones, all new construction and substantial improvements must 
be constructed with electrical, heating, ventilation, plumbing, and air conditioning equipment 
and other service facilities that are designed and/or located so as to prevent water from entering 
or accumulating within the components during conditions of flooding. In addition, for all new 
construction and substantial improvements, fully enclosed areas below the lowest floor that are 
usable solely for parking of vehicles, building access, or storage in an area other than a basement 
and which are subject to flooding must be designed to automatically equalize hydrostatic flood 
forces on exterior walls by allowing for the entry and exit of floodwaters. Designs for meeting 
this requirement must either be certified by a registered professional engineer or architect or 
meet or exceed the following minimum criteria: a minimum of two openings having a total net 
area of not less than one square inch for every square foot of enclosed area subject to flooding; 
and the bottom of all openings must be no higher than one foot above grade. Openings may be 
equipped with screens, louvers, valves, or other coverings or devices provided that they permit 
the automatic entry and exit of floodwaters. 

Regulatory Floodway: Within the regulatory floodway, the community is responsible for 
prohibiting encroachments, including fill, new construction, and substantial improvements of 
existing buildings, unless it has been demonstrated through hydrologic and hydraulic analyses 
that the proposed encroachment will not increase flood levels within the community or adjacent 
communities. 

The community must require permits for all development in the SFHA and ensure that 
construction materials and methods used will minimize future flood damage in accordance with 
44 CFR 60.3 of the NFIP regulations. Permit files must contain documentation to substantiate 
how buildings actually were constructed. The role of the community in ensuring, through its 
permitting and inspection process, that construction of new or substantially improved buildings 
meets the minimum NFIP regulations is crucial to the NFIPs success. 

Flood insurance and floodplain management measures are strongly linked since flood 
insurance rates for buildings built after the issuance of the initial FIRM (post-FIRM 
construction) for a community are based on the buildings risk of flooding. Most rates are 
determined based on the elevation of the lowest floor of the building in relation to the BFE. 
Generally, buildings that comply with the communitys floodplain management regulations (and 
NFIP minimum requirements) are charged the lowest rates, and those that do not comply may be 
charged much higher rates. Enforcement of floodplain management regulations by communities 
is critical for the NFIP to achieve its objectives of protecting lives and property and providing 
flood insurance within participating communities at affordable insurance rates. 

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Occasionally, as a result of willful disregard for the NFIP requirements or a lack of 
understanding of the requirements, a community may not fully enforce all of the provisions of its 
ordinance. This failure to enforce puts its participation in the NFIP in peril. FEMA imposes 
sanctions on communities for failure to enforce their floodplain management program. These 
sanctions are examined more thoroughly in Part A of the evaluation, Achieving Community 
Compliance (Monday et al., 2006). 

The regulatory standards of the NFIP discussed above are minimum standards in that 
they are generally applicable everywhere and provide a basic measure of protection. However, 
the minimum standards of the NFIP often do not provide sufficient protection from all flood 
hazards, nor do they take into consideration the effects of urbanizing watersheds on future flood 
elevations. In recognition of the limitations inherent in the NFIP minimum standards, many 
states have imposed more restrictive requirements on their communities. In addition, many 
communities have voluntarily adopted higher regulatory standards at the local level based upon 
local conditions and anticipated development. 

1.4. Scope and Limitations of Study 
High levels of compliance are vital to the NFIPs fiscal soundness, its ability to pay 
claims, and the protection of millions of structures. FEMA has established a compliance 
program, monitors compliance by NFIP communities, and takes action when it identifies 
communities that are not meeting program requirements. However, as discussed in Study Part 
A, it is not clear that FEMA or their partners in the program have sufficient resources to assess 
compliance in all communities on a regular basis. Studies Part A and B of the evaluation of 
compliance were initiated to answer core evaluation questions22 aimed at gaining an 
understanding of what levels of noncompliance exist, why they exist, and the efficacy of the 
sanctions available when noncompliance is detected. Additional coordination with FEMA and 
AIR yielded a subset series of comprehensive questions this report seeks to address. 
Specifically, Study Part B was designed to determine the level of compliance of residential and 
nonresidential buildings with minimum NFIP requirements. The study responds to the following 
questions. 

 How widespread are floodplain development violations? 
 What are the most common violations? 
 Does compliance vary in different geographic areas? 
 Does community size affect compliance? 
 Do economic factors influence compliance? 
 Does compliance vary by the source of floodingcoastal or riverine? 
These core questions were developed by the NFIP Steering Committee. The committee is comprised of a group 
of in-house FEMA staff, retired government executives, and private sector and academic experts from various 
disciplines with extensive knowledge of the history, objectives, and issues faced by the NFIP, that were convened to 
develop the candidate evaluation questions the AIR sub-studies set out to answer. 

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 Is compliance better in Community Rating System (CRS)23 communities? 
 Are communities meeting the 44 CFR 60.3 requirement to issue building permits 
for all development in the SFHA, ensure that the proposed lowest floor and asbuilt 
elevations (after construction has been completed) are at or above BFE, and 
obtain and retain documentation of design and construction methods? 
 Does compliance vary depending on the flood zone? 
 Is there a difference in compliance between buildings insured by the NFIP and those 
not insured by the program? 
 Has compliance improved over time? 
 Does the method of construction of buildings affect compliance? 
 Is there better compliance among commercial buildings, manufactured homes, or 
other residential structures? 
The study design addresses buildings meeting the following criteria. 

 Completed on or after January 1, 1990. This ensures an adequate sample of 
buildings in most communities and allows comparison of changes in floodplain 
management practices over a 14-year time period while avoiding the need for local 
officials to locate permits issued before 1990. 
 Constructed after FEMA had issued a FIRM for the community (post-FIRM 
construction). 
 Located in SFHAs that were studied by detailed methods, that is, for which FEMA 
had established BFEs or flood depths. The study does not include buildings 
constructed in approximate Zone A flood zones because development in these zones 
is subjected to fewer measurable floodplain management requirements. 
Approximate Zone A designates SFHAs for which FEMA has not conducted 
detailed hydraulic analyses and, therefore, has not provided BFEs or flood depths. 
In general, these areas were not subject, or projected to be subjected, to development 
pressure at the initiation of the communitys FIS. 
 Either insured or not insured by an NFIP flood insurance policy. 
This study focused only on buildings; it did not identify violations in other types of 
floodplain development such as mining, dredging, filling, grading, paving, or channel alterations 
and maintenance. Compliance with the NFIP regulatory requirements of these other floodplain 
development activities is critical to the success of the NFIP. Floodplain development not 
properly enforced can result in increased flood hazards and damages to existing buildings. The 
scope of this study was further limited primarily to violations; it addressed program deficiencies 
only in that it determined whether communities maintained building permits and inspection 
records. FEMAs guidance for monitoring compliance differentiates explicitly between a 

The CRS is a voluntary incentive program that recognizes and encourages community floodplain management 
activities that exceed the minimum NFIP requirements. See Section 3.3 for further information about the CRS. 

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program deficiency and a violation. A program deficiency is defined as a defect in a 
communitys floodplain management regulations or administrative procedures that impairs 
effective implementation of floodplain management regulations. A violation is defined as the 
failure of a building or other development to be fully compliant with the communitys floodplain 
management regulations. 

1.5. Organization of This Report 
The remainder of this report discusses the studys methods, survey results and 
conclusions, and recommendations evolving from this study. Section 2 discusses the methods 
used to select the communities and buildings for inclusion in the sample. It also discusses 
preparations that were made prior to the actual survey (team selection and training, contact with 
the selected communities, and the project database). Section 2 then sets forth the limitations of 
the study, describes the characteristics of the communities and buildings in the sample, and 
defines the compliance classification categories created for the study. Section 3 presents the 
study results. First, it discusses the findings regarding community record keeping and retention 
(permit files and elevation certificates and other data). Then, it presents the building 
construction survey results, by compliance classification categories and by community 
characteristics (e.g., geographic area, population, per-capita income, source of flooding, CRS 
participation) and next by building characteristic (building construction type, building usage, 
etc). Section 4 includes an overall summary and conclusions about community compliance with 
the NFIP building regulations and Section 5 offers recommendations growing out of this study. 

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2. METHOD 
2.1. Community Selection Process 
In the first stage of selection, geographic areas (referred to herein as clusters) of the 
nation were selected with large concentrations of post-FIRM buildings. Clusters were selected to 
provide geographic spread across the nation and ensure representation of most community and 
building types. This systematic sampling approach to selection of the clusters was necessary to 
ensure that sufficient structures meeting our criteria of being post-FIRM construction located in a 
detailed flood hazard area (Zone VE, AE, AO or AH) and built after January 1, 1990, were 
available within the communities to be sampled. While the exact number of structures located 
within the nations SFHAs remains unknown, almost two-thirds of the 20,000 communities in 
the NFIP have 20 or fewer policy holders. Because the available budget for the study was 
limited, clusters were chosen to maximize inference about rates of compliance within 
communities where a preponderance of NFIP post-FIRM policies are found rather than across 
the country nationally. 

In the second stage of selection, a community selection process, described in the next 
subsection, was used to develop a viable list of communities. From this list, communities were 
selected randomly to be studied. Because communities were selected randomly at the second 
stage, inferential statistics can be conducted within the sample. While we cannot define point 
estimates and confidence intervals around estimates of findings at the national level, we expect 
that our results are roughly representative of what we would expect to find among communities 
that fit the study criteria. The communities included in this study are predominantly rapidly-
growing coastal communities on the Atlantic, Gulf, and West coasts and inland communities in 
the Southwest and along the Mississippi River. Fifty communities ultimately were included in 
Study Part B. The cluster and community selection processes are discussed below. 

2.1.1. Cluster Selection Process 
Eighteen clusters were identified for potential inclusion in Study Part B, but for cost 
reasons the clusters were reduced to 10 (representing different geographic areas). Although the 
additional 8 clusters would have provided better geographic spread, they either represented areas 
with relatively small numbers of post-FIRM policies or had similar types of development as in 
the 10 clusters ultimately selected for inclusion. 

Each cluster was made up of either a metropolitan area or a group of several closely 
located counties or communities. The clusters selected were geographically and economically 
diverse and included areas with high growth rates both in terms of population and the number of 
post-FIRM policies. Although the clusters were systematically selected (to ensure the desired 
large concentration of post-FIRM buildings and diversity, and to minimize costs), a random 
process was used to select the communities sampled in the second stage of selection. The cluster 
areas selected cover states that account for 84 percent of NFIP post-FIRM policies. The 10 
cluster areas and their central nodal communities are as follows: 

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Washington/Baltimore (Loudoun Co., VA) Coastal North Carolina (Dare Co., NC)
Florida West Coast (Tampa, FL) Mid-Atlantic (New Castle Co., DE)
Florida Panhandle (Escambia Co., FL) Northern California (Contra Costa Co., CA)
Louisiana (New Orleans, LA) Mississippi River (St. Louis, MO)
Coastal Texas (Galveston, TX) Southwest (Maricopa Co., AZ)


2.1.2. Community Selection Process 
To select the communities for Study Part B, Geographic Information System (GIS) 
application methods were used to generate a list of communities within a 100-mile radius of each 
central node community identified within the clusters shown above. That effort yielded a list of 
potential communities, which was processed against FEMAs Community Information System.24 
Using the Community Information System, the community identification number, NFIP 
participation status, map type and dates, community ordinance levels, and policy information 
were added to the list. Next, the communities were categorized as participating with a map, 
participating without a map, and non-participating. This categorization yielded a subset list of 
viable candidate communities for inclusion in the study from the participating mapped 
communities. The list then was further refined by eliminating communities where post-FIRM 
buildings constructed after January 1, 1990, numbered fewer than the desired sample size. A 
breakdown of the number of communities identified within each cluster using this approach is 
shown in Table 1. All communities were selected from those included within the Participating 
Communities with Detailed SFHAs column. A comprehensive list of the communities within 
this category can be found in Appendix A. 

FEMAs Community Information System is the primary database used to record community-specific NFIP 
participation status, mapping and general insurance information. 

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TABLE 1. Breakdown of Communities in Cluster Areas 

Cluster 
Participating 
Communities 
with Detailed 
SFHAs 
Participating 
Communities 
with Only 
Approximate 
Zone A SFHAs 
Participating 
Communities 
without Maps 
Non-
Participating 
Communities 
with Maps 
Non-
Participating 
Communities 
without maps Undetermined1 Total 
California-North 129 18 27 0 12 22 208 
Coastal North 
Carolina/ Virginia 84 17 5 0 34 16 156 
Florida 
Panhandle 69 33 3 2 25 1 133 
Florida-West 
Coast 92 10 3 0 19 11 135 
Louisiana 126 47 12 0 28 13 226 
Mid-Atlantic 364 51 13 0 72 26 526 
Mississippi River 218 77 30 5 182 9 521 
Southwest 47 2 1 0 2 0 52 
Texas-Coastal 132 27 7 0 10 3 179 
Washington/ 
Baltimore 243 63 13 2 67 13 401 

1 The undetermined category includes communities with identified discrepancies between the 44 CFR 60.3 ordinance level (see Page12 for ordinance level
information) and map information in the Community Information System.


Within each cluster, seven communities were randomly selected from the participating 
communities with detailed SFHAs that had a viable sample size (more than 35 insured properties 
within Zone AE, VE, AO, or AH). While it was the intent to survey only five communities 
within each cluster area, there was a risk that the selected communities may opt not to participate 
in the study or that it might not be possible to locate the now-superseded map panel25 in effect at 
the time of construction of numerous buildings within one of the communities. The latter could 
result in an inadequate sample size for an otherwise viable candidate community because the 
BFE at the time of construction could not be verified. As discussed in Section 1.3, the BFE 
determines the required elevation of new construction; thus, identifying the BFE in effect at the 
time of construction is a key component necessary to verify compliance. Accordingly, the 
selection of the specific communities to be surveyed within each cluster was at times governed 

Depending on the size of the community or county and the scale of the map, the FIRM may consist of one or more 
individual pages, each of which is known as a panel. 

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by the completeness of the mapping records for the communities. All of the selected 
communities agreed to participate; therefore, selection of the two communities in each cluster to 
be ultimately eliminated was based first on whether there were problems in obtaining copies of 
now-superseded FIRMs for use in verifying the BFE in effect at the time of construction. Then, 
if all FIRM panels for all of the communities within a cluster could be located, two communities 
were eliminated through a random selection process. 

To protect the anonymity of the communities surveyed, the names of the specific 
communities sampled as part of Study Part B have not been included in this report. However, 
the community characteristics and a unique identification number assigned to each community 
randomly selected for inclusion in the study are shown in Table 2. The characteristics include 
the floodplain management ordinance level (44 CFR 60.3 of the NFIP regulations) that apply in 
the community, population group, per-capita income group, whether the community is subject to 
inland or coastal flooding26, and whether the community has joined the NFIPs CRS. Three of 
these characteristics are defined in the paragraphs that follow. 

NFIP regulations identify minimum requirements that communities must fulfill in order 
to join and stay in the program. The requirements that apply to a particular community depend 
on its flood hazards and level of detail of the data FEMA provides the community. The specific 
requirements are found in 60.3 and apply to communities as follows: 

 60.3(a) FEMA has not provided any maps or flood data; 
 60.3(b) FEMA has provided a map with approximate A Zones; 
 60.3(c) FEMA has provided a FIRM with BFEs; 
 60.3(d) FEMA has provided a FIRM with BFEs and a floodway; 
 and 60.3(e) FEMA has provided a FIRM that shows coastal high hazard 
areas (V Zones). 
The communities sampled have been categorized into six population groups based on the 
number of full-time residents27 residing within the community. The groups are as follows: 

 Group 1: less than or equal to 9,999; 
 Group 2: 10,000  49,999; 
 Group 3: 50,000-99,999; 
 Group 4: 100,000-499,999; 
 Group 5: 500,000-999,999; and 
26 

Coastal flooding includes flooding from any body of water subject to tidal fluctuations and includes large numbers 
of communities on estuaries. Communities classified as coastal can also be subject to flooding from rivers that are 
not associated with tidal fluctuations and may or may not include V flood zones. 

27 

Based on 2004 Census Data 

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 Group 6: 1,000,000 or greater. 
The sampled communities have also been categorized into three per-capita income 
groups. Group 1 represents annual per-capita income ranging from $10,000 to $19,999 per year; 
Group 2 represents annual per-capita income ranging from $20,000-29,999; and Group 3 
represents annual per-capita income of $30,000 or greater. 

Each surveyed community will be provided with the survey data for use in their 
floodplain management programs, and FEMA regional offices will work with the communities 
to help resolve any problems that are identified. The two reserve communities eliminated from 
the survey are shown as shaded on Table 2. 

TABLE 2. Randomly Selected Communities 

Community Applicable 60.3 Population Per-capita Flooding 
Cluster Identification No. Level Regulations 20041 Income2 Source CRS Community 
California  North NOCA-1 D Group 6 Group 3 Coastal Yes 
California  North NOCA-2 D Group 3 Group 2 Inland Yes 
California  North NOCA-3 E Group 3 Group 3 Coastal Yes 
California -North NOCA-4 D Group 3 Group 2 Coastal Yes 

California-NorthNOCA-5CGroup2Group2CoastalNoCalifornia-NorthNOCA-6DGroup2Group3InlandYesCalifornia-NorthNOCA-7CGroup3Group1InlandNo
Florida -West Coast WCFL-1 E Group 3 Group 2 Coastal Yes 
Florida -West Coast WCFL-2 E Group 2 Group 2 Coastal Yes 
Florida -West Coast WCFL-3 D Group 2 Group 1 Inland Yes 
Florida -West Coast WCFL-4 C Group 2 Group 1 Coastal Yes 

Florida-WestCoastWCFL-5EGroup2Group2CoastalYesFlorida-WestCoastWCFL-6EGroup2Group2CoastalNoFlorida-WestCoastWCFL-7EGroup2Group2CoastalNo
Florida Panhandle FL/AL-1 E Group 2 Group 3 Coastal Yes 
Florida Panhandle FL/AL-2 E Group 1 Group 3 Coastal Yes 
Florida Panhandle FL/AL-3 D&E Group 4 Group 1 Coastal No 
Florida Panhandle FL/AL-4 D Group 1 Group 2 Inland Yes 

FloridaPanhandleFL/AL-5DGroup2Group1InlandNoFloridaPanhandleFL/AL-6EGroup4Group1CoastalYesFloridaPanhandleFL/AL-7EGroup2Group2CoastalNo
Louisiana LA-1 D Group 1 Group 2 Coastal Yes 
Louisiana LA-2 C Group 2 Group 1 Coastal Yes 
Louisiana LA-3 E Group 3 Group 1 Coastal Yes 
Louisiana LA-4 D Group 4 Group 2 Inland No 

LouisianaLA-5EGroup3Group1CoastalNoLouisianaLA-6DGroup2Group1InlandYesLouisianaLA-7CGroup1Group1InlandYes
12004 US Census data 
21999 US Census data 

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TABLE 2. Randomly Selected Communities (continued) 

Community Applicable 60.3 Population Per-capita Flooding 
Cluster Identification No. Level Regulations 20041 Income2 Source CRS Community 
Mid-Atlantic DE/NJ-1 E Group 1 Group 3 Coastal Yes 
Mid-Atlantic DE/NJ-2 E Group 1 Group 3 Coastal No 
Mid-Atlantic DE/NJ-3 E Group 1 Group 3 Coastal Yes 
Mid-Atlantic DE/NJ-4 E Group 1 Group 3 Coastal Yes 

Mid-AtlanticDE/NJ-5D&EGroup4Group2CoastalNoMid-AtlanticDE/NJ-6CGroup3Group1CoastalNoMid-AtlanticDE/NJ-7EGroup2Group2CoastalNo
Mississippi River MO/IL-1 D Group 2 Group 3 Inland No 
Mississippi River MO/IL-2 D Group 3 Group 2 Inland No 
Mississippi River MO/IL-3 D Group 4 Group 1 Inland No 
Mississippi River MO/IL-4 D Group 3 Group 2 Inland No 

MississippiRiverMO/IL-5DGroup1Group2InlandNoMississippiRiverMO/IL-6DGroup2Group1InlandNoMississippiRiverMO/IL-7DGroup2Group1InlandNo
North Carolina/Virginia NC/VA-1 E Group 2 Group 1 Coastal No 
North Carolina/Virginia NC/VA-2 E Group 1 Group 2 Coastal Yes 
North Carolina/Virginia NC/VA-3 E Group 2 Group 2 Coastal Yes 
North Carolina/Virginia NC/VA-4 D Group 1 Group 1 Inland Yes 

NorthCarolina/VirginiaNC/VA-5EGroup3Group2CoastalNoNorthCarolina/VirginiaNC/VA-6D&EGroup2Group1CoastalYesNorthCarolina/VirginiaNC/VA-7DGroup3Group1InlandYes
Southwest SW-1 D Group 2 Group 1 Inland Yes 
Southwest SW-2 D Group 2 Group 2 Inland No 
Southwest SW-3 D Group 6 Group 2 Inland Yes 
Southwest SW-4 D Group 6 Group 1 Inland Yes 

SouthwestSW-5DGroup4Group3InlandYesSouthwestSW-6DGroup2Group1InlandNoSouthwestSW-7DGroup2Group2InlandYes
Texas-Coastal CTX-1 D Group 2 Group 1 Inland No 
Texas-Coastal CTX-2 D Group 4 Group 1 Coastal No 
Texas-Coastal CTX-3 C Group 1 Group 1 Coastal No 
Texas-Coastal CTX-4 E Group 1 Group 2 Coastal Yes 

Texas-CoastalCTX-5DGroup4Group2InlandNoTexas-CoastalCTX-6EGroup2Group2CoastalNoTexas-CoastalCTX-7CGroup2Group3InlandNo
Washington/Baltimore Balt/Wash-1 D Group 4 Group 3 Inland yes 
Washington/Baltimore Balt/Wash-2 D&E Group 5 Group 2 Coastal No 
Washington/Baltimore Balt/Wash-3 D&E Group 5 Group 1 Coastal No 
Washington/Baltimore Balt/Wash-4 E Group 1 Group 2 Coastal No 

Washington/BaltimoreBalt/Wash-5D&EGroup2Group2CoastalNoWashington/BaltimoreBalt/Wash-6D&EGroup3Group2CoastalNoWashington/BaltimoreBalt/Wash-7D&EGroup2Group2CoastalNo
12004 US Census data 
21999 US Census data 

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2.2. Building Selection Process 
All or most of the post-FIRM buildings (both insured and uninsured) located within the 
detailed SFHAs (Zone AE, VE, AO, or AH) of each candidate community were identified using 
two sources. Data on insured post-FIRM buildings were obtained from the NFIP Policy-in-Force 
database.28 Address records from First American Real Estate Solutions GIS database system 
were acquired to obtain comprehensive records of floodprone properties, both insured and 
uninsured.29 Uninsured buildings were included to determine if there was a correlation between 
uninsured and noncompliant buildings, that is, to test the hypothesis that owners of noncompliant 
buildings may have dropped flood insurance policies because of high flood insurance premiums 
resulting from their noncompliant status. From the comprehensive list of buildings, 35 to 45 
candidate buildings suitable for survey in each community were selected randomly. 

The list of candidate buildings was processed to eliminate duplicate buildings (e.g., units 
within the same condominium or apartment building). However, no effort was made to eliminate 
buildings within the same row of townhouses or commercial compound units, or to ascertain 
whether a given parcel of land may have been removed from the SFHA by a Letter of Map 
Revision based on Fill (LOMR-F)30 before the building on the site was constructed. 

The primary objective of this study was to determine what percentage of buildings in the 
sample were built to the requirements of the BFE and/or flood zone in effect at the time of 
construction. Accordingly, it was necessary to obtain both current as well as now-superseded 
copies of FISs and FIRMs for use in determining the BFE and/or flood zone in effect at the time 
of construction of the selected buildings. Many of the communities FIRMs were found to have 
been revised multiple times to reflect updated flood hazards. While most superseded FISs and 
FIRM panels were located, there were instances where the FIRM panels and/or the FIS report in 
effect at the time of construction could not be located and an otherwise viable pre-selected 
building was eliminated from the list of buildings to be surveyed. As was the practice with the 
selection of reserve communities, reserve buildings beyond the number that would ultimately be 
surveyed were randomly selected. This would ensure an adequate sample size even if buildings 
were eliminated because the BFE in effect at the time of construction could not be verified or 
access to the property once in the field was not possible. 

2.3. Preparation for Survey of Buildings 
In preparation for the survey of buildings, survey team members were selected and 
trained, the selected communities were contacted, and a database was created and pre-populated 
with information already available on the buildings. 

28 

The Policy-in-Force database retains FEMAs flood insurance policy records. 

29 

First American Real Estate Solutions is a private firm that offers flood map reading and zone determination 
services to mortgage lenders, insurance companies, etc. 

30 

A LOMR-F is an official revision, by letter, to an effective NFIP map. A LOMR-F provides FEMA's 
determination concerning whether a structure or parcel has been elevated on fill above the BFE and excluded from 
the SFHA. The letter becomes effective on the date sent. 

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2.3.1. Team Member Selection and Training 
Four Association of State Floodplain Managers Certified Floodplain Managers (CFMs)31 
from Dewberrys staff were assigned to this study. In addition, Study Part B was conducted 
using a single surveyor who performed the elevation surveys in all the cluster/communities 
studied. This surveyor passed the CFM exam midway through completion of the field work for 
this study. 

In December 2004, Dewberry held specialized training for the project staff. The training 
gave the CFMs and surveyor an overview of the project and its objectives, and provided them 
with guidance on the measurements to be recorded and potential violations they were likely to 
encounter. 

2.3.2. Community Coordination 
Several weeks before each community visit, the surveyed communities were contacted to 
identify the community officials involved with the NFIP, verify their willingness to participate, 
and establish dates for a community visit. This initial contact was followed by a formal letter 
explaining the objectives of the study and purpose of the visit, and transmitting a list of the 
randomly selected buildings to be surveyed. The letter encouraged the community officials to 
notify their residents of the survey by placing an article in their local newspaper or through 
written notification sent to individual property owners. A template press release was enclosed to 
be used at the communitys discretion. 

The letter sent to each community requested that they make the permit file, including at a 
minimum the following documents, available for each building on the accompanying list during 
the site visit: 

 Building permits 
 Elevation Certificates or other records of the as-built elevations of the buildings 
 Records of floodproofing of nonresidential commercial buildings (where applicable) 
 Information on the placement of fill 
 Records of all variances requested (both denied and approved) 
 Certification by a registered professional engineer or architect of the building design 
and methods of construction 
Most of the communities visited were helpful in reviewing the list of buildings randomly 
pre-selected for survey in advance of the meeting and in identifying problems with the list. 

Program developed and administered by the Association of State Floodplain Managers to recognize individuals 
who have demonstrated their understanding of floodplain management. Certification has three requirements: an 
individual must pass a standardized exam; obtain a specified number of continuing education credits every two 
years; and pay a fee for initial certification and recertification every two years. 

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Problems with the lists were relatively common. First, dates of construction in the dataset 
proved incorrect in some instances. Where available, on-line tax assessor websites served as an 
excellent resource for verifying construction dates, but they were not available for all 
communities. Second, many communities had experienced annexations and de-annexations. A 
building now within a selected communitys corporate limits may not have been so at the time of 
construction, and vice versa. Permit records and Elevation Certificates were thus unavailable. 
Although the community could falsely identify a building as outside their jurisdiction at the time 
of construction or as too old (built before January 1, 1990) in order to avoid detection of gross 
violations, the survey team felt confident of the integrity of the community officials they dealt 
with most notably because many were very candid about violations they were aware of within 
their community. 

To account for the possibility of having to eliminate randomly selected buildings from 
the sample due to the problems noted above, building address lists sent out to communities 
during later months of the study included as many as 45 buildings to ensure an adequate sample 
would be achieved without the need for further coordination with the communities, which could 
result in delays and in a non-random sample. All selections of the buildings to be surveyed were 
done randomly from the validated list reviewed by community officials. 

2.3.3. Project Database 
A database was created for this project to process and record the key data collected 
during the study. Prior to the community visit, the database was populated with address records 
including flood zone, building type, occupancy, date of construction, policy information, etc., 
obtained from the Policy-in-Force database and from First American Real Estate Solutions. Its 
first use was in developing the list of randomly selected buildings to be surveyed discussed in 
section 1.3.2. 

The database was formatted to receive pertinent data from the communitys permit files 
and all data collected during the building elevation survey and inspection including, but not 
limited to, the following: 

 Flood zone in effect at time of construction 
 BFE at time of construction 
 Date building permit was issued and the date of construction 
 Occupancy type (i.e., residential, nonresidential, manufactured housing, etc.) 
 Building type (i.e., slab-on-grade, split level, basement, etc.) 
 Elevation Certificate and inspection records 
 Elevation of the lowest floor as recorded in the communitys permit files as well as 
the field-verified elevations as recorded by the study survey team 
 Existence and size of flood openings in the foundation 
 Location of electrical and mechanical equipment 
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The database also contains a record of the specific noncompliant findings and 
photographs linked to the survey data captured for each building. 

2.4. Survey Approach 
The survey approach included an administrative survey  an inspection of the 
communitys permit files  and a field survey. The objective of the administrative survey was to 
review community record keeping and retention as it relates to the construction of buildings in 
SFHAs, and the objective of the field survey was to determine if buildings built within the 
surveyed communities had been built to minimum NFIP standards. 

2.4.1. Administrative Survey 
The CFM was deployed several days before the surveyor to meet with the appropriate 
community officials and review the floodplain development permit files. As discussed in 
Section 1.2, a minimum of 35 suitable buildings were pre-selected for survey in each 
community. During the background research to identify the location of each building and the 
BFE in effect at the time of construction, some of the buildings were eliminated because of 
errors in the source databases or the inability to locate the map panel in effect at the time of 
construction or through verification by the community that the building was too old or outside 
its jurisdiction. All buildings that remained within the sample (typically 25-35) were 
administratively surveyed by the CFM through inspection of the communitys permit files 
during the community visit. The CFM recorded relevant information on the availability of 
documents retained by the community including floodplain development permit applications, 
Elevation Certificates or other elevation data sources, floodproofing certificates, variances 
issued, etc. The CFM also recorded the date of construction and FIRM zone and BFE in effect 
on the date of construction as identified in the available permit records. 

If no elevation certificate or comparable elevation data were on file for a building, a 
physical survey of the building was performed. From the remaining pool of administratively 
surveyed buildings for which elevation data existed, enough buildings were selected to ensure 
that physical surveys were conducted for a total of 25 buildings within the community. For 
example, if the permit file did not include elevation data for 15 out of the 35 pre-selected 
buildings, the 15 buildings without existing elevation data were physically surveyed, and 10 of 
the remaining buildings for which elevation data did exist in the permit files were randomly 
chosen to verify the accuracy of the data in the permit files. This approach ensured that elevation 
data were captured on at least 1,250 buildings. 

2.4.2. Elevation Surveys and Building Inspections 
For the elevation surveys and building inspections, a two-person survey team was 
deployed to each of the communities selected. The survey team consisted of a CFM and a 
surveyor equipped with dual-frequency Global Positioning System (GPS) receivers as well as 
conventional survey equipment. In preparation for the field surveys, the survey team queried the 
National Spatial Reference System (NSRS), maintained by the National Geodetic Survey (NGS) 
at www.ngs.noaa.gov, to obtain the Data Sheets that describe the available vertical control 

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monuments within the selected communities. This information was essential to identify GPS 
control points within the communities and ensure that the monument with the best vertical 
control was used to establish elevations. 

All surveys conducted by the survey team were performed with rigorous GPS survey 
procedures accurate to 5 centimeters (2 inches) at the 95-percent confidence level. The surveyor 
selected a minimum of three target points per building to be surveyed: (1) lowest floor elevation, 
e.g., bottom of front door or top of foundation from which 8 feet is subtracted to the basement 
floor where applicable, (2) lowest adjacent grade point, and (3) highest adjacent grade point. 
Elevations were also shot of any visible electrical and mechanical equipment and any accessory 
buildings on site. Where access was possible, the CFM briefly looked around the building and 
into the backyard to see if there was evidence of a full or walk-out basement. This inspection by 
the CFM also served to validate that the correct reference levels were captured. (Community 
surveyors commonly do not understand the correct reference levels to be surveyed, which is a 
major reason why some Elevation Certificates are in error) The remainder of the survey 
included recording the building diagram number, foundation type, and estimated square footage 
of each building and taking digital photos of the front and back of each building. In addition, the 
CFM inspected each building for the following noncompliance issues and recorded his or her 
findings in the project database: 

 Buildings with enclosures below BFE being used for purposes other than parking, 
access, or limited storage 
 Enclosure walls below the lowest floor of an elevated building in a Zone VE that do 
not appear to be free of obstruction or appear to have non-breakaway walls 
 Attached garages not properly wet floodproofed 
 Nonresidential buildings not elevated or floodproofed 
 The presence of fill in coastal high hazard areas (Zone VE) 
 Size, location, and design of flood openings in Zone AE not meeting the minimum 
NFIP criteria 
 Manufactured homes improperly anchored or elevated 
Dewberry then determined if each building was constructed so that its top of bottom 
floor elevation (Zone AE), LHSM (Zone VE), and electrical and mechanical are at or above the 
BFE. 

2.5. Limitations 
This study does not reflect a statistical sample of communities or a truly random sample 
of post-FIRM buildings; thus, the percentages included in this report do not represent national 
rates of compliance. The percentages represent rates of compliance for only the 1,591 buildings 
administratively surveyed and 1,253 buildings physically surveyed. The cost of surveying a 
random sample of communities and buildings sufficient to draw inference statistically within and 
across communities nationally would have been prohibitive. Instead, as discussed in subsection 

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2.1.1, 10 cluster areas were chosen that generally represent the various types of flooding 
experienced by NFIP communities and various geographical areas. These clusters were located 
primarily in the areas with the preponderance of NFIP post-FIRM policies. Five communities 
were randomly selected from each cluster node, and 25 buildings were randomly selected within 
each community. The sample has the following limitations: 

 The sample has limited geographic spread. The study selected the 10 clusters in the 
areas of the nation that had the most post-FIRM policies; these communities are 
generally coastal communities on the Atlantic, Gulf, and West coasts and inland 
communities in the Southwest and along the Mississippi River. 
 The sample is not proportional. Only seven of the communities surveyed are in 
Florida even though that state has about half of all post-FIRM insured buildings. 
Further, the distribution of foundation types may not reflect the distribution of 
foundation types in the NFIP policy base. 
 Only developing communities were sampled, and only communities with more than 
25 post-FIRM buildings built after 1990 were sampled. As a result, smaller slow-
growing communities generally are not represented in the sample, and, thus, the 
study can draw no conclusions on the levels of compliance in these communities. 
However, a very high percentage of the post-FIRM construction is occurring in 
larger, fast-growing communities as well as smaller tourist destinations along the 
coasts. 
 Substantial improvements have not been included within the sample. To fully 
address compliance within post-FIRM construction, substantial improvements would 
be included. However, they have not been addressed by this study because of the 
difficulty of obtaining and verifying construction/improvement dates. 
In spite of these limitations, the data collected through this study allow important 
observations to be made about compliance in post-FIRM buildings within communities that fit 
the study criteria.32 These data help address quantitatively, if not with statistical results that 
generalize nationally, one facet of compliance. That facet is compliance with the construction 
standards for individual buildings. The data collected are essential for evaluating the 
effectiveness of promoting, monitoring, and enforcing the NFIP requirements as discussed in An 
Evaluation of Compliance with the National Flood Insurance Program Part A: Achieving 
Community Compliance, Monday et al., 2006 (also referred to throughout this report as Study 
Part A). These data when used in conjunction with the information collected through Study Part 
A help identify deficiencies in the compliance program and will help direct focus towards areas 
where resources are most needed. 

The communities selected are predominantly rapidly-growing coastal communities on the Atlantic, Gulf, and 
West coasts and inland communities in the Southwest and along the Mississippi River. Buildings included in the 
study are post-FIRM buildings constructed after January 1, 1990 in detailed SFHAs. Buildings both insured and 
uninsured by a flood insurance policy are included. 

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2.6. Study Sample Characteristics 
This study was limited to 10 cluster areas and five communities within each cluster. As a 
result, 50 communities were included in the sample. Within those communities, a total of 1,591 
buildings were surveyed administratively; that is, their floodplain development permit files were 
reviewed. Physical inspections and Elevation Certificates were prepared for 1,253 of the 1,591 
total buildings. The key characteristics of the communities, as well as the buildings reviewed as 
part of Study Part B are identified below. 

As discussed in subsection 2.1.2, two reserve communities identified within each cluster 
were eliminated. Communities were selected for elimination if there were problems in obtaining 
copies of now-superseded FIRMs for use in verifying the BFE in effect at the time of 
construction. If all FIRM panels for all communities within a cluster could be located, a random 
selection process was used. 

Table 3 provides a breakdown of the number and percentage of communities included in 
Study Part B based on community characteristics including: source of flooding (coastal or 
inland), level of 44 CFR 60.3 regulations adopted, CRS status, population, and per-capita 
income. Also included in Table 3 for comparison are the percentages of these characteristics for 
all NFIP communities. While the percentages found in this study may not correspond with the 
national percentages, they are representative of the distribution of floodprone buildings 
nationwide. Five coastal states  Florida, Texas, Louisiana, California, and New Jersey  
account for nearly 70 percent of all policies. These five states plus five other coastal states 
account for 81 percent of all policies. Floridians have about 41 percent of all policies  but more 
than half of these policies are in 20 of the states 437 participating communities. Outside of 
Florida, the median policy count per community is eight, but this number disguises the fact that 
many communities have no policies. Among participating communities, for example, 3,452 had 
no policies in August 2004. Almost two-thirds of the 20,000 communities in the NFIP have 20 
or fewer policyholders. One percent of participating communities have almost 65 percent of all 
policies.33 

Source: FEMAs Community Information System, 2004 

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TABLE 3. Community Characteristics 

Percentage of Percentage of 
Communities-Study B Communities-
Characteristic Sample Nationwide1 
Source of Flooding 
Coastal 62.0% 7.9% 
Inland 38.0% 84.1% 
Unknown 0.0% 7.9% 
Level of 44 CFR 60.3 Regulations 
60.3 c (communities with BFEs but no floodway) 8.0% 17.3% 
60.3 d (communities with BFEs and floodways) 46.0% 78.3% 
60.3 d and e (communities with BFEs, floodways, and coastal VE zones 10.0% 1.3% 
60.3 e (communities with coastal VE Zones only) 36.0% 3.1% 
CRS Community 
Yes 52.0% .05% 
No 48.0% 99.95% 
Population (Full-time Residents) 
Less than or Equal to 9,999 26.0% N/A 
10,000 -49,999 30.0% N/A 
50,000 -99,999 18.0% N/A 
100,000 -499,999 16.0% N/A 
500,000 -999,999 4.0% N/A 
1,000,000 or greater 6.0% N/A 
Per-capita Income 
$10,000 -$19,999 32.0% N/A 
$20,000 -$29,999 46.0% N/A 
$30,000 or greater 22.0% N/A 

Source: FEMA Community Information System 2004 
N/A -Data Unavailable 
1The percentages shown are representative of the subset of communities in the NFIP with detailed flood hazards (Zones AE, AO, AH, or 
VE). 11,581 communities were included in this subset during the sample selection phase of this study performed in 2004. 

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Table 4 provides a breakdown of the number and percentage of buildings included in 
Study Part B based on the following characteristics: insured or uninsured, located in each of the 
different applicable flood zone designations, and representing different building types/uses. 

TABLE 4. Building Characteristics 

Characteristic Number of Buildings Percentage of Buildings 

Insured Versus Uninsured 

Uninsured 272 21.7%
Insured 981 78.3%


Flood Zone 

AE 1,046 83.5% 
AH 38 3.0% 
AO 103 8.2% 
VE 66 5.3% 

Building Type/Usage 

Single Family Detached 920 73.4% 
Duplex 14 1.1% 
Manufactured Home 48 3.8% 
Townhouse/ Row House 90 7.2% 
Multi-Family (Condo/ Apartment) 48 3.8% 
Commercial/Industrial 118 9.4% 
Multi-Use Building 10 0.8% 
Public Building 5 0.4% 

The National Flood Insurance Programs Market Penetration Rate: Estimates and Policy 
Implications (Dixon, et al., 2006), prepared as part of the NFIP Evaluation, estimates overall 
market penetration rates of insured single family homes in SFHAs at 50-52 percent. A greater 
percentage of insured buildings were found in this study, but because these findings are the 
byproduct of a different research design, they are not necessarily suggestive of greater rates of 
market penetration within our study area than might be found nationally. The Market 
Penetration study found that the number of insured buildings was higher in the South and West 
than in the Northeast and Midwest, in communities subject to coastal flooding than to inland 
flooding, and in buildings with newer mortgages, which is perhaps supportive of our findings of 
the number of insured buildings within our sample. 

The percentages of buildings within the different flood zones found here also are in line 
with the percentages of NFIP policies in force. Slightly fewer than 2 percent of NFIP policies 
are in Zone VE, about 68 percent are in Zone AE, and the remaining 30 percent are in other 
zones, primarily those outside of the SFHA.34 

As of September 30, 2004. 

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2.7. Compliance Classification Categories 
When this study was initiated, it was anticipated that, in general, compliance with basic 
elevation requirements would be good but that many problems with items like enclosures, 
mechanical and utility equipment, flood openings, etc., would be encountered. Local officials 
have the greatest misunderstandings concerning these items, and the regulations governing them 
are technically the most difficult to apply and enforce. Further, even if these items are compliant 
when a building is constructed, they can be modified later by the property owner without the 
community's knowledge. In terms of damage reduction, however, the real cost savings result 
from ensuring that the first full finished floor is elevated above the BFE. As the tables presented 
in this report demonstrate, the percentages of fully compliant buildings in many of the cluster 
areas are low; however, a fair evaluation needs to distinguish between those types of violations 
that are and are not likely to result in significant damage to a building during the 1 percent 
annual chance flood. 

As discussed in Section 1.3, the NFIP regulations set forth requirements that new and 
substantially improved buildings be constructed in ways that will minimize or prevent damage. 
Communities that guide development following the standards of the NFIP have seen positive 
results  new buildings and neighborhoods typically experience less damage from flooding.35 
This report does not address specifically the costs or consequences associated with 
noncompliance with specific NFIP building requirements, which would require additional 
modeling.36 The data presented, however, are provided in a format that will allow the user to 
distinguish between violations that are likely to result in the building experiencing costly 
damages and those that are likely to result in minimal flood damages and costs. For example, a 
slab-on-grade building 2 feet below the BFE will likely sustain at least 20- to 30-percent damage 
in value in a 1 percent annual chance flood.37 In contrast, a building with an air conditioning 
condenser 2 feet below the BFE, but otherwise fully compliant, will sustain damages limited to 
the cost of replacing the air conditioning unit, which has a useful life of only 7 to 10 years. To 
allow for detailed analysis of the survey findings, noncompliance found within the communities 
and buildings surveyed has been broken out in detail. The compliance category classifications, 
which were developed in coordination with FEMA, allow for distinction between violations, are 
as follows. 

35 

Based on NFIP evidence that buildings built to the minimum NFIP standards suffer 80 percent less damage than 
unprotected buildings. Source: www.fema.gov/plan/prevent/floodplain/How_the_NFIP_works.shtm. 

36 

See the Costs and Consequences of Flooding and the Impact on the National Flood Insurance Program 
(Sarmiento and Miller, 2006) study shows the financial impact of NFIP flood plain management guidelines by payer 
under different levels of flood insurance penetration. 

37 

Based on depth damage curves used by FEMA to set actuarial flood insurance rates. 

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 Fully Compliant  Used for buildings with no compliance issues. 
 Noncompliant-Within 6 inches  Used for any building with the lowest floor below 
the BFE by 6 inches or less and no other compliance issues. When other compliance 
issues were present, the Noncompliant-Within 6 Inches and Other Issues category 
was used (see below). 
 Noncompliant-Within 6 Inches and Other Issues  Used for buildings with the 
finished floor or LHSM below the BFE by 6 inches or less where there are other 
compliance issues present such as lowest electrical and mechanical equipment 
(LEM) below the BFE, insufficient openings, etc. 
 Noncompliant-Openings Issue  Used for buildings that do not meet the requirement 
that the flood openings have a net area of not less than one square inch for each 
square foot of enclosed area or where the bottom of the opening was not within one 
foot of grade. 
 Noncompliant-LEM Issue  Used for buildings with electrical and mechanical 
equipment below the BFE. Most often this applied to heating, ventilation, and air 
conditioning (HVAC) units, either air conditioning condensers or heat pumps, with 
the top of the slab or platform below the BFE. 
 Noncompliant-Multiple Issues. Used when multiple compliance issues apply. For 
instance, where the LEM were below the BFE and insufficient flood openings 
applied. The Noncompliant-Multiple Issues category was not used if the finished 
floor or LHSM was below the BFE. A description of the issues encountered with 
each individual building was recorded in the Comments section of the project 
database. 
 Noncompliant-Finished Enclosure  Used to identify enclosed areas used as 
habitable living space below the BFE of Zone VE construction (Building Diagram 
Types 5 and 6).38 The threshold set for this classification was that the enclosed 
finished space comprised more than 300 square feet but did not exceed more than 
one third of the square footage of the bottom level of the building. Finished 
enclosures exceeding one third of the square footage were classified as having their 
finished floor below the BFE and classified as Noncompliant-LHSM (see below). 
 Noncompliant-Finished Space  Used to identify enclosed areas used as habitable 
living space below the BFE in Building Diagram Type 7 (building elevated on full-
story foundation walls with a fully enclosed area below the elevated floor). This 
category was applicable in this study to buildings where the lowest finished floor 
was designed for parking, access, or storage but where a portion exceeding one third 
FEMA uses building diagram types to distinguish between different construction methods. Building Diagrams 5 
includes all buildings elevated on piers, posts, piles, columns, or shear parallel walls with no obstruction below the 
elevated floor. Diagram 6 includes all buildings elevated on piers, posts, piles, columns, or shear parallel walls with 
a full or partial enclosure below the elevated floor. See subsection 3.2.2 (page 45) for full list of the building 
diagram types. 

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of the total bottom floor had been converted to habitable living space. When in 
doubt as to the use of the space, this categorization was not applied. 

 Noncompliant-LHSM Issue  Used for coastal construction (Zone VE) with its 
LHSM more than 6 inches below the BFE. This category takes precedence and is 
used if the LHSM is more than 6 inches below the BFE regardless of whether other 
compliance issues also exist. The Noncompliant-Multiple Issues category is not 
used if the LHSM is more than 6 inches below the BFE. 
 Noncompliant-In Floodway  Applied to buildings located within the floodway 
shown on the effective FIRM at the time of construction. 
 Noncompliant-Lowest floor  Used for buildings with their lowest floor more than 6 
inches below the BFE. This category takes precedence and is used if the lowest 
floor is more than 6 inches below the BFE regardless of whether other compliance 
issues also exist. The Noncompliant-Multiple Issues category is not used if the 
finished floor is more than 6 inches below the BFE. 
 Undetermined  Applied when compliance could not be verified. Within this study, 
this classification was applied to 3 buildings where the GPS elevation data were lost 
and to 10 buildings located in AO Zones where the natural (pre-fill) ground 
elevation could not be obtained. The requirement in AO zones is that the building be 
above the highest adjacent grade of the natural ground elevation by an amount equal 
to the AO depth shown on the FIRM at the time of construction. 
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3. STUDY RESULTS 
Participating communities are monitored individually on a regular, though fairly 
infrequent basis, and there have been studies of the performance of buildings under certain 
circumstances and in certain locales. But the overall questions of how well the NFIP is being 
administered across the United States, and what proportion of flood-prone buildings is built to 
the programs standards have been unanswered. It is those questions that this study has sought to 
address. 

The data collected allow important observations to be made about compliance within 
areas where current and future flood risk is greatest and thus where success in compliance is 
most important. These surveys were concentrated primarily, but not exclusively, in many of the 
nations most vulnerable communities (e.g., several in the New Orleans area) as well as in 
communities with high concentrations of policyholders across the country, such as coastal 
Florida and Texas. 

The data gathered help address quantitatively, compliance with record-keeping 
requirements and construction standards for individual buildings. Section 3.1 presents the study 
results as regards community record keeping and retention. Section 3.2 presents the study results 
as regards the elevation surveys; it presents the results first by compliance classification 
categories (Section 3.2.1) and then by community and building characteristics (Section 3.2.2). 
The final section, Section 3.2.3, extrapolates select findings from the sample to communities and 
structures in the 10 clusters areas as a whole. 

The tables and discussion in the sections that follow include point estimates derived from 
the sample of communities and buildings included in this study. These point estimates are based 
in some cases on limited numbers of communities or buildings that meet the criteria being 
evaluated. As a result, lower and upper confidence limits are provided for the point estimates to 
give the reader an understanding of the precision of the estimation. A large range between the 
lower and upper confidence interval signifies considerable uncertainty. For certain categories of 
compliance being evaluated, setting meaningful confidence intervals was not possible due to 
very small numbers of communities or buildings that meet the criteria being evaluated. In these 
instances, conclusions about rates of compliance outside the sample can not be drawn. All 
estimates provided in Study Part B are provided at the 95 percent confidence interval. 

3.1. Community Record Keeping and Retention 
Part of the field visit to each community included a review of the communitys permit 
files. The permit file review served three purposes: 1) It allowed the study team to verify that the 
community was issuing building permits for all floodplain development, ensuring that the lowest 
floor elevation proposed and as-built were at or above BFE, and obtaining and retaining 
documentation of design and construction methods; 2) It allowed the study team to verify, when 
records were present, that the building met the sample criteria of having been constructed after 
January 1, 1990; and 3) It allowed the study team to determine whether the CRS communities in 
the sample had more complete permit files than the non-CRS communities. 

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The CRS, initiated in 1990, is an NFIP program that encourages communities to perform 
floodplain management activities that exceed the NFIPs minimum requirements by rewarding 
such communities with discounted flood insurance. Any community participating in the NFIP 
may join the CRS provided that the community is in full compliance with the NFIPs minimum 
requirements and that it makes a commitment to perform a minimum number of additional 
floodplain management activities. As a basic requirement, CRS communities must keep permit 
files that include Elevation Certificates for all structures built, substantially damaged, or 
substantially improved in the SFHA since the community entered the CRS. The CRS classes 
(one through nine, with Class 10 for not participating in the CRS and Class 1 for the highest 
level of participation) are based on 18 creditable activities, organized under four categories: 
Public Information, Mapping and Regulations, Flood Damage Reduction, and Flood 
Preparedness. Further information on the CRS is available at 
http://www.fema.gov/business/nfip/crs.shtm and in An Evaluation of Compliance with the 
National Flood Insurance Program Part A: Achieving Community Compliance, Monday et al., 
2006. 

3.1.1. Permit Files 
As illustrated in Table 5, permit files were available for greater than 76 percent of the 
randomly selected buildings in 35 of the communities surveyed. In contrast, three communities 
were able to produce fewer than 25 percent of the permit files for the buildings selected for 
survey. 

TABLE 5. Permit Files 

Number of Communities within Percentage of Total Communities within 
Percentage of Permit Files Available Percentage Range Percentage Range 

0  25% 3 6.0% 
26% -50% 4 8.0% 
51% -75% 8 16.0% 
76% -100% 35 70.0% 
Total 50 100.0% 

As discussed in Section 2.3.2, each community was contacted by phone and in writing in 
advance of the field visit. In addition, each was provided with a copy of the list of the randomly 
selected buildings to be surveyed. In most instances, the communities reviewed the list in 
advance, ensured that the selections complied with the Study Part B criteria,39 and had the permit 

Buildings eligible for survey as Part of Study B were located within a detailed SFHA and built after January 1, 
1990. 

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files pulled and ready for the survey teams visit. However, there were communities that made 
no preparation for the visit. For example, in one community, the CFM contacted the community 
three times while in the community for a week but did not gain access to the files because the 
community stated that they were too shorthanded to pull the files. 

Within many of the communities, the survey team found that files containing the 
comprehensive set of records for flood prone buildings they sought to review did not exist. 
While most of the records were typically in the possession of the Zoning or Building 
Department, it was common for the team to be sent to the Engineering Department for elevation 
data and as-built plans. The survey team also encountered instances where the files had been 
archived off site and were discarded in accordance with a records management schedule used 
within the community, which may have contributed to low percentages of permit files being 
available in some communities. 

The review of each permit file addressed the following issues: 

 Was a building permit issued? If so, when was it dated? 
 Was a fill permit issued? 
 If the building was in the floodway, was there a No-Rise Certificate40 on file? 
 Was there an Elevation Certificate or the equivalent on file? If so, when was it 
dated? 
 What was the date of the map panel, BFE, and flood zone at the time of 
construction? 
 What was the lowest floor elevation, lowest adjacent grade, floodproofed elevation, 
etc., as recorded on the Elevation Certificate? 
 Was a variance issued? If so, was justification provided? 
 Was a post-construction inspection performed? 
 Were the design and construction methods certified? 
As illustrated in summary Table 6, communities participating in the CRS had a better 
record of making permit files available to the survey team. This may be the result of the focus 
that is placed on good record keeping and retention by the CRS. The overall average for non-
CRS community permit file availability was 66.5 percent compared to 86.5 percent for CRS 
communities. 

Certification, presented prior to construction, that hydrologic and hydraulic analyses have been conducted and that 
these analyses demonstrate that the proposed encroachment will not increase flood levels within the community. 

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TABLE 6. CRS versus Non-CRS Community Permit File Availability 

Confidence Interval 
Total Number of Permit Files Percentage of Permit Files 
Community Type Reviewed Available1 Lower Upper 

Non-CRS Communities 756 66.5% 55.4% 81.4%
CRS Communities 835 86.5% 81.4% 93.8%


1

95-Percent statistical confidence interval for estimate 

3.1.2. Elevation Certificates 
The availability of a FEMA Elevation Certificate or equivalent elevation data within the 
permit file for the randomly selected buildings was of particular interest, primarily because, as 
discussed in Sections 2.1.2 and 2.4.1, the studys approach to reducing the number of buildings 
to be physically surveyed included the review of the permit files for the existence of an Elevation 
Certificate or equivalent elevation data. When no Elevation Certificate or comparable elevation 
data was on file for a building, a physical survey of the building was performed. From the 
remaining pool of administratively surveyed buildings for which elevation data existed, enough 
buildings were randomly selected to ensure that physical surveys were conducted for a total of 
25 buildings within the community. For example, if the permit file did not include elevation data 
for 15 out of the 35 pre-selected buildings, the 15 buildings without existing elevation data were 
physically surveyed, and 10 of the remaining buildings for which elevation data did exist in the 
permit files were randomly chosen to verify the accuracy of the existing survey. 

Overall, Elevation Certificates or equivalent elevation data often were missing from 
community permit files, as illustrated by Table 7. 

TABLE 7. Breakdown of the Number of Elevation Certificates or Equivalent Elevation 
Data 

Percentage of Elevation Certificates or 
Equivalent Available 
0 -25% 
Number of Communities within 
Percentage Range 
6 
Percentage of Total Communities within 
Percentage Range 
12.0% 
26% -50% 14 28.0% 
51% -75% 7 14.0% 
76% -100% 23 46.0% 
Total 50 100.0% 

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Elevation Certificates or equivalent elevation data were available more widely among the 
sample of communities participating in the CRS but did not reach rates expected for CRS 
communities given the requirement for obtaining and retaining Elevation Certificates for all 
floodplain development after participation in CRS begins. All of the CRS communities included 
in this study except one have participated in the NFIP since the early 1990s and thus should have 
been able to produce close to 100 percent of the Elevation Certificates requested in accordance 
with their commitment through CRS, which requires that they obtain and retain Elevation 
Certificates for all floodplain development.41 A breakdown of availability of Elevation 
Certificates or equivalent elevation data for CRS versus non-CRS communities is shown in 
Table 8. It should be noted that since this table does not distinguish between true Elevation 
Certificates and equivalent as-built elevation data retained in the community permit file, the 
number of Elevation Certificates found within the sample are fewer than shown below. 

TABLE 8. Availability of Elevation Data for CRS versus Non-CRS Communities 

Confidence Interval 
Total Number of Permit Percentage of Permit 
Community Type Files Reviewed Files Available1 Lower Upper 

Non-CRS Participant 756 44.2% 32.6% 57.8%
CRS Participant 835 72.1% 64.2% 83.0%


1 95-percent Statistical confidence interval for estimate 

3.2. Elevation Survey Results 
This Section of the report summarizes and characterizes the elevation survey results. 
Section 3.2.1 presents the elevation survey results by compliance classification categories 
(defined in Section 2.7). This section includes some analysis and possible explanations for the 
findings seen within the 1,253 buildings surveyed, but does not attempt to draw any inferences 
about violations that might be found in similar communities or structures found within the cluster 
areas they represent. Section 3.2.2 discusses elevation survey results by community and 
structure characteristics (discussed in Section 2.6) and attempts to answer the key study 
questions presented in Section 1.4 of this report. The questions are also presented again in 
Section 3.2.2 for the readers reference. Within Section 3.2.2, the results of statistical tests of 
significance used to draw comparisons between community and structure characteristics are 
presented. Notably, for example, the analysis performed examines if statistically significant 
evidence can be found that better compliance exists within communities participating in the CRS 
than in non-CRS communities. All comparisons found within this section, unless otherwise 
noted, are based on statistical analysis and tests conducted at the 5-percent significance level (95


Twenty six of the communities surveyed participate in the CRS. Nine of the communities joined CRS in 1991, 
12 joined in 1992, 2 joined in 1993, 2 joined in 1994, and the one joined in 2001. One additional community 
included in this study was accepted into the CRS in October 2005; however, since the date the community joined is 
after the date they were assessed, it is evaluated as a non-CRS community throughout this study. 

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percent confidence interval). The final section, Section 3.2.3, uses statistical tests to extrapolate 
findings from the sample to communities and structures in the 10 clusters areas as a whole. 

3.2.1. Results by Compliance Classification Categories 
The percentages of compliant and noncompliant buildings identified in the sample of the 
1,253 buildings physically surveyed as part of Study Part B are presented in Table 9 and 
discussed below. A more detailed table showing a breakdown by cluster, community, and 
compliance category, is provided in Appendix B. 

TABLE 9. Compliance Results 

Confidence Interval1 
Compliance Category Percentage Lower Upper 
Fully Compliant 63.1% 58.0% 69.9% 
Noncompliant-Low Floor 5.3% 3.4% 7.4% 
Noncompliant-LHSM 0.2% N/A2 N/A2 
Noncompliant-Basement 1.9% 0.0% 4.2% 
Noncompliant-Within 6" 1.4% 0.6% 2.1% 
Noncompliant-Within 6" and Other Issue(s) 1.9% 0.9% 3.0% 
Noncompliant-Finished Enclosure (Building Type 5 and 6) 1.3% 0.5% 2.1% 
Noncompliant-Finished Space Issue (Building Diagram 7) 1.1% 0.0% 2.3% 
Noncompliant-Flood Opening Issue 9.3% 6.2% 12.6% 
Noncompliant-LEM Issue 9.3% 6.0% 13.0% 
Noncompliant-Multiple Issues 3.8% 2.1% 5.4% 
Noncompliant-Located within Floodway 0.3% N/A2 N/A2 
Undetermined 1.0% 0.0% 2.2% 

195-Percent statistical confidence interval for estimate. 

2Insufficient number of data points to set meaningful confidence intervals. 

Fully Compliant  Of the buildings surveyed, 63.1 percent (791) were found to be in full 
compliance with all of the building requirements of the NFIP. The 95 percent confidence 
interval for this estimate runs from 58.0 percent to 69.9 percent. This means that were we to 
repeatedly survey other communities or buildings within these clusters, 95 percent of the time we 
would find the percent of fully compliant buildings would be between 58.0 and 69.9 percent. 

Noncompliant - Lowest floor Violations  Of the buildings surveyed, 7.2 percent (90) 
had their lowest floors more than 6 inches below BFE. The 7.2 percent is comprised of the 
following: 

 Noncompliant  Lowest floor (Zone AE): Sixty-six (5.3 percent) of the buildings in 
the sample had their lowest floor more than 6 inches below BFE. The confidence 
interval for this estimate runs from 3.4 percent to 7.4 percent. The majority of the 
violations are found in single family detached residential homes located in Zone AE. 
In several instances, elevated buildings with non-compliant enclosures were included 
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 in this category. The lowest floor elevation in most of these buildings is 1 to 3 feet 
below BFE. These buildings generally are subject to high flood insurance rates. 
 Noncompliant LHSM (Zone VE): Three (0.2 percent) of the buildings found in the 
sample had their LHSM more than six inches below BFE42 . 
 Noncompliant  Basement: Twenty four (1.9 percent) of the buildings within the 
sample have basements below BFE. Sixteen of these noncompliant basement 
buildings are in one subdivision. The basements in this subdivision are generally 1 
to 3 feet below BFE. Further investigation into this community revealed that Letter 
of Map Revision requests based on fill (LOMR-F)43 applications were submitted to 
FEMA both prior to and after the construction of the subject subdivision. The FEMA 
response letters to the request to remove the area from the SFHA by LOMR-F were 
denied and identified widespread compliance problems within the community. 
Specifically, the response letters identified 17 buildings with basements built below 
the BFE, eight of which were determined to be located within the floodway. It is 
unclear which, if any, of the buildings noted in the letters described above and within 
the sample overlap. Nonetheless, the community has a pattern of noncompliance 
that has been identified on more than one occasion. 
The flood depths that would be expected during the 1 percent annual chance flood do 
not appear to be high enough within the buildings sampled to result in overtopping 
or failure of the basement walls or floors. Nonetheless, the flood insurance 
premiums on these building will reflect their exposure to damages. Because of 
limitations on basement coverage, the rates for noncompliant basements are much 
lower than for buildings without a basement with lowest floor violations at the same 
elevation. 

Noncompliant - Lowest Floor Violations within 6 Inches of BFE and Noncompliant 
within 6 Inches and Other Issues  Of the buildings in the survey, 3.3 percent (41) have their 
lowest floor 6 inches or less below BFE44 . Most of these buildings are only 1-2 inches below 
BFE. These probably are not intentional violations of the regulations and may be errors on the 
part of the surveyor that established the elevation at the time of construction. The following 
factors must be considered: 

 For flood insurance rating purposes, these buildings are rounded up and rated as 
being at BFE. 
42 

Upper and lower confidence levels are not provided due to the small number buildings in the sample found within 
the compliance category. 

43 

A LOMR-F is an official revision, by letter, to an effective NFIP map. A LOMR-F provides FEMA's 
determination concerning whether a structure or parcel has been elevated on fill above the BFE and excluded from 
the SFHA. The letter becomes effective on the date sent. 

44 

1.4 percent (17) buildings were found to have their lowest floor within 6 inches of the BFE and 1.9 percent (24) 
buildings were found to be have their lowest floor within 6 inches of the BFE and other compliance issues. 
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 Many of these violations may result from surveyor error and may have been thought 
by the community to be compliant buildings. 
 Some of the differences may be due to how the surveyor and/or community 
interpolated between cross sections in establishing the BFE and how Dewberry 
interpolated those same elevations. It is very difficult to read the BFE from the flood 
profile to 0.1- or 0.2-foot accuracy. 
 Dewberry is confident that their GPS elevation surveys are accurate to  5 cm or 
about 2 inches at the 95 percent confidence level; however, it is unclear what 
assumptions can be made about the accuracy of local surveyors. Further discussion 
on elevation surveys is included in subsection 2.6.4. 
These buildings point out the need for accurate surveys as well as the advisability of 
constructing buildings above BFE rather than trying to place the top of the floor at BFE as 
builders appear to have done in several of the communities surveyed. The NFIP encourages 
communities to regulate development beyond the minimum NFIP standards through programs 
such as the CRS. In addition, some states also require that their communities regulate to a higher 
standard for certain aspects of floodplain management. Nineteen states have stricter building 
construction requirements than does the NFIP. The most common additional standard is 
freeboard (requiring new buildings to be elevated higher than the BFE). Typically, one to two 
feet of freeboard is applied. This additional protection has multiple benefits including: lowering 
flood insurance premiums,45 allowing for errors that may be introduced by inaccurate 
interpretation of flood profiles, benchmarks, and surveying errors, as well as providing added 
protection against increased flood levels brought about by future development. 

Noncompliant Buildings with Finished Enclosures below BFE (Building Diagram 
Type 5 and 6)46  Of the buildings surveyed, 1.3 percent47 (16) had finished enclosures below 
BFE. This study distinguished between enclosed areas used as habitable living space below the 
BFE of Zone VE post, pile, or column construction and buildings elevated on full-story 
foundation walls below the elevated floor (Building Diagram Type 7). The finished enclosure 
classification was applied to pile and column buildings (Building Diagram 5 and 6) built to Zone 
VE standards. Within our sample, these buildings typically had the majority of the area under 
the elevated floor reserved for parking but in each case had an enclosed finished room with non-
flood resistant materials and furnishings. 

45 

Flood insurance premiums for post-FIRM buildings are actuarial, meaning they are based on the known risk the 
building is exposed to. Post-FIRM buildings base the risk on the elevation of the lowest finished floor in relation to 
the BFE. The higher the floor is above the BFE, the lower the rate. 

46 

Building Diagrams 5 includes all buildings elevated on piers, posts, piles, columns, or shear parallel walls with no 
obstruction below the elevated floor. Diagram 6 includes all buildings elevated on piers, posts, piles, columns, or 
shear parallel walls with a full or partial enclosure below the elevated floor. See subsection 3.2.2 (page 45) for a full 
list of the building diagram types. 

47 

The confidence interval for this estimate runs from 0.5 percent to 2.1 percent. 

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Noncompliant Buildings with Finished Space below BFE (Building Diagram Type 7) 

 Of the buildings surveyed, 1.1 percent48 (14) had finished enclosures below BFE. As noted 
above, this study distinguished between finished enclosed areas found within Zone VE 
construction and buildings elevated on full-story foundation walls below the elevated floor. The 
Finished Space classification applied in this category is applicable to Diagram 7 buildings 
(buildings elevated on full-story foundation walls with a partially or fully enclosed area below 
the elevated floor). The walls of the enclosures in this category are subject to hydrostatic and 
hydrodynamic forces. The buildings within the sample placed in this category typically had a 
garage and adjacent fully finished room with non-flood-resistant materials such as carpeting, 
wall board (drywall or sheet rock), and household furnishings. These types of violations can be 
hard to identify definitively in the field, and it is possible that some finished enclosures were 
designated as unfinished by the survey team. When the survey team was uncertain as to the use 
of the space, they assumed the space was used for storage only and did not recognize the room as 
finished space. 
Noncompliant - Openings Issue  Of the buildings surveyed, 9.3 percent (117) do not 
meet the flood openings requirements at 44 CFR 60.3(c)(5). The 95 percent confidence interval 
for this estimate runs from 6.2 percent to 12.6 percent. The openings requirement was added to 
the regulations in the 1986 revision and was not incorporated into community ordinances until 
the late 1980s or early 1990s. It is possible that some buildings without openings were built in 
compliance with the community ordinance in effect at the time of construction. Some 
observations on openings within the survey are as follows: 

 Buildings with Insufficient Openings: Seventy-two of these buildings have openings 
but the number or size of the openings is insufficient to meet the 1-square-inch-per1-
square-foot criteria. Many of these buildings have 50 to 90 percent of the required 
area and fall within the factors of safety built into the requirement. 
 Coastal AE Zones: Although the NFIP encourages Zone VE type construction in 
coastal AE Zones subject to wave impacts, openings are required in breakaway walls 
built in a coastal Zone AE. 13 of the noncompliant buildings identified by this study 
as having insufficient openings are pile and column buildings that appear to be built 
to Zone VE standards in Zone AE. One subdivision that contains five of these 
buildings has since been re-mapped as Zone VE. These buildings may have been 
built to Zone VE standards in anticipation of the re-mapping. While these buildings 
are noncompliant, they were observed to have performed well under Zone VE 
flooding conditions during Hurricane Ivan (Robinson, 2005). 
 Stem Wall Foundations: Stem wall foundations (also called raised slabs) do not 
require openings since they are back-filled to above the BFE. In the field, it is 
difficult to distinguish these buildings from crawl space buildings. As a result, 
Study Part B may have identified buildings of this foundation type as noncompliant. 
However, because most of the openings violations found were the result of 
The confidence interval for this estimate runs from 0 percent to 2.3 percent. 

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inadequate opening size, it is anticipated that the misclassification will have little to 
no impact on the percentage of buildings in the category. 

 Attached Garages: Sixteen of the buildings have attached garages with their floors 
below BFE and without openings. The slab for the living area of these buildings is 
at or above BFE, but to meet the requirements of local building codes in many states, 
the garage floor has to be 6 or more inches lower. Many of these garage floors are 
approximately 6 inches below BFE. If these buildings had compliant openings, the 
openings would be above the BFE to meet the 1 foot above grade requirement and 
would thus not serve to allow the free flow of flood waters during the 1 percent 
annual chance flood as intended by the openings requirement. 
 Buildings Openings that are Too High: Eighteen buildings have openings that are 
more than 1 foot above the lowest adjacent grade. Some of these may, in fact, be 
openings to allow air flow in lieu of flood waters. In other instances, the problem 
may be in how the lot was graded and landscaped after the construction was 
completed. 
 Older Buildings: Many of the buildings with no openings were built between 1990 
and 1992 when communities were just adopting the requirement. The requirement 
may not have been included in the community ordinance or not well understood by 
local officials and builders. 
Although these buildings are violations of the local ordinance, many are unlikely to 
sustain significant damage during a 1 percent annual chance flood.49 For the walls to collapse 
due to hydrostatic pressure, there generally would have to be a difference of several feet between 
the floodwaters outside the building and those inside the buildings, or there would have to be 
high-velocity floodwaters. It is unlikely that many of the buildings found within the sample 
would suffer severe damage under base flood conditions. Further, many of the buildings 
surveyed either have enough openings to be within the factors of safety of the requirement or 
have garage doors that will leak enough to equalize the hydrostatic pressures. 

Noncompliant - Electrical and Mechanical Equipment (LEM) Issue  Of the 
buildings surveyed, 9.3 percent (117) have electrical and mechanical equipment below the BFE. 
The confidence interval for this estimate runs from 6.0 to 13.0 percent. In nearly all cases, these 
were HVAC units, either air conditioning condensers or heat pumps, with the top of the slab or 
platform below the BFE. These units are designed to be outside in the weather and can take a 
certain amount of moisture but not inundation of their electrical motors. In rating flood 
insurance premiums, HVAC equipment generally is not considered. 

 The majority of these violations are HVAC units placed on concrete pads on the 
ground next to slab buildings. These HVAC units are generally 6 inches or less 
below the BFE. These units will probably survive a base flood with little or no 
Solid walls can collapse if floodwaters get too deep. To prevent collapse the enclosure must have openings to 
allow floodwaters to enter and exist, thus automatically equalizing hydrostatic flood forces on the walls. 

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damage. The reason for the large number of violations may be that communities are 
verifying that the slab of the building is at the proper elevation but not inspecting the 
property to ensure that the HVAC equipment is installed above the BFE. HVAC 
contractors generally install HVAC units late in the construction process. The 
contractor places a pre-fabricated pad on the ground and installs the HVAC unit on 
top of that pad. Because the pad is typically placed at natural ground level rather 
than at a level consistent with the slab of the building, the HVAC unit is situated 
below BFE. Generally, many of these HVAC units could be made compliant with a 
wheelbarrow full of gravel placed under the concrete pad. 

HVAC units that are only a few inches below the BFE may not sustain damage. 
Besides being weather resistant, the HVAC unit itself is elevated slightly above the 
pad, and the lower part of the unit generally consists of sealed coils. Electrical 
motors that can be damaged are generally at the top of the unit. HVAC units 
generally have a limited economic life and can be replaced at reasonable cost. In 
some climates, damage to HVAC units may result in residences being uninhabitable 
until the unit is repaired or replaced. 

 The other violations found were generally HVAC units placed on the ground next to 
other types of foundations. These units are often 1 to 3 feet below BFE and will 
sustain significant damages during a base flood. 
Noncompliant - Building located within the Floodway  Four buildings within the 
sample were found to be located within the floodway50 . All four were located in one community. 
Two of the buildings were located within the same subdivision, and all four buildings were 
located along the same flooding source. Three had their lowest finished floor above BFE, and 
the fourth had its lowest finished floor within 6 inches of BFE. Three out of the four buildings 
also had Elevation Certificates and permits available within the community file. The dates of 
construction spanned from 1995 to 2000. During this time span, the community maps in effect 
included the published FIRM and a separately published Flood Boundary Floodway Map 
(FBFM) that depicted the boundaries of the floodway. It cannot be stated with any certainty, but 
the study team believes that the FBFM panels may not have been in use at the community. In the 
late 1980s, FEMA discontinued the practice of creating separately published FIRMs and FBFMs 
and began combining the two maps into one product, the FIRM. This combining of the two 
maps was done after more than two years of review and discussion of the NFIP map products by 
a task force comprised of representatives from the major map user groups. The maps for the 
community were not revised and put into the new map format until 2002, well after most 
communities FIRMs and FBFMs had been combined. It is speculated that this could have 
contributed to confusion about the FBFM and resulted in it not being used. Based on the few 
occurrences of buildings found to have been built within the floodway, it is surmised that 

Upper and lower confidence levels not provided due to the small number buildings in the sample found within the 
compliance category. 

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communities are generally doing an adequate job of keeping new development out of the 
floodway. 

3.2.2. Results by Community and Building Characteristics 
Section 3.2.2 characterizes levels of compliance by community characteristics 
(geographic area, population, per-capita income, source of flooding, CRS participation, flood 
zone, insured versus uninsured, date of construction, construction method, and building 
type/usage). The results are analyzed in an effort to answer the following questions: 

 Size or Type of Community: Can any conclusions be drawn about the types or sizes 
of the communities that have higher and lower compliance rates? 
 CRS: Are rates of compliance higher in CRS communities? Are there explanations 
for any differences between CRS and non-CRS communities other than their 
participation in the CRS? 
 Geographic Areas: Are there regional differences in levels of compliance? Do some 
parts of the nation appear to have lower or higher levels of compliance than others? 
 Flooding Source: Does coastal construction have higher or lower rates of compliance 
than buildings subject to other flooding sources? 
 Foundation Types: Are there differences in rates of compliance for different types of 
building foundations? 
 Occupancy Types: Are there marked differences in the rates of compliance for single 
family versus multi-family and commercial/industrial buildings? 
 Age of the Building: Has the level of compliance increased over time? 
Included below is a discussion of the compliance findings by community characteristics 
across all cluster areas. 

Geographic Area  The 10 clusters selected for this study are located primarily in the 
areas with the preponderance of NFIP post-FIRM policies and include primarily coastal 
communities on the Atlantic, Gulf, and West coasts and inland communities in the Southwest 
and along the Mississippi River. The geographic areas and the clusters and states they include 
are shown in Table 10. 

TABLE 10. Geographic Areas and Their Clusters and States 

Geographic Area Cluster States 
Atlantic Coast 
Gulf Coast 
Inland Mississippi River 
West Coast 
Mid-Atlantic, Washington/Baltimore, Coastal 
North Carolina/Virginia 
Florida-West Coast, Florida Panhandle, 
Louisiana, Coastal Texas 
Mississippi River 
California-North 
New Jersey, Delaware, Maryland, Virginia, North 
Carolina 
Florida, Alabama, Louisiana, Texas 
Illinois, Missouri 
California 
Inland Southwest Southwest Arizona 

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Our results show that geography does matter. Our analysis suggests that rates of 
compliance are better in the Southwest and lower on the West Coast. When looked at on a 
cluster by cluster basis, better rates of compliance were found in the Southwest and Washington-
Baltimore cluster and lower rates of compliance were found in the California-North, Coastal 
Texas, and Florida Panhandle clusters. It is speculated that these differences in rates of 
compliance are attributable to the prevailing building construction method found within the 
region. Generally higher rates of compliance were observed in communities with primarily slab-
on-grade construction such as that found in the Southwest and Washington-Baltimore clusters 
and lower rates in communities that use various types of elevated foundations such as were 
found in the California-North, Coastal Texas, and Florida Panhandle clusters. 

TABLE 11. Compliance Comparison by Geographic Region 

Total No. of 
Surveyed Fully 
Confidence Interval 
Non Compliant 
(All 
Confidence Interval 
Geographic Region Buildings Compliant1 Lower Upper Categories)1 Lower Upper Undetermined2 

Atlantic Coast 379 70.7% 61.2% 80.2% 29.3% 19.8% 38.8% 0.0% 
Gulf Coast 501 59.1% 50.7% 67.6% 33.7% 32.4% 49.3% 7.2% 
Inland Mississippi River 124 58.9% 20.9% 99.4% 41.1% 0.6% 79.1% 0.0% 
West Coast 125 52.8% 16.7% 88.9% 42.7% 11.1% 83.3% 4.5% 
Inland Southwest 124 71.0% 41.7% 93.8% 23.3% 6.2% 58.3% 5.7% 

195-Percent statistical confidence interval for estimate 

2Insufficient number of data points to set meaningful confidence intervals. 

Population  For analysis purposes, this study places communities into groups based on 
their permanent resident population as found on the Census Bureau website. The data were 
stratified by population to determine whether larger communities have better rates of compliance 
than smaller communities. The rates of fully compliant buildings range from an average of 57.4 
percent in the smallest communities (population below 9,999) to a high of 86.3 percent in the 
larger communities (population ranging from 500,000 to 999,999). Table 12 compares 
community compliance by population range. We found little evidence of a strong relationship 
between the size of the community and the number of compliant buildings. It should be noted 
that many tourist destinations are included in the overall sample; thus, the population included in 
Census is not a true indicator of the communities actual size. Rather, it reflects only the 
population of full-time, year-round residents. Given this fact, no definitive conclusions or 
explanations for the possible differences are offered about the impact of community size on 
compliance within the sample. 

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TABLE 12. Community Compliance by Population 

No. Communities 
in Population 
Total No. of 
Surveyed Percent Fully 
Confidence Interval 
Percent 
Noncompliant 
Confidence Interval 
Population Range Range Buildings Compliant1 Lower Upper (All Categories)1 Lower Upper 

Below 9,999 13 329 57.7% 46.70% 68.78% 42.3% 31.22% 53.30% 
10,000-49,999 15 370 62.2% 50.66% 73.72% 37.8% 26.28% 49.34% 
50,000-99,000 9 226 68.8% 49.60% 87.96% 31.2% 12.04% 50.40% 
100,000-499,999 8 203 61.3% 47.07% 75.43% 38.8% 24.57% 52.93% 
500,000-999,999 2 51 86.2% N/A2 N/A2 13.8% N/A2 N/A2 
Over 1,000,000 3 74 60.9% N/A2 N/A2 39.1% N/A2 N/A2 

195-percent statistical confidence interval for estimate. 

2N/A -Number of data points are insufficient to set meaningful confidence intervals. 

Per-capita Income  For the purposes of this study, communities were placed into three 
groups based on their per-capita income as found on the Census Bureau website: 1) per-capita 
income less than $19,999; 2) per-capita income $20,000 to $29,999; and 3) per-capita income 
$30,000 or higher. The data were stratified by per-capita income to determine whether 
communities with more economic resources have better compliance. As shown in Table 13, the 
study found that rates of fully compliant buildings are strikingly similar across all per-capita 
income categories identified for this study. However, many of the communities in the Study Part 
B sample are tourist destinations and, thus, per-capita income may not be truly indicative of the 
community tax base and resources. The number of communities within the sample that are 
participating in the CRS provides further evidence of the resources and commitment to 
floodplain management of the communities in the sample that may not be fully evident without 
looking at other variables in conjunction with per-capita income. 

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TABLE 13. Compliance by Communities Per-Capita Income 

Percent 
Per Capita Income No. Communities 
Total No. of 
Surveyed Percent Fully Confidence Interval 
Noncompliant 
(All Confidence Interval 
Group in Income Range Buildings Compliant1 Lower Upper Categories)* Lower Upper 

Group 1: Per-Capita 
Income Less Than 
$19,999 16 405 64.3% 52.4% 76.1% 35.7% 23.9% 47.6% 

Group 2: Per-Capita 
Income $20,000 to 
$29,999 23 553 63.0% 54.2% 71.9% 37.0% 28.1% 45.8% 

Group 3: Per-Capita 
Income $30,000 or 
Higher 11 270 60.8% 46.5% 75.1% 39.2% 24.9% 53.5% 

195-Percent statistical confidence interval for estimate 

Source of Flooding  Each NFIP community carries a classification in FEMAs 
Community Information System as being subject to either inland or coastal flooding. Coastal 
flooding includes flooding from any body of water subject to tidal fluctuations and includes large 
numbers of communities on estuaries. For example, Albany, New York is a coastal community 
since the Hudson River is tidal within the city limits. Communities classified as coastal can also 
be subject to flooding from rivers that are not associated with tidal fluctuations. It should be 
further noted that coastal communities may or may not include V flood zones. V Zones are 
areas that are inundated by tidal floods with velocity waters and breaking waves. The 
classification of each community was further validated through the 44 CFR 60.3 level of 
regulations field in the Community Information System or, where absent, through the flood 
hazard information present on the FIRM for the community. 

Generally, our analysis showed that no significant difference exists in the rate of 
compliance between buildings affected by coastal versus inland flooding. At the onset of this 
study, it was surmised that a greater occurrence of lowest floor violations would be found in 
buildings subject to inland flooding than in buildings subject to coastal flooding. This 
assumption was made based on the complexity of determining the BFE along riverine flooding 
sources and of elevating the foundation to the proper height. BFEs along the coasts and lakes 
and in ponding and shallow flooding areas (AH and AO Zones) are printed on the FIRM in 
parentheses below the flood zone designation and, thus, not subject to interpretation. On the 
other hand, BFEs along river channels typically must be interpolated using the published flood 
profile.51 Using flood profiles can be difficult. While this study did not find evidence that the 
fraction of buildings with lowest floor violations in coastal versus inland flooding sources was 
significantly different, it is nonetheless speculated that some of the violations found may be due 

A flood profile is a graph showing the relationship of water surface elevations to a specific location, the latter 
generally is expressed as a distance above a mouth of a stream or confluence. 

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to how the surveyor and/or community interpolated between cross sections in determining the 
BFE. 

It is also believed that lowest floor violations may have resulted from the use of unstable 
bench marks by the local surveyors. Most land surveyors cannot afford the time to determine or 
use the most accurate benchmark as their starting point (base station) for Elevation Certificate 
surveys. Instead, to keep costs to a minimum, surveyors normally select any benchmark that is 
nearest to the property to be surveyed. Accuracy to them is less important than selecting 
benchmarks based on proximity and convenience of use; to do otherwise would remove their 
profit incentive. This is not a violation of professional ethics but is standard practice. FEMAs 
own Elevation Reference Marks are notorious for being inaccurate and unstable, and, therefore, 
they are no longer being used on new Digital FIRMs. When a surveyor starts from an elevation 
that is erroneous, the Elevation Certificates elevation of lowest floor, lowest adjacent grade, 
highest adjacent grade, etc., will also have errors, even if the most accurate conventional or GPS 
survey procedures are used to extend control from the benchmark to the structure being 
surveyed. 

A second observation made about the difference in percentages of noncompliant 
buildings in coastal versus inland areas, albeit not statistically significant, is that there is a higher 
occurrence of problems with flood openings in the coastal sample. As discussed in Section 2.5, 
contributing to the higher number in coastal areas is the number of buildings in coastal Zone AE 
built to Zone VE standards. In addition, a variety of foundations are used in coastal communities 
because of the variations in flood depth, which may result in more problems with flood openings 
in these areas than in areas where slab foundations are the norm. Table 14 compares compliance 
of buildings subject to inland and coastal flooding sources. 

TABLE 14. Compliance of Buildings Subject to Inland versus Coastal Flooding 

Community Type 
No. of 
Communities 
Represented 
Total No. of 
Surveyed 
Buildings 
Percent Fully 
Compliant1 
Confidence 
Interval 
Lower Upper 
Percent 
Noncompliant 
(all 
Categories)1 
Confidence 
Interval 
Lower Upper Undetermined2 
Coastal 31 779 59.9% 53.1% 66.8% 39.7% 33.2% 46.9% 0.4% 
Inland 19 449 68.4% 56.5% 79.3% 29.5% 20.7% 43.5% 2.1% 

195-Percent statistical confidence interval for estimate. 

2Insufficient number of data points to set meaningful confidence intervals. 

Community Rating System  As discussed in Section 3.1.2, all of the CRS communities 
included in this study have participated in CRS since the early 1990s except one which joined in 
2001. As a result, at the start of this study the team expected to find better rates of compliance 
among communities participating in the CRS than in those not participating in the program. The 
percentage of fully compliant structures within the group of CRS and non-CRS communities, 
however, are strikingly similar (62.2 as opposed to 64.1 percent, respectively), and, thus, there is 
no evidence to support that compliance is better or worse in CRS than in non-CRS communities. 

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However, there is significant evidence to suggest that fewer lowest floor and LHSM violations 
are found in the CRS communities as compared to non-CRS communities. 

Also of interest was the number of violations found in one of the individual CRS 
communities. One community has a low CRS classification,52 but within the community, the 
survey team identified numerous problems including five lowest floor violations, five finished 
enclosures, problems with flood openings, etc. In contrast, there were five CRS communities 
that had 90 percent or more of their buildings in full compliance with all of the NFIP 
requirements. A comparison of the number and percentage of fully compliant structures within 
the CRS communities versus the non-CRS communities in the sample is shown in Table 15. 

TABLE 15. Compliance of CRS Communities and Non-CRS Communities 

Communities Type 
No. of 
Communities 
Represented 
Total No. 
of 
Surveyed 
Buildings 
Percent Fully 
Compliant1 
Confidence Interval 
Lower Upper 
Percent 
Noncompliant 
(all 
Categories)1 
Confidence 
Interval 
Lower Upper Undetermined2 
CRS 26 648 62.2% 53.0% 70.1% 36.60% 29.9% 47.0% 1.20% 
Non-CRS 24 605 64.1% 55.7% 73.2% 35.00% 26.8% 44.3% 0.9% 

195-Percent statistical confidence interval for estimate. 

2Insufficient number of data points to set meaningful confidence intervals. 

Flood Zone  Generally our analysis showed a significantly better rate of compliance in 
Zone AO than in other flood zones. Elevations associated with Zone AO are represented on the 
FIRM as whole foot elevations. All new construction and substantial improvements of 
residential buildings must have the lowest floor (including the basement, if any) elevated above 
the highest adjacent grade at least as high as the depth number specified in feet on the 
communitys FIRM (at least two feet if no depth number is specified). As discussed above, it is 
theorized that the existence of a whole foot flood depth or elevation that is clearly identified on 
the FIRM, may increase the accuracy of the flood elevation determined and placement of fill or 
the lowest floor. The Zone AO buildings found within our sample were primarily slab-on-grade 
construction on filled pads and predominantly located in the Southwest and Coastal Texas. Slab-
on-grade construction is one of the easiest construction methods for which to determine the 
proper lowest floor elevation. While on a whole there is no evidence of significant differences in 
rates of compliance other than in AO zones, there is mild evidence to suggest that VE Zones 
have a higher fraction of buildings with LHSM violations than found in the other flood zones. 
An overall summary that breaks down the sample by flood zone and compliance is included 
below. 

A low CRS classification as defined here is a classification between 5 to 7. To protect the anonymity of the 
community, the specific classification for NOCA-1 is not provided here. 

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TABLE 16. Building Compliance by Flood Zone 

Flood Zone 
AE 
Total No. of 
Buildings 
Surveyed 
1,046 
Percent Fully 
Compliant1 
61.9% 
Confidence Interval 
Lower Upper 
58.6% 69.3% 
Percent 
Noncompliant-
All Categories1 
37.1% 
Confidence Interval 
Lower Upper 
30.7% 41.4% 
Undetermined2 
0.2% 
AH 38 65.8% 24.3% 98.4% 34.2% 1.6% 75.7% 0.0% 
AO 103 78.6% 74.7% 98.9% 14.6% 1.1% 25.3% 10.7% 
VE 66 57.6% 29.2% 79.1% 42.4% 20.9% 70.8% 0.0% 
Total 1253 

195-Percent statistical confidence interval for estimate. 

2Insufficient number of data points to set meaningful confidence intervals. 

Insured versus Uninsured  As discussed in Section 2.2 of this report, the study team 
acquired address information from First American Real Estate Solutions for the purpose of 
obtaining a comprehensive set of addresses of buildings located within the detailed SFHAs 
within the Study Part B community sample. These addresses then were processed against 
addresses found in FEMAs BureauNet Policy-in-Force database to identify those structures 
covered and not covered by an active flood insurance policy. Including both insured and 
uninsured buildings within the sample was important because through this verification of 
compliance, FEMA sought to ascertain if flood insurance may have been dropped for structures 
where serious violations may have resulted in high premiums. Marginally significant evidence 
was found of a relationship between compliance and uninsured buildings. Table 17 shows the 
percentage of insured and uninsured buildings broken down into compliant, noncompliant, and 
undetermined categories. 

TABLE 17. Building Compliance by Insured versus Uninsured 

Structure 
Type 
Total No. 
Surveyed 
Fully 
Compliant1 
Confidence Interval 
Lower Upper 
Noncompliant 
(All Categories)1 
Confidence Interval 
Lower Upper Undetermined2 
Insured 981 63.6% 53.8% 69.5% 36.4% 30.5% 46.2% 0.0% 
Uninsured 272 58.8% 46.5% 68.3% 41.2% 31.7% 53.5% 0.0% 

195-Percent statistical confidence interval for estimate. 

2Percentage total small to be shown or to set meaningful confidence intervals. 

Date of Construction  Study Part B looks at the number of building constructed from 
1990 to 2004 by compliance category. Table 17 compares compliance category by date of 
construction during three segments of this time period: 1990 to 1995, 1996 to 2000, and 2001 to 
2004. The analysis showed a significant increase in the percentage of fully compliant buildings 
from the earliest to the most recent time period. While a decline in the percentages of buildings 
with basement and lowest-floor violations can be seen in Table 18, statistical analysis of the data 

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did not demonstrate a significant trend of improvement over time. The specific improvement in 
the number of basement violations can be explained by the fact that 16 of the 24 total basement 
violations are located in one subdivision built during the time period 1990-1995 in community. 

TABLE 18. Building Compliance by Date of Construction 

Date of 
Construction Confidence Interval 
Date of 
Construction 
Confidence 
Interval 
Date of 
Construction Confidence Interval 
Compliance Category 1990-19961 Lower Upper 1996-20011 Lower Upper 2001-20051 Lower Upper 
Fully Compliant 53.1% 48.5% 66.2% 66.2% 57.4% 71.2% 71.3% 58.2% 77.8% 
Noncompliant-LEM Issue 
Noncompliant-Multiple 
Issues 
Noncompliant-Flood 
Opening Issue 
10.9% 
4.1% 
13.0% 
9.0% 
3.3% 
9.1% 
24.1% 
17.0% 
23.5% 
9.7% 
3.2% 
7.1% 
9.0% 
3.5% 
8.4% 
19.5% 
12.6% 
18.4% 
7.6% 
4.0% 
8.0% 
3.8% 
1.6% 
4.8% 
15.1% 
14.0% 
24.6% 
Noncompliant-Within 6" 
Noncompliant-Within 6" 
and Other Issue(s) 
1.6% 
2.3% 
0.8% 
4.9% 
8.9% 
14.3% 
1.1% 
2.1% 
0.8% 
0.6% 
8.1% 
8.4% 
1.2% 
0.8% 
0.0% 
0.0% 
21.0% 
7.6% 
Noncompliant-Basement 
Noncompliant-Finished 
Enclosure 
Noncompliant-Finished 
Space Issue 
Noncompliant-In 
Floodway 
4.1% 
1.1% 
2.1% 
0.9% 
0.0% 
0.0% 
N/A2 
N/A2 
55.2% 
20.0% 
N/A2 
N/A2 
0.7% 
1.2% 
0.9% 
0.2% 
0.0% 
0.8% 
N/A2 
N/A2 
33.8% 
11.1% 
N/A2 
N/A2 
0.8% 
1.6% 
0.8% 
0.4% 
0.0% 
0.0% 
N/A2 
N/A2 
22.0% 
20.2% 
N/A2 
N/A2 
Noncompliant-LHSM 0.5% N/A2 N/A2 0.2% N/A2 N/A2 0.0% N/A2 N/A2 
Noncompliant-Low Floor 5.7% 2.7% 16.7% 5.8% 7.1% 14.0% 3.2% 0.0% 18.0% 
Undetermined 0.7% N/A* N/A* 1.6% N/A2 N/A2 0.4% N/A2 N/A2 

195-Percent statistical confidence interval for estimate. 

2Percentage total small to be shown or to set meaningful confidence intervals. 

Building Construction Method  Eight building diagrams are used by FEMA to 
distinguish between construction methods under the NFIP. These classifications are applied to 
ensure uniformity in the preparation of Elevation Certificates and for validating building 
elevation information and the appropriate insurance premium rate. Descriptions of the building 
types in each diagram follow: 

 Diagram 1  All slab-on-grade single-and multiple-floor buildings (other than split-level) 
and multi-story buildings either detached or row type (e.g., townhouses); with or without 
attached garage. 
 Diagram 2  All single- and multiple-floor buildings with basement (other than split-
level) and multi-story buildings with basement either detached or row type (e.g., 
townhouses); with or without attached garage. 
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 Diagram 3  All split-level buildings that are slab-on-grade either detached or row type 
(e.g., townhouses); with or without attached garage. The distinguishing feature that sets 
Diagram 3 apart from Diagram 4 is the bottom floor (excluding garage) is at or above 
ground level on at least one side. 
 Diagram 4  All split-level buildings (other than slab-on-grade), either detached or row 
type (e.g., townhouses); with or without attached garage. The distinguishing feature that 
sets Diagram 4 apart from Diagram 3 is the bottom floor (basement or underground 
garage) is below ground level (grade) on all sides. 
 Diagram 5  All buildings elevated on piers, posts, piles, columns, or shear parallel walls. 
No obstruction below the elevated floor. 
 Diagram 6  All buildings elevated on piers, posts, piles, columns, or shear parallel walls 
with full or partial enclosure below the elevated floor. 
 Diagram 7  All buildings elevated on full story foundation walls with a partially or fully 
enclosed area below the elevated floor. This includes walkout levels, where at least one 
side is at or above grade. The principal use of this building is located in the elevated 
floors of the building. 
 Diagram 8  All buildings elevated on a crawl space with the floor of the crawl space at 
or above grade on at least one side, with or without an attached garage. 
As illustrated in Table 19, good levels of compliance were found within Diagram 1 (slabon-
grade) and Diagram 3 (split-level buildings that are slab-on-grade with the bottom floor at or 
above ground level on at least one side). Evidence of worse compliance was seen among 
Building Diagram 4 (split-level buildings that are slab-on-grade with the bottom floor basement 
or underground garage below ground level on all sides) and 7 (buildings elevated on full story 
foundation walls with a partially or fully enclosed area below the elevated floor). Openings were 
problematic for Diagram 6 (buildings elevated on piers, posts, piles, columns, or shear parallel 
walls with full or partial enclosure below the elevated floor), Diagram 7 and Diagram 8 
(buildings elevated on a crawl space with the floor of the crawl space at or above grade on at 
least one side). These finding lend further support to the general observation that higher rates of 
compliance were observed in communities with primarily slab-on-grade construction and lower 
rates in communities that use various types of elevated foundations. 

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TABLE 19. Building Compliance by Building Diagram Number 

Total No. of Confidence Interval Confidence Interval 
Building Buildings Fully Noncompliant-
Diagram Number Surveyed Compliant1 Lower Upper All Categories1 Lower Upper Undetermined2 

1 627 71.5% 60.7% 77.6% 26.4% 22.4% 39.3% 2.1% 
2 58 55.2% 14.4% 80.7% 44.8% 19.3% 85.6% 

0 
3 13 76.9% 30.5% 100.0% 23.1% 0.0% 69.5% 

0 
4 3 33.3% N/A2 N/A2 66.7% N/A2 N/A2 0 
5 58 60.3% 35.3% 76.8% 39.7% 23.2% 64.7% 0 
6 151 58.9% 34.3% 66.9% 41.1% 33.1% 65.7% 0 
7 77 35.1% 11.6% 49.3% 64.9% 50.7% 88.4% 0 
8 266 52.6% 41.7% 66.3% 47.4% 33.7% 58.3% 0 

Total Surveyed 1,253 

195-Percent statistical confidence interval for estimate.
2Insufficient number of data points to set meaningful confidence intervals.


Building Types/Usage  To allow for detailed analysis of the compliance findings as 
they relate to the type and building uses found within our sample, the study team identified and 
recorded the following classifications of buildings: 

 Single Family Detached 
 Duplex 
 Townhouse or Row House 
 Manufactured home 
 Multi-Family (Condos or Apartments) 
 Commercial/Industrial 
 Multi-Use (Includes building with shared commercial and residential space) 
 Public Building 
In general, as illustrated by Table 20, higher levels of compliance were observed in 
townhomes/rowhouses and in public buildings included within the sample. Poor compliance was 
found in manufactured homes. Within the manufactured buildings, there was a high occurrence 
of electrical and mechanical below the BFE. These were primarily air conditioning condensers 
found at grade. 

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TABLE 20. Building Compliance by Building Type/Usage 

Total No. of 
Buildings Fully 
Confidence Interval 
Noncompliant 
Confidence Interval 
Building Description Surveyed Compliant1 Lower Upper (All Categories) 1 Lower Upper Undetermined2 
Single Family Detached 920 60.4% 54.8% 68.7% 38.6% 31.3% 45.2% 1.0% 
Duplex 14 64.3% 14.9% 93.4% 37.7% 6.6% 85.1% 0.0% 
Townhouse/Row house 90 80.0% 35.7% 87.5% 20.0% 12.5% 64.3% 0.0% 
Manufactured Home 48 37.5% 16.3% 62.1% 62.5% 37.9% 83.7% 0.0% 
Multi-Family (Condo/Apartments) 48 77.1% 49.4% 90.9% 22.9% 9.1% 50.6% 0.0% 
Commercial/Industrial 118 74.6% 66.4% 88.3% 22.0% 11.7% 33.6% 3.4% 
Multi-Use Building 10 70.0% N/A2 N/A2 30.0% N/A2 N/A2 0.0% 
Public Building 5 80.0% N/A2 N/A2 20.0% N/A2 N/A2 0.0% 
Total Structures 1,253.00 

195-Percent statistical confidence interval for estimate. 

2Insufficient number of data points to set meaningful confidence intervals. 

3.2.3. Results Extrapolated to Community Clusters 
This section presents the results of statistical methods used to extrapolate the results 
found in the sample of the 1,253 structures surveyed as part of this study to the communities and 
structures that share characteristics in common with our sample. As discussed in Section 2.1, the 
sample is representative of areas of the country where a preponderance of NFIP post-FIRM 
policies are found. Our objective was to examine compliance within communities where 
detailed hydrologic and hydraulic studies have been performed to establish BFEs and or flood 
depths. Accordingly, sampling for this study identified all the participating NFIP communities 
within our cluster areas with BFEs and or flood depths. The 1513 communities, shown in 
Appendix A, were found to meet our criteria. From those 1513 communities, 50 were randomly 
selected for inclusion in this study. Within the 50 communities included, 18,742 buildings53 
were identified as being located in the detailed flood hazards zones (AE, VE, AO and AH) 
addressed by Study Part B. 

It must be noted that analyses have been conducted on a limited basis and the data are 
presented for only the most commonly found compliance categories included in this study. 

The 18,742 buildings represent those buildings included in the project database. These buildings and their 
corresponding addresses were obtained from the NFIP Policy-in-Force database and First American Real Estate 
Solutions GIS database (see Section 3.2 for further detail). 

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We project that there are an estimated 984,792 buildings within our cluster areas located 
in the detailed SFHAs addressed by our study. Based on our findings within the 1,253 buildings 
within the 50 communities we surveyed we would expect to find 644,539 fully complaint 
buildings within the cluster areas addressed by this study. The confidence interval for this 
estimate runs from 263,518 to 984,326 at the 95 percent confidence interval. This means that 
were we to survey other communities or buildings, 95 percent of the time we would find the 
number of fully compliant buildings would be between 263,518 and 984,326. A table including 
cluster wide projections of the number and percentage of compliant buildings and the most 
commonly found compliance problems and their corresponding projections is shown as Table 

21. 
TABLE 21. Building Compliance (Extrapolated to all clusters) 

Confidence Interval 
Compliance Category Weighted Projection1 Lower Upper 
Noncompliant Buildings with LEM Issues 90,501 16,571 164,432 
Noncompliant Buildings with openings Issue 69,673 23,078 116,269 
Noncompliant with Low Floor or LHSM issues 55,075 7,042 103,109 

FullyCompliantBuildings644,539263,518984,3262Percentageoffullycompliantbuildings65.45%26.8%100%2
PercentageofnoncompliantbuildingswithLEMIssues9.19%1.7%16.7%
PercentageofnoncompliantbuildingswithopeningsIssues7.07%2.3%11.8%
PercentageofnoncompliantbuildingswithLowFloororLHSMissues5.59%0.7%10.5%
195-Percent statistical confidence interval for estimate. 

2Value exceeded total number of buildings; it was replaced with the total number of buildings minus the number of buildings established as noncompliant 
through this survey. 

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4. SUMMARY AND CONCLUSIONS 
Part A and Part B the Evaluation of Community Compliance and previous research have 
shown that, among the 20,000 participating communities nationwide, there is, in fact, a high 
level of willingness to comply with the NFIP standards; many exemplary local programs; and 
real progress being made by many communities in coping with flood risk. The fact that most of 
those communities are operating competent programs supports the underlying assumption of the 
NFIP, as discussed in Part A, that communities will elect to participate in the program and that 
they will adequately enforce NFIP standards, with the incentive for participation being the 
availability of flood insurance for the community and its property owners. It also confirms that a 
predominantly cooperative enforcement model is an appropriate match for the NFIP. 

When Study B was initiated, it was anticipated that, in general, compliance with the 
requirement that the lowest floor (Zone AE) or LHSM (Zone VE) be at or above BFE would be 
good, but that many problems would be encountered with items like enclosures, mechanical and 
utility equipment, and openings. This study found the original assumptions to be well founded. 
While only 63 percent54 of the 1,253 buildings physically surveyed were in full compliance with 
all of the building requirements of the NFIP, communities were found to be successfully meeting 
the elevation requirements of the program. Eighty-nine percent55 of all buildings surveyed have 
their lowest floor at or above the BFE or within 6 inches of that elevation. In terms of damage 
reduction, ensuring that the lowest floor elevated to or above the BFE is significant and results in 
minimizing flood insurance claims and federal disaster assistance. 

In addition to the 89 percent of buildings found to have been built to the BFE or within 6 
inches of that elevation, an additional 4.3 percent have their main working\living floors above 
BFE. This 4.3 percent is comprised of buildings with finished enclosures or basements below 
the BFE. The buildings with noncompliant finished enclosures typically had the majority of the 
area under the elevated floor reserved for parking but in each case had an enclosed finished room 
with non-flood resistant materials and furnishings. The noncompliant basements found were one 
to three feet below BFE and not likely to experience damages due to hydrostatic pressure56 
during base flood conditions. For these reasons, as well as, limitations on flood insurance 
coverage for basements and noncompliant finished enclosures, the claims on these buildings and 
corresponding cost to the NFIP would be much lower than for buildings with lowest floor 
violations at the same elevation. 

54 

This estimate runs between 58 to 70 percent at the 95 percent confidence interval 

55 

The confidence inteval for this estimate runs between 86 and 94 at the 95 percent confidence interval 

56 

Solid walls can collapse if floodwaters get too deep. To prevent collapse the enclosure must have openings to 
allow floodwaters to enter and exist, thus automatically equalizing hydrostatic flood forces on the walls. 

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As anticipated, the most common violations found were mechanical and utility equipment 
located below the BFE and openings that do not meet the openings requirements at 44 CFR 
60.3(c)(5). Between them, these two types of violations account for 50.6 percent of the 
violations found within our sample. The prevalence of these problems varied widely among 
clusters. The regulations governing mechanical and utility equipment and openings are 
technically the most difficult to apply and enforce. Further, although these items can be 
compliant when a building is built, they can be modified later by the property owner without the 
community's knowledge. For these reasons, it is difficult to determine if the violations found are 
the result of misunderstandings by local officials of the requirements, willful disregard, less 
importance or focus placed on ensuring that the requirements are met, or lack of enforcement. 

Another speculation made at the start of this study was that better levels of compliance 
would be found in larger communities with large areas of their community located within flood 
hazard areas and more economic resources. This assumption was based on the premise that more 
economic resources would be available within the community to support full-time floodplain 
management staff and more resources would be devoted to outreach and public education. It was 
further surmised that because FEMA and its state partners put the vast majority of their resources 
and effort into promotion of compliance within communities with the greatest number of policies 
in an effort to protect the financial stability of the Flood Insurance Fund, better levels of 
compliance would be found in the larger communities within the sample. While the vast 
majority of the communities participating in the NFIP have little development at risk and are 
experiencing no or very slow growth, many of the communities included in this study face 
enormous risk to millions of dollars of property and are likely to have received more training and 
technical assistance than NFIP communities with smaller policy bases and less development at 
risk. Although this study found little evidence of a strong relationship between the size or 
economic resources of the community and the number of compliant buildings, there was one 
exception. 

Some regional differences in the number of compliant buildings were found. Better rates 
of compliance were found in the Southwest and Washington-Baltimore cluster and lower rates of 
compliance were found in the California-North, Coastal Texas, and Florida Panhandle clusters. 
It is speculated that these differences in rates of compliance are attributable to the prevailing 
building construction method found within the region. Generally higher rates of compliance 
were observed in communities with primarily slab-on-grade construction and lower rates in 
communities that use various types of elevated foundations such as were found in the California-
North, Coastal Texas, and Florida Panhandle clusters. Although no hard data was gathered 
through this study to support the speculation that regional differences in the number of fully 
compliant buildings are the result of Floodplain Manager education, States with broad 
participation in floodplain management associations and large numbers of CFMs generally were 
observed to have good rates of compliance. 

This study revealed surprising findings about the level of compliance within communities 
participating in the CRS. Twenty-six of the 50 communities included in Study B participate in 
the CRS. All have participated since the early 1990s except for one that joined in 2001. At the 
start of this study, the team expected to find better rates of compliance with the NFIP building 

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requirements among communities participating in the CRS than in those not participating in the 
program. However, the percentage of fully compliant structures within the group of CRS and 
non-CRS communities are strikingly similar (62.2 as opposed to 64.1 percent, respectively), and, 
thus, there is no statistically significant evidence that compliance is better or worse in CRS 
communities than in non-CRS communities. Nevertheless, there is significant evidence to 
suggest that fewer lowest floor and LHSM violations are found in the CRS communities as 
compared to non-CRS communities. Due to the record keeping and retention requirements of 
the CRS, it was anticipated that communities participating in the program would be able to 
provide permit files and Elevation Certificates for all buildings permitted since they joined the 
CRS program. Communities participating in the CRS had a better record of making permit files 
available to the survey team (86.5 percent) as compared to communities that do not participate in 
CRS (66.5 percent). They also had a better record of making Elevation Certificates or equivalent 
elevation data available to the team (72.1 percent) than communities not participating in the 
program (50.6 percent). Nonetheless, the sample of communities participating in the CRS fell 
far short of the rates expected for CRS communities given the requirement for obtaining and 
retaining Elevation Certificates for all floodplain development after participation in CRS begins. 

In general, this study found problems with record keeping and retention by communities. 
As a result, it is unclear to what degree communities are meeting the 44 CFR 60.3 requirement 
to issue building permits for all development in the SFHA, if they are commonly ensuring that 
the proposed lowest floor and as-built elevations (after construction has been completed) are at 
or above BFE, and if they obtain and retain documentation of design and construction methods. 
As discussed in Section 3.1.1, many communities archive or dispose of their older permit files 
periodically, and many do not understand that they need to retain their floodplain development 
permit records and Elevation Certificates indefinitely. This study did not perform analyses to 
make a direct correlation between where incomplete community permit records57 were found and 
if violations were found in those same buildings. However, a communitys floodplain 
development files, especially its building and zoning permits, are widely regarded as an excellent 
means of assessing the effectiveness of the communitys floodplain management program. 
Community permit files are reviewed during community assistance visits and often serve as 
harbingers of violations to be encountered. Incomplete permit files are often indicative of a 
community program that does not have adequate administrative procedures in place or the staff 
resources to ensure that buildings are built and remain in compliance with the NFIP regulations. 

There is evidence that compliance has improved over time. Study B compares results by 
compliance category for three segments of time: 1990 to 1995, 1996 to 2000, and 2001 to 2004. 
The analysis shows a significant increase in the percentage of fully compliant buildings from the 
earliest to the most recent time period. 

Incomplete as defined here includes building permits and or Elevation Certificates or equivalent elevation data 
that were unavailable to the study team. In a larger context, a communitys permit file should include, but not 
limited to, the permit application form, as-built lowest floor elevation, certification of design standards, certificate 
of compliance or occupancy. 

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In conclusion, as discussed in Part A of this study, Achieving Community Compliance, 
(Monday et al., 2006) and throughout this study, the NFIPs success is based on two conditions. 
The first is that communities will choose to participate in the program and, therefore, will adopt 
and agree to enforce floodplain management ordinances established under authority of the 
National Flood Insurance Act, as amended. The incentive for such participation, and all that it 
entails, is the availability of flood insurance for the community and its property owners. 

Second, once a community begins participating in the NFIP, it is assumed that it 
administers and enforces its ordinance in such a way that development in its floodprone areas 
actually does meet the local (and NFIP) standards and, thus, is protected from future flood 
damage. If either condition is not metif communities do not elect to participate in the program 
or if they do so but fail to adequately enforce the standards  lives and property are placed in 
harms way; buildings will suffer unnecessary flood damage; sound land use planning in 
floodplains is discouraged; the NFIPs actuarial soundness is jeopardized; changes in public 
policies and regulations may be based on unreliable data; and the costs to society from future 
floods will be increased unnecessarily. In short, a high level of continuous compliance with the 
NFIP standards is crucial to the programs success. Thus, the question of the extent and nature 
of compliance and noncompliance is an important element of any assessment of the NFIP and 
must be continually monitored. 

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5. RECOMMENDATIONS 
The $1.1 billion in estimated flood damages prevented annually due to reduced frequency 
and severity of losses58 resulting from enforcement of floodplain management regulations 
provides testament to the successful implementation of many of the NFIPs floodplain 
management measures. However, the data gathered through this study point to the need for 
greater focus on enforcement and additional training and technical guidance in several areas. In 
addition, this study identified problems with community record keeping and retention related to 
construction of buildings in the nations SFHAs. 

Recommendations for improving the specific deficiencies identified through Part B of the 
Evaluation of Community Compliance follow. These recommendations include specific actions 
that communities can take to improve compliance as well as actions FEMA and its state partners 
can take to promote improved compliance. 

Community Compliance Part B Recommendation #1 (CCB1): Adoption of freeboard should 
be strongly promoted 

The prevalence of lowest floor (Zone AE) and LHSM (Zone VE) violations, and 
noncompliant buildings found to be within 6 inches of the BFE, reinforces the advisability of 
communities or states adding a requirement for freeboard rather than meeting the minimum 
requirement that the top of the floor be built at BFE. Freeboard is the additional height 
requirement above the BFE that provides a factor of safety against flooding and wave run-up. 
Freeboard compensates for the many unknown or not easily measured factors that could 
contribute to increased flood heights, such as wave action, obstructed culverts or bridges, and the 
effects of urbanization. It reduces the risk of flood damage, helping account for the one-foot rise 
in flood levels allowed by the NFIP floodway standard and reduced floodplain storage due to 
development. It also reflects the uncertainties in flood hazard modeling, topography, and 
mapping limitations. Freeboard also provides a measure of safety against errors that may be 
introduced by inaccurate interpretation of flood profiles, the use of unstable benchmarks, and 
surveying errors. Further, floods at levels above the 1-percent annual chance elevation do occur, 
so added freeboard provides some protection against higher floods as well. 

Incentive programs such as the CRS encourage the adoption of higher regulatory 
standards such as freeboard. In addition, some states also require that their communities regulate 
to a higher standard for certain aspects of floodplain management. Nineteen states have stricter 
building construction requirements than does the NFIP. The most common of which is 
freeboard. The measure of protection bestowed buildings where freeboard has been applied is 
also rewarded through lower flood insurance premiums.59 The benefits of adopting freeboard 

58 

Source: FEMA website http://www.fema.gov/plan/prevent/floodplain/How_the_NFIP_works.shtm. 

59 

Flood insurance premiums for post-FIRM buildings are intended to be actuarial, meaning they are based on the 
known risk the building is exposed to. The anticipated risk to a post-FIRM building is based on the elevation of the 
lowest finished floor in relation to the BFE. The higher the floor is above the BFE, the lower the rate. 

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should be widely promoted through training, FEMA and community websites, and in technical 
publications. Communities should be strongly encouraged to codify the requirement in their 
local ordinances. 

CCB#2: Promote frequent verification inspections during construction 

One of the most effective ways to ensure compliance with the NFIP building standards, 
as well as higher standards such as freeboard requirements that a community may have adopted, 
is to inspect the site frequently during construction. Errors in the elevation of the lowest floor 
are most easily found and corrected in earlier phases of construction, while detection of errors in 
the placement of electrical and mechanical equipment is not possible until later in the 
construction process. An inspection program also puts builders, developers, and property owners 
on notice that the community will insist that projects are completed in compliance with the 
regulations. 

CCB#3: Perform periodic checks to ensure that the property continues to remain in 
compliance 

Communities should periodically check to ensure that the property continues to remain in 
compliance over time. Later inspections are particularly important when a building has an 
enclosure below the lowest floor. Such areas can be easily modified into habitable fully 
furnished space in violation of the NFIP regulations creating safety hazards. This study 
identified 30 noncompliant finished enclosures. Many of these are surmised to have been 
converted to habitable fully finished living space without community consent. 

CCB#4: A concerted effort is needed to focus greater attention on community permit file 
record keeping and retention 

Strong adherence to a floodplain management program that requires permits for all 
floodplain development, monitors construction as it takes place as well as periodically over time 
to ensure compliance with the NFIP requirements or the communitys own higher standards, and 
ensures adequate documentation of those activities, benefits the NFIP compliance program in 
two ways. First, it allows FEMA and its state partners involved in community assistance visits to 
quickly assess the adequacy of the communitys program and direct limited resources towards 
communities with the greatest needs. Second, good records show what was approved, forming a 
paper trail needed for administrative or legal proceedings when buildings are found to be in 
violation of the communitys ordinance. Complete records are also of value to future buyers and 
owners seeking information about the property. This information may include information on 
the placement of fill on the site, building standards, and key elevation data needed for flood 
insurance rating. 

Improvements in this area may be brought about by having FEMA regional offices, 
FEMA state partners, and ISO/CRS personnel focus greater attention on the record keeping and 
retention requirements of the program during contacts with communities. 

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CCB#5: FEMA should consider revising the opening requirements found in 44 CFR 60.3 
(c)(5) for buildings in coastal AE zones with non supporting breakaway walls. 

The FEMA 2000 Coastal Construction Manual recommends that buildings in Coastal AE 
zones 60 be constructed to be more resistant to coastal flood forces. Further, the nations private 
sector building code organizations and consensus standards groups (i.e., IBC, IRC, NFPA 5000, 
ASCE 7, ASCE 24) recognize the Coastal AE zone hazard and require appropriate design and 
construction requirements similar to those established for VE zones under the NFIP. 
Nonetheless, the Coastal AE zone, has yet to be included in the NFIP regulations. At present, 
buildings in Coastal AE zones constructed to Zone VE standards that include non supporting 
breakaway walls below the lowest floor and do not also have openings that meet the openings 
requirements of 44 CFR 60.3(c)(5) are considered noncompliant. Thirteen of the noncompliant 
buildings identified by this study as having insufficient openings are pile and column buildings 
that appear to be built to Zone VE standards in Zone AE. It is recognized that a regulatory 
change does not happen without great deliberation. Until such time as a regulatory change might 
be implemented, FEMA should issue clear guidance regarding the opening requirement in 
breakaway walls in coastal AE zones. 

CCB#6: FEMA should continue its support of training for local staff, state training 
requirements, and certification of local floodplain managers. 

It is impossible to know if the instances of noncompliance found in this study are the 
result of misunderstandings concerning NFIP requirements by local officials, willful disregard, 
less importance or focus placed on ensuring that certain requirements are met, or lack of 
enforcement once violations are found. Nonetheless, it is widely believed that most communities 
and individuals are willing to abide by technical standards set for the program and that public 
servants are interested in protecting people and their property. With the latter premise in mind, it 
is surmised that community compliance could be improved by making more resources available 
for both FEMA and the states to increase staff levels and travel support, and to produce and 
deliver more workshop and training materials. This recommendation is also found in Part A of 
the evaluation of community compliance. 

The Coastal Construction Manual identifies a new hazard zone called a Coastal A zone, that is not included in the 
NFIP regulations. Coastal A zones are those areas located landward of an open coast with or without mapped V 
Zones where the principal sources of flooding are tides, storm surges, seiches or tsunamis instead of riverine 
sources. Coastal A Zones are subject to wave effects, velocity flows, erosion, scour, and all combinations of the 
above. These areas are expected to receive 1 -3 foot breaking waves during a 100-year event. 

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CCB#7: FEMA and ISO/CRS Personnel should monitor compliance in communities participating in 
CRS more closely and take decisive action to bring communities into compliance or retrograde their 
CRS class. 

All CRS communities are required to maintain programs that are compliant with the 
NFIP standards. Compliance of CRS communities is arguably even more important to the 
success of the NFIP than that of other communities, for two reasons. 

First, CRS communities are being recognized and rewarded for having better 
floodplain management programs. Equity dictates that they be held to that standard and thus 
there ought to be no question about the NFIP minimum requirements being met. 

Second, noncompliance in CRS communities increases the overall costs of the NFIP and 
affects the vitality of the flood insurance fund, just as noncompliance in other communities does. 
However, it could be argued that CRS community noncompliance is marginally even more 
costly, because the policyholders in those communities are contributing less to the National 
Flood Insurance Fund because they pay lower premiums. 

FEMA/ISO is supposed to retrograde a community to Class 10 (non-participation in the 
CRS and no discount on flood insurance) if it finds that a community does not meet the 
minimum requirements of the NFIP (i.e., has program deficiencies or violations). FEMA/ISO 
also is supposed to retrograde a community to Class 10 if it is not meeting the other prerequisites 
of participation in the CRS (for example, the community does not keep elevation certificates on 
file or does not conduct enough activities to receive 500 points). A retrograde to Class 10 
removes a community from the CRS. 

Part A of the evaluation of community compliance found monitoring and enforcement in 
CRS communities to be deficient. These shortcomings are perceived to be the result of poor 
recordkeeping and retention, confusion within ISO/CRS personnel and the FEMA regional 
offices about their roles and responsibilities, unclear policy on CAVs, and communication gaps 
between ISO and FEMA. Study B found further evidence of noncompliant programs in CRS 
communities in the areas of both recordkeeping and retention and noncompliant buildings. A 
concerted effort is needed to remedy the deficiencies in this program. 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



59 

6. APPENDICES 
APPENDIX A  PARTICIPATING COMMUNITIES WITH DETAILED 
SFHAS 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
California -North CA Alameda Alameda 7/16/1991 C 
California -North CA Contra Costa Antioch 9/4/1987 D 
California -North CA Marin Belvedere 5/2/1977 C 
California -North CA Contra Costa Benicia 8/3/1989 D 
California -North CA Solano Benicia 8/3/1989 D 
California -North CA Alameda Berkeley 9/1/1978 D 
California -North CA Santa Clara Burbank 1/20/1999 D 
California -North CA San Mateo Burlingame 9/16/1981 E 
California -North CA Santa Cruz Capitola 6/3/1986 D 
California -North CA Contra Costa Clayton 9/7/2001 D 
California -North CA Lake Clearlake 8/3/1992 D 
California -North CA Sonoma Cloverdale 7/16/1996 D 
California -North CA Contra Costa Concord 9/7/2001 D 
California -North CA Marin Corte Madera 12/15/1977 C 
California -North CA Sonoma Cotati 12/5/1996 D 
California -North CA Santa Clara Cupertino 5/1/1980 D 
California -North CA Solano Davis 12/20/2002 D 
California -North CA Solano Dixon 5/19/1981 C 
California -North CA Contra Costa El Cerrito 6/1/1977 C 
California -North CA Marin Fairfax 1/5/1978 C 
California -North CA Solano Fairfield 9/15/1993 D 
California -North CA Sacramento Folsom 9/30/1992 D 
California -North CA San Mateo Foster City 1/19/1995 E 
California -North CA Santa Clara Fremont 2/9/2000 D 
California -North CA San Joaquin Galt 8/16/1995 D 
California -North CA Santa Clara Gilroy 8/17/1998 D 
California -North CA Nevada Grass Valley 2/5/1997 D 
California -North CA San Mateo Half Moon Bay 6/3/1986 E 
California -North CA Alameda Hayward 2/9/2000 D 
California -North CA Sonoma Healdsburg 10/18/1983 D 
California -North CA Contra Costa Hercules 9/30/1982 D 
California -North CA San Benito Hollister 9/27/1991 D 
California -North CA Amador Ione 6/6/2000 C 
California -North CA Sacramento Isleton 7/2/1987 C 
California -North CA Amador Jackson 7/17/1997 D 
California -North CA Contra Costa Lafayette 12/20/2002 D 
California -North CA Lake Lakeport 9/28/1990 D 
California -North CA Marin Larkspur 4/17/1984 C 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



60 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
California -North CA Placer Lincoln 11/21/2001 D 
California -North CA Alameda Livermore 9/17/1997 D 
California -North CA Merced Livingston 8/2/1995 D 
California -North CA San Joaquin Lodi 6/18/1987 D 
California -North CA Placer Loomis 11/21/2001 D 
California -North CA Santa Clara Los Altos 7/16/1980 D 
California -North CA Santa Clara Los Altos Hills 1/2/1980 D 
California -North CA Santa Clara Los Gatos 1/17/1979 C 
California -North CA Contra Costa Martinez 5/2/2002 C 
California -North CA Sutter Marysville 8/10/1982 D 
California -North CA San Mateo Millbrae 9/30/1981 C 
California -North CA Santa Clara Milpitas 6/22/1998 D 
California -North CA Stanislaus Modesto 5/7/2001 D 
California -North CA Contra Costa Moraga 5/19/1981 D 
California -North CA Santa Clara Morgan Hill 12/22/1998 D 
California -North CA Contra Costa Mountain View 6/19/1997 D 
California -North CA Napa Napa 1/19/2000 D 
California -North CA Alameda Newark 2/9/2000 D 
California -North CA Stanislaus Newman 1/3/1990 D 
California -North CA Marin Novato 9/29/1989 D 
California -North CA Stanislaus Oakdale 9/5/1979 C 
California -North CA Alameda Oakland 9/30/1982 E 
California -North CA Contra Costa Oakley 2/2/2002 C 
California -North CA Contra Costa Orinda 7/17/1997 D 
California -North CA San Mateo Pacifica 2/19/1987 C 
California -North CA San Mateo Palo Alto 6/2/1999 E 
California -North CA Stanislaus Patterson 1/3/1990 C 
California -North CA Sonoma Petaluma 9/29/1989 D 
California -North CA Contra Costa Pinole 8/15/1980 D 
California -North CA Contra Costa Pittsburg 9/7/2001 D 
California -North CA El Dorado Placerville 9/30/1983 D 
California -North CA Contra Costa Pleasant Hill 9/30/1983 D 
California -North CA Alameda Pleasanton 9/30/1997 D 
California -North CA Mendocino Point Arena 6/3/1986 E 
California -North CA San Mateo Portola Valley 9/22/1981 C 
California -North CA San Mateo Redwood City 5/17/1982 E 
California -North CA Contra Costa Richmond 9/7/2001 E 
California -North CA Solano Rio Vista 8/4/1987 D 
California -North CA Placer Rocklin 11/21/2001 D 
California -North CA Sonoma Rohnert Park 6/1/1981 D 
California -North CA Placer Roseville 11/21/2001 D 
California -North CA Marin Ross 2/4/1981 C 
California -North CA Sacramento Sacramento 7/6/1998 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



61 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
California -North CA San Mateo San Carlos 8/21/1979 D 
California -North CA Alameda San Jose 8/17/1998 D 
California -North CA San Benito San Juan Bautista 9/27/1991 C 
California -North CA Alameda San Leandro 2/9/2000 D 
California -North CA Contra Costa San Pablo 11/17/1993 C 
California -North CA Santa Clara Santa Clara 1/20/1999 D 
California -North CA Santa Cruz Santa Cruz 6/17/1986 D 
California -North CA Sonoma Santa Rosa 8/3/1981 D 
California -North CA Marin Sausalito 9/30/1980 D 
California -North CA Sonoma Sebastopol 9/28/1990 C 
California -North CA San Mateo South San Francisco 9/2/1981 E 
California -North CA Napa St. Helena 1/7/1998 D 
California -North CA San Joaquin Stockton 4/2/2002 D 
California -North CA Solano Suisun City 6/1/1982 C 
California -North CA Amador Sutter Creek 9/28/1990 D 
California -North CA Marin Tiburon 5/16/1977 C 
California -North CA San Joaquin Tracy 6/18/1987 C 
California -North CA Mendocino Ukiah 8/5/1985 D 
California -North CA Alameda Unincorporated Areas 7/16/1991 C 
California -North CA Yuba Unincorporated Areas 9/15/1983 C 
California -North CA Butte Unincorporated Areas 4/20/2000 D 
California -North CA Contra Costa Unincorporated Areas 9/7/2001 D 
California -North CA El Dorado Unincorporated Areas 10/18/1995 D 
California -North CA Glenn Unincorporated Areas 6/5/1997 D 
California -North CA Lake Unincorporated Areas 9/28/1990 D 
California -North CA Marin Unincorporated Areas 2/3/1993 D 
California -North CA Merced Unincorporated Areas 8/2/1995 D 
California -North CA Napa Unincorporated Areas 1/19/2000 D 
California -North CA Placer Unincorporated Areas 11/21/2001 D 
California -North CA Sacramento Unincorporated Areas 7/6/1998 D 
California -North CA San Joaquin Unincorporated Areas 4/2/2002 D 
California -North CA Santa Clara Unincorporated Areas 1/20/1999 D 
California -North CA Santa Cruz Unincorporated Areas 6/17/1986 D 
California -North CA Stanislaus Unincorporated Areas 5/7/2001 D 
California -North CA Sutter Unincorporated Areas 9/28/1990 D 
California -North CA Yolo Unincorporated Areas 12/20/2002 D 
California -North CA Mendocino Unincorporated Areas 6/16/1992 D & E 
California -North CA Solano Unincorporated Areas 5/7/2001 D & E 
California -North CA Solano Vacaville 5/7/2001 D 
California -North CA Contra Costa Walnut Creek 10/4/2002 D 
California -North CA Santa Cruz Watsonville 6/15/1984 D 
California -North CA Sacramento West Sacramento 1/19/1995 C 
California -North CA Colusa Williams 5/15/2003 C 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



62 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
California -North CA Glenn Willows 12/7/1982 C 
California -North CA Yolo Winters 11/20/1998 C 
California -North CA Yolo Woodland 4/2/2002 C 
California -North CA San Mateo Woodside 11/15/1979 D 
California -North CA Napa Yountville 9/28/1990 D 
Coastal NC/VA NC Pamlico Alliance 8/5/1985 D 
Coastal NC/VA NC Beaufort Aurora 5/15/2003 C 
Coastal NC/VA NC Beaufort Bath 5/15/2003 E 
Coastal NC/VA NC Pamlico Bayboro 12/4/1985 C 
Coastal NC/VA NC Carteret Beaufort 10/18/1983 C 
Coastal NC/VA NC Beaufort Belhaven 5/15/2003 C 
Coastal NC/VA NC Carteret Bogue 6/2/1999 D 
Coastal NC/VA NC Craven Bridgeton 5/4/1987 C 
Coastal NC/VA NC Carteret Cape Carteret 10/18/1983 E 
Coastal NC/VA NC Tyrrell Columbia 8/5/1985 D 
Coastal NC/VA NC Washington Creswell 2/4/1987 D 
Coastal NC/VA NC Pasquotank Elizabeth City 8/5/1985 E 
Coastal NC/VA NC Pitt Farmville 4/17/1989 D 
Coastal NC/VA NC Pitt Greenville 4/30/1986 D 
Coastal NC/VA NC Lenoir Grifton 11/20/1998 D 
Coastal NC/VA NC Craven Havelock 5/4/1987 D 
Coastal NC/VA NC Perquimans Hertford 7/3/1985 C 
Coastal NC/VA NC Dare Kill Devil Hills 4/2/1993 E 
Coastal NC/VA NC Lenoir Kinston 6/15/1982 D 
Coastal NC/VA NC Dare Kitty Hawk 4/2/1993 E 
Coastal NC/VA NC Edgecombe Leggett 12/20/1999 D 
Coastal NC/VA NC Pamlico Minnesott Beach 8/5/1985 C 
Coastal NC/VA NC Carteret Morehead City 10/18/1983 E 
Coastal NC/VA NC Dare Nags Head 12/20/2000 E 
Coastal NC/VA NC Craven New Bern 5/4/1987 C 
Coastal NC/VA NC Carteret Newport 10/18/1983 C 
Coastal NC/VA NC Pamlico Oriental 12/4/1985 C 
Coastal NC/VA NC Beaufort Pantego 5/15/2003 D 
Coastal NC/VA NC Edgecombe Pinetops 3/28/1980 D 
Coastal NC/VA NC Washington Plymouth 8/19/1985 D 
Coastal NC/VA NC Edgecombe Princeville 4/15/1980 D 
Coastal NC/VA NC Craven River Bend 8/19/1986 D 
Coastal NC/VA NC Washington Roper 8/5/1985 D 
Coastal NC/VA NC Dare Southern Shores 4/2/1993 E 
Coastal NC/VA NC Edgecombe Speed 7/2/1987 D 
Coastal NC/VA NC Pamlico Stonewall 12/4/1985 C 
Coastal NC/VA NC Edgecombe Tarboro 2/4/1988 D 
Coastal NC/VA NC Craven Trent Woods 9/8/1999 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



63 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Coastal NC/VA NC Camden Unincorporated Areas 12/4/1985 C 
Coastal NC/VA NC Hertford Unincorporated Areas 7/3/1985 C 
Coastal NC/VA NC Tyrrell Unincorporated Areas 8/19/1985 C 
Coastal NC/VA NC Beaufort Unincorporated Areas 5/15/2003 D 
Coastal NC/VA NC Bertie Unincorporated Areas 12/4/1985 D 
Coastal NC/VA NC Chowan Unincorporated Areas 7/3/1985 D 
Coastal NC/VA NC Craven Unincorporated Areas 12/5/1997 D 
Coastal NC/VA NC Edgecombe Unincorporated Areas 8/3/1981 D 
Coastal NC/VA NC Greene Unincorporated Areas 1/6/1983 D 
Coastal NC/VA NC Halifax Unincorporated Areas 5/5/1981 D 
Coastal NC/VA NC Lenoir Unincorporated Areas 8/16/1988 D 
Coastal NC/VA NC Martin Unincorporated Areas 7/16/1991 D 
Coastal NC/VA NC Northampton Unincorporated Areas 11/4/1988 D 
Coastal NC/VA NC Pasquotank Unincorporated Areas 12/4/1985 D 
Coastal NC/VA NC Perquimans Unincorporated Areas 7/3/1985 D 
Coastal NC/VA NC Washington Unincorporated Areas 5/15/2003 D 
Coastal NC/VA NC Pamlico Unincorporated Areas 9/4/1985 D & E 
Coastal NC/VA NC Carteret Unincorporated Areas 11/6/1998 E 
Coastal NC/VA NC Currituck Unincorporated Areas 5/5/2003 E 
Coastal NC/VA NC Dare Unincorporated Areas 5/5/2003 E 
Coastal NC/VA NC Hyde Unincorporated Areas 5/15/2003 E 
Coastal NC/VA NC Craven Vanceboro 8/4/1988 D 
Coastal NC/VA NC Beaufort Washington 5/15/2003 D 
Coastal NC/VA NC Beaufort Washington Park 5/15/2003 C 
Coastal NC/VA NC Bertie Williamston 9/20/1996 D 
Coastal NC/VA NC Bertie Windsor 8/19/1985 D 
Coastal NC/VA NC Perquimans Winfall 7/3/1985 C 
Coastal NC/VA VA Southampton Boykins 9/4/2002 D 
Coastal NC/VA VA Indep City Chesapeake 5/2/1999 C 
Coastal NC/VA VA Southampton Courtland 9/4/2002 D 
Coastal NC/VA VA Indep City Franklin 9/4/2002 D 
Coastal NC/VA VA Indep City Hampton 7/3/1995 E 
Coastal NC/VA VA Indep City Newport News 1/17/1986 D 
Coastal NC/VA VA Indep City Norfolk 7/16/1996 E 
Coastal NC/VA VA Indep City Poquoson 8/3/1992 E 
Coastal NC/VA VA Indep City Portsmouth 11/2/1983 D 
Coastal NC/VA VA Indep City Suffolk 9/4/2002 D & E 
Coastal NC/VA VA Newport News Unincorporated Areas 1/17/1986 D 
Coastal NC/VA VA Portsmouth Unincorporated Areas 11/2/1983 D 
Coastal NC/VA VA Southampton Unincorporated Areas 9/4/2002 D 
Coastal NC/VA VA Isle of Wight Unincorporated Areas 9/4/2002 D & E 
Coastal NC/VA VA Suffolk Unincorporated Areas 9/4/2002 D & E 
Coastal NC/VA VA Virginia Beach Unincorporated Areas 12/5/1996 D & E 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



64 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Coastal NC/VA VA Norfolk Unincorporated Areas 7/16/1996 E 
Coastal NC/VA VA Northampton Unincorporated Areas 7/20/1998 E 
Coastal NC/VA VA Indep City Virginia Beach 12/5/1996 D & E 
Florida -West Coast FL Seminole Altamonte Springs 4/17/1995 D 
Florida -West Coast FL Orange Apopka 12/6/2000 C 
Florida -West Coast FL De Soto Arcadia 6/3/1988 D 
Florida -West Coast FL Lake Astatula 7/3/2002 C 
Florida -West Coast FL Polk Bartow 12/20/2000 D 
Florida -West Coast FL Orange Belle Isle 12/6/2000 C 
Florida -West Coast FL Polk Bowling Green 5/4/1988 D 
Florida -West Coast FL Manatee Bradenton 11/16/1983 E 
Florida -West Coast FL Hernando Brooksville 9/18/1986 D 
Florida -West Coast FL Lee Cape Coral 9/18/1985 C 
Florida -West Coast FL Orange Casselberry 4/17/1995 D 
Florida -West Coast FL Sumter Center Hill 1/18/1989 C 
Florida -West Coast FL Lake Clermont 7/3/2002 C 
Florida -West Coast FL Citrus Crystal River 8/15/1984 E 
Florida -West Coast FL Pasco Dade City 8/17/1981 C 
Florida -West Coast FL Polk Davenport 12/20/2000 C 
Florida -West Coast FL Polk Dundee 12/20/2000 D 
Florida -West Coast FL Pinellas Dunedin 7/2/1992 E 
Florida -West Coast FL Marion Dunnellon 2/1/1985 C 
Florida -West Coast FL Orange Edgewood 12/6/2000 C 
Florida -West Coast FL Lake Eustis 7/3/2002 C 
Florida -West Coast FL Polk Fort Meade 12/20/2000 D 
Florida -West Coast FL Polk Frostproof 12/20/2000 C 
Florida -West Coast FL Lake Fruitland Park 7/3/2002 C 
Florida -West Coast FL Lake Groveland 7/3/2002 C 
Florida -West Coast FL Polk Haines City 12/20/2000 D 
Florida -West Coast FL Citrus Inglis 3/1/1984 C 
Florida -West Coast FL Citrus Inverness 5/17/1982 C 
Florida -West Coast FL Pinellas Kenneth City 9/1/1983 D 
Florida -West Coast FL Osceola Kissimmee 6/6/2001 D 
Florida -West Coast FL Lake Lady Lake 7/3/2002 C 
Florida -West Coast FL Polk Lake Hamilton 12/20/2000 C 
Florida -West Coast FL Seminole Lake Mary 5/17/1995 D 
Florida -West Coast FL Polk Lake Wales 12/20/2000 C 
Florida -West Coast FL Polk Lakeland 12/20/2000 D 
Florida -West Coast FL Pinellas Largo 3/16/1983 C 
Florida -West Coast FL Lake Leesburg 7/3/2002 C 
Florida -West Coast FL Sumter Leesburg 7/3/2002 C 
Florida -West Coast FL Seminole Longwood 4/17/1995 C 
Florida -West Coast FL Pinellas Madeira Beach 3/2/1983 E 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



65 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Florida -West Coast FL Lake Mascotte 7/3/2002 C 
Florida -West Coast FL Lake Minneola 7/3/2002 C 
Florida -West Coast FL Lake Montverde 7/3/2002 C 
Florida -West Coast FL Polk Mulberry 12/20/2000 D 
Florida -West Coast FL Pasco New Port Richey 7/5/1983 C 
Florida -West Coast FL Sarasota North Port 9/2/1981 D 
Florida -West Coast FL Orange Ocoee 12/6/2000 C 
Florida -West Coast FL Orange Orlando 12/6/2000 D 
Florida -West Coast FL Seminole Oviedo 4/17/1995 D 
Florida -West Coast FL Manatee Palmetto 11/16/1983 E 
Florida -West Coast FL Pinellas Pinellas Park 2/17/1989 C 
Florida -West Coast FL Sarasota Plantation 7/21/1995 D 
Florida -West Coast FL Pasco Port Richey 7/5/1983 D 
Florida -West Coast FL Charlotte Punta Gorda 5/5/2003 E 
Florida -West Coast FL Pinellas Redington Shores 3/2/1983 E 
Florida -West Coast FL Seminole Sanford 4/17/1995 D 
Florida -West Coast FL Pinellas Seminole 1/18/1984 C 
Florida -West Coast FL Osceola St. Cloud 6/6/2001 C 
Florida -West Coast FL Pinellas St. Petersburg 11/2/1994 E 
Florida -West Coast FL Hillsborough Tampa 9/30/1982 E 
Florida -West Coast FL Pinellas Tarpon Springs 6/1/1983 E 
Florida -West Coast FL Lake Tavares 7/3/2002 C 
Florida -West Coast FL Hillsborough Temple Terrace 6/18/1990 D 
Florida -West Coast FL Pinellas Treasure Island 3/2/1983 E 
Florida -West Coast FL Lake Umatilla 7/3/2002 C 
Florida -West Coast FL Marion Unincorporated Areas 1/19/1983 C 
Florida -West Coast FL Glades Unincorporated Areas 5/17/1982 D 
Florida -West Coast FL Hardee Unincorporated Areas 5/4/1988 D 
Florida -West Coast FL Highlands Unincorporated Areas 2/16/1983 D 
Florida -West Coast FL Osceola Unincorporated Areas 6/6/2001 D 
Florida -West Coast FL Sumter Unincorporated Areas 3/15/1982 D 
Florida -West Coast FL Charlotte Unincorporated Areas 5/5/2003 D & E 
Florida -West Coast FL Manatee Unincorporated Areas 6/30/1999 DE 
Florida -West Coast FL Pasco Unincorporated Areas 6/30/1999 D & E 
Florida -West Coast FL Pinellas Unincorporated Areas 5/6/1996 D & E 
Florida -West Coast FL Volusia Unincorporated Areas 2/19/2003 D & E 
Florida -West Coast FL Citrus Unincorporated Areas 11/6/1998 E 
Florida -West Coast FL Dixie Unincorporated Areas 11/2/1983 E 
Florida -West Coast FL Hillsborough Unincorporated Areas 6/30/1999 E 
Florida -West Coast FL Lee Unincorporated Areas 5/5/2003 E 
Florida -West Coast FL Levy Unincorporated Areas 6/2/1992 E 
Florida -West Coast FL Sarasota Unincorporated Areas 9/29/1996 E 
Florida -West Coast FL Sarasota Venice 5/18/1992 E 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



66 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Florida -West Coast FL Hardee Wauchula 5/4/1988 D 
Florida -West Coast FL Orange Windermere 12/6/2000 C 
Florida -West Coast FL Orange Winter Garden 12/6/2000 D 
Florida -West Coast FL Polk Winter Haven 12/20/2000 C 
Florida -West Coast FL Orange Winter Park 12/6/2000 D 
Florida -West Coast FL Seminole Winter Springs 4/17/1995 D 
Florida -West Coast FL Citrus Yankeetown 3/1/1984 E 
Florida -West Coast FL Pasco Zephyrhills 12/17/1991 C 
Florida -West Coast FL Hardee Zolfo Springs 5/4/1988 D 
Florida Panhandle AL Baldwin Bay Minette 6/17/2002 D 
Florida Panhandle AL Mobile Bayou La Batre 7/6/1998 E 
Florida Panhandle AL Escambia Brewton 4/16/1990 D 
Florida Panhandle AL Mobile Chickasaw 7/6/1998 D 
Florida Panhandle AL Mobile Citronelle 7/6/1998 D 
Florida Panhandle AL Baldwin Creola 7/6/1998 D 
Florida Panhandle AL Baldwin Daphne 6/17/2002 D & E 
Florida Panhandle AL Escambia East Brewton 12/4/1979 D 
Florida Panhandle AL Coffee Elba 5/7/1976 D 
Florida Panhandle AL Coffee Enterprise 7/2/1980 D 
Florida Panhandle AL Baldwin Fairhope 6/17/2002 E 
Florida Panhandle AL Escambia Flomaton 12/17/1987 C 
Florida Panhandle AL Geneva Geneva 3/4/1987 D 
Florida Panhandle AL Butler Greenville 5/1/1980 D 
Florida Panhandle AL Baldwin Gulf Shores 6/17/2002 E 
Florida Panhandle AL Washington Jackson 12/17/1987 D 
Florida Panhandle AL Baldwin Loxley 6/17/2002 D 
Florida Panhandle AL Baldwin Mobile 7/6/1998 E 
Florida Panhandle AL Mobile Mobile 7/6/1998 E 
Florida Panhandle AL Baldwin Orange Beach 6/17/2002 D 
Florida Panhandle AL Mobile Prichard 7/6/1998 D 
Florida Panhandle AL Baldwin Robertsdale 6/17/2002 D 
Florida Panhandle AL Mobile Saraland 7/6/1998 D 
Florida Panhandle AL Mobile Satsuma 7/6/1998 D 
Florida Panhandle AL Baldwin Spanish Fort 6/17/2002 E 
Florida Panhandle AL Choctaw Unincorporated Areas 9/30/1988 C 
Florida Panhandle AL Dale Unincorporated Areas 7/4/1989 C 
Florida Panhandle AL Marengo Unincorporated Areas 1/17/1990 C 
Florida Panhandle AL Butler Unincorporated Areas 7/5/1982 D 
Florida Panhandle AL Dallas Unincorporated Areas 9/29/1986 D 
Florida Panhandle AL Lowndes Unincorporated Areas 8/15/1984 D 
Florida Panhandle AL Monroe Unincorporated Areas 6/4/1990 D 
Florida Panhandle AL Baldwin Unincorporated Areas 6/17/2002 D & E 
Florida Panhandle AL Mobile Unincorporated Areas 7/6/1998 D & E 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



67 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Florida Panhandle FL Holmes Bonifay 12/5/1990 C 
Florida Panhandle FL Washington Caryville 6/17/1991 D 
Florida Panhandle FL Okaloosa Cinco Bayou 12/6/2002 C 
Florida Panhandle FL Okaloosa Crestview 12/6/2002 D 
Florida Panhandle FL Okaloosa Destin 12/6/2002 E 
Florida Panhandle FL Washington Ebro 6/17/1991 D 
Florida Panhandle FL Okaloosa Fort Walton Beach 12/6/2002 E 
Florida Panhandle FL Walton Freeport 3/7/2000 C 
Florida Panhandle FL Escambia Gulf Breeze 1/19/2000 E 
Florida Panhandle FL Okaloosa Mary Esther 12/6/2002 C 
Florida Panhandle FL Santa Rosa Milton 7/18/1985 DE 
Florida Panhandle FL Okaloosa Niceville 12/6/2002 D & E 
Florida Panhandle FL Escambia Pensacola 7/17/2002 D & E 
Florida Panhandle FL Walton Ponce de Leon 12/5/1990 C 
Florida Panhandle FL Bay Unincorporated Areas 7/17/1995 C 
Florida Panhandle FL Washington Unincorporated Areas 6/17/1991 D 
Florida Panhandle FL Okaloosa Valparaiso 12/6/2002 C 
Florida Panhandle FL Washington Vernon 6/17/1991 D 
Florida Panhandle FL Holmes Westville 12/5/1990 C 
Florida Panhandle MS Perry Beaumont 8/16/1988 C 
Florida Panhandle MS Harrison Biloxi 3/15/1984 D 
Florida Panhandle MS Jackson Gautier 8/18/1992 E 
Florida Panhandle MS Harrison Gulfport 10/4/2002 D 
Florida Panhandle MS Greene Leakesville 9/30/1988 C 
Florida Panhandle MS Greene McLain 12/1/1983 C 
Florida Panhandle MS Jackson Moss Point 9/4/1987 D 
Florida Panhandle MS Jackson Ocean Springs 8/18/1992 E 
Florida Panhandle MS Jackson Pascagoula 3/15/1984 E 
Florida Panhandle MS George Unincorporated Areas 8/16/1988 C 
Florida Panhandle MS Wayne Unincorporated Areas 8/16/1988 C 
Florida Panhandle MS Greene Unincorporated Areas 5/2/1994 D 
Florida Panhandle MS Perry Unincorporated Areas 7/2/1991 D 
Florida Panhandle MS Harrison Unincorporated Areas 10/4/2002 E 
Florida Panhandle MS Jackson Unincorporated Areas 4/16/1993 E 
Florida Panhandle MS Wayne Waynesboro 8/16/1988 C 
Louisiana LA Vermilion Abbeville 8/3/1981 C 
Louisiana LA St. Tammany Abita Springs 5/17/1988 C 
Louisiana LA West Baton Rouge Addis 9/7/2000 C 
Louisiana LA Rapides Alexandria 9/3/1997 D 
Louisiana LA St. Mary Baldwin 12/15/1978 D 
Louisiana LA Rapides Ball 11/22/1999 C 
Louisiana LA Acadia Basile 1/15/1988 D 
Louisiana LA St. Mary Berwick 4/3/1995 C 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



68 

Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Louisiana LA Washington Bogalusa 5/4/1988 C 
Louisiana LA St. Martin Breaux Bridge 3/16/1988 C 
Louisiana LA St. Martin Broussard 1/20/1999 D 
Louisiana LA Lafayette Carencro 1/20/1999 D 
Louisiana LA Rapides Cheneyville 3/2/1981 D 
Louisiana LA Acadia Church Point 11/5/1980 D 
Louisiana LA Concordia Clayton 1/31/1980 D 
Louisiana LA East Feliciana Clinton 12/4/1979 D 
Louisiana LA St. Tammany Covington 11/19/1980 D 
Louisiana LA Acadia Crowley 7/27/1982 D 
Louisiana LA Iberia Delcambre 4/4/1983 D 
Louisiana LA East Baton Rouge Denham Springs 8/23/2001 D 
Louisiana LA Ascension Donaldsonville 5/15/1980 D 
Louisiana LA Lafayette Duson 1/20/1999 C 
Louisiana LA Jefferson Davis Elton 2/3/1982 D 
Louisiana LA Vermilion Erath 4/4/1983 C 
Louisiana LA Acadia Estherwood 2/4/1981 D 
Louisiana LA St. Landry Eunice 6/1/1981 D 
Louisiana LA Concordia Ferriday 12/15/1977 C 
Louisiana LA St. Mary Franklin 4/15/1992 C 
Louisiana LA Rapides Glenmora 2/3/1982 D 
Louisiana LA LaFourche Golden Meadow 7/11/1975 C 
Louisiana LA Ascension Gonzales 8/18/1992 C 
Louisiana LA St. Helena Greensburg 4/1/1980 D 
Louisiana LA Jefferson Gretna 3/23/1995 C 
Louisiana LA Iberville Grosse Tete 3/1/1978 C 
Louisiana LA Tangipahoa Hammond 7/21/1999 D 
Louisiana LA Jefferson Harahan 3/23/1995 C 
Louisiana LA Catahoula Harrisonburg 4/5/1988 C 
Louisiana LA St. Martin Henderson 5/3/1982 D 
Louisiana LA Terrebonne Houma 5/19/1981 C 
Louisiana LA East Feliciana Jackson 6/4/1980 D 
Louisiana LA Jefferson Jean Lafitte 3/23/1995 C 
Louisiana LA Jefferson Davis Jennings 4/15/1981 D 
Louisiana LA Catahoula Jonesville 3/1/1978 C 
Louisiana LA Jefferson Kenner 3/23/1995 E 
Louisiana LA Tangipahoa Kentwood 4/15/1980 D 
Louisiana LA Pointe Coupee Krotz Springs 1/15/1988 D 
Louisiana LA Lafayette Lafayette 1/20/1999 D 
Louisiana LA Jefferson Davis Lake Arthur 4/15/1981 D 
Louisiana LA Vermilion Lake Arthur 4/15/1981 D 
Louisiana LA Rapides Lecompte 6/2/1999 D 
Louisiana LA LaFourche Lockport 8/15/1980 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Louisiana LA St. Tammany Madisonville 3/16/1983 E 
Louisiana LA St. Tammany Mandeville 4/4/1983 E 
Louisiana LA Avoyelles Marksville 7/16/1980 C 
Louisiana LA St. Landry Melville 7/3/1978 D 
Louisiana LA Acadia Mermentau 3/2/1981 D 
Louisiana LA St. Mary Morgan City 5/20/1996 C 
Louisiana LA Acadia Morse 4/15/1981 C 
Louisiana LA Pointe Coupee New Roads 11/16/1995 D 
Louisiana LA St. Landry Opelousas 8/3/1981 D 
Louisiana LA St. Martin Parks 7/16/1980 D 
Louisiana LA St. Mary Patterson 5/2/1995 C 
Louisiana LA St. Tammany Pearl River 5/4/1988 C 
Louisiana LA Rapides Pineville 9/5/1984 C 
Louisiana LA West Baton Rouge Port Allen 9/7/2000 C 
Louisiana LA St. Landry Port Barre 4/15/1981 C 
Louisiana LA Ascension Port Vincent 8/23/2001 C 
Louisiana LA Acadia Rayne 12/14/1982 D 
Louisiana LA Concordia Ridgecrest 4/3/1978 D 
Louisiana LA Iberville Rosedale 2/26/1980 C 
Louisiana LA Lafayette Scott 1/20/1999 D 
Louisiana LA Avoyelles Simmesport 7/16/1980 C 
Louisiana LA St. Tammany Slidell 4/21/1999 D 
Louisiana LA Ascension Sorrento 12/28/1982 D 
Louisiana LA West Feliciana St. Francisville 5/2/1977 C 
Louisiana LA St. Martin St. Martinville 12/16/1980 D 
Louisiana LA Tangipahoa Tangipahoa 9/28/1979 D 
Louisiana LA LaFourche Thibodaux 12/15/1989 C 
Louisiana LA Tangipahoa Tickfaw 8/23/2000 D 
Louisiana LA Allen Unincorporated Areas 1/3/1990 C 
Louisiana LA Ascension Unincorporated Areas 1/20/1993 C 
Louisiana LA Catahoula Unincorporated Areas 5/4/2000 C 
Louisiana LA Iberville Unincorporated Areas 8/5/1991 C 
Louisiana LA LaFourche Unincorporated Areas 5/4/1992 C 
Louisiana LA St. Landry Unincorporated Areas 10/16/1991 C 
Louisiana LA West Baton Rouge Unincorporated Areas 9/7/2000 C 
Louisiana LA Concordia Unincorporated Areas 6/2/1994 D 
Louisiana LA East Baton Rouge Unincorporated Areas 5/17/1993 D 
Louisiana LA Grant Unincorporated Areas 11/16/1995 D 
Louisiana LA Jefferson Davis Unincorporated Areas 6/15/1988 D 
Louisiana LA Lafayette Unincorporated Areas 1/20/1999 D 
Louisiana LA Pointe Coupee Unincorporated Areas 11/16/1995 D 
Louisiana LA Rapides Unincorporated Areas 6/2/1999 D 
Louisiana LA St. Helena Unincorporated Areas 9/27/1991 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Louisiana LA St. Martin Unincorporated Areas 12/16/1980 D 
Louisiana LA Tangipahoa Unincorporated Areas 9/28/1979 D 
Louisiana LA Tensas Unincorporated Areas 4/3/1978 D 
Louisiana LA Terrebonne Unincorporated Areas 4/2/1992 D 
Louisiana LA Washington Unincorporated Areas 5/4/1988 D 
Louisiana LA Cameron Unincorporated Areas 5/4/1992 E 
Louisiana LA Jefferson Unincorporated Areas 3/23/1995 E 
Louisiana LA Plaquemines Unincorporated Areas 9/30/1993 E 
Louisiana LA St. Bernard Unincorporated Areas 6/30/1999 E 
Louisiana LA St. Charles Unincorporated Areas 6/16/1992 E 
Louisiana LA St. John the Baptist Unincorporated Areas 2/2/1983 E 
Louisiana LA St. Mary Unincorporated Areas 6/30/1999 E 
Louisiana LA Vermilion Unincorporated Areas 5/4/1992 E 
Louisiana LA Concordia Vidalia 1/5/1982 D 
Louisiana LA Livingston Walker 8/23/2001 D 
Louisiana LA Jefferson Westwego 3/23/1995 C 
Louisiana LA Lafayette Youngsville 1/20/1999 C 
Louisiana LA East Baton Rouge Zachary 8/3/1982 D 
Louisiana MS Lincoln Brookhaven 1/7/2000 D 
Louisiana MS Pike McComb 8/1/1979 D 
Louisiana MS Adams Natchez 9/29/1989 D 
Louisiana MS Pearl River Picayune 3/3/1992 D 
Louisiana MS Walthall Tylertown 1/16/1992 C 
Louisiana MS Copiah Unincorporated Areas 8/4/1988 C 
Louisiana MS Lawrence Unincorporated Areas 9/15/1989 C 
Louisiana MS Wilkinson Unincorporated Areas 7/16/1990 C 
Louisiana MS Adams Unincorporated Areas 9/29/1989 D 
Louisiana MS Claiborne Unincorporated Areas 5/1/1978 D 
Louisiana MS Lamar Unincorporated Areas 7/2/1991 D 
Louisiana MS Pearl River Unincorporated Areas 1/19/1996 D 
Louisiana MS Pike Unincorporated Areas 9/15/1989 D 
Louisiana MS Hancock Unincorporated Areas 8/18/1992 E 
Mid-Atlantic DE Sussex Bethany Beach 5/5/2003 E 
Mid-Atlantic DE Sussex Bethel 5/5/2003 D 
Mid-Atlantic DE Sussex Blades 5/5/2003 D 
Mid-Atlantic DE Kent Bowers 5/5/2003 D 
Mid-Atlantic DE Sussex Bridgeville 5/5/2003 D 
Mid-Atlantic DE Kent Camden 5/5/2003 D 
Mid-Atlantic DE New Castle Clayton 5/5/2003 D 
Mid-Atlantic DE Sussex Dagsboro 5/5/2003 D 
Mid-Atlantic DE New Castle Delaware City 5/5/2003 C 
Mid-Atlantic DE Sussex Dewey Beach 5/5/2003 E 
Mid-Atlantic DE Kent Dover 5/5/2003 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic DE New Castle Elsmere 5/5/2003 D 
Mid-Atlantic DE Sussex Fenwick Island 5/5/2003 E 
Mid-Atlantic DE Sussex Frankford 5/5/2003 D 
Mid-Atlantic DE Kent Frederica 5/5/2003 C 
Mid-Atlantic DE Sussex Greenwood 5/5/2003 D 
Mid-Atlantic DE Kent Harrington 5/5/2003 D 
Mid-Atlantic DE Sussex Henlopen Acres 5/5/2003 E 
Mid-Atlantic DE Sussex Laurel 5/5/2003 D 
Mid-Atlantic DE Kent Leipsic 5/5/2003 C 
Mid-Atlantic DE Sussex Lewes 5/5/2003 E 
Mid-Atlantic DE Kent Little Creek 5/5/2003 D 
Mid-Atlantic DE Sussex Milford 12/20/2000 D 
Mid-Atlantic DE Sussex Millsboro 5/5/2003 D 
Mid-Atlantic DE Sussex Millville 5/5/2003 D 
Mid-Atlantic DE Sussex Milton 5/5/2003 D 
Mid-Atlantic DE New Castle New Castle 5/5/2003 C 
Mid-Atlantic DE New Castle Newark 5/5/2003 D 
Mid-Atlantic DE New Castle Newport 5/5/2003 D 
Mid-Atlantic DE Sussex Ocean View 5/5/2003 D 
Mid-Atlantic DE Sussex Rehoboth Beach 5/5/2003 E 
Mid-Atlantic DE Sussex Seaford 5/5/2003 D 
Mid-Atlantic DE Sussex Selbyville 5/5/2003 D 
Mid-Atlantic DE Kent Smyrna 5/5/2003 D 
Mid-Atlantic DE Sussex South Bethany 5/5/2003 E 
Mid-Atlantic DE New Castle Unincorporated Areas 5/5/2003 D 
Mid-Atlantic DE Sussex Unincorporated Areas 5/5/2003 D & E 
Mid-Atlantic DE New Castle Wilmington 5/5/2003 D 
Mid-Atlantic DE Kent Wyoming 5/5/2003 D 
Mid-Atlantic MD Harford Aberdeen 1/7/2000 D 
Mid-Atlantic MD Worcester Berlin 9/18/1986 D 
Mid-Atlantic MD Queen Annes Centreville 9/27/1985 D 
Mid-Atlantic MD Cecil Charlestown 11/17/1982 C 
Mid-Atlantic MD Cecil Chesapeake City 10/15/1981 D 
Mid-Atlantic MD Kent Chestertown 2/15/1984 DE 
Mid-Atlantic MD Caroline Denton 12/18/1979 D 
Mid-Atlantic MD Talbot Easton 9/28/1984 D 
Mid-Atlantic MD Cecil Elkton 6/16/1992 D 
Mid-Atlantic MD Caroline Federalsburg 9/7/1998 D 
Mid-Atlantic MD Wicomico Fruitland 11/15/1985 D 
Mid-Atlantic MD Caroline Greensboro 11/1/1979 D 
Mid-Atlantic MD Cecil Havre de Grace 1/7/2000 D 
Mid-Atlantic MD Kent Millington 11/3/1982 D 
Mid-Atlantic MD Cecil North East 10/15/1981 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic MD Worcester Ocean City 2/4/1988 E 
Mid-Atlantic MD Cecil Perryville 9/30/1992 C 
Mid-Atlantic MD Cecil Port Deposit 2/16/1977 D 
Mid-Atlantic MD Queen Annes Queenstown 9/28/1984 D 
Mid-Atlantic MD Cecil Rising Sun 5/15/1986 D 
Mid-Atlantic MD Kent Rock Hall 9/1/1983 D 
Mid-Atlantic MD Wicomico Salisbury 9/28/1984 C 
Mid-Atlantic MD Dorchester Secretary 4/2/1992 C 
Mid-Atlantic MD Wicomico Sharptown 9/27/1985 C 
Mid-Atlantic MD Worcester Snow Hill 5/15/1980 D 
Mid-Atlantic MD Somerset Unincorporated Areas 7/20/1998 C 
Mid-Atlantic MD Caroline Unincorporated Areas 9/7/1998 D 
Mid-Atlantic MD Dorchester Unincorporated Areas 6/16/1992 D 
Mid-Atlantic MD Harford Unincorporated Areas 1/7/2000 D 
Mid-Atlantic MD Kent Unincorporated Areas 6/16/1992 D 
Mid-Atlantic MD Talbot Unincorporated Areas 6/16/1992 D 
Mid-Atlantic MD Queen Annes Unincorporated Areas 6/16/1992 D & E 
Mid-Atlantic MD Worcester Unincorporated Areas 4/21/1999 E 
Mid-Atlantic NJ Atlantic Absecon 8/23/1999 E 
Mid-Atlantic NJ Monmouth Allenhurst 9/15/1983 E 
Mid-Atlantic NJ Mercer Allentown 9/16/1981 C 
Mid-Atlantic NJ Monmouth Asbury Park 9/15/1983 D 
Mid-Atlantic NJ Atlantic Atlantic City 2/1/1985 E 
Mid-Atlantic NJ Cape May Avalon 2/2/1983 E 
Mid-Atlantic NJ Monmouth Avon-by-the-Sea 7/5/1983 E 
Mid-Atlantic NJ Ocean Barnegat 6/20/2000 C 
Mid-Atlantic NJ Ocean Bay Head 9/7/2000 E 
Mid-Atlantic NJ Hudson Bayonne 8/15/1983 C 
Mid-Atlantic NJ Ocean Beachwood 3/2/1983 D 
Mid-Atlantic NJ Essex Belleville 9/4/1987 D 
Mid-Atlantic NJ Camden Bellmawr 2/15/1980 C 
Mid-Atlantic NJ Monmouth Belmar 3/1/1984 E 
Mid-Atlantic NJ Morris Berkeley Heights 11/21/2001 D 
Mid-Atlantic NJ Morris Bernardsville 3/17/2003 D 
Mid-Atlantic NJ Burlington Beverly 2/5/1992 D 
Mid-Atlantic NJ Essex Bloomfield 9/4/1987 D 
Mid-Atlantic NJ Hunterdon Bloomsbury 12/1/1981 D 
Mid-Atlantic NJ Burlington Bordentown 2/2/1990 D 
Mid-Atlantic NJ Somerset Bound Brook 7/4/1988 D 
Mid-Atlantic NJ Monmouth Bradley Beach 6/15/1983 E 
Mid-Atlantic NJ Cumberland Bridgeton 1/18/1984 D 
Mid-Atlantic NJ Monmouth Brielle 9/30/1983 D 
Mid-Atlantic NJ Burlington Burlington 1/2/1987 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic NJ Hunterdon Califon 8/3/1981 D 
Mid-Atlantic NJ Camden Camden 12/1/1981 C 
Mid-Atlantic NJ Salem Carneys Point 6/1/1982 D 
Mid-Atlantic NJ Union Carteret 4/15/1992 C 
Mid-Atlantic NJ Essex Chatham 7/19/2001 D 
Mid-Atlantic NJ Gloucester Chester 4/1/1982 D 
Mid-Atlantic NJ Union Clark 9/2/1982 D 
Mid-Atlantic NJ Hunterdon Clinton 3/1/1984 D 
Mid-Atlantic NJ Camden Collingswood 3/19/1982 D 
Mid-Atlantic NJ Atlantic Corbin City 9/30/1981 C 
Mid-Atlantic NJ Middlesex Cranbury 5/17/1982 D 
Mid-Atlantic NJ Union Cranford 2/16/1983 D 
Mid-Atlantic NJ Monmouth Deal 8/6/2002 E 
Mid-Atlantic NJ Middlesex Dunellen 2/4/1988 D 
Mid-Atlantic NJ Middlesex East Brunswick 5/3/1990 D 
Mid-Atlantic NJ Essex East Newark 9/30/1977 C 
Mid-Atlantic NJ Essex East Orange 2/4/1988 D 
Mid-Atlantic NJ Bergen East Rutherford 9/20/1995 D 
Mid-Atlantic NJ Monmouth Eatontown 9/16/1981 C 
Mid-Atlantic NJ Middlesex Edison 6/19/1985 D 
Mid-Atlantic NJ Union Elizabeth 11/1/1985 D 
Mid-Atlantic NJ Monmouth Englishtown 3/16/1981 D 
Mid-Atlantic NJ Essex Essex Fells 1/2/1980 D 
Mid-Atlantic NJ Mercer Ewing 6/6/2001 D 
Mid-Atlantic NJ Monmouth Fair Haven 10/16/1979 C 
Mid-Atlantic NJ Monmouth Fairview 9/20/1995 D 
Mid-Atlantic NJ Somerset Far Hills 7/3/1978 D 
Mid-Atlantic NJ Hunterdon Flemington 7/16/1996 D 
Mid-Atlantic NJ Atlantic Folsom 1/6/1982 D 
Mid-Atlantic NJ Monmouth Freehold 4/4/1983 D 
Mid-Atlantic NJ Hunterdon Frenchtown 7/19/2001 D 
Mid-Atlantic NJ Union Garwood 5/17/1988 D 
Mid-Atlantic NJ Camden Gibbsboro 10/15/1981 D 
Mid-Atlantic NJ Hunterdon Glen Gardner 5/17/1982 D 
Mid-Atlantic NJ Hudson Guttenberg 7/16/1984 C 
Mid-Atlantic NJ Camden Haddonfield 12/23/1977 D 
Mid-Atlantic NJ Atlantic Hammonton 1/6/1982 D 
Mid-Atlantic NJ Hunterdon Hampton 2/2/1990 D 
Mid-Atlantic NJ Essex Harrison 9/30/1977 C 
Mid-Atlantic NJ Middlesex Helmetta 10/16/1984 D 
Mid-Atlantic NJ Hunterdon High Bridge 9/30/1981 D 
Mid-Atlantic NJ Middlesex Highland Park 6/1/1977 C 
Mid-Atlantic NJ Mercer Hightstown 3/15/1977 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic NJ Hudson Hoboken 11/17/1982 C 
Mid-Atlantic NJ Mercer Hopewell 6/6/2001 D 
Mid-Atlantic NJ Essex Irvington 11/14/1980 D 
Mid-Atlantic NJ Ocean Island Heights 5/16/1983 D 
Mid-Atlantic NJ Middlesex Jamesburg 5/15/1984 D 
Mid-Atlantic NJ Hudson Jersey City 3/1/1984 E 
Mid-Atlantic NJ Monmouth Keansburg 5/16/1983 E 
Mid-Atlantic NJ Bergen Kearny 12/1/1977 C 
Mid-Atlantic NJ Union Kenilworth 3/2/1983 D 
Mid-Atlantic NJ Monmouth Keyport 7/15/1992 D 
Mid-Atlantic NJ Ocean Lakehurst 12/15/1982 D 
Mid-Atlantic NJ Monmouth Lakewood 1/18/1989 D 
Mid-Atlantic NJ Hunterdon Lambertville 4/1/1981 D 
Mid-Atlantic NJ Camden Lawnside 9/1/1978 D 
Mid-Atlantic NJ Hunterdon Lebanon 2/3/1982 D 
Mid-Atlantic NJ Union Linden 3/2/1994 D 
Mid-Atlantic NJ Camden Lindenwold 9/17/1980 D 
Mid-Atlantic NJ Atlantic Linwood 1/19/1983 D 
Mid-Atlantic NJ Monmouth Little Silver 12/15/1982 E 
Mid-Atlantic NJ Essex Livingston 6/20/2001 D 
Mid-Atlantic NJ Monmouth Long Branch 1/5/1984 E 
Mid-Atlantic NJ Bergen Lyndhurst 9/20/1995 D 
Mid-Atlantic NJ Morris Madison 4/15/2002 D 
Mid-Atlantic NJ Monmouth Manasquan 12/15/1983 E 
Mid-Atlantic NJ Ocean Mantoloking 12/20/2000 E 
Mid-Atlantic NJ Somerset Manville 2/15/1978 D 
Mid-Atlantic NJ Essex Maplewood 8/15/1977 D 
Mid-Atlantic NJ Middlesex Matawan 9/30/1981 C 
Mid-Atlantic NJ Burlington Medford Lakes 6/1/1981 D 
Mid-Atlantic NJ Middlesex Metuchen 12/4/1979 D 
Mid-Atlantic NJ Middlesex Middlesex 3/18/1986 D 
Mid-Atlantic NJ Hunterdon Milford 11/18/1981 D 
Mid-Atlantic NJ Essex Millburn 3/17/2002 D 
Mid-Atlantic NJ Somerset Millstone 4/3/1978 D 
Mid-Atlantic NJ Middlesex Milltown 2/4/1981 D 
Mid-Atlantic NJ Cumberland Millville 6/15/1982 D 
Mid-Atlantic NJ Monmouth Monmouth Beach 7/15/1992 E 
Mid-Atlantic NJ Essex Montclair 8/4/1987 D 
Mid-Atlantic NJ Morris Morris Plains 7/5/2000 D 
Mid-Atlantic NJ Morris Morristown 7/3/1986 D 
Mid-Atlantic NJ Union Mountainside 2/16/1977 D 
Mid-Atlantic NJ Gloucester National Park 9/2/1982 D 
Mid-Atlantic NJ Middlesex New Brunswick 12/4/1979 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic NJ Morris New Providence 12/20/2001 D 
Mid-Atlantic NJ Union Newark 3/28/1980 D 
Mid-Atlantic NJ Essex North Arlington 9/20/1995 D 
Mid-Atlantic NJ Somerset North Plainfield 3/1/1984 C 
Mid-Atlantic NJ Essex Nutley 6/18/1987 D 
Mid-Atlantic NJ Cape May Ocean City 7/15/1992 E 
Mid-Atlantic NJ Ocean Ocean Gate 5/19/1981 C 
Mid-Atlantic NJ Monmouth Oceanport 2/16/1977 D 
Mid-Atlantic NJ Middlesex Old Bridge 8/3/1992 D 
Mid-Atlantic NJ Essex Orange 6/15/1984 D 
Mid-Atlantic NJ Burlington Palmyra 5/4/1992 D 
Mid-Atlantic NJ Gloucester Paulsboro 9/2/1982 D 
Mid-Atlantic NJ Morris Peapack and Gladstone 12/15/1977 D 
Mid-Atlantic NJ Burlington Pemberton 3/4/1980 D 
Mid-Atlantic NJ Salem Penns Grove 7/5/1982 C 
Mid-Atlantic NJ Burlington Pennsauken 10/16/1991 D 
Mid-Atlantic NJ Salem Pennsville 12/15/1982 D 
Mid-Atlantic NJ Warren Phillipsburg 7/19/2001 D 
Mid-Atlantic NJ Somerset Plainfield 7/16/1997 D 
Mid-Atlantic NJ Atlantic Pleasantville 1/19/1983 C 
Mid-Atlantic NJ Ocean Point Pleasant 6/13/1980 C 
Mid-Atlantic NJ Atlantic Port Republic 7/15/1992 D 
Mid-Atlantic NJ Union Rahway 12/20/2002 D 
Mid-Atlantic NJ Somerset Raritan 12/15/1981 D 
Mid-Atlantic NJ Monmouth Red Bank 5/19/1981 D 
Mid-Atlantic NJ Burlington Riverton 8/19/1991 D 
Mid-Atlantic NJ Somerset Rocky Hill 8/21/1981 D 
Mid-Atlantic NJ Essex Roseland 12/20/2001 D 
Mid-Atlantic NJ Union Roselle 7/17/1978 D 
Mid-Atlantic NJ Union Roselle Park 11/5/1997 D 
Mid-Atlantic NJ Monmouth Rumson 7/15/1992 E 
Mid-Atlantic NJ Camden Runnemede 1/2/1980 C 
Mid-Atlantic NJ Bergen Rutherford 9/20/1995 D 
Mid-Atlantic NJ Salem Salem 8/2/1982 D 
Mid-Atlantic NJ Middlesex Sayreville 1/16/1987 D 
Mid-Atlantic NJ Somerset Scotch Plains 1/19/2001 D 
Mid-Atlantic NJ Cape May Sea Isle City 1/6/1983 E 
Mid-Atlantic NJ Monmouth Shrewsbury 8/1/1979 D 
Mid-Atlantic NJ Atlantic Somers Point 11/17/1982 C 
Mid-Atlantic NJ Somerset Somerville 1/6/1983 D 
Mid-Atlantic NJ Middlesex South Amboy 9/4/1986 D 
Mid-Atlantic NJ Monmouth South Belmar 11/2/1995 C 
Mid-Atlantic NJ Middlesex South Bound Brook 9/30/1982 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic NJ Essex South Orange 7/18/1977 D 
Mid-Atlantic NJ Middlesex South Plainfield 8/1/1980 D 
Mid-Atlantic NJ Middlesex South River 9/18/1986 D 
Mid-Atlantic NJ Ocean South Toms River 1/6/1983 D 
Mid-Atlantic NJ Middlesex Spotswood 2/16/1990 D 
Mid-Atlantic NJ Monmouth Spring Lake Heights 12/15/1981 D 
Mid-Atlantic NJ Essex Springfield 8/2/1982 D 
Mid-Atlantic NJ Hunterdon Stockton 6/6/2001 D 
Mid-Atlantic NJ Camden Stratford 9/17/1980 D 
Mid-Atlantic NJ Essex Summit 5/2/2002 D 
Mid-Atlantic NJ Gloucester Swedesboro 7/5/1982 D 
Mid-Atlantic NJ Monmouth Tinton Falls 4/15/1982 D 
Mid-Atlantic NJ Mercer Trenton 2/2/1990 D 
Mid-Atlantic NJ Ocean Tuckerton 5/2/1983 D 
Mid-Atlantic NJ Camden Unincorporated Areas 12/1/1981 C 
Mid-Atlantic NJ Burlington Unincorporated Areas 1/2/1987 D 
Mid-Atlantic NJ Essex Unincorporated Areas 1/2/1980 D 
Mid-Atlantic NJ Gloucester Unincorporated Areas 12/1/1982 D 
Mid-Atlantic NJ Middlesex Unincorporated Areas 3/18/1986 D 
Mid-Atlantic NJ Morris Unincorporated Areas 7/3/1986 D 
Mid-Atlantic NJ Salem Unincorporated Areas 8/2/1982 D 
Mid-Atlantic NJ Union Unincorporated Areas 8/1/1978 D 
Mid-Atlantic NJ Warren Unincorporated Areas 1/4/2002 D 
Mid-Atlantic NJ Monmouth Unincorporated Areas 7/15/1992 E 
Mid-Atlantic NJ Ocean Unincorporated Areas 7/15/1992 E 
Mid-Atlantic NJ Union Union 8/1/1978 D 
Mid-Atlantic NJ Monmouth Union Beach 7/15/1992 E 
Mid-Atlantic NJ Essex Verona 2/15/1980 D 
Mid-Atlantic NJ Atlantic Vineland 7/5/1982 D 
Mid-Atlantic NJ Cumberland Vineland 7/5/1982 D 
Mid-Atlantic NJ Union Watchung 8/20/2002 D 
Mid-Atlantic NJ Monmouth West Long Branch 1/16/1981 D 
Mid-Atlantic NJ Hudson West New York 5/1/1984 C 
Mid-Atlantic NJ Essex West Orange 12/12/1980 D 
Mid-Atlantic NJ Union Westfield 12/18/1979 D 
Mid-Atlantic NJ Middlesex Woodbridge 9/1/1983 D 
Mid-Atlantic NJ Camden Woodlynne 12/1/1981 D 
Mid-Atlantic NY Nassau Cedarhurst 7/16/1997 D 
Mid-Atlantic NY Nassau Freeport 4/2/1997 C 
Mid-Atlantic NY Nassau Hewlett Bay Park 7/16/1997 C 
Mid-Atlantic NY Nassau Hewlett Neck 7/16/1997 E 
Mid-Atlantic NY Nassau Malverne 4/2/1997 D 
Mid-Atlantic NY Kings New York 5/21/2001 D & E 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic NY Nassau Rockville Centre 4/2/1997 C 
Mid-Atlantic NY Queens Unincorporated Areas 8/16/1996 D 
Mid-Atlantic NY Queens Valley Stream 7/16/1997 D 
Mid-Atlantic NY Nassau Woodsburgh 7/16/1997 C 
Mid-Atlantic PA Delaware Aldan 9/30/1993 D 
Mid-Atlantic PA Lehigh Allentown 7/2/2003 D 
Mid-Atlantic PA Montgomery Ambler 10/19/2001 D 
Mid-Atlantic PA Chester Atglen 3/17/2002 D 
Mid-Atlantic PA Chester Avondale 3/17/2002 D 
Mid-Atlantic PA Berks Bechtelsville 5/21/2001 D 
Mid-Atlantic PA Northampton Bethlehem 4/6/2001 D 
Mid-Atlantic PA Berks Birdsboro 5/21/2001 D 
Mid-Atlantic PA Montgomery Bridgeport 10/19/2001 D 
Mid-Atlantic PA Bucks Bristol 6/20/2001 D 
Mid-Atlantic PA Delaware Brookhaven 9/30/1993 D 
Mid-Atlantic PA Montgomery Bryn Athyn 10/19/2001 D 
Mid-Atlantic PA Bucks Chalfont 6/20/2001 D 
Mid-Atlantic PA Delaware Chester 9/30/1993 D 
Mid-Atlantic PA Delaware Chester Heights 9/30/1993 D 
Mid-Atlantic PA Lancaster Christiana 4/15/1981 D 
Mid-Atlantic PA Delaware Clifton Heights 9/30/1993 D 
Mid-Atlantic PA Chester Coatesville 3/17/2002 D 
Mid-Atlantic PA Montgomery Collegeville 10/19/2001 D 
Mid-Atlantic PA Delaware Collingdale 9/30/1993 D 
Mid-Atlantic PA Delaware Colwyn 9/30/1993 D 
Mid-Atlantic PA Montgomery Conshohocken 10/19/2001 D 
Mid-Atlantic PA Delaware Darby 9/30/1993 D 
Mid-Atlantic PA Bucks Doylestown 6/20/2001 D 
Mid-Atlantic PA Montgomery East Norriton 10/19/2001 D 
Mid-Atlantic PA Northampton Easton 4/6/2001 D 
Mid-Atlantic PA Delaware Eddystone 9/30/1993 D 
Mid-Atlantic PA Lehigh Emmaus 11/7/2001 D 
Mid-Atlantic PA Delaware Folcroft 9/30/1993 D 
Mid-Atlantic PA Lehigh Fountain Hill 11/7/2001 D 
Mid-Atlantic PA Northampton Freemansburg 4/6/2001 D 
Mid-Atlantic PA Montgomery Green Lane 10/19/2001 D 
Mid-Atlantic PA Bucks Hatboro 10/19/2001 D 
Mid-Atlantic PA Montgomery Hatfield 10/19/2001 D 
Mid-Atlantic PA Bucks Horsham 10/19/2001 D 
Mid-Atlantic PA Montgomery Jenkintown 10/19/2001 C 
Mid-Atlantic PA Chester Kennett Square 3/17/2002 D 
Mid-Atlantic PA Bucks Langhorne 4/2/2002 D 
Mid-Atlantic PA Bucks Langhorne Manor 4/2/2002 D 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic PA Montgomery Lansdale 10/19/2001 D 
Mid-Atlantic PA Delaware Lansdowne 9/30/1993 D 
Mid-Atlantic PA Lehigh Macungie 11/7/2001 D 
Mid-Atlantic PA Delaware Marcus Hook 9/30/1993 D 
Mid-Atlantic PA Delaware Media 9/30/1993 D 
Mid-Atlantic PA Chester Modena 3/17/2002 C 
Mid-Atlantic PA Bucks Morrisville 6/20/2001 D 
Mid-Atlantic PA Delaware Morton 9/30/1993 D 
Mid-Atlantic PA Bucks New Britain 6/20/2001 D 
Mid-Atlantic PA Bucks New Hope 6/20/2001 D 
Mid-Atlantic PA Bucks Newtown 6/20/2001 D 
Mid-Atlantic PA Montgomery Norristown 10/19/2001 D 
Mid-Atlantic PA Montgomery North Wales 10/19/2001 C 
Mid-Atlantic PA Delaware Norwood 9/30/1993 C 
Mid-Atlantic PA Lancaster Paradise 9/2/1988 C 
Mid-Atlantic PA Chester Parkesburg 3/17/2002 D 
Mid-Atlantic PA Delaware Parkside 9/30/1993 D 
Mid-Atlantic PA Montgomery Pennsburg 10/19/2001 D 
Mid-Atlantic PA Bucks Perkasie 6/20/2001 D 
Mid-Atlantic PA Philadelphia Philadelphia 8/2/1996 D 
Mid-Atlantic PA Montgomery Phoenixville 3/17/2002 D 
Mid-Atlantic PA Montgomery Pottstown 10/19/2001 D 
Mid-Atlantic PA Delaware Prospect Park 9/30/1993 D 
Mid-Atlantic PA Bucks Quakertown 6/20/2001 D 
Mid-Atlantic PA Delaware Ridley Park 9/30/1993 D 
Mid-Atlantic PA Bucks Riegelsville 6/20/2001 D 
Mid-Atlantic PA Delaware Rose Valley 9/30/1993 D 
Mid-Atlantic PA Montgomery Royersford 10/19/2001 D 
Mid-Atlantic PA Delaware Rutledge 9/30/1993 D 
Mid-Atlantic PA Montgomery Schwenksville 10/19/2001 D 
Mid-Atlantic PA Bucks Sellersville 6/20/2001 D 
Mid-Atlantic PA Philadelphia Sharon Hill 9/30/1993 D 
Mid-Atlantic PA Montgomery Skippack 10/19/2001 D 
Mid-Atlantic PA Chester South Coatesville 3/17/2002 D 
Mid-Atlantic PA Montgomery Spring City 3/17/2002 D 
Mid-Atlantic PA Delaware Springfield 10/19/2001 D 
Mid-Atlantic PA Berks St. Lawrence 5/21/2001 D 
Mid-Atlantic PA Montgomery Stowe 9/21/2001 D 
Mid-Atlantic PA Delaware Swarthmore 9/30/1993 D 
Mid-Atlantic PA Delaware Trainer 9/30/1993 D 
Mid-Atlantic PA Montgomery Trappe 10/19/2001 D 
Mid-Atlantic PA Bucks Tullytown 6/20/2001 D 
Mid-Atlantic PA Northampton Unincorporated Areas 4/3/1987 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mid-Atlantic PA Philadelphia Unincorporated Areas 8/2/1996 D 
Mid-Atlantic PA Delaware Upland 9/30/1993 D 
Mid-Atlantic PA Chester West Chester 3/17/2002 D 
Mid-Atlantic PA Montgomery West Conshohocken 10/19/2001 D 
Mid-Atlantic PA Northampton West Easton 4/6/2001 D 
Mid-Atlantic PA Chester West Goshen 3/17/2002 D 
Mid-Atlantic PA Montgomery West Norriton 10/19/2001 D 
Mid-Atlantic PA Bucks Yardley 6/20/2001 D 
Mid-Atlantic PA Delaware Yeadon 9/30/1993 D 
Mississippi River IL St. Clair Alorton 6/4/1980 D 
Mississippi River IL Madison Alton 5/1/1984 D 
Mississippi River IL St. Clair Belleville 11/19/1980 D 
Mississippi River IL Madison Bethalto 7/2/1980 D 
Mississippi River IL Scott Bluffs 6/15/1981 D 
Mississippi River IL Madison Brooklyn 3/28/1980 D 
Mississippi River IL Calhoun Brussels 2/4/1981 D 
Mississippi River IL Jackson Carbondale 11/1/1979 D 
Mississippi River IL St. Clair Caseyville 3/16/1981 D 
Mississippi River IL Marion Central City 3/18/1996 D 
Mississippi River IL Washington Centralia 12/18/1984 D 
Mississippi River IL St. Clair Centreville 3/4/1980 C 
Mississippi River IL Cass Chandlerville 9/18/1986 D 
Mississippi River IL Sangamon Chatham 9/2/1981 D 
Mississippi River IL Randolph Chester 11/16/1983 C 
Mississippi River IL St. Clair Collinsville 2/18/1981 D 
Mississippi River IL St. Clair Columbia 3/17/2003 D 
Mississippi River IL Jackson Dowell 12/5/1989 C 
Mississippi River IL St. Clair Dupo 2/4/1981 D 
Mississippi River IL Madison East Alton 3/18/1980 D 
Mississippi River IL St. Clair East Carondelet 3/2/1981 D 
Mississippi River IL St. Clair East St. Louis 11/1/1979 D 
Mississippi River IL Madison Edwardsville 1/18/1984 D 
Mississippi River IL Greene Eldred 8/1/1983 D 
Mississippi River IL Jackson Elkville 12/18/1984 D 
Mississippi River IL Jersey Elsah 2/18/1981 D 
Mississippi River IL Randolph Evansville 4/15/1988 C 
Mississippi River IL St. Clair Fairmont City 3/28/1980 D 
Mississippi River IL St. Clair Fayetteville 6/15/1981 D 
Mississippi River IL Pike Florence 8/15/1983 D 
Mississippi River IL Monroe Fults 9/4/1985 C 
Mississippi River IL Jersey Grafton 10/23/1981 D 
Mississippi River IL Madison Granite City 6/1/1978 C 
Mississippi River IL Calhoun Hamburg 2/15/1984 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mississippi River IL Greene Hardin 8/1/1983 D 
Mississippi River IL Madison Hartford 5/1/1979 D 
Mississippi River IL Williamson Herrin 4/16/1990 C 
Mississippi River IL Madison Highland 11/5/1986 D 
Mississippi River IL Greene Hillview 9/30/1983 D 
Mississippi River IL Pike Hull 9/18/1986 C 
Mississippi River IL Morgan Jacksonville 6/2/1994 D 
Mississippi River IL Sangamon Jerome 11/16/1983 D 
Mississippi River IL Williamson Johnston City 4/1/1982 D 
Mississippi River IL Calhoun Kampsville 8/1/1983 D 
Mississippi River IL Greene Kampsville 8/1/1983 D 
Mississippi River IL Randolph Kaskaskia 9/4/1985 C 
Mississippi River IL St. Clair Lebanon 7/2/1981 D 
Mississippi River IL Sangamon Leland Grove 12/16/1982 D 
Mississippi River IL St. Clair Madison 7/16/1980 D 
Mississippi River IL Union Makanda 3/15/1982 D 
Mississippi River IL Williamson Marion 9/15/1983 D 
Mississippi River IL St. Clair Mascoutah 6/15/1981 D 
Mississippi River IL Morgan Meredosia 4/15/1982 D 
Mississippi River IL Jefferson Mount Vernon 2/15/1984 D 
Mississippi River IL Pike Nebo 8/1/1984 D 
Mississippi River IL Sangamon Pawnee 5/3/1982 C 
Mississippi River IL Pike Pearl 9/5/1984 D 
Mississippi River IL Menard Petersburg 9/18/1986 D 
Mississippi River IL Perry Pinckneyville 9/16/1982 D 
Mississippi River IL Sangamon Pleasant Plains 9/2/1981 C 
Mississippi River IL Madison Pontoon Beach 2/5/1982 D 
Mississippi River IL Randolph Prairie du Rocher 9/4/1985 C 
Mississippi River IL Adams Quincy 10/15/1981 D 
Mississippi River IL Sangamon Riverton 12/1/1981 D 
Mississippi River IL Sangamon Rochester 6/15/1982 D 
Mississippi River IL Randolph Rockwood 11/16/1983 C 
Mississippi River IL Madison Roxana 5/1/1979 D 
Mississippi River IL Marion Salem 5/1/1979 D 
Mississippi River IL St. Clair Sauget 7/9/1982 D 
Mississippi River IL Madison South Roxana 11/26/1982 D 
Mississippi River IL Sangamon Springfield 2/2/1982 D 
Mississippi River IL St. Clair Swansea 12/1/1981 D 
Mississippi River IL Sangamon Thayer 5/3/1982 C 
Mississippi River IL Brown Unincorporated Areas 11/1/1985 C 
Mississippi River IL Calhoun Unincorporated Areas 2/1/1984 C 
Mississippi River IL Cass Unincorporated Areas 11/15/1985 C 
Mississippi River IL Menard Unincorporated Areas 9/2/1988 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mississippi River IL Randolph Unincorporated Areas 6/3/1986 C 
Mississippi River IL Schuyler Unincorporated Areas 7/18/1985 C 
Mississippi River IL Union Unincorporated Areas 2/19/1986 C 
Mississippi River IL Adams Unincorporated Areas 1/19/1996 D 
Mississippi River IL Clinton Unincorporated Areas 9/29/1989 D 
Mississippi River IL Fayette Unincorporated Areas 6/15/1981 D 
Mississippi River IL Greene Unincorporated Areas 8/5/1985 D 
Mississippi River IL Madison Unincorporated Areas 7/16/1980 D 
Mississippi River IL Monroe Unincorporated Areas 3/17/2003 D 
Mississippi River IL Morgan Unincorporated Areas 1/17/1986 D 
Mississippi River IL Pike Unincorporated Areas 1/3/1986 D 
Mississippi River IL Sangamon Unincorporated Areas 1/6/1983 D 
Mississippi River IL Scott Unincorporated Areas 1/3/1986 D 
Mississippi River IL St. Clair Unincorporated Areas 8/5/1985 D 
Mississippi River IL Pike Valley City 8/1/1983 D 
Mississippi River IL Monroe Valmeyer 9/4/1985 C 
Mississippi River IL Madison Venice 1/5/1978 C 
Mississippi River IL Franklin West Frankfort 5/16/1983 D 
Mississippi River IL Greene Wilmington 3/17/2003 D 
Mississippi River IL Madison Wood River 5/1/1979 D 
Mississippi River MO Pike Annada 11/19/1986 C 
Mississippi River MO St. Louis Arnold 10/16/1996 D 
Mississippi River MO St. Louis Ballwin 8/23/2000 D 
Mississippi River MO St. Louis City Bellefontaine Neighbors 8/23/2000 D 
Mississippi River MO St. Louis Bel-Ridge 8/23/2000 D 
Mississippi River MO Franklin Berger 6/15/1982 C 
Mississippi River MO St. Louis Berkeley 8/23/2000 D 
Mississippi River MO St. Louis Black Jack 8/23/2000 D 
Mississippi River MO Pike Bowling Green 5/2/1977 D 
Mississippi River MO St. Louis Breckenridge Hills 8/23/2000 D 
Mississippi River MO St. Louis Brentwood 8/23/2000 D 
Mississippi River MO Cape Girardeau Cape Girardeau 11/5/1980 D 
Mississippi River MO Osage Chamois 3/18/1987 C 
Mississippi River MO St. Louis Chesterfield 8/23/2000 D 
Mississippi River MO St. Louis Clarkson Valley 8/23/2000 D 
Mississippi River MO Pike Clarksville 4/1/1977 C 
Mississippi River MO St. Louis City Clayton 8/23/2000 D 
Mississippi River MO Boone Columbia 8/16/1995 D 
Mississippi River MO St. Louis Cool Valley 8/23/2000 D 
Mississippi River MO St. Charles Cottleville 3/17/2003 D 
Mississippi River MO St. Louis Crestwood 8/23/2000 D 
Mississippi River MO St. Louis Creve Coeur 8/23/2000 D 
Mississippi River MO Jefferson Crystal City 12/28/1982 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mississippi River MO St. Charles Dardenne Prairie 3/17/2003 D 
Mississippi River MO Jefferson De Soto 8/6/2002 D 
Mississippi River MO St. Louis Des Peres 8/23/2000 D 
Mississippi River MO Reynolds Ellington 1/16/1981 D 
Mississippi River MO Lincoln Elsberry 11/4/1988 D 
Mississippi River MO Jefferson Eureka 8/23/2000 D 
Mississippi River MO St. Francois Farmington 1/16/1981 D 
Mississippi River MO St. Louis Fenton 8/23/2000 D 
Mississippi River MO St. Louis Ferguson 8/23/2000 D 
Mississippi River MO Jefferson Festus 1/2/1981 D 
Mississippi River MO St. Louis Florissant 8/23/2000 D 
Mississippi River MO Lincoln Foley 3/1/1978 D 
Mississippi River MO Madison Fredericktown 12/6/2002 D 
Mississippi River MO St. Louis Frontenac 8/23/2000 D 
Mississippi River MO Callaway Fulton 5/15/1986 D 
Mississippi River MO Gasconade Gasconade 12/18/1984 C 
Mississippi River MO Bollinger Glen Allen 8/15/1990 D 
Mississippi River MO St. Louis Grantwood Village 8/23/2000 D 
Mississippi River MO St. Louis Hanley Hills 8/23/2000 D 
Mississippi River MO Marion Hannibal 3/1/1982 D 
Mississippi River MO Boone Hartsburg 8/16/1982 D 
Mississippi River MO St. Louis Hazelwood 8/23/2000 D 
Mississippi River MO Jefferson Herculaneum 11/17/1993 D 
Mississippi River MO Gasconade Hermann 4/23/1976 D 
Mississippi River MO Iron Ironton 12/4/1984 C 
Mississippi River MO Cape Girardeau Jackson 1/3/1986 D 
Mississippi River MO Callaway Jefferson City 10/6/1981 D 
Mississippi River MO St. Louis City Jennings 8/23/2000 D 
Mississippi River MO Jefferson Kimmswick 1/6/1982 D 
Mississippi River MO St. Louis Kirkwood 8/23/2000 D 
Mississippi River MO St. Louis Ladue 8/23/2000 D 
Mississippi River MO St. Charles Lake St. Louis 3/17/2003 D 
Mississippi River MO Pike Louisiana 4/3/1978 D 
Mississippi River MO St. Louis Mackenzie 8/23/2000 D 
Mississippi River MO St. Louis Manchester 8/23/2000 D 
Mississippi River MO St. Louis City Maplewood 8/23/2000 D 
Mississippi River MO Bollinger Marble Hill 8/15/1990 D 
Mississippi River MO St. Louis Maryland Heights 8/23/2000 D 
Mississippi River MO Audrain Mexico 2/16/1983 D 
Mississippi River MO Callaway Mokane 9/18/1986 D 
Mississippi River MO St. Louis Moline Acres 8/23/2000 D 
Mississippi River MO Gasconade Morrison 9/18/1986 C 
Mississippi River MO Franklin New Haven 2/18/1981 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mississippi River MO Phelps Newburg 2/20/1976 C 
Mississippi River MO St. Louis Northwoods 8/23/2000 D 
Mississippi River MO St. Louis Oakland 8/23/2000 D 
Mississippi River MO St. Charles O'Fallon 3/17/2003 D 
Mississippi River MO St. Charles Old Monroe 6/5/1985 D 
Mississippi River MO St. Louis Olivette 8/23/2000 D 
Mississippi River MO St. Louis Overland 8/23/2000 D 
Mississippi River MO St. Louis Pacific 2/19/1992 D 
Mississippi River MO St. Louis City Pagedale 8/23/2000 D 
Mississippi River MO St. Francois Park Hills 2/18/1998 D 
Mississippi River MO St. Charles Portage Des Sioux 3/17/2003 D 
Mississippi River MO St. Louis City Richmond Heights 8/2/1995 D 
Mississippi River MO St. Louis City Riverview 8/23/2000 D 
Mississippi River MO St. Louis Rock Hill 8/23/2000 D 
Mississippi River MO Phelps Rolla 12/17/1993 D 
Mississippi River MO Dent Salem 8/1/1979 D 
Mississippi River MO St. Louis Shrewsbury 8/23/2000 D 
Mississippi River MO Lincoln Silex 9/16/1982 D 
Mississippi River MO St. Louis St. Charles 3/17/2003 D 
Mississippi River MO St. Louis City St. Louis 3/15/1993 D 
Mississippi River MO Ste. Genevieve St. Mary 8/16/1988 C 
Mississippi River MO St. Charles St. Paul 3/17/2003 D 
Mississippi River MO St. Charles St. Peters 3/17/2003 D 
Mississippi River MO Ste. Genevieve Ste. Genevieve 9/30/1977 C 
Mississippi River MO Crawford Steelville 12/6/2002 D 
Mississippi River MO Franklin Sullivan 6/15/1981 D 
Mississippi River MO St. Louis Sunset Hills 8/23/2000 D 
Mississippi River MO St. Louis Town and Country 8/23/2000 D 
Mississippi River MO Lincoln Troy 5/5/1981 D 
Mississippi River MO Gasconade Unincorporated Areas 12/18/1984 C 
Mississippi River MO Iron Unincorporated Areas 12/4/1984 C 
Mississippi River MO Marion Unincorporated Areas 5/16/1977 C 
Mississippi River MO Ste. Genevieve Unincorporated Areas 9/30/1977 C 
Mississippi River MO Bollinger Unincorporated Areas 8/15/1990 D 
Mississippi River MO Boone Unincorporated Areas 6/15/1983 D 
Mississippi River MO Cape Girardeau Unincorporated Areas 11/5/1980 D 
Mississippi River MO Franklin Unincorporated Areas 10/16/1984 D 
Mississippi River MO Jefferson Unincorporated Areas 10/6/1981 D 
Mississippi River MO Pulaski Unincorporated Areas 3/17/2002 D 
Mississippi River MO St. Charles Unincorporated Areas 3/17/2003 D 
Mississippi River MO St. Louis Unincorporated Areas 3/15/1993 D 
Mississippi River MO Washington Unincorporated Areas 11/3/1982 D 
Mississippi River MO Franklin Union 3/2/1983 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Mississippi River MO St. Louis City University City 8/23/2000 D 
Mississippi River MO St. Louis Valley Park 8/23/2000 D 
Mississippi River MO Audrain Vandalia 2/4/1988 C 
Mississippi River MO Warren Washington 11/3/1982 D 
Mississippi River MO St. Louis Webster Groves 8/23/2000 D 
Mississippi River MO St. Louis Weldon Spring 3/17/2003 D 
Mississippi River MO St. Louis City Wellston 8/23/2000 D 
Mississippi River MO St. Charles Wentzville 3/17/2003 D 
Mississippi River MO St. Louis West Alton 3/17/2003 D 
Mississippi River MO St. Louis Westwood 8/23/2000 D 
Mississippi River MO St. Louis Winchester 8/23/2000 D 
Mississippi River MO Lincoln Winfield 11/17/1982 D 
Southwest AZ Maricopa Apache Junction 3/19/1990 D 
Southwest AZ Maricopa Avondale 7/19/2001 D 
Southwest AZ Maricopa Buckeye 7/19/2001 D 
Southwest AZ Yavapai Camp Verde 6/6/2001 D 
Southwest AZ Maricopa Carefree 7/19/2001 D 
Southwest AZ Pinal Casa Grande 9/29/1989 D 
Southwest AZ Maricopa Cave Creek 7/19/2001 D 
Southwest AZ Maricopa Chandler 7/19/2001 C 
Southwest AZ Yavapai Chino Valley 6/6/2001 D 
Southwest AZ Yavapai Clarkdale 6/6/2001 D 
Southwest AZ Yavapai Cottonwood 6/6/2001 D 
Southwest AZ Maricopa El Mirage 7/19/2001 D 
Southwest AZ Pinal Florence 8/17/1981 D 
Southwest AZ Maricopa Fountain Hills 7/19/2001 D 
Southwest AZ Maricopa Gila Bend 7/19/2001 D 
Southwest AZ Maricopa Gilbert 7/19/2001 C 
Southwest AZ Maricopa Glendale 7/19/2001 D 
Southwest AZ Gila Globe 5/1/1980 D 
Southwest AZ Maricopa Goodyear 7/19/2001 D 
Southwest AZ Pinal Kearny 8/17/1981 D 
Southwest AZ Pima Marana 2/8/1999 D 
Southwest AZ Pinal Mesa 7/19/2001 D 
Southwest AZ Gila Miami 5/1/1980 D 
Southwest AZ Maricopa Paradise Valley 7/19/2001 D 
Southwest AZ Gila Payson 3/18/1980 D 
Southwest AZ Yavapai Peoria 7/19/2001 D 
Southwest AZ Maricopa Phoenix 7/19/2001 D 
Southwest AZ Yavapai Prescott 6/6/2001 D 
Southwest AZ Yavapai Prescott Valley 6/6/2001 D 
Southwest AZ La Paz Quartzsite 12/22/1998 D 
Southwest AZ Maricopa Queen Creek 7/19/2001 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Southwest AZ Maricopa Scottsdale 7/19/2001 D 
Southwest AZ Pinal Superior 11/4/1981 D 
Southwest AZ Maricopa Surprise 7/19/2001 D 
Southwest AZ Maricopa Tempe 7/19/2001 D 
Southwest AZ Maricopa Tolleson 7/19/2001 C 
Southwest AZ Yuma Unincorporated Areas 11/15/1985 C 
Southwest AZ Coconino Unincorporated Areas 9/30/1995 D 
Southwest AZ Gila Unincorporated Areas 7/19/2001 D 
Southwest AZ La Paz Unincorporated Areas 3/4/2002 D 
Southwest AZ Maricopa Unincorporated Areas 7/19/2001 D 
Southwest AZ Mohave Unincorporated Areas 10/20/2000 D 
Southwest AZ Pima Unincorporated Areas 2/8/1999 D 
Southwest AZ Pinal Unincorporated Areas 3/5/1990 D 
Southwest AZ Yavapai Unincorporated Areas 6/6/2001 D 
Southwest AZ Maricopa Wickenburg 7/19/2001 D 
Southwest AZ Maricopa Youngtown 7/19/2001 D 
Texas -Coastal LA Calcasieu Unincorporated Areas 6/8/1998 D 
Texas -Coastal LA Cameron Unincorporated Areas 5/4/1992 E 
Texas -Coastal TX Galveston Alvin 9/22/1999 D & E 
Texas -Coastal TX Chambers Anahuac 1/6/1983 E 
Texas -Coastal TX Brazoria Angleton 9/22/1999 D 
Texas -Coastal TX Matagorda Bay City 6/5/1985 D 
Texas -Coastal TX Harris Baytown 4/20/2000 D & E 
Texas -Coastal TX Chambers Beach City 1/19/1983 E 
Texas -Coastal TX Jefferson Beaumont 8/6/2002 D 
Texas -Coastal TX Austin Bellville 6/16/1999 D 
Texas -Coastal TX Jefferson Bevil Oaks 9/4/1987 D 
Texas -Coastal TX Brazoria Bonney 9/22/1999 D 
Texas -Coastal TX Brazoria Brazoria 9/22/1999 D 
Texas -Coastal TX Washington Brenham 8/17/1981 D 
Texas -Coastal TX Orange Bridge City 9/2/1982 C 
Texas -Coastal TX Waller Brookshire 2/17/1989 D 
Texas -Coastal TX Brazoria Brookside Village 9/22/1999 D 
Texas -Coastal TX Galveston Clear Lake Shores 4/4/1983 C 
Texas -Coastal TX Liberty Cleveland 8/4/1987 D 
Texas -Coastal TX Brazoria Clute 9/22/1999 D 
Texas -Coastal TX Montgomery Conroe 9/22/1999 D 
Texas -Coastal TX Brazoria Danbury 9/22/1999 D 
Texas -Coastal TX Liberty Dayton 9/30/1988 D 
Texas -Coastal TX Liberty Dayton Lakes 11/15/1989 D 
Texas -Coastal TX Harris Deer Park 4/20/2000 D 
Texas -Coastal TX Galveston Dickinson 3/4/1991 D 
Texas -Coastal TX Jackson Edna 7/5/1982 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Texas -Coastal TX Wharton El Campo 3/1/1983 D 
Texas -Coastal TX Harris El Lago 4/20/2000 D & E 
Texas -Coastal TX Brazoria Freeport 9/22/1999 D & E 
Texas -Coastal TX Harris Friendswood 9/22/1999 D 
Texas -Coastal TX Harris Galena Park 4/20/2000 D 
Texas -Coastal TX Galveston Galveston 12/6/2002 D & E 
Texas -Coastal TX Jackson Ganado 9/28/1979 C 
Texas -Coastal TX Jefferson Groves 1/6/1983 C 
Texas -Coastal TX Waller Hempstead 6/15/1981 D 
Texas -Coastal TX Harris Hilshire Village 4/20/2000 D 
Texas -Coastal TX Galveston Hitchcock 4/4/1983 C 
Texas -Coastal TX Brazoria Holiday Lakes 9/22/1999 D 
Texas -Coastal TX Montgomery Houston 4/20/2000 D & E 
Texas -Coastal TX Harris Humble 4/20/2000 D 
Texas -Coastal TX Walker Huntsville 5/7/2001 D 
Texas -Coastal TX Brazoria Iowa Colony 9/22/1999 D 
Texas -Coastal TX Harris Jacinto City 4/20/2000 D 
Texas -Coastal TX Galveston Jamaica Beach 12/6/2002 E 
Texas -Coastal TX Harris Jersey Village 4/20/2000 D 
Texas -Coastal TX Brazoria Jones Creek 9/22/1999 D & E 
Texas -Coastal TX Waller Katy 2/8/1983 D 
Texas -Coastal TX Galveston Kemah 4/4/1983 E 
Texas -Coastal TX Hardin Kountze 4/17/1996 D 
Texas -Coastal TX Galveston La Marque 2/16/1983 D 
Texas -Coastal TX Harris La Porte 4/20/2000 D & E 
Texas -Coastal TX Brazoria Lake Jackson 9/22/1999 D 
Texas -Coastal TX Harris League City 9/22/1999 D & E 
Texas -Coastal TX Liberty Liberty 11/18/1988 D 
Texas -Coastal TX Brazoria Liverpool 9/22/1999 D 
Texas -Coastal TX Hardin Lumberton 4/17/1996 D 
Texas -Coastal TX Montgomery Magnolia 9/22/1999 D 
Texas -Coastal TX Brazoria Manvel 9/22/1999 D 
Texas -Coastal TX Harris Missouri City 4/20/2000 D 
Texas -Coastal TX Liberty Mont Belvieu 8/16/1982 D 
Texas -Coastal TX Montgomery Montgomery 9/22/1999 D 
Texas -Coastal TX Harris Nassau Bay 4/20/2000 D & E 
Texas -Coastal TX Brazos Navasota 2/4/1988 D 
Texas -Coastal TX Jefferson Nome 2/2/1983 D 
Texas -Coastal TX Montgomery Oak Ridge North 9/22/1999 D 
Texas -Coastal TX Chambers Old River-Winfree 2/17/1993 C 
Texas -Coastal TX Orange Orange 6/5/1997 D 
Texas -Coastal TX Brazoria Oyster Creek 9/22/1999 D & E 
Texas -Coastal TX Matagorda Palacios 2/5/1986 D & E 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Texas -Coastal TX Montgomery Panorama Village 9/22/1999 D 
Texas -Coastal TX Galveston Pasadena 4/20/2000 D & E 
Texas -Coastal TX Montgomery Patton Village 9/22/1999 D 
Texas -Coastal TX Harris Pearland 4/20/2000 D 
Texas -Coastal TX Orange Pine Forest 2/16/1983 D 
Texas -Coastal TX Orange Pinehurst 1/6/1983 D 
Texas -Coastal TX Harris Piney Point Village 4/20/2000 D 
Texas -Coastal TX Fort Bend Pleak 4/20/2000 D 
Texas -Coastal TX Montgomery Plum Grove 7/16/1987 D 
Texas -Coastal TX Jefferson Port Neches 1/6/1983 C 
Texas -Coastal TX Waller Prairie View 4/15/1982 D 
Texas -Coastal TX Fort Bend Richmond 4/20/2000 D 
Texas -Coastal TX Montgomery Roman Forest 9/22/1999 D 
Texas -Coastal TX Orange Rose City 1/6/1983 C 
Texas -Coastal TX Hardin Rose Hill Acres 4/17/1996 D 
Texas -Coastal TX Fort Bend Rosenberg 4/20/2000 D 
Texas -Coastal TX Austin San Felipe 6/16/1999 C 
Texas -Coastal TX Galveston Seabrook 4/20/2000 D & E 
Texas -Coastal TX Harris Shoreacres 4/20/2000 D & E 
Texas -Coastal TX Hardin Silsbee 4/17/1996 D 
Texas -Coastal TX Fort Bend Simonton 4/20/2000 D 
Texas -Coastal TX Harris South Houston 4/20/2000 D 
Texas -Coastal TX Harris Southside Place 4/20/2000 D 
Texas -Coastal TX Montgomery Splendora 9/22/1999 D 
Texas -Coastal TX Harris Spring Valley 4/20/2000 D 
Texas -Coastal TX Fort Bend Stafford 4/20/2000 D 
Texas -Coastal TX Montgomery Stagecoach 9/22/1999 D 
Texas -Coastal TX Fort Bend Sugar Land 4/20/2000 D 
Texas -Coastal TX Brazoria Surfside Beach 9/22/1999 D & E 
Texas -Coastal TX Brazoria Sweeny 9/22/1999 D 
Texas -Coastal TX Harris Taylor Lake Village 4/20/2000 D 
Texas -Coastal TX Galveston Texas City 5/4/1992 D & E 
Texas -Coastal TX Fort Bend Thompsons 4/20/2000 C 
Texas -Coastal TX Harris Tomball 4/20/2000 D 
Texas -Coastal TX Colorado Unincorporated Areas 1/3/1990 C 
Texas -Coastal TX Austin Unincorporated Areas 4/15/2002 D 
Texas -Coastal TX Brazoria Unincorporated Areas 9/22/1999 D 
Texas -Coastal TX Fort Bend Unincorporated Areas 11/7/2001 D 
Texas -Coastal TX Jackson Unincorporated Areas 2/18/1981 D 
Texas -Coastal TX Jasper Unincorporated Areas 5/18/1992 D 
Texas -Coastal TX Jefferson Unincorporated Areas 8/6/2002 D 
Texas -Coastal TX Liberty Unincorporated Areas 11/18/1988 D 
Texas -Coastal TX Montgomery Unincorporated Areas 9/22/1999 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Texas -Coastal TX Tyler Unincorporated Areas 2/19/1992 D 
Texas -Coastal TX Waller Unincorporated Areas 9/14/1979 D 
Texas -Coastal TX Wharton Unincorporated Areas 9/16/1982 D 
Texas -Coastal TX Calhoun Unincorporated Areas 11/7/2001 D & E 
Texas -Coastal TX Chambers Unincorporated Areas 5/18/1999 D & E 
Texas -Coastal TX Galveston Unincorporated Areas 12/6/2002 D & E 
Texas -Coastal TX Hardin Unincorporated Areas 4/17/1996 D & E 
Texas -Coastal TX Harris Unincorporated Areas 4/20/2000 D & E 
Texas -Coastal TX Matagorda Unincorporated Areas 5/4/1992 E 
Texas -Coastal TX Orange Vidor 1/6/1983 D 
Texas -Coastal TX Waller Waller 9/14/1979 D 
Texas -Coastal TX Brazoria West Columbia 9/22/1999 D 
Texas -Coastal TX Orange West Orange 1/6/1983 D 
Texas -Coastal TX Harris West University Place 4/20/2000 C 
Texas -Coastal TX Wharton Wharton 9/16/1982 D 
Texas -Coastal TX Montgomery Willis 9/22/1999 D 
Texas -Coastal TX Montgomery Woodbranch 9/22/1999 D 
Texas -Coastal TX Montgomery Woodloch 9/22/1999 D 
Washington/Baltimore MD Harford Aberdeen 1/7/2000 D 
Washington/Baltimore MD Anne Arundel Annapolis 11/4/1981 C 
Washington/Baltimore MD Baltimore Baltimore 9/30/1988 D & E 
Washington/Baltimore MD Harford Bel Air 1/7/2000 D 
Washington/Baltimore MD Washington Boonsboro 7/16/1980 D 
Washington/Baltimore MD Montgomery Brookeville 6/19/1989 D 
Washington/Baltimore MD Dorchester Cambridge 1/16/1981 C 
Washington/Baltimore MD Queen Annes Centreville 9/27/1985 D 
Washington/Baltimore MD Cecil Charlestown 11/17/1982 C 
Washington/Baltimore MD Calvert Chesapeake Beach 11/1/1984 E 
Washington/Baltimore MD Kent Chestertown 2/15/1984 D & E 
Washington/Baltimore MD Dorchester Church Creek 10/18/1988 C 
Washington/Baltimore MD Allegany Cumberland 9/1/1983 D 
Washington/Baltimore MD Caroline Denton 12/18/1979 D 
Washington/Baltimore MD Talbot Easton 9/28/1984 D 
Washington/Baltimore MD Frederick Frederick 8/19/1991 D 
Washington/Baltimore MD Allegany Frostburg 12/18/1979 D 
Washington/Baltimore MD Washington Funkstown 2/1/1978 D 
Washington/Baltimore MD Montgomery Gaithersburg 12/1/1982 D 
Washington/Baltimore MD Caroline Greensboro 11/1/1979 D 
Washington/Baltimore MD Washington Hagerstown 2/15/1984 D 
Washington/Baltimore MD Washington Hancock 2/17/1982 D 
Washington/Baltimore MD Cecil Havre de Grace 1/7/2000 D 
Washington/Baltimore MD Anne Arundel Highland Beach 10/15/1982 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore MD Charles Indian Head 10/15/1985 C 
Washington/Baltimore MD Washington Keedysville 1/2/1980 D 
Washington/Baltimore MD Prince Georges Laurel 8/19/1985 D 
Washington/Baltimore MD St. Marys Leonardtown 11/19/1987 D 
Washington/Baltimore MD Allegany Midland 8/15/1979 D 
Washington/Baltimore MD Queen Annes Millington 11/3/1982 D 
Washington/Baltimore MD Garrett Mountain Lake Park 8/16/1994 D 
Washington/Baltimore MD Anne Arundel North Beach 9/28/1984 E 
Washington/Baltimore MD Cecil North East 10/15/1981 D 
Washington/Baltimore MD Garrett Oakland 10/18/1995 D 
Washington/Baltimore MD Cecil Perryville 9/30/1992 C 
Washington/Baltimore MD Cecil Port Deposit 2/16/1977 D 
Washington/Baltimore MD Queen Annes Queenstown 9/28/1984 D 
Washington/Baltimore MD Cecil Rising Sun 5/15/1986 D 
Washington/Baltimore MD Kent Rock Hall 9/1/1983 D 
Washington/Baltimore MD Montgomery Rockville 1/5/1978 D 
Washington/Baltimore MD Dorchester Secretary 4/2/1992 C 
Washington/Baltimore MD Washington Sharpsburg 1/2/1980 D 
Washington/Baltimore MD Talbot St. Michaels 11/1/1984 C 
Washington/Baltimore MD Carroll Sykesville 10/10/1980 D 
Washington/Baltimore MD Allegany Unincorporated Areas 9/29/1989 D 
Washington/Baltimore MD Anne Arundel Unincorporated Areas 9/27/1985 D 
Washington/Baltimore MD Caroline Unincorporated Areas 9/7/1998 D 
Washington/Baltimore MD Carroll Unincorporated Areas 8/7/1981 D 
Washington/Baltimore MD Dorchester Unincorporated Areas 6/16/1992 D 
Washington/Baltimore MD Frederick Unincorporated Areas 8/19/1991 D 
Washington/Baltimore MD Garrett Unincorporated Areas 8/16/1994 D 
Washington/Baltimore MD Harford Unincorporated Areas 1/7/2000 D 
Washington/Baltimore MD Howard Unincorporated Areas 4/2/1997 D 
Washington/Baltimore MD Kent Unincorporated Areas 6/16/1992 D 
Washington/Baltimore MD Montgomery Unincorporated Areas 6/16/1992 D 
Washington/Baltimore MD St. Marys Unincorporated Areas 5/17/1993 D 
Washington/Baltimore MD Talbot Unincorporated Areas 6/16/1992 D 
Washington/Baltimore MD Washington Unincorporated Areas 9/30/1992 D 
Washington/Baltimore MD Baltimore Unincorporated Areas 9/30/1988 D & E 
Washington/Baltimore MD Charles Unincorporated Areas 6/5/1985 D & E 
Washington/Baltimore MD Queen Annes Unincorporated Areas 6/16/1992 D & E 
Washington/Baltimore MD Carroll Union Bridge 8/1/1977 D 
Washington/Baltimore MD Frederick Walkersville 9/30/1980 D 
Washington/Baltimore MD Carroll Westminster 10/10/1980 D 
Washington/Baltimore PA Adams Abbottstown 9/2/1981 D 
Washington/Baltimore PA Bedford Bedford 9/2/1988 C 
Washington/Baltimore PA Somerset Berlin 7/15/1988 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore PA Perry Bloomfield 3/1/1978 D 
Washington/Baltimore PA Adams Bonneauville 8/3/1981 D 
Washington/Baltimore PA Cumberland Camp Hill 12/11/1981 D 
Washington/Baltimore PA Cumberland Carlisle 2/3/1982 D 
Washington/Baltimore PA Adams Carroll Valley 9/2/1988 C 
Washington/Baltimore PA Somerset Central City 6/18/1990 C 
Washington/Baltimore PA Franklin Chambersburg 7/17/1978 D 
Washington/Baltimore PA Huntingdon Coalmont 8/3/1989 C 
Washington/Baltimore PA Lancaster Columbia 9/22/1999 D 
Washington/Baltimore PA Dauphin Dauphin 4/15/1977 D 
Washington/Baltimore PA York Delta 9/1/1983 D 
Washington/Baltimore PA York Dover 3/2/1981 D 
Washington/Baltimore PA Dauphin Duncannon 12/18/1979 D 
Washington/Baltimore PA Lancaster Elizabethtown 4/17/1978 D 
Washington/Baltimore PA Bedford Everett 11/16/1990 C 
Washington/Baltimore PA Adams Fairfield 8/2/1990 C 
Washington/Baltimore PA York Felton 7/2/1992 D 
Washington/Baltimore PA Somerset Garrett 6/4/1990 C 
Washington/Baltimore PA Adams Gettysburg 8/15/1983 D 
Washington/Baltimore PA York Goldsboro 2/15/1980 D 
Washington/Baltimore PA Franklin Guilford 6/18/1990 D 
Washington/Baltimore PA York Hallam 2/15/1980 D 
Washington/Baltimore PA Adams Hampton 9/21/2001 D 
Washington/Baltimore PA Cumberland Harrisburg 5/2/1977 D 
Washington/Baltimore PA Dauphin Highspire 12/11/1981 D 
Washington/Baltimore PA Blair Hollidaysburg 6/1/1982 D 
Washington/Baltimore PA Somerset Hooversville 6/18/1990 C 
Washington/Baltimore PA Bedford Hopewell 8/15/1989 C 
Washington/Baltimore PA Dauphin Hummelstown 3/15/1977 D 
Washington/Baltimore PA Huntingdon Huntingdon 5/16/1995 D 
Washington/Baltimore PA Bedford Hyndman 12/15/1989 C 
Washington/Baltimore PA Huntingdon Kistler 9/15/1977 D 
Washington/Baltimore PA Lancaster Lancaster 12/18/1979 D 
Washington/Baltimore PA Cumberland Lemoyne 12/4/1979 D 
Washington/Baltimore PA York Lewisberry 11/17/1982 D 
Washington/Baltimore PA Cumberland Lower Allen 9/30/1977 D 
Washington/Baltimore PA York Manchester 12/1/1981 D 
Washington/Baltimore PA Lancaster Manheim 4/4/1983 D 
Washington/Baltimore PA Bedford Manns Choice 9/6/1989 C 
Washington/Baltimore PA Huntingdon Mapleton 7/5/1977 D 
Washington/Baltimore PA Lancaster Marietta 2/1/1980 D 
Washington/Baltimore PA Perry Marysville 5/16/1977 D 
Washington/Baltimore PA Adams McSherrystown 6/8/1998 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore PA Cumberland Mechanicsburg 3/3/1992 D 
Washington/Baltimore PA Franklin Mercersburg 7/15/1992 C 
Washington/Baltimore PA Somerset Meyersdale 6/17/1986 D 
Washington/Baltimore PA Dauphin Middletown 8/15/1983 D 
Washington/Baltimore PA Adams Midway 8/15/1989 C 
Washington/Baltimore PA Huntingdon Mill Creek 3/2/1989 C 
Washington/Baltimore PA Franklin Mont Alto 7/16/1990 C 
Washington/Baltimore PA Cumberland Mount Holly Springs 1/5/1996 D 
Washington/Baltimore PA Huntingdon Mount Union 7/18/1977 D 
Washington/Baltimore PA York Mount Wolf 5/15/1980 D 
Washington/Baltimore PA Cumberland New Cumberland 2/16/1977 D 
Washington/Baltimore PA Blair Newry 1/18/1984 D 
Washington/Baltimore PA Mifflin Newton Hamilton 2/15/1978 D 
Washington/Baltimore PA York North York 7/2/1982 D 
Washington/Baltimore PA Huntingdon Orbisonia 7/3/1995 C 
Washington/Baltimore PA Chester Oxford 12/1/1981 D 
Washington/Baltimore PA Dauphin Paxtang 3/18/1980 D 
Washington/Baltimore PA Cumberland Plainfield 4/6/2001 D 
Washington/Baltimore PA Bedford Pleasantville 9/30/1988 C 
Washington/Baltimore PA Juniata Port Royal 1/5/1978 D 
Washington/Baltimore PA Blair Roaring Spring 9/1/1977 D 
Washington/Baltimore PA Somerset Rockwood 6/18/1990 C 
Washington/Baltimore PA Dauphin Royalton 4/15/1977 D 
Washington/Baltimore PA Somerset Salisbury 7/2/2003 C 
Washington/Baltimore PA York Shrewsbury 12/15/1990 D 
Washington/Baltimore PA Somerset Somerset 3/3/1992 D 
Washington/Baltimore PA York Spring Grove 8/15/1983 D 
Washington/Baltimore PA Dauphin Steelton 4/15/1977 D 
Washington/Baltimore PA Lancaster Strasburg 2/4/1981 D 
Washington/Baltimore PA Chester Unincorporated Areas 11/2/1990 C 
Washington/Baltimore PA Franklin Unincorporated Areas 9/21/2001 C 
Washington/Baltimore PA Adams Unincorporated Areas 1/16/1981 D 
Washington/Baltimore PA Cumberland Unincorporated Areas 9/20/1995 D 
Washington/Baltimore PA Dauphin Unincorporated Areas 4/15/1977 D 
Washington/Baltimore PA Fulton Unincorporated Areas 4/15/1981 D 
Washington/Baltimore PA Huntingdon Unincorporated Areas 5/16/1995 D 
Washington/Baltimore PA Juniata Unincorporated Areas 5/1/1978 D 
Washington/Baltimore PA Lancaster Unincorporated Areas 12/18/1979 D 
Washington/Baltimore PA Lebanon Unincorporated Areas 1/2/1991 D 
Washington/Baltimore PA Mifflin Unincorporated Areas 11/15/1979 D 
Washington/Baltimore PA Perry Unincorporated Areas 5/21/2001 D 
Washington/Baltimore PA Somerset Unincorporated Areas 3/3/1992 D 

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Are Minimum Building Requirements Being Met?



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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore PA York Unincorporated Areas 12/18/1979 D 
Washington/Baltimore PA Franklin Waynesboro 11/1/1985 D 
Washington/Baltimore PA Blair Williamsburg 3/1/1978 D 
Washington/Baltimore PA York Windsor 11/3/1982 D 
Washington/Baltimore PA Bedford Woodbury 5/15/1980 D 
Washington/Baltimore PA Cumberland Wormleysburg 2/16/1977 D 
Washington/Baltimore PA York Wrightsville 9/22/1999 D 
Washington/Baltimore PA York Yoe 12/1/1982 D 
Washington/Baltimore PA York York 6/15/1977 D 
Washington/Baltimore PA Lancaster York Haven 12/18/1979 D 
Washington/Baltimore VA Alexandria Alexandria 5/15/1991 C 
Washington/Baltimore VA Clarke Berryville 5/2/2002 D 
Washington/Baltimore VA Rockingham Bridgewater 1/20/1993 C 
Washington/Baltimore VA Rockingham Broadway 8/18/1992 D 
Washington/Baltimore VA Fairfax Clifton 5/2/1977 D 
Washington/Baltimore VA Goochland Columbia 9/29/1978 D 
Washington/Baltimore VA Culpeper Culpeper 3/2/1989 C 
Washington/Baltimore VA Rockingham Dayton 10/15/1985 C 
Washington/Baltimore VA Prince William Dumfries 1/5/1995 D 
Washington/Baltimore VA Rockingham Elkton 9/3/1992 D 
Washington/Baltimore VA Fairfax Fairfax 2/19/2003 C 
Washington/Baltimore VA Falls Chruch Falls Church 2/3/1982 D 
Washington/Baltimore VA Warren Front Royal 7/15/1988 D 
Washington/Baltimore VA Rockingham Grottoes 12/20/2002 D 
Washington/Baltimore VA Harrisonburg Harrisonburg 11/3/1989 D 
Washington/Baltimore VA Prince William Haymarket 1/5/1995 D 
Washington/Baltimore VA Fairfax Herndon 8/1/1979 D 
Washington/Baltimore VA Loudoun Leesburg 7/5/2001 D 
Washington/Baltimore VA Page Luray 8/23/1999 D 
Washington/Baltimore VA Prince William Manassas 1/5/1995 D 
Washington/Baltimore VA Prince William Manassas Park 1/5/1995 D 
Washington/Baltimore VA Prince William Occoquan 1/5/1995 D 
Washington/Baltimore VA Loudoun Purcellville 7/5/2001 C 
Washington/Baltimore VA Prince William Quantico 1/5/1995 D 
Washington/Baltimore VA Fauquier Remington 3/18/1980 D 
Washington/Baltimore VA Fluvanna Scottsville 4/2/1990 D 
Washington/Baltimore VA Page Stanley 2/3/1982 D 
Washington/Baltimore VA Staunton Staunton 12/16/1988 D 
Washington/Baltimore VA Essex Tappahannock 8/4/1987 C 
Washington/Baltimore VA Rockingham Timberville 6/5/1985 C 
Washington/Baltimore VA Caroline Unincorporated Areas 8/15/1989 C 
Washington/Baltimore VA Culpeper Unincorporated Areas 3/2/1989 C 
Washington/Baltimore VA Essex Unincorporated Areas 12/16/1988 C 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore VA Fairfax Unincorporated Areas 3/5/1990 C 
Washington/Baltimore VA King George Unincorporated Areas 12/15/1990 C 
Washington/Baltimore VA Madison Unincorporated Areas 4/3/1989 C 
Washington/Baltimore VA Waynesboro Unincorporated Areas 5/4/1988 C 
Washington/Baltimore VA Albemarle Unincorporated Areas 4/2/1990 D 
Washington/Baltimore VA Augusta Unincorporated Areas 5/17/1993 D 
Washington/Baltimore VA Fauquier Unincorporated Areas 8/19/1991 D 
Washington/Baltimore VA Fluvanna Unincorporated Areas 8/15/1978 D 
Washington/Baltimore VA Goochland Unincorporated Areas 3/1/1979 D 
Washington/Baltimore VA Hanover Unincorporated Areas 9/2/1981 D 
Washington/Baltimore VA Harrisonburg Unincorporated Areas 11/3/1989 D 
Washington/Baltimore VA Henrico Unincorporated Areas 2/4/1981 D 
Washington/Baltimore VA King William Unincorporated Areas 2/6/1991 D 
Washington/Baltimore VA Loudoun Unincorporated Areas 7/5/2001 D 
Washington/Baltimore VA Nelson Unincorporated Areas 8/1/1978 D 
Washington/Baltimore VA Page Unincorporated Areas 8/19/1991 D 
Washington/Baltimore VA Powhatan Unincorporated Areas 9/15/1978 D 
Washington/Baltimore VA Prince William Unincorporated Areas 1/5/1995 D 
Washington/Baltimore VA Richmond Unincorporated Areas 7/20/1998 D 
Washington/Baltimore VA Rockingham Unincorporated Areas 9/3/1992 D 
Washington/Baltimore VA Shenandoah Unincorporated Areas 8/1/1978 D 
Washington/Baltimore VA Stafford Unincorporated Areas 3/3/1992 D 
Washington/Baltimore VA Warren Unincorporated Areas 8/1/1979 D 
Washington/Baltimore VA Winchester Unincorporated Areas 11/15/1978 D 
Washington/Baltimore VA Westmoreland Unincorporated Areas 8/3/1992 E 
Washington/Baltimore VA Fairfax Vienna 2/3/1982 D 
Washington/Baltimore VA Fauquier Warrenton 8/1/1979 D 
Washington/Baltimore VA Augusta Waynesboro 5/4/1988 C 
Washington/Baltimore VA Frederick Winchester 11/15/1978 D 
Washington/Baltimore WV Jefferson Charles Town 9/30/1992 D 
Washington/Baltimore WV Tucker Davis 6/2/1992 D 
Washington/Baltimore WV Pendleton Franklin 8/15/1989 C 
Washington/Baltimore WV Mineral Keyser 9/27/1991 D 
Washington/Baltimore WV Berkeley Martinsburg 7/16/1997 D 
Washington/Baltimore WV Hardy Moorefield 1/19/2001 C 
Washington/Baltimore WV Morgan Paw Paw 3/5/1996 C 
Washington/Baltimore WV Grant Petersburg 5/4/2000 C 
Washington/Baltimore WV Mineral Piedmont 9/27/1991 D 
Washington/Baltimore WV Jefferson Shepherdstown 3/18/1980 C 
Washington/Baltimore WV Grant Unincorporated Areas 5/4/2000 C 
Washington/Baltimore WV Hardy Unincorporated Areas 1/19/2001 C 
Washington/Baltimore WV Randolph Unincorporated Areas 9/27/1991 C 
Washington/Baltimore WV Berkeley Unincorporated Areas 8/6/2002 D 

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Appendix A  Participating Communities with Detailed SFHAs (continued) 

Current Map Date Level of 
Community Cluster State County Community (As of 9/30/03) Regs 
Washington/Baltimore WV Jefferson Unincorporated Areas 1/6/1999 D 
Washington/Baltimore WV Mineral Unincorporated Areas 10/20/1999 D 
Washington/Baltimore WV Morgan Unincorporated Areas 5/18/2000 D 
Washington/Baltimore WV Tucker Unincorporated Areas 6/2/1992 D 

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APPENDIX B  NATIONAL SURVEY RESULTS BY COMPLIANCE 
CATEGORY 

Total No. of No. Fully % Fully Noncompliant-% Noncompliant-
Comm Cluster Community ID Surveyed Structures Compliant Compliant LEM Issue LEM Issue 
California -North NOCA-1 25. 6. 24.0% 1. 4.0% 
California -North NOCA-2 25. 25. 100.0% 0 0.0% 
California -North NOCA-3 25. 9. 36.0% 3. 12.0% 
California -North NOCA-4 25. 12. 48.0% 1. 4.0% 
California -North NOCA-5 25. 14. 56.0% 0 0.0% 
California -North Total 125. 66. 52.8% 5. 4.0% 
Coastal North Carolina/Virginia NC/VA-1 25. 21. 84.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 24. 96.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 10. 40.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 15. 57.7% 2. 7.7% 
Coastal North Carolina/Virginia NC/VA-5 26. 18. 69.2% 0 0.0% 
Coastal North Carolina/Virginia Total 127. 88. 69.3% 4. 3.1% 
Florida -West Coast WCFL-1 27. 17. 63.0% 6. 22.2% 
Florida -West Coast WCFL-2 24. 9. 37.5% 2. 8.3% 
Florida -West Coast WCFL-3 25. 25. 100.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 12. 50.0% 12. 50.0% 
Florida -West Coast WCFL-5 25. 13. 52.0% 9. 36.0% 
Florida -West Coast Total 125. 76. 60.8% 29. 23.2% 
Florida Panhandle FL/AL-1 23 16. 69.6% 4. 17.4% 
Florida Panhandle FL/AL-2 25. 14. 56.0% 1. 4.0% 
Florida Panhandle FL/AL-3 26. 12. 46.2% 4. 15.4% 
Florida Panhandle FL/AL-4 24. 14. 58.3% 1. 4.2% 
Florida Panhandle FL/AL-5 26 11. 42.3% 1. 3.8% 
Florida Panhandle Total 124. 67. 54.0% 11. 8.9% 
Louisiana LA-1 26. 13. 50.0% 3. 11.5% 
Louisiana LA-2 26 13. 50.0% 5. 19.2% 
Louisiana LA-3 25 21. 84.0% 0 0.0% 
Louisiana LA-4 25. 14. 56.0% 0 0.0% 
Louisiana LA-5 25 23. 92.0% 1. 4.0% 
Louisiana Total 127. 84. 66.1% 9. 7.1% 
Mid-Atlantic DE/NJ-1 25. 17. 68.0% 1. 4.0% 
Mid-Atlantic DE/NJ-2 25. 13. 52.0% 0 0.0% 
Mid-Atlantic DE/NJ-3 25. 13. 52.0% 6. 24.0% 
Mid-Atlantic DE/NJ-4 25. 17. 68.0% 5. 20.0% 
Mid-Atlantic DE/NJ-5 26. 14. 53.8% 4. 15.4% 
Mid-Atlantic Total 126. 74. 58.7% 16. 12.7% 
Mississippi River MO/IL-1 22 21. 95.5% 0 0.0% 
Mississippi River MO/IL-2 23. 8. 34.8% 12. 52.2% 
Mississippi River MO/IL-3 26. 13. 50.0% 3. 11.5% 
Mississippi River MO/IL-4 25. 23. 92.0% 1. 4.0% 
Mississippi River MO/IL-5 28 8. 28.6% 0 0.0% 
Mississippi River Total 124. 73. 58.9% 16. 12.9% 
Southwest SW-1 25. 10. 40.0% 9. 36.0% 
Southwest SW-2 25. 21. 84.0% 3. 12.0% 
Southwest SW-3 24. 20. 83.3% 3. 12.5% 
Southwest SW-4 25. 23. 92.0% 2. 8.0% 
Southwest SW-5 25. 14. 56.0% 2. 8.0% 
Southwest Total 124. 88. 71.0% 19. 15.3% 
Texas-Coastal CTX-1 25. 15. 60.0% 0 0.0% 
Texas-Coastal CTX-2 25. 13. 52.0% 2. 8.0% 
Texas-Coastal CTX-3 25. 9. 36.0% 2. 8.0% 
Texas-Coastal CTX-4 25. 11. 44.0% 1. 4.0% 
Texas-Coastal CTX-5 25. 21. 84.0% 1. 4.0% 
Texas-Coastal Total 125. 69. 55.2% 6. 4.8% 
Washington/Baltimore Balt/Wash-1 25. 23. 92.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 20. 80.0% 1. 4.0% 
Washington/Baltimore Balt/Wash-3 26. 24. 92.3% 1. 3.8% 
Washington/Baltimore Balt/Wash-4 25. 21. 84.0% 0 0.0% 
Washington/Baltimore Balt/Wash-5 25. 18. 72.0% 0 0.0% 
Washington/Baltimore Total 126. 106. 84.1% 2. 1.6% 

TOTALNUMBER125379163.1%1179.3%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS58%-69.9%6.0%-13.0%
95-percent statistical confidence level for estimate. 

Evaluation of the National Flood Insurance Program 

An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix B  National Survey Results by Compliance Category (continued) 

Noncompliant-
Total No. of Noncompliant-% Noncompliant-Openings % Noncompliant-
Comm Cluster Community ID Surveyed Structures Multiple Issues Multiple Issues Issue Openings Issue 
California -North NOCA-1 25. 3. 12.0% 3. 12.0% 
California -North NOCA-2 25. 0.0% 0 0.0% 
California -North NOCA-3 25. 4. 16.0% 8. 32.0% 
California -North NOCA-4 25. 0.0% 9. 36.0% 
California -North NOCA-5 25. 6. 24.0% 5. 20.0% 
California -North Total 125. 13. 10.4% 25. 20.0% 
Coastal North Carolina/Virginia NC/VA-1 25. 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 1. 4.0% 11. 44.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 3. 11.5% 5. 19.2% 
Coastal North Carolina/Virginia NC/VA-5 26. 0.0% 7. 26.9% 
Coastal North Carolina/Virginia Total 127. 4. 3.1% 24. 18.9% 
Florida -West Coast WCFL-1 27. 1. 3.7% 3. 11.1% 
Florida -West Coast WCFL-2 24. 0.0% 4. 16.7% 
Florida -West Coast WCFL-3 25. 0.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 0.0% 0 0.0% 
Florida -West Coast WCFL-5 25. 0.0% 3. 12.0% 
Florida -West Coast Total 125. 1. 0.8% 10. 8.0% 
Florida Panhandle FL/AL-1 23 0.0% 0 0.0% 
Florida Panhandle FL/AL-2 25. 1. 4.0% 5. 20.0% 
Florida Panhandle FL/AL-3 26. 2. 7.7% 3. 11.5% 
Florida Panhandle FL/AL-4 24. 1. 4.2% 8. 33.3% 
Florida Panhandle FL/AL-5 26 3. 11.5% 2. 7.7% 
Florida Panhandle Total 124. 7. 5.6% 18. 14.5% 
Louisiana LA-1 26. 3. 11.5% 1. 3.8% 
Louisiana LA-2 26 0.0% 0 0.0% 
Louisiana LA-3 25 0.0% 0 0.0% 
Louisiana LA-4 25. 1. 4.0% 1. 4.0% 
Louisiana LA-5 25 0.0% 1. 4.0% 
Louisiana Total 127. 4. 3.1% 3. 2.4% 
Mid-Atlantic DE/NJ-1 25. 0.0% 3. 12.0% 
Mid-Atlantic DE/NJ-2 25. 0.0% 7. 28.0% 
Mid-Atlantic DE/NJ-3 25. 1. 4.0% 3. 12.0% 
Mid-Atlantic DE/NJ-4 25. 1. 4.0% 1. 4.0% 
Mid-Atlantic DE/NJ-5 26. 3. 11.5% 1. 3.8% 
Mid-Atlantic Total 126. 5. 4.0% 15. 11.9% 
Mississippi River MO/IL-1 22 0.0% 0 0.0% 
Mississippi River MO/IL-2 23. 0.0% 0 0.0% 
Mississippi River MO/IL-3 26. 1. 3.8% 2. 7.7% 
Mississippi River MO/IL-4 25. 0.0% 0 0.0% 
Mississippi River MO/IL-5 28 0.0% 0 0.0% 
Mississippi River Total 124. 1. 0.8% 2. 1.6% 
Southwest SW-1 25. 0.0% 2. 8.0% 
Southwest SW-2 25. 0.0% 0 0.0% 
Southwest SW-3 24. 0.0% 0 0.0% 
Southwest SW-4 25. 0.0% 0 0.0% 
Southwest SW-5 25. 0.0% 0 0.0% 
Southwest Total 124. 0. 0.0% 2. 1.6% 
Texas-Coastal CTX-1 25. 0.0% 2. 8.0% 
Texas-Coastal CTX-2 25. 4. 16.0% 1. 4.0% 
Texas-Coastal CTX-3 25. 3. 12.0% 1. 4.0% 
Texas-Coastal CTX-4 25. 4. 16.0% 7. 28.0% 
Texas-Coastal CTX-5 25. 1. 4.0% 2. 8.0% 
Texas-Coastal Total 125. 12. 9.6% 13. 10.4% 
Washington/Baltimore Balt/Wash-1 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 0 0.0% 1. 4.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-4 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-5 25. 0 0.0% 4. 16.0% 
Washington/Baltimore Total 126. 0. 0.0% 5. 4.0% 

TOTALNUMBER1253473.8%1179.3%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS2.1%-5.4%6.2%-12.6%
95-percent statistical confidence level for estimate. 

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An Evaluation of Compliance with the National Flood Insurance Program: Part B
Are Minimum Building Requirements Being Met?



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Appendix B  National Survey Results by Compliance Category (continued) 

Total No. of Noncompliant-% Noncompliant-
Surveyed Noncompliant-% Noncompliant-Within 6" and Other Within 6" and Other 
Comm Cluster Community ID Structures Within 6" Within 6" Issue(s) Issue(s) 
California -North NOCA-1 25. 0 0.0% 0 0.0% 
California -North NOCA-2 25. 0 0.0% 0 0.0% 
California -North NOCA-3 25. 0 0.0% 0 0.0% 
California -North NOCA-4 25. 1. 4.0% 1. 4.0% 
California -North NOCA-5 25. 0 0.0% 0 0.0% 
California -North Total 125. 1. 0.8% 1. 0.8% 
Coastal North Carolina/Virginia NC/VA-1 25. 0 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 0 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 0 0.0% 1. 3.8% 
Coastal North Carolina/Virginia NC/VA-5 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia Total 127. 0. 0.0% 4. 3.1% 
Florida -West Coast WCFL-1 27. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-2 24. 1. 4.2% 0 0.0% 
Florida -West Coast WCFL-3 25. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-5 25. 0 0.0% 0 0.0% 
Florida -West Coast Total 125. 1. 0.8% 0. 0.0% 
Florida Panhandle FL/AL-1 23 3. 13.0% 0 0.0% 
Florida Panhandle FL/AL-2 25. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-3 26. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-4 24. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-5 26 0 0.0% 2. 7.7% 
Florida Panhandle Total 124. 3. 2.4% 2. 1.6% 
Louisiana LA-1 26. 0 0.0% 1. 3.8% 
Louisiana LA-2 26 1. 3.8% 4. 15.4% 
Louisiana LA-3 25 0 0.0% 4. 16.0% 
Louisiana LA-4 25. 1. 4.0% 2. 8.0% 
Louisiana LA-5 25 0 0.0% 0 0.0% 
Louisiana Total 127. 2. 1.6% 11. 8.7% 
Mid-Atlantic DE/NJ-1 25. 1. 4.0% 0 0.0% 
Mid-Atlantic DE/NJ-2 25. 1. 4.0% 0 0.0% 
Mid-Atlantic DE/NJ-3 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-4 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-5 26. 0 0.0% 0 0.0% 
Mid-Atlantic Total 126. 2. 1.6% 0. 0.0% 
Mississippi River MO/IL-1 22 0 0.0% 0 0.0% 
Mississippi River MO/IL-2 23. 0 0.0% 0 0.0% 
Mississippi River MO/IL-3 26. 0 0.0% 0 0.0% 
Mississippi River MO/IL-4 25. 1. 4.0% 0 0.0% 
Mississippi River MO/IL-5 28 0 0.0% 0 0.0% 
Mississippi River Total 124. 1. 0.8% 0. 0.0% 
Southwest SW-1 25. 0 0.0% 1. 4.0% 
Southwest SW-2 25. 0 0.0% 0 0.0% 
Southwest SW-3 24. 1 4.2% 0 0.0% 
Southwest SW-4 25. 0 0.0% 0 0.0% 
Southwest SW-5 25. 0 0.0% 1. 4.0% 
Southwest Total 124. 1. 0.8% 2. 1.6% 
Texas-Coastal CTX-1 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-2 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-3 25. 1. 4.0% 2. 8.0% 
Texas-Coastal CTX-4 25. 1. 4.0% 1. 4.0% 
Texas-Coastal CTX-5 25. 0 0.0% 0 0.0% 
Texas-Coastal Total 125. 2. 1.6% 3. 2.4% 
Washington/Baltimore Balt/Wash-1 25. 2. 8.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 1. 4.0% 0 0.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-4 25. 0 0.0% 1. 4.0% 
Washington/Baltimore Balt/Wash-5 25. 1. 4.0% 0 0.0% 
Washington/Baltimore Total 126. 4. 3.2% 1. 0.8% 

TOTALNUMBER1253171.4%241.9%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS0.6%-2.1%0.9%-3.0%
95-percentstatisticalconfidencelevelforestimate.
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Appendix B  National Survey Results by Compliance Category (continued) 

Total No. of Noncompliant-%Noncompliant-
Surveyed Noncompliant-% Noncompliant-Finished Enclosure Finished Enclosure 
Comm Cluster Community ID Structures Basement Basement (Bldg Diag 5-6) (Bldg Diag 5-6) 
California -North NOCA-1 25. 0 0.0% 0 0.0% 
California -North NOCA-2 25. 0 0.0% 0 0.0% 
California -North NOCA-3 25. 0 0.0% 0 0.0% 
California -North NOCA-4 25. 0 0.0% 0 0.0% 
California -North NOCA-5 25. 0 0.0% 0 0.0% 
California -North Total 125. 0. 0.0% 0. 0.0% 
Coastal North Carolina/Virginia NC/VA-1 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-5 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia Total 127. 0. 0.0% 0. 0.0% 
Florida -West Coast WCFL-1 27. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-2 24. 0 0.0% 1. 4.2% 
Florida -West Coast WCFL-3 25. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-5 25. 0 0.0% 0 0.0% 
Florida -West Coast Total 125. 0. 0.0% 1. 0.8% 
Florida Panhandle FL/AL-1 23 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-2 25. 0 0.0% 2. 8.0% 
Florida Panhandle FL/AL-3 26. 0 0.0% 2. 7.7% 
Florida Panhandle FL/AL-4 24. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-5 26 0 0.0% 1. 3.8% 
Florida Panhandle Total 124. 0. 0.0% 5. 4.0% 
Louisiana LA-1 26. 0 0.0% 1. 3.8% 
Louisiana LA-2 26 0 0.0% 0 0.0% 
Louisiana LA-3 25 0 0.0% 0 0.0% 
Louisiana LA-4 25. 0 0.0% 0 0.0% 
Louisiana LA-5 25 0 0.0% 0 0.0% 
Louisiana Total 127. 0. 0.0% 1. 0.8% 
Mid-Atlantic DE/NJ-1 25. 0 0.0% 1. 4.0% 
Mid-Atlantic DE/NJ-2 25. 0 0.0% 3. 12.0% 
Mid-Atlantic DE/NJ-3 25. 0 0.0% 2. 8.0% 
Mid-Atlantic DE/NJ-4 25. 1. 4.0% 0 0.0% 
Mid-Atlantic DE/NJ-5 26. 0 0.0% 1. 3.8% 
Mid-Atlantic Total 126. 1. 0.8% 7. 5.6% 
Mississippi River MO/IL-1 22 0 0.0% 0 0.0% 
Mississippi River MO/IL-2 23. 0 0.0% 0 0.0% 
Mississippi River MO/IL-3 26. 4. 15.4% 0 0.0% 
Mississippi River MO/IL-4 25. 0 0.0% 0 0.0% 
Mississippi River MO/IL-5 28 16. 57.1% 0 0.0% 
Mississippi River Total 124. 20. 16.1% 0. 0.0% 
Southwest SW-1 25. 1. 4.0% 0 0.0% 
Southwest SW-2 25. 0 0.0% 0 0.0% 
Southwest SW-3 24. 0 0.0% 0 0.0% 
Southwest SW-4 25. 0 0.0% 0 0.0% 
Southwest SW-5 25. 0 0.0% 0 0.0% 
Southwest Total 124. 1. 0.8% 0. 0.0% 
Texas-Coastal CTX-1 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-2 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-3 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-4 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-5 25. 0 0.0% 0 0.0% 
Texas-Coastal Total 125. 0. 0.0% 0. 0.0% 
Washington/Baltimore Balt/Wash-1 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 2. 8.0% 0 0.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-4 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-5 25. 0 0.0% 2. 8.0% 
Washington/Baltimore Total 126. 2. 1.6% 2. 1.6% 

TOTALNUMBER1253241.9%16CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS0%-4.2%0.5%-2.1%
95-percentstatisticalconfidencelevelforestimate.
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Appendix B  National Survey Results by Compliance Category (continued) 

Noncompliant-
Total No. of Finished % Noncompliant-
Surveyed Enclosure (Bldg Finished Enclosure Noncompliant-% Noncompliant-In 
Comm Cluster Community ID Structures Diag 7) (Bldg Diag 7) In Floodway Floodway 
California -North NOCA-1 25. 5 20.0% 0 0.0% 
California -North NOCA-2 25. 0 0.0% 0 0.0% 
California -North NOCA-3 25. 0 0.0% 0 0.0% 
California -North NOCA-4 25. 0 0.0% 0 0.0% 
California -North NOCA-5 25. 0 0.0% 0 0.0% 
California -North Total 125. 5. 4.0% 0. 0.0% 
Coastal North Carolina/Virginia NC/VA-1 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-5 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia Total 127. 0. 0.0% 0. 0.0% 
Florida -West Coast WCFL-1 27. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-2 24. 4. 16.7% 0 0.0% 
Florida -West Coast WCFL-3 25. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-5 25. 0 0.0% 0 0.0% 
Florida -West Coast Total 125. 4. 3.2% 0. 0.0% 
Florida Panhandle FL/AL-1 23 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-2 25. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-3 26. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-4 24. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-5 26 1. 3.8% 0 0.0% 
Florida Panhandle Total 124. 1. 0.8% 0. 0.0% 
Louisiana LA-1 26. 1. 3.8% 0 0.0% 
Louisiana LA-2 26 0 0.0% 0 0.0% 
Louisiana LA-3 25 0 0.0% 0 0.0% 
Louisiana LA-4 25. 0 0.0% 0 0.0% 
Louisiana LA-5 25 0 0.0% 0 0.0% 
Louisiana Total 127. 1. 0.8% 0. 0.0% 
Mid-Atlantic DE/NJ-1 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-2 25. 1. 4.0% 0 0.0% 
Mid-Atlantic DE/NJ-3 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-4 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-5 26. 0 0.0% 0 0.0% 
Mid-Atlantic Total 126. 1. 0.8% 0. 0.0% 
Mississippi River MO/IL-1 22 0 0.0% 0 0.0% 
Mississippi River MO/IL-2 23. 0 0.0% 0 0.0% 
Mississippi River MO/IL-3 26. 0 0.0% 0 0.0% 
Mississippi River MO/IL-4 25. 0 0.0% 0 0.0% 
Mississippi River MO/IL-5 28 0 0.0% 0 0.0% 
Mississippi River Total 124. 0. 0.0% 0. 0.0% 
Southwest SW-1 25. 0 0.0% 0 0.0% 
Southwest SW-2 25. 0 0.0% 0 0.0% 
Southwest SW-3 24. 0 0.0% 0 0.0% 
Southwest SW-4 25. 0 0.0% 0 0.0% 
Southwest SW-5 25. 0 0.0% 0 0.0% 
Southwest Total 124. 0. 0.0% 0. 0.0% 
Texas-Coastal CTX-1 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-2 25. 0 0.0% 4. 16.0% 
Texas-Coastal CTX-3 25. 1 4.0% 0 0.0% 
Texas-Coastal CTX-4 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-5 25. 0 0.0% 0 0.0% 
Texas-Coastal Total 125. 1. 0.8% 4. 3.2% 
Washington/Baltimore Balt/Wash-1 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-4 25. 1 4.0% 0 0.0% 
Washington/Baltimore Balt/Wash-5 25. 0 0.0% 0 0.0% 
Washington/Baltimore Total 126. 1. 0.8% 0. 0.0% 

TOTALNUMBER1253141.1%40.3%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS0%-2.3%N/A95-percentstatisticalconfidencelevelforestimate.
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Appendix B  National Survey Results by Compliance Category (continued) 

Total No. of 
Surveyed Noncompliant-% Noncompliant-Noncompliant-% Noncompliant-
Comm Cluster Community ID Structures LHSM LHSM Low Floor Low Floor 
California -North NOCA-1 25. 0 0.0% 5. 20.0% 
California -North NOCA-2 25. 0 0.0% 0 0.0% 
California -North NOCA-3 25. 0 0.0% 0 0.0% 
California -North NOCA-4 25. 0 0.0% 1. 4.0% 
California -North NOCA-5 25. 0 0.0% 0 0.0% 
California -North Total 125. 0. 0.0% 6. 4.8% 
Coastal North Carolina/Virginia NC/VA-1 25. 0 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 0 0.0% 1. 4.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 0 0.0% 0 0.0% 
Coastal North Carolina/Virginia NC/VA-5 26. 0 0.0% 1. 3.8% 
Coastal North Carolina/Virginia Total 127. 0. 0.0% 3. 2.4% 
Florida -West Coast WCFL-1 27. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-2 24. 0 0.0% 3. 12.5% 
Florida -West Coast WCFL-3 25. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-4 24. 0 0.0% 0 0.0% 
Florida -West Coast WCFL-5 25. 0 0.0% 0 0.0% 
Florida -West Coast Total 125. 0. 0.0% 3. 2.4% 
Florida Panhandle FL/AL-1 23 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-2 25. 2. 8.0% 0 0.0% 
Florida Panhandle FL/AL-3 26. 0 0.0% 3. 11.5% 
Florida Panhandle FL/AL-4 24. 0 0.0% 0 0.0% 
Florida Panhandle FL/AL-5 26 0 0.0% 5. 19.2% 
Florida Panhandle Total 124. 2. 1.6% 8. 6.5% 
Louisiana LA-1 26. 0 0.0% 3. 11.5% 
Louisiana LA-2 26 0 0.0% 3. 11.5% 
Louisiana LA-3 25 0 0.0% 0 0.0% 
Louisiana LA-4 25. 0 0.0% 6. 24.0% 
Louisiana LA-5 25 0 0.0% 0 0.0% 
Louisiana Total 127. 0. 0.0% 12. 9.4% 
Mid-Atlantic DE/NJ-1 25. 0 0.0% 2. 8.0% 
Mid-Atlantic DE/NJ-2 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-3 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-4 25. 0 0.0% 0 0.0% 
Mid-Atlantic DE/NJ-5 26. 1. 3.8% 2. 7.7% 
Mid-Atlantic Total 126. 1. 0.8% 4. 3.2% 
Mississippi River MO/IL-1 22 0 0.0% 1 4.5% 
Mississippi River MO/IL-2 23. 0 0.0% 3. 13.0% 
Mississippi River MO/IL-3 26. 0 0.0% 3. 11.5% 
Mississippi River MO/IL-4 25. 0 0.0% 0 0.0% 
Mississippi River MO/IL-5 28 0 0.0% 4. 14.3% 
Mississippi River Total 124. 0. 0.0% 11. 8.9% 
Southwest SW-1 25. 0 0.0% 2. 8.0% 
Southwest SW-2 25. 0 0.0% 1. 4.0% 
Southwest SW-3 24. 0 0.0% 0 0.0% 
Southwest SW-4 25. 0 0.0% 0 0.0% 
Southwest SW-5 25. 0 0.0% 3. 12.0% 
Southwest Total 124. 0. 0.0% 6. 4.8% 
Texas-Coastal CTX-1 25. 0 0.0% 3. 12.0% 
Texas-Coastal CTX-2 25. 0 0.0% 1. 4.0% 
Texas-Coastal CTX-3 25. 0 0.0% 6. 24.0% 
Texas-Coastal CTX-4 25. 0 0.0% 0 0.0% 
Texas-Coastal CTX-5 25. 0 0.0% 0 0.0% 
Texas-Coastal Total 125. 0. 0.0% 10. 8.0% 
Washington/Baltimore Balt/Wash-1 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 0 0.0% 0 0.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 1. 3.8% 
Washington/Baltimore Balt/Wash-4 25. 0 0.0% 2. 8.0% 
Washington/Baltimore Balt/Wash-5 25. 0 0.0% 0 0.0% 
Washington/Baltimore Total 126. 0. 0.0% 3. 2.4% 

TOTALNUMBER125330.2%665.3%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERSN/A3.4%-7.4%
95-percentstatisticalconfidencelevelforestimate.
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Appendix B  National Survey Results by Compliance Category (continued) 

Total No. of Surveyed 
Comm Cluster Community ID Structures Undetermined % Undetermined 
California -North NOCA-1 25. 2. 8.0% 
California -North NOCA-2 25. 0 0.0% 
California -North NOCA-3 25. 1. 4.0% 
California -North NOCA-4 25. 0 0.0% 
California -North NOCA-5 25. 0 0.0% 
California -North Total 125. 3. 2.4% 
Coastal North Carolina/Virginia NC/VA-1 25. 0 0.0% 
Coastal North Carolina/Virginia NC/VA-2 25. 0 0.0% 
Coastal North Carolina/Virginia NC/VA-3 25. 0 0.0% 
Coastal North Carolina/Virginia NC/VA-4 26. 0 0.0% 
Coastal North Carolina/Virginia NC/VA-5 26. 0 0.0% 
Coastal North Carolina/Virginia Total 127. 0. 0.0% 
Florida -West Coast WCFL-1 27. 0 0.0% 
Florida -West Coast WCFL-2 24. 0 0.0% 
Florida -West Coast WCFL-3 25. 0 0.0% 
Florida -West Coast WCFL-4 24. 0 0.0% 
Florida -West Coast WCFL-5 25. 0 0.0% 
Florida -West Coast Total 125. 0. 0.0% 
Florida Panhandle FL/AL-1 23 0 0.0% 
Florida Panhandle FL/AL-2 25. 0 0.0% 
Florida Panhandle FL/AL-3 26. 0 0.0% 
Florida Panhandle FL/AL-4 24. 0 0.0% 
Florida Panhandle FL/AL-5 26 0 0.0% 
Florida Panhandle Total 124. 0. 0.0% 
Louisiana LA-1 26. 0 0.0% 
Louisiana LA-2 26 0 0.0% 
Louisiana LA-3 25 0 0.0% 
Louisiana LA-4 25. 0 0.0% 
Louisiana LA-5 25 0 0.0% 
Louisiana Total 127. 0. 0.0% 
Mid-Atlantic DE/NJ-1 25. 0 0.0% 
Mid-Atlantic DE/NJ-2 25. 0 0.0% 
Mid-Atlantic DE/NJ-3 25. 0 0.0% 
Mid-Atlantic DE/NJ-4 25. 0 0.0% 
Mid-Atlantic DE/NJ-5 26. 0 0.0% 
Mid-Atlantic Total 126. 0. 0.0% 
Mississippi River MO/IL-1 22 0 0.0% 
Mississippi River MO/IL-2 23. 0 0.0% 
Mississippi River MO/IL-3 26. 0 0.0% 
Mississippi River MO/IL-4 25. 0 0.0% 
Mississippi River MO/IL-5 28 0 0.0% 
Mississippi River Total 124. 0. 0.0% 
Southwest SW-1 25. 0 0.0% 
Southwest SW-2 25. 0 0.0% 
Southwest SW-3 24. 0 0.0% 
Southwest SW-4 25. 0 0.0% 
Southwest SW-5 25. 0 0.0% 
Southwest Total 124. 0. 0.0% 
Texas-Coastal CTX-1 25. 5. 20.0% 
Texas-Coastal CTX-2 25. 0 0.0% 
Texas-Coastal CTX-3 25. 0 0.0% 
Texas-Coastal CTX-4 25. 0 0.0% 
Texas-Coastal CTX-5 25. 0 0.0% 
Texas-Coastal Total 125. 5. 4.0% 
Washington/Baltimore Balt/Wash-1 25. 0 0.0% 
Washington/Baltimore Balt/Wash-2 25. 0 0.0% 
Washington/Baltimore Balt/Wash-3 26. 0 0.0% 
Washington/Baltimore Balt/Wash-4 25. 0 0.0% 
Washington/Baltimore Balt/Wash-5 25. 0 0.0% 
Washington/Baltimore Total 126. 0. 0.0% 

TOTALNUMBER125380.6%
CONFIDENCEINTERVALFORTOTAL-ALLCLUSTERS0%-2.2%
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7. ACRONYMS 
Acronym Definition 

AIR American Institutes for Research 

BFE Base (1-percent-annual-chance) Flood Elevation 

CAV Community Assistance Visit 

CFM Certified Floodplain Manager 

CFR Code of Federal Regulations 
Confidence Interval 

CID Community identification number 

CIS Community Information System 

CRS Community Rating System 

FBFM Flood Boundary Floodway Map 

FEMA Federal Emergency Management Agency 

FIRM Flood Insurance Rate Map 

FIS Flood Insurance Study 

44 CFR 60.3 Title 44, Section 60.3, of the Code of Federal Regulations 

GIS Geographic Information System 

GPS global positioning system 

HVAC heating, ventilation, and air conditioning 

ISO Insurance Services Office 

LEM lowest electrical and mechanical equipment 

LHSM lowest horizontal structural member 

LOMR-F Letter of Map Revision based on Fill 

NFIP National Flood Insurance Program 

NGS National Geodetic Survey 

NSRS National Spatial Reference System 

SFHA Special Flood Hazard Area 

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8. REFERENCES 
FEMA. 1981. Design Guidelines for Flood Damage Reduction. Washington, DC
FEMA. 1986. A Unified National Program for Floodplain Management. Washington, DC. 
FEMA. 1998. Managing Floodplain Development through the National Flood Insurance


Program. Washington, DC. 
FEMA. 2000. Coastal Construction Manual. Washington, DC. 
FEMA. 2003. National Flood Insurance Program: Flood Insurance Manual. Washington, DC. 
Dixon, Lloyd, et. al. 2006. The Market Penetration Rate of Flood Insurance: Estimates and 


Policy Implications. Washington, D.C.: 

Monday, Jacquelyn, et. al. 2006. An Evaluation of Compliance with the National Flood 
Insurance Program Part A: Achieving Community Compliance. 
Robinson, Michael. 2005. National Flood Insurance Program, personal communication. 
Sarmiento, and Ted A. Miller. 2006. Costs and Consequences of Flooding and the Impact on the


National Flood Insurance Program. Washington, D.C.: Pacific Institutes for Research and 
American Institutes for Research. 

Evaluation of the National Flood Insurance Program 

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Are Minimum Building Requirements Being Met?



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