U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Publishing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001

22–703 PDF 2017

S. HRG. 114–451 

THE NATIONAL FLOOD INSURANCE PROGRAM: 

REVIEWING THE RECOMMENDATION OF THE 

TECHNICAL MAPPING ADVISORY COUNCIL’S 

2015 ANNUAL REPORT 

HEARING 

BEFORE THE

COMMITTEE ON 

BANKING, HOUSING, AND URBAN AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED FOURTEENTH CONGRESS 

SECOND SESSION 

ON 

EXAMINING THE TESTIMONY RELATED TO THE REAUTHORIZATION OF 

THE NATIONAL FLOOD INSURANCE PROGRAM AS WELL AS THE RECOMMENDATIONS IN THE TECHNICAL MAPPING ADVISORY COUNCIL’S 

ANNUAL REPORT 

SEPTEMBER 13, 2016 

Printed for the use of the Committee on Banking, Housing, and Urban Affairs 

( 

Available at: http://www.fdsys.gov/ 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS 

RICHARD C. SHELBY, Alabama, Chairman 

MIKE CRAPO, Idaho 

BOB CORKER, Tennessee 

DAVID VITTER, Louisiana 

PATRICK J. TOOMEY, Pennsylvania 

MARK KIRK, Illinois 

DEAN HELLER, Nevada 

TIM SCOTT, South Carolina 

BEN SASSE, Nebraska 

TOM COTTON, Arkansas 

MIKE ROUNDS, South Dakota 

JERRY MORAN, Kansas 

SHERROD BROWN, Ohio 

JACK REED, Rhode Island 

CHARLES E. SCHUMER, New York 

ROBERT MENENDEZ, New Jersey 

JON TESTER, Montana 

MARK R. WARNER, Virginia 

JEFF MERKLEY, Oregon 

ELIZABETH WARREN, Massachusetts 

HEIDI HEITKAMP, North Dakota 

JOE DONNELLY, Indiana 

WILLIAM D. DUHNKE III, Staff Director 

MARK POWDEN, Democratic Staff Director 

JELENA MCWILLIAMS, Deputy Staff Director and Chief Counsel 

SHANNON HINES, Professional Staff Member 

LAURA SWANSON, Democratic Deputy Staff Director 

BETH COOPER, Democratic Professional Staff Member 

DAWN RATLIFF, Chief Clerk 

TROY CORNELL, Hearing Clerk 

SHELVIN SIMMONS, IT Director 

JIM CROWELL, Editor 

(II)

C O N T E N T S 

TUESDAY, SEPTEMBER 13, 2016 

Page 

Opening statement of Chairman Shelby ................................................................ 1 

Opening statements, comments, or prepared statements of: 

Senator Brown .................................................................................................. 2 

WITNESSES 

Roy E. Wright, Deputy Associate Administrator for Insurance and Mitigation, 

Federal Emergency Management Agency .......................................................... 3 

Prepared statement .......................................................................................... 27 

Responses to written questions of: 

Senator Toomey ......................................................................................... 36 

Senator Menendez ..................................................................................... 36 

Senator Warren ......................................................................................... 37 

Senator Schumer ....................................................................................... 37 

Senator Kirk .............................................................................................. 38 

John Dorman, Chair, Technical Mapping Advisory Council, and Assistant 

State Emergency Management Director for Risk Management, and Director, North Carolina Flood Risk Management Program .................................... 5 

Prepared statement .......................................................................................... 30 

Scott K. Edelman, Vice Chair, Technical Mapping Advisory Council, and 

Senior Vice President, AECOM .......................................................................... 7 

Prepared statement .......................................................................................... 34 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

FEMA—‘‘Technical Mapping Advisory Council Overview’’ .................................. 41 

Letter submitted by Tom Salomone, 2016 President, National Association 

of REALTORS® .................................................................................................... 47 

Letter submitted by Chad Berginnis, Executive Director, Association of State 

Floodplain Managers ........................................................................................... 49 

Letter submitted by Chad Berginnis, Executive Director, Association of State 

Floodplain Managers and James M. Drinan, JD, Executive Director, American Planning Association ................................................................................... 53 

Joint letter submitted by American Bankers Association, American Insurance 

Association, Council of Insurance Agents and Brokers, Financial Services 

Roundtable, The Independent Insurance Agents and Brokers of America, 

National Association of Mutual Insurance Committees, National Association 

of Professional Insurance Agents, and Property Casualty Insurers Association of America regarding the Principles for Flood Insurance Reauthorization ........................................................................................................................ 55

(III)

(1) 

THE NATIONAL FLOOD INSURANCE PROGRAM: REVIEWING THE RECOMMENDATION 

OF THE TECHNICAL MAPPING ADVISORY 

COUNCIL’S 2015 ANNUAL REPORT 

TUESDAY, SEPTEMBER 13, 2016 

U.S. SENATE, COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS, Washington, DC. 

The Committee met at 10:32 a.m., in room SD–538, Dirksen Senate Office Building, Hon. Richard C. Shelby, Chairman of the Committee, presiding. 

OPENING STATEMENT OF CHAIRMAN RICHARD C. SHELBY 

Chairman SHELBY. The hearing will come to order. 

Today, we will hear testimony related to the upcoming reauthorization of the National Flood Insurance Program, which expires 

next year. 

Today’s witnesses will discuss the recommendations in the Technical Mapping Advisory Council’s annual report. The Council was 

created by the Biggert-Waters Flood Insurance Reform Act. Its job 

is to review matters related to the national flood mapping program 

and make recommendations to FEMA. 

This year’s report includes recommendations on how FEMA can 

better communicate flood risk which can form the basis for more 

accurate flood insurance rates. Flood insurance not only helps 

homeowners recover in the event of a flood; it also enables communities to reduce flood risk through the adoption of floodplain management standards. However, the program cannot be successful 

without accurate mapping and flood risk modeling. 

For years, right here I have advocated for a Flood Insurance Program that uses the best science and data to map properties so that 

both the Government and the homeowners fully understand the 

risk of flooding. 

Today, most homeowners do not understand the true flood risk 

to their property. This is due in part to the fact that FEMA’s rate 

model was—and still is—based on limited data from the early 

1970s and nearly half of FEMA’s maps remain out of date. 

The technology available today is better than ever before and will 

enable us to produce very detailed maps. Such maps, overlaid with 

historical flooding data and state-of-the-art modeling, would allow 

the National Flood Insurance Program to more accurately predict 

flooding risk and price flood insurance policies accordingly. 

2 

The U.S. continues to experience repeated and devastating flood disasters that have resulted in more than $51 billion in payments 

from the National Flood Insurance Program. $51 billion. In fact, 

the recent flooding in Louisiana is anticipated to cost more than $1 

billion, making it the fourth largest disaster in the history of the 

program. 

These record-breaking disasters have required the program to borrow $23 billion from the U.S. Treasury to pay claims. If we 

want to ensure the long-term viability of the NFIP without borrowing from the Treasury, flood insurance rates must accurately 

reflect risk. The basic Flood Insurance Program has not changed 

substantially since 1968. 

I am hopeful that this report will spur the change that is long 

overdue. 

Senator Brown. 

STATEMENT OF SENATOR SHERROD BROWN 

Senator BROWN. Thank you, Chairman Shelby, for calling this 

hearing today and for your always prompt beginning of the hearing. 

Flooding is the most common and most costly natural disaster 

facing our country. With a growing population and a changing climate, our entire Nation—not just the coastal States—will continue 

to grapple with this issue. It will have a direct impact on Ohioans 

and other Americans who live in or near floodplains. It will also 

have an indirect impact on all taxpayers no matter where any of 

us live. 

The people of Louisiana experienced historic, devastating flooding in August from a storm that dumped as much as 2 feet of rain 

in just about 48 hours. Thousands of homes and businesses were 

destroyed; at least 13 people died. The cost is so far very difficult 

to calculate. 

Some homeowners and businesses had flood insurance policies to 

help their recovery. Many others did not, possibly because it was 

not required or because they assumed they were safe outside of the 

100-year floodplain. 

I hope to get an update from Deputy Associate Administrator 

Wright on how the NFIP is responding to the devastation in Louisiana. 

In addition, given the significant concerns that have been raised 

around FEMA’s claims process, I want to hear more about FEMA’s 

‘‘Transformation’’ effort to improve the NFIP following Superstorm 

Sandy and how that is working for policyholders in Louisiana. 

I also view today’s hearing as the first step in a comprehensive 

examination of the program leading up to its reauthorization in 

2017. 

The National Flood Insurance Program seeks to combat the effects of flooding through its three interrelated components: 

One, flood insurance, to help property owners recover quickly 

after a flood and reduce the need for Federal emergency appropriations; 

Two, floodplain management, to minimize damage to people and 

property through mitigation and local ordinances; 

And, three, floodplain mapping. 

3 

By identifying and mapping flood hazards, floodplain mapping 

underpins both the insurance and the mitigation components of the 

program. 

The subject of today’s hearing goes to the heart of something 

both familiar and vital to us all: our homes and communities. 

Just ask the people of Louisiana. 

We need to focus on ways to keep people and property out of 

harm’s way and help them bounce back when disaster does strike. 

We also need to make smart investments in infrastructure and 

mitigation to make our communities more resilient and to save taxpayer dollars today and in the years ahead. 

Accurate understanding and communication of the flood risks we 

face is critical to those decisions. 

Congress recognized the importance of accurate maps in our 2012 

NFIP reauthorization, when we authorized increased funding for 

FEMA’s flood mapping and established the Technical Mapping Advisory Committee to provide expert advice on improving mapping 

for current and future conditions. 

Our witnesses today will discuss TMAC’s recommendations. I 

hope to gain an understanding of the time, resources, and any congressional actions that will be necessary to make them come about. 

I hope this hearing brings that to us. 

Mr. Wright, I understand that the short notice of today’s hearing 

did not permit you to submit advance written testimony as is called 

for in the rules of the Committee. I hope you will be submitting 

that testimony for the record. 

Mr. WRIGHT. I will, sir. 

Senator BROWN. Thank you. 

With that, I welcome the witnesses, and I look forward to hearing the testimony of all three of you on this important topic. 

Chairman SHELBY. First, we will receive the testimony of Mr. 

Roy Wright, Deputy Associate Administrator for Insurance and 

Mitigation for the Federal Emergency Management Agency. 

Next we will hear from Mr. John Dorman, who serves as the 

Chair of the Technical Mapping Advisory Council. He is also the 

assistant State emergency management director for risk management for North Carolina. 

Last, we will receive testimony from Mr. Scott Edelman, the Vice 

Chair of the Technical Mapping Advisory Council. Mr. Edelman is 

also the senior vice president for North America for AECOM Water 

Resources. Is that right? 

We welcome all of you today. Your written testimony will be 

made part of the hearing record in its totality. We will start with 

you, Mr. Wright. 

STATEMENT OF ROY E. WRIGHT, DEPUTY ASSOCIATE ADMINISTRATOR FOR INSURANCE AND MITIGATION, FEDERAL 

EMERGENCY MANAGEMENT AGENCY 

Mr. WRIGHT. Good morning, Chairman Shelby, Ranking Member 

Brown, and Members of the Committee. I am Roy Wright, and I 

serve as that Deputy Associate Administrator. Thank you for the 

opportunity to testify about FEMA’s Technical Mapping Advisory 

Council—the ‘‘TMAC,’’ as we will call it—the recommendations it 

4 

has provided to FEMA, and our progress addressing those recommendations. 

As indicated by their name and clearly stated in the TMAC charter, the Council is an advisory board established to advise and 

make recommendations to the FEMA Administrator and the flood 

mapping program. The Council’s recommendations aid FEMA in 

furthering our efforts to provide communities with the best available data and tools to make better informed decisions that reduce 

the risk and consequences of flooded across our Nation. 

These recommendations in the mapping field complement our endeavors elsewhere in the National Flood Insurance Program. Mr. 

Brown asked about the transformation we are doing for the customer, experienced policyholders, really a generational leap forward that we are taking on our actuarial and claims underwriting 

processes; ensuring that policyholders, like those that we serve in 

Louisiana, get their claims paid accurately and quickly. 

We can talk more about this, but I will highlight inside of the first 30 days, almost 29,000 claims have been filed, more than $300 

million in advance and early payments have moved out to insured. 

This is a pace that has never been seen in the history of National 

Flood. 

To the TMAC, FEMA fundamentally agrees with the intent of all 

22 of the recommendations in the 2015 annual report. As I look at 

those recommendations, I kind of see them in three streams: there 

are those of a technical nature that can be addressed through our 

normal policy updates; a second group that are probably a stretch 

for our program, but they can be accomplished with current science 

and resource levels; and, third, a transformative set that requires 

the science to evolve and resource levels that may not exactly be 

knowable today. 

Over the last several months, we evaluated each and every one 

of these recommendations to understand resource requirements 

and impacts to inform implementation, priority sequence, and investments. 

Perhaps the most transformative recommendation made in the 

TMAC 2015 report is to transition from the 1-percent annual 

chance as the basis for flood insurance ratings to a structure-specific flood frequency determination. This recommendation will require an entirely new approach to insurance rating and underwriting, including new regulatory hazard and risk products. It 

could also have cascading effects on floodplain management standards in communities. 

In January 2016, the TMAC also delivered its Future Condition, 

Risk Assessment, and Modeling report looking beyond today’s risk. 

The recommendations there really have tried to push us in ways 

that drive past what is currently practiced, so putting our agency 

in a position to address and inform future building in the country. 

This summer, the TMAC submitted the 2016 Flood Mapping Program Review as required under Section 17 of the Homeowners 

Flood Insurance Affordability Act of 2014. This report included a 

set of recommendations to further advance the program’s credible 

flood hazard data into the future. Based on the advice from the 

TMAC and my recommendation, the Administrator has certified 

the flood mapping program as credible. 

5 

We have already begun implementing the technical recommendations that we can address through policy. We continue to make 

strategic investments like high-resolution topography, structurespecific data sets, and enhanced flood models; and are laying out 

the planning that we need to lay the foundation for this transformative work going forward. 

Those transformative pieces, including the TMAC’s recommendation to transition away from the 1-percent annual chance to provide 

the structure-specific risk information, will necessitate additional 

research and planning, internally and with our partners. 

This said, to the Chairman’s point, we need to meet these transformations in flood hazard analysis with complementary leaps forward in our actuarial and underwriting practices. I consider this 

new approach to insurance rating and underwriting crucial to the 

program. Simply, we need to set premiums that best reflect the 

risk. 

While the flood risk analysis is essential, nothing is more powerful to communicate risk than a pricing signal. These initiatives and 

investments will be critical as FEMA assesses how we move away 

from being able to support kind of a big event understood to understand the whole manifold of events that can take place. We have 

got to move to structure-specific flood frequencies, and eventually 

we need to actually see the actuarial structure of the program fundamentally shift. 

I appreciate the extraordinary time invested by the Technical 

Mapping Advisory Council. Their hard work and dedication will 

serve this program well. I am happy to address your questions, and 

thank you, Mr. Chairman. 

Chairman SHELBY. Mr. Dorman. 

STATEMENT OF JOHN DORMAN, CHAIR, TECHNICAL MAPPING 

ADVISORY COUNCIL, AND ASSISTANT STATE EMERGENCY 

MANAGEMENT DIRECTOR FOR RISK MANAGEMENT, AND DIRECTOR, NORTH CAROLINA FLOOD RISK MANAGEMENT 

PROGRAM 

Mr. DORMAN. Thank you, Chairman Shelby, Senator Brown, and 

Members of the Committee for the opportunity to come and provide 

a perspective on the 2015 Technical Mapping Advisory Council. As 

noted, I am John Dorman. I am the North Carolina assistant State 

emergency management director for risk management—that is a 

mouthful—and also the director of the Flood Risk Management 

Program. 

Necessity is the mother of all innovation. That is an English 

proverb that speaks well to the overall tenet of the TMAC recommendations. FEMA has diligently overseen the generation of the 

current flood maps that focus more toward the hazard. However, 

transformational strategies must be implemented to address the 

needs of the country and the program, such as insurance rates that 

reflect structure-anticipated flood loss; communication that focuses 

on financial loss as opposed to just an ‘‘in and out’’; and homeowners’ understanding of and confidence in the data used for flood 

hazard determination and insurance premiums. 

For North Carolina, Hurricanes Floyd, Francis, Ivan, and Irene 

all demonstrated and compelled North Carolina to the need for imVerDate Nov 24 2008 15:35 Jun 29, 2017 Jkt 046629 PO 00000 Frm 00009 Fmt 6633 Sfmt 6633 L:\HEARINGS 2016\09-13 ZZDISTILLER\91316.TXT JASON
6 

plementing transformational strategies. Thus, North Carolina has 

successfully implemented the ability to generate structure-based 

flood probability; structure-based flood risk assessments; structurebased real-time impact and warning; and structure-based, riskbased insurance rating. We are doing that. Recent events across 

the country have again shown a lack of accuracy and awareness of 

structure-specific flood risks that both large storms and localized 

flash flooding can present. With these needs ever apparent, I believe TMAC has constructed recommendations that, if implemented, will transform the program and improve the Nation’s resiliency to flooding. While there are 22 recommendations, I would like 

to quickly speak to four of those that will be transformational. 

First—and you have heard this before—fundamental to accurate 

flood hazard identification and risk assessment is accurate, highresolution elevation data. Recent developments in data collection 

technologies offer the most accurate and efficient collection of 

ground elevation possible. Technology such as Geiger LiDAR sensors collect data at both a higher altitude and higher accuracy allowing for faster acquisition and a lower cost of acquiring and processing the data. This higher-resolution data also allows the opportunity to meet other needs of other stakeholders—such as the Department of Transportation and Utilities—that allow stakeholders 

to play a part in sharing the cost. 

Second, the transition from a 1-percent or 100-year flood delineation and its elevation to a structure-specific annual chance frequency with elevation is critical for the awareness of every property that is in the flood zone, and it is, of course, interesting to note 

that 26 percent of all flood claims occur outside of the 100-year 

flood line. The recent events in Louisiana demonstrate the importance of altering our Nation’s mentality that one is safe if they live 

outside of that line on to a raised awareness of flood prevention at 

the structure level. 

Third, the transitioning to a focus of structure-based risk assessment. This increased level of detail that calculate structure-specific 

percent chance of flooding and estimated annualized damage calculations can inform mitigation decisions and create more accurate 

risk-based insurance premiums. This will directly result in mitigation actions to reduce losses, lessen the financial burden of the Federal Government to help communities recover from disasters, and 

create a more financially sound FIMA. 

Finally, we must transition to a dynamic, queried display of data, 

models, maps, and risk assessments. I will just say I have seven 

children, and most of them are in the Millennial generation, and 

as we have seen, the Nation has changed in how it looks at and 

demands data. We must create a more robust database that enables data to be dynamically queried and displayed on the Web 

site. Floodplain modeling and mapping is an ever changing science, 

based largely on the statistics and the changes in land use and topography. We need to create an efficient methodology to quickly 

and efficiently update flood hazard and risk information and provide that at the fingertips of the end users on all types of devices. 

I want to point out that all or some of the four recommendations 

I have just mentioned have been successfully implemented in four 

7 

States. These recommendations are not ideas or pie-in-the-sky. 

They are proven concepts that are operational today. 

Thank you again for the opportunity to address the Committee 

on this important topic. I would be willing and happy to answer 

any questions you may have. 

Chairman SHELBY. Mr. Edelman. 

STATEMENT OF SCOTT K. EDELMAN, VICE CHAIR, TECHNICAL 

MAPPING ADVISORY COUNCIL, AND SENIOR VICE PRESIDENT, AECOM 

Mr. EDELMAN. Good morning, Chairman Shelby and Members of 

the Committee. I am Scott Edelman, senior vice president of 

AECOM. I have spent my career solely focused on solving our Nation’s water-related opportunities and challenges. I appreciate this 

opportunity to appear before the Committee on Banking, Housing, 

and Urban Affairs. 

I have been involved with creating maps for FEMA since 1981, 

and I am privileged serving as Vice Chair on the Technical Mapping Advisory Committee established by the 112th Congress. We as 

a Nation have simply endured too much pain and suffering due to 

floods. 

I believe that Roy Wright’s strong support and encouragement of 

the TMAC has resulted in two reports that show a path to the next 

evolution of the NFIP. In the future, I believe that if the recommendations of the TMAC reports are supported by Congress and 

the Administration, we can make significant strides to reduce both 

the pain and suffering that our citizens are enduring at a record 

level and the burden these unprecedented events continue to drain 

resources from our U.S. Treasury. 

Of the 29 recommendations contained in the TMAC 2015 reports, 

I believe that the three most important priorities and potential 

benefits are: 

First, the reintroduction of a 5-year rolling plan, to allow 

leveraging of Federal dollars; 

Second, the movement to structure-based risk assessments, to 

create a safer Nation; 

Third, preparing the Nation for future conditions, to stop building new problems. 

First, the reinstatement of the 5-year rolling plan allows the 

leveraging of local and State dollars. FEMA cannot make the Nation a safer place alone. The operating principles of FEMA’s Whole 

Community doctrine is critical as applied to flood-related mitigation. Flood waters know no jurisdictional boundaries as they devastate lives and property, and, therefore, we need to fully engage 

local communities and make these shared responsibilities more apparent to all. When Congress funded Map Modernization in 2003, 

FEMA produced the Multi-Year Flood Hazard Identification Plan, 

MHIP. MHIP addressed every county in the Nation with when and 

how much anticipated funding would be available. The result was 

an enterprise-wide approach to maximize the return on Federal investments in which FEMA served as the chief risk officer to those 

investment in the studies, and communities felt strong local ownership of the studies and results. This approach better aligned FEMA 

with State and local efforts to reduce the loss of life and property. 

8 

Second is structure-based risk assessments. We must change the 

perception that if I am just on the other side of the 100-year flood 

line I am safe. Too much time is spent trying to justify the movement of the flood line by a few feet when in actuality the risk of 

flooding of the structure only has changed ever so slightly. Much 

of the problem is due to uncertainty of the line itself. 

To my knowledge, this is the only product that engineers produce 

and communicate to the public that deals with averages and not 

what is safe. 

We also have a great deal of uncertainty within the calculations. 

In all actuality, the current 100-year average line shown on the 

flood maps is probably closer to a safe design of a 10-year event. 

Moving to a structure-based risk assessment begins to change 

the conversation from one focused on ‘‘in versus out’’ to one that 

starts to communicate levels of risk. We must also take into account affordability and grandfathering with sunset clauses to take 

into account our most vulnerable communities and constituents. 

Third, we need to prepare the Nation for the future. GAO asked 

FEMA to evaluate the impact of future conditions on the National 

Flood Insurance Program. The report concluded that by the year 

2100 on average our floodplains are going to increase by 45 percent, the number of polices we have are going to increase by 80 

percent, and the average loss per policy in today’s dollars will increase by 50 percent. This is an immense challenge to our country. 

We need to encourage local communities to adopt higher standards 

on a volunteer basis, understanding that the higher standards results in less loss of life. Many communities have done this, including Mecklenburg County and the city of Charlotte. Based on their 

adoption of future conditions elevations, Mecklenburg County has 

estimated savings from flood damages from a single 100-year event 

to be over $150 million. We need to stop building future problems 

so we can fully concentrate on mitigation of existing problems. 

My passion is not solely on the science but the need to help the 

Nation with this longstanding challenge and the billions of tax dollars that are unnecessarily wasted because of poor land use decisions and the attempt to tame or ignore Mother Nature. 

I want to again thank the Committee for this opportunity. I urge 

Members of the Committee to refer to the two TMAC reports for 

more detail as a formal part of our testimony. 

I would be happy to answer any questions you may have. 

Chairman SHELBY. I will ask all of you this: In your view, does 

the Flood Insurance Program accurately map, price, and communicate flood risk to homeowners in communities? Mr. Wright, does 

it or does it not? 

Mr. DORMAN. I believe it does present it in a way that is consistent. I would tell you that there is so much more potential related to making it more precise. It can be actuarially sound for the 

80 percent of the policies that are in that space, but there is significant ability for us to improve. 

Chairman SHELBY. Mr. Dorman. 

Mr. DORMAN. Sir, I believe the guidelines and standards that are 

being followed does allow for the making of appropriate maps. I do 

believe that the relationship between the individual and the insurance rater is the most important component to that, and I would 

9 

say that they would feel it is not adequate. But for the level of data 

that they currently have, I believe it is meeting its need. 

Chairman SHELBY. Mr. Edelman. 

Mr. EDELMAN. We have two challenges with the 100-year flood 

line, first as it deals with averages. As engineers, when we communicate numbers to the public, we deal in what is safe. If a 20-ton 

truck was going to go over a bridge that is supposed to be safe for 

20 tons, you expect to put thousands of trucks over that every time 

and not have the bridge fail. The standard that we are using on 

the maps, though, is that every other truck would fail that bridge. 

So we are communicating that wrong. 

Second is uncertainty. We are a very young Nation. We have 

gauge records of 20, 40, 60 years that are trying to predict something that is 100 years out. If I was going to do the engineering 

on the Nile River, I would probably have thousands of years of 

records I could use. This uncertainty creates a large unknown such 

that our elevations many times could be many feet higher or lower 

than what is shown on the maps. 

Chairman SHELBY. The chance of flood determinations, Mr. 

Edelman, the report recommends that the National Flood Insurance Program move away from identifying the 1-percent annual 

risk to a structure-specific flood frequency determination and associated flood elevations. This 1-percent determination has been in 

place since the creation of the program. What are the specific differences between the two approaches? And how would the program 

change under the structure-specific determination methodology? 

And what is the downside here? Because a lot of the stuff we have 

today is not working. 

Mr. EDELMAN. You are absolutely correct, Mr. Chairman. The 

problem that we have today is this in versus out mentality, that 

if you are just a few feet outside the 100-year line you are safe. 

What we are proposing is that all structures have some level of 

risk. If you are built on the top of a hill, your risk is going to be 

very low. But if you are just really close to that line, you still have 

risk. And we need to have a graduated system for moving through 

this. 

The challenge that we are going to have is not so much on the 

technology. We can do this today. We know how to do this. The 

challenge will be with the implementation of how do we then move 

the program from the current position to this new world, and I believe we are going to have to do this with grandfathering, with sunset clauses that may take 10 or 20 years to fade on out to make 

this accurate. 

Chairman SHELBY. Senator Brown. 

Senator BROWN. Thank you. 

Mr. Edelman, you used the phrase in your testimony, ‘‘We must 

change the perception,’’ and I want to ask you and Mr. Dorman a 

couple of questions, and you can go first, about how we communicate flood risk to consumers. When most people think about flood 

risk, when they think about NFIP, they think about whether they 

are in or out of the 100-year floodplain, assuming they are not at 

risk if they are outside of that zone. You have both intimated that. 

What exactly does the notion of the 100-year floodplain obscure for 

consumers? And by that, you know, how do we better communicate 

10 

with people so that they understand better their flood risk and insure their properties appropriately? How do we communicate that? 

Mr. Edelman, if you would start on that. 

Mr. EDELMAN. OK. We can identify that by being structure-specific. What people want to know is what is the risk of my property, 

of my building, not so much what is generally happening in my 

neighborhood or my town. So we have to be very structure-specific 

to do that, and by allowing people to use the latest technology to 

click on their individual house to see what that risk is. 

Senator BROWN. Mr. Dorman. 

Mr. DORMAN. Well, I can speak for North Carolina. What we 

have done is we have collected first-floor elevations for all properties in the 100-year flood zone. And when there is a flood and it 

starts flooding inside that property, there is a financial cost to 

them. At the current pace we have, all we know for homeowners 

is you are either in the 100-year or not, whether you are going to 

flood more frequently or whether you are not. So everyone at the 

current time sees either a 100-year event, it is going to happen to 

me or not. 

So what we have done in North Carolina and I believe what the 

TMAC is proposing is that for each individual property we determine at the 100-year or different levels of frequency what the financial cost will be to the individual. That, from my perspective, 

speaks very clearly to an individual what they need to do to cover 

themselves. 

Senator BROWN. Specifically, what Mr. Edelman said, you designate each structure with—attach the flood risk to each structure. 

Mr. DORMAN. And the financial damage that will occur from that. 

Senator BROWN. OK. Mr. Wright, NFIP came under fire for its 

management of the Sandy claims process. You talked about the 

good news of the unprecedented response to Louisiana. Tell me 

what lessons you learned from Superstorm Sandy and your response and what steps you have taken to improve it. 

Mr. WRIGHT. So, clearly, there was the scale of Sandy, 144,000 

claims, $8.5 billion that was paid out initially. And as this Committee’s investigation pointed out, there were plenty of stumbles in 

terms of how that is done, and part of the charge that Administrator Fugate has given to me is to set that back to right. At this 

point, 97 percent of those files that requested review have been reviewed; 80 percent of those offers have been made; and we are 

wrapping that up here in the weeks to come. 

But fundamentally for me, what it did was to force us to step 

back and say the relic of this program, much of which you can tie 

back to 1986 and 1999, had to change. So we saw this in what we 

did in Louisiana. I was on the ground very early. I have been down 

there twice. We have been in folks’ homes. Folks, where they have 

an insurance policy, want to know that the money is coming. We 

push the money. Again, it does no change the overall claim 

amount, but get those dollars so that they can begin their own repairs, ensuring that they have an off ramp when they get frustrated and confused. 

So I have been out in the press, and we have been pushing these 

things. If you are not getting the answer you want from the insurance company, do not wait until the end. Come to us. We have 

11 

added a tremendous amount of oversight in terms of quality control, tripled the amount that has historically been done in the program, far more transparency, not only about from the company’s 

data but—in spite of the fact that the State insurance commissioner does not regulate my program, I volunteered to provide all 

of my information related to our performance to the State insurance commissioner. So if you have got problems, let us know. 

Some of this is about simplification. This will be the first event 

that will be able to fully avail itself of our new appeals process. I 

think one of the big things I learned from Sandy is if we would 

have had a robust and fair appeals process, we could have addressed concerns as they came our way. The prior regime that was 

in place just was not credible enough. I could say more, but—— 

Senator BROWN. What did you mean when you said make sure 

that there is an off ramp when a homeowner is confused? 

Mr. WRIGHT. When someone files a claim, we tell them to call 

their agent or their company, and we sell through 80 different companies that are out there, and that is the first place to go to file 

your claim. But this program is underwritten by the Federal Emergency Management Agency, and so if I have a customer or a policyholder who has been frustrated by their company, somehow something got dropped, this is my program at the end of the day. And 

what we have done is said, ‘‘You call me.’’ And I am out there. You 

call 1–800–621–FEMA, and you push number 2 for flood insurance, 

and you get to someone so that we can resolve this. You should not 

have to wait. 

Senator BROWN. Good. Thank you. 

Thanks, Mr. Chairman. 

Chairman SHELBY. Senator Scott. 

Senator SCOTT. Thank you, Mr. Chairman. Good morning to the 

panel. Thank you all for being here. Mr. Wright, good seeing you 

again. 

Just one quick question on the Sandy crisis. What percentage of 

homeowners had flood insurance in that area? 

Mr. WRIGHT. So I do not have great insight into that. Give me 

a little moment to kind of explain. I know how many flood insurance claims I have. No question about that. But FEMA does not 

retain data on structures and properties across America. So we 

have approximate pieces. 

I know at a hearing with both you and Mr. Vitter in July, we 

talked a bit about this, and one of the elements that I have worked 

on since then is, as part of our broader affordability work, we are 

going and doing some data matching with the Census Bureau, 

where we are taking our 5.1 million policies and bringing in some 

of the census data, because we need better answers to this question 

about how many structures are in versus out. 

Senator SCOTT. So you have no clue on the percentage of homeowners—— 

Mr. WRIGHT. We have a series of studies that range—— 

Senator SCOTT. Mr. Wright, let me ask you a quick question. 

Mr. WRIGHT. I apologize. 

Senator SCOTT. Because, unfortunately, 5 minutes is not as long 

in Washington, DC, as it is other places. You do not have a clue 

at this point, and perhaps you can provide that to me, because here 

12 

is my point: My answer—I spent, as you know, 20 years in the insurance business, and so my assumption is that the answer is, ‘‘Not 

many.’’ And because the answer is like, ‘‘Not many,’’ when I look 

at my State and the flood insurance mapping that is going on right 

now, when we look in Horry County specifically—a 1,000-year flood 

just occurred in South Carolina. We know that most of it was in 

the middle of the State. Unfortunately, part of the consequences of 

the flood mapping and using the 100-year model is that there are 

places in Horry County that will now have to have flood insurance 

that did not flood even during a 1,000-year flood. Perhaps an additional 35,000 houses will need flood insurance even though they 

are not, according to the 1,000-year flood, in real danger, with an 

increased premium of around $6,000. Said differently, for the 

homeowner who has a mortgage, that could be about another $500- 

a-month in your mortgage premium. A substantial increase. 

I know that there is no way that FEMA takes into consideration 

low-income houses and the impact that the mapping would have on 

their ability to keep their homes. It is probably impossible for that 

to be an expectation. What concerns me, however, is knowing that 

one of the worst disasters from a flood perspective occurred really 

outside of an area that anyone would anticipate flood insurance, it 

does lead to a logical conclusion that many folks who have flood insurance will be absorbing the price and the responsibility of flooding in places where you just cannot model it. 

A part of that process has created much concern in Horry County 

because, while it is a 10-year remapping process, it is a 90-day appeal. And in those 90 days, you have to—according to my friends 

in Horry County, the community has to develop hydrology, hydrologic data and analysis, in order to appeal what took 10 years on 

one side, you only get 90 days on the other side. And, frankly, the 

information that we use to create pricing, according to my folks 

who did not experience flooding, is at best inconsistent with the realities that they have experienced for the last couple hundred 

years. 

Mr. WRIGHT. So a couple of key points. All of the mapping efforts 

that you are discussing have been in motion for a number of years, 

most of them for less than 10 but for a number of years, and the 

event from last fall, we did not go back and redo the work, so it 

is based on the 1-percent annual chance from a prior cycle. 

To the point about the price, in every instance, given the direction in the 2014 legislation that was passed and signed into law, 

anyone who is coming in is not getting the $6,000 price. They are 

actually coming in at a newly mapped rate. That average is between $300 and $500, depending on the level of coverage. They do 

escalate over time, but they are coming in at a much lower rate. 

I think to the appeal question, I think it is very important. What 

I will assure you of is we have been sharing the data with the community throughout the process. They do not just get it at the end. 

In fact, they have a number of instances where the community gets 

a preview of it, and it says, ‘‘Do you want to give us additional information? Do you have things that would change it?’’ 

The 90 days per se related to that appeal period is set in statute. 

And so what we have done very intentionally is work a long way 

13 

on the front side so there are no surprises, so that when the 90 

days starts that is set in statute, folks are primed to play. 

Senator SCOTT. I am out of time. I will just end my comments 

with one comment as opposed to a question, and Mr. Vitter made 

this point during our small business hearing when you were there 

to testify. I recognize that the average price of flood insurance is 

under $1,000. I have flood insurance at my home, and I am 30 

miles outside of Charleston. I will tell you that in some areas—and 

I think one of the examples that you used was the flood insurance 

premium was somewhere over $25,000. So we are not talking about 

a $300 to $500 average premium. We are talking about the outliers 

that are becoming more of—less of an anomaly and more baked 

into the reality of many homeowners. And I do not know many 

homeowners who can afford what some will experience in Horry 

County—maybe not all, but more than a few—a $6,000 premium, 

which is going to be hard to absorb, and it would be great if we 

could find a way to take that into perspective and context as we 

think about flooding and disasters going forward. 

Thank you. 

Chairman SHELBY. Senator Tester. 

Senator TESTER. Thank you, Mr. Chairman, and I want to thank 

you and Senator Brown for holding this hearing. 

Before I get to the witnesses, I want to speak about a bill—and 

Senator Heller was here earlier—than Senator Heller and I have. 

We have been working on it. It is called the ‘‘Flood Insurance Market Parity and Modernization Act.’’ It is an important bill that will 

offer consumers flood insurance options, and I think it will help 

NFIP remain viable over the long haul. It will introduce private insurance into the marketplace under the supervision of State insurance commissioners. It was introduced in the House by Murphy 

and Ross. It passed the House 419–0, which is an unusual thing 

for the House to do. But the fact is I think it speaks of the support 

of this bill, and I would love to see the Committee take this up because I think it is something that could help. I know that there are 

Members of this Committee who oppose it, but that is what hearings are about, hammering out the differences. And so I just bring 

that up because I think it is important. 

You know, this hearing should be held in front of the Energy 

Committee. Things are changing. Here are some things that I 

heard in the testimony: a pace never seen before in National Flood, 

the growth; 26 percent of the claims are outside the flood lines; in 

83 years, our floodplains are going to increase by 45 percent. And 

then I heard premiums need to reflect risk; otherwise, the taxpayer 

pays for it. 

And, quite frankly, this puts us in a conundrum because, as Senator Scott said, we have—you know, we have got people who cannot afford these kind of claims. By the same token, if we want to 

talk about fiscal prudence, we cannot expect the taxpayers, as we 

see these claims go up and up and up and up and up and up and 

up, and billions and billions of dollars—I think the Chairman said 

Sandy was a billion bucks. That is probably going to be a cheap one 

next year. Who knows? 

So I appreciate the work you do, and it puts us in a difficult situation because I think most of us believe the premiums need to reVerDate Nov 24 2008 15:35 Jun 29, 2017 Jkt 046629 PO 00000 Frm 00017 Fmt 6633 Sfmt 6633 L:\HEARINGS 2016\09-13 ZZDISTILLER\91316.TXT JASON
14 

flect the risk, but we do not want to premium people outside their 

homes, which means we need to come to the realization that things 

are changing in our climate, and they are changing quickly, and 

more quickly than we can adapt to them in a reasonable way. And 

if we are going to continue in this body of the U.S. Senate to have 

policies in this country that promote climate change, we had better 

get the wallet out, and we had better expect the taxpayers and our 

next generations to pay a lot of money. That is my editorial comment. 

Now I want to talk to you, Mr. Wright, about—by the way, could 

you give me some figures on what is happening— how long have 

you been with the agency? 

Mr. WRIGHT. I have been with the agency for 8 years. I have 

been in this role for 15 months. 

Senator TESTER. OK. So it would be unfair. I am going to ask 

your agency to see what FEMA’s budget has done over the last 20 

years. My guess is it has probably grown not just double but a hell 

of a lot more than that. 

Mr. WRIGHT. There has been an up-and-down swing—we will get 

you some numbers—in both the Disaster Relief Fund as well as the 

base funding for the programs. 

Senator TESTER. OK. Thank you. 

We have an issue in Montana on levees. It used to be that the 

Army Corps would give FEMA information and—and correct me if 

I am wrong—they would accredit those levees. The Army Corps decided they were not going to do that anymore because they said 

they do not have the budget capability of doing these accreditations 

and, quite frankly, the liability is too high, which puts the communities in a position where they cannot afford to do the accreditation. And it puts you in a position that you cannot afford to make 

the decision as to whether it is a viable levee or not without that 

information. 

Could you talk to me, is the relationship between FEMA and the 

Army Corps when it comes to levees, is that over with? Or are you 

still working with these guys? Can you work with them? Are they 

offering you information? Give me an idea what is going on. 

Mr. WRIGHT. So we work very closely with the Army Corps of 

Engineers. I think if you go back 5, 6 years ago, I think that that 

relationship needed a tremendous amount of work, and we have repaired it in that period of time. 

You point out their resourcing issues, so they have three different kinds of analysis that they do of levees. Their top tier one 

meets everything we need, but they do not do those very often. 

Their bottom tier one, which they do all the time, meets very little 

of the needs that we have. 

And so under our regulations, the primary responsibility for 

levee certification belongs to the levee owner. In many instances, 

the Corps built them and then turned them over to the local sponsor. 

There are a few changes that I have put in place. One of them 

is to work very closely with the local levee districts or authorities 

so that we can give appropriate credit for however much protection 

it does provide. Simply telling me that, you know, this levee has 

done very well for the last 40 years is not sufficient. In some inVerDate Nov 24 2008 15:35 Jun 29, 2017 Jkt 046629 PO 00000 Frm 00018 Fmt 6633 Sfmt 6633 L:\HEARINGS 2016\09-13 ZZDISTILLER\91316.TXT JASON
15 

stances, I have spoken with levee board members, and I have said, 

‘‘Have you drilled a boring in this in the last 40 years? Have you 

checked for safety?’’ 

Senator TESTER. Right. 

Mr. WRIGHT. And they go, ‘‘No.’’ You know, that is one of those 

pieces that from a safety perspective is concerning to me. 

Senator TESTER. Yes. 

Mr. WRIGHT. And so what I have got to do is find the best kind 

of balance of how do we work with them, and we have made partial 

credit more feasible in terms of how it reflects, but there is a cost 

to that certification. 

Senator TESTER. Well, I appreciate your work, Mr. Wright, and 

I appreciate the work of all the folks on this panel, and I appreciate your testimony even though I was focused more on Mr. 

Wright than the rest of you. But I would just say that if there is 

stuff coming down the pipe where you need help to make this happen—because it is not happening, and we are putting a lot more 

folks in the floodplain because of that—not in all cases. I should 

not make a blanket statement. You know what I mean, Roy. 

Mr. WRIGHT. I do. 

Senator TESTER. Thank you very, very much. 

Mr. WRIGHT. Thank you. 

Chairman SHELBY. Senator Vitter. 

Senator VITTER. Thank you, Mr. Chairman. Thanks to all of you 

for your important work in this area. 

I first want to underscore the significance of the recent Louisiana 

flooding. I think it was really, unfortunately, underreported in the 

national news for various reasons—a lot of other things going on, 

the Olympics, the Presidential race. And I think it is underappreciated in this body. We were away on the August recess. But by 

any metric, it was the most significant disaster since Sandy. Red 

Cross confirms that; FEMA confirms that. 

There have been over 138,000 individual FEMA claims. That 

compares to flooding in northern and central Louisiana earlier this 

year. That was very significant, under 40,000. Flooding in South 

Carolina last year that was very significant, about 26,000. So it 

was literally a 1,000-year flood event. It was a big event. And, unfortunately, only about 22 percent of those flooded had flood insurance, not because they did not meet some requirement or some notion of what was the prudent thing to do; rather, they were way 

outside what was understood as any sort of flood zone. 

Mr. Wright, thank you for your work and for FEMA’s work. Do 

you want to make any quick comment on the significance of the 

event and also the percentage of those uninsured? 

Mr. WRIGHT. Absolutely. As I look back at the last dozen years, 

this one is number four on the list. I have got Katrina, Sandy, and 

then Hurricane Ike from 2008. From a pure policy count number, 

it is number four in line. It is in a riverine area, more inland. And 

as I walked through some of the neighborhoods, and particularly 

in areas inside the special flood hazard area first, there were a tremendous number of rental homes by which the landlord presumably had it paid off, they did not carry flood insurance, and the 

renter did not flood insurance. There was one block where only one 

16 

out of eight of those homes had flood insurance, yet they were all 

inside. 

I would then also speak to those beyond. So I look at some of the 

things—I always get in trouble when you call out parishes, but I 

looked particularly at East Baton Rouge and Livingston parishes 

where we saw a tremendous amount outside. Those folks clearly 

saw the 1,000-year event. And so as you see that structure—I look 

at the counts particularly in East Baton Rouge and the kind of concentration of that. This absolutely is a devastating event. 

Senator VITTER. Thank you. I just want to underscore that because the Administration is going to properly make an emergency 

request. But, again, 78 percent of those affected, no flood insurance, not because they did something wrong but because the great 

majority of them were way outside what was identified as any sort 

of flood area. 

To go to this mapping issue, Mr. Dorman, thank you for your 

work. You point out in your testimony the good work of North 

Carolina as well as Alabama and Virginia in their use to the Flood 

Risk Information System, and there are similar ways of going 

about obtaining that much greater level of clarity and accuracy. In 

layman’s terms, what do other States and the Federal Government 

have to do to capture that level of real-time and property-specific 

understanding? 

Mr. DORMAN. Well, I would say a couple things: 

Efficient use of technology. This same set of LiDAR data can give 

you building footprints. North Carolina collected 5.2 million building footprints to know where the buildings are located. The LiDAR 

technology does that. It also gives you first-floor elevation. 

Partnerships—partnerships where North Carolina has worked 

with our local governments to give us all the tax parcel information 

that we tie to the buildings. 

So, Senator, I would say the data is out there. For the most part, 

the data is out there. It comes down to efficient use of technology 

and the efficient use of partnerships. And for North Carolina, we 

have been able to leverage up to $20 million of partnership 

leveraging with other entities in sharing that set of data that they 

have a vested interest on. I mentioned that a little bit. The Department of Transportation needs information for their road 

centerlines. The LiDAR data does that for them. Utilities need it 

for power lines, for transmission and distribution. 

So we have not gone out and collected it ourselves. We have 

partnered and used technology to do that. 

Senator VITTER. Great. Thank you. 

Thank you, Mr. Chairman. 

Chairman SHELBY. Senator Reed. 

Senator REED. Well, thank you very much, Mr. Chairman, and 

thank you for holding the hearing. I was very active with my colleagues in trying to create this organization back a few years ago, 

and thank you for your work, gentlemen, and collectively your colleagues. 

We have set you with the task of updating flood maps, but that 

is a constant challenge, and it also requires resources. And I wonder, Mr. Edelman, can you comment? Because the annual report 

points out quite clearly how resources fell in 2011, and they are not 

17 

keeping up with the challenge, particularly as we see some of these 

ocean effects and flooding effects getting more dramatic. Can you 

comment on that? 

Mr. EDELMAN. Yes, I can. It is really important for us to have 

a stable program, and this is one of the reasons behind trying to 

establish a 5-year plan. Perhaps if we could look at something more 

toward the way that the Transportation Improvement Program, the 

TIP, is done, it would allow for easier planning of activities so we 

do not have these whipsaws up and down and we can fully leverage 

everything. 

The second part of your question there really goes down to the 

heart that as a Nation we need to get out in front of this problem 

and stop building new problems. What we really need to do is draw 

that line in the sand such that let us not create more problems. Let 

us put our hands around what we have, have new development 

occur responsibly, and then let us come back, and then we can 

start working away at our existing problems. 

Senator REED. Well, thank you. 

Now let me turn to Mr. Wright, and this, I think, is a good segue, 

because in Rhode Island we have a Coastal Resources Management 

Council. There is a lot of good work in terms of use of the seashore, 

and we have a lot of it. They are not formally engaged in making 

the maps and revising the maps, but they are a critical source of 

input for exactly the reason Mr. Edelman referred to. 

Can you describe how FEMA is conducting research with these 

agencies, working with these agencies to provide a context for the 

map making? 

Mr. WRIGHT. Absolutely. So I am looking for partners, particularly at a State level, anytime I can find them. I know that my 

staff met with some of the folks from the Rhode Island Coastal 

Commission just here this past summer. As we look at these 

pieces—because to John’s point, there are plenty of other State 

agencies that are doing pieces of this. But for me, this more fundamentally gets down to the understanding of risk. 

When we integrate these programs across a Federal, State, and 

local level, I think we do a more effective job to communicate the 

risk and bring the understanding that is necessary. It is not that 

you get seven different flavors of what is my flood risk from—the 

coastal commission has an answer, the local town council has an 

opinion, FEMA has an opinion. How do you bring those pieces together? That is what is going to best inform that homeowner. 

Senator REED. Well, thank you very much. Again, I think your 

response illustrates another aspect of this, whereas there are generalized models of flooding that you have to use that have been 

validated, et cetera. Then there are the very localized conditions. 

And I wonder, and maybe Mr. Dorman can comment on this. Is 

there a tension here? Is it being effectively resolved between a generalized model versus some very specific conditions in a State or a 

locality? 

Mr. DORMAN. Well, I think the generalized model should be utilized across the board. The question is: What inputs do you put 

into the model? If you put very specific localized inputs into the 

model, it gives you a much higher resolution of result, and that is 

why I believe the TMAC— and what I would suggest is going to 

18 

the structural level. You can define the 100-year flood zone with 

that model. But if you use that same model and apply the elevation 

of the building, you can actually come up with when does the water 

intersect and enter the building’s foundation, and that is where 

that localized, more specific data applies. 

Senator REED. Any other comments, Mr. Wright or Mr. Edelman, 

on this point about localization versus the generic model? 

Mr. EDELMAN. Yes. Everything we need to do, we need to adapt 

to the local conditions. There are some studies that we work on 

that are more broad in general, and that is good to get an understanding of what are the overall future use losses or future expenses that the program may have. But when we are talking with 

the homeowners and the communities, everything we do has to be 

at the local individual level for it to be personal to them and to 

have defendability with the results. 

Senator REED. Well, thank you very much, Mr. Wright, Mr. 

Dorman, and Mr. Edelman. Thank you. 

Chairman SHELBY. Senator Menendez, finally. Thank you. 

Senator MENENDEZ. Thank you, Mr. Chairman. I want to thank 

the panel. This is an incredibly important topic, but I want to focus 

my comments elsewhere. 

Mr. Wright, as you know, the handling of Sandy flood insurance 

claims by FEMA and its contractors was an utter disaster, resulting in untold thousands of survivors being lowballed and unable to 

rebuild. 

Now, I exposed this pattern of underpayment in hearings and 

press conferences more than 2 years ago and subsequently worked 

with your predecessor and with you to establish a virtually unprecedented opportunity for all policyholders to have their claims reviewed once again. And while FEMA should have gotten it right 

the first time, I do appreciate FEMA’s acknowledging it made critical mistakes and attempting to remedy them. 

Unfortunately, even the remedy has been fraught with hurdles 

and delays, with many Sandy victims still waiting 200, 300, or 400 

days beyond the 90-day timeframe FEMA initially promised. But I 

want to focus on the present rather than the past and get New 

Jerseyans the funds they need to rebuild as quickly as possible. 

On this front, I worked with you to speed the recovery by establishing a pilot program to get Sandy survivors the funds FEMA 

itself agreed it underpaid originally without jeopardizing the homeowner’s right to appeal to a third-party neutral. If it taking so long 

to conclude the neutral hearings, why not pay the undisputed 

amount up front and let people get going? 

So let me take a moment to give the Committee a real-world example of how this policy change made a tangible difference in people’s lives. 

Ms. Donna Amon, a woman from Bayville, New Jersey, took advantage of the pilot program and received her relatively modest interim payment without having to waive her right to an appeal. She 

had recently suffered an unimaginable tragedy when her husband 

was killed in an accident while at work. After working with her for 

several months, she wrote the following, after receiving her interim 

payment: 

19 

‘‘I cannot thank you all enough. I finally received about $6,500 

long-owed under my flood policy, and it could not have come at a 

better time as I was in a very tight financial bind after losing my 

husband as he was working on a boat that went down near the 

Tappan Zee Bridge and went in to save the other two crew members. First the Sandy storm, and then losing my husband. You feel 

so alone, and I really felt no one cared. My home was demolished 

in February, and 2 weeks after, I lost my husband, then the finances. Getting the money up front was so important for basic 

things. I am still pursuing the neutral because I feel I was underpaid even after the review found I should be owed $6,500. But I 

could not just wait 5 or 6 months for the neutral to conclude. This 

helps the little people so much. Please keep it going. Do not stop 

now. Other families need the same help that I have received. Sincerely, Donna.’’ 

Now, previously, Sandy survivors were faced with an almost impossible choice: either accept the offer from FEMA and waive your 

right to an appeal, or wait potentially for months on end without 

any payments until the neutral issues a determination and FEMA 

accepts it. Many survivors who know the FEMA offer was still less 

than they deserve were all but forced to accept the underpayment 

because they needed the funds immediately to keep their heads 

above water. 

Now, unfortunately, I understand that FEMA now claims it does 

not have the authority to implement even these basic commonsense fixes. And I do not want to go into the debate over the Administrative Procedures Act or FEMA’s regulatory authority. You 

know, I can go through a list of things FEMA refused to do at first 

but later their lawyer said, yes, you know, allow Sandy survivors 

to appeal their claim outside of the normal appeal process, outside 

of the court system, allow Sandy survivors who survived their proof 

of loss to nonetheless have their claim reviewed again, to have an 

independent third-party neutral outside of FEMA established and 

able to overturn a decision of FEMA. FEMA first said none of these 

things could happen, and then subsequently they did. 

So I ask you, Mr. Wright, do you believe that Sandy survivors 

or, for that fact, anyone who faces this in our country should have 

to choose between exercising their right to appeal from a thirdparty neutral or receiving the undisputed amount FEMA acknowledges it owes them in a timely fashion? And do you believe it is 

fair to say that Sandy survivors who have waited nearly 4 years 

to get what they were entitled to have suffered an emotional and 

financial hardship? 

Mr. WRIGHT. Mr. Menendez, I appreciate your leadership on this, 

and I, like you, am entirely focused on getting everyone the dollars 

that they are entitled to. And I think that I have demonstrated to 

you and your team over the last 15 months, I get to ‘‘yes’’ as much 

as anything. I have moved a lot of barriers out of the way, and the 

struggle I have had on this one, without going into particulars, the 

Administrative Procedures Act, is now I am stumbling through 

these pieces. So I have gone back to my team and said the outcome 

is speed to get these answers, and so I have to find more ways to 

speed this up, to get folks through the neutral, so we are at a point 

where 97 percent of the files are reviewed and 80 percent of the 

20 

offers are made, which has not been fast enough for me or for you. 

And so I have got to stay legal in these various parameters I have 

under the laws and regulations. I will do that and continue to push 

to get these payments done, because they are entitled to closure 

and they are entitled to the payments. 

Senator MENENDEZ. Well, I want to—my time has expired. If the 

Chairman would indulge for another minute, here are the two 

questions I asked you: Do you believe that Sandy survivors or, for 

that fact, anyone else, should have to choose between exercising 

their right to appeal from a third-party neutral or receiving the undisputed amount FEMA acknowledges that it owes them in a timely fashion? That is not whether it is the law or not. Do you believe 

that as a proposition? 

Mr. WRIGHT. So I have to run a consistent process. I have got 

more than 10,000 that have already been closed, and so as I have 

worked this with the legal side, I have got to find a way to hold 

that together so that I treat everyone—— 

Senator MENENDEZ. OK. So I cannot get a simple straight answer on a simple proposition. I am not talking about the legalistics 

of it. I am talking about the value here. Is it fair that someone has 

to ultimately give their right up for a third-party neutral in order 

to be able to accept the payment that is undisputed in the first 

place? Is that a fairness question? 

Mr. WRIGHT. What I want to be able to do is give them the option for their dollars and give them the option for getting that neutral review if they choose to do that. We did agree to add that 

piece, and we are speeding up the pace of it. It has not gong fast 

enough. 

I will continue to work to find a way to get payments in people’s 

hands. 

Senator MENENDEZ. Well, Mr. Chairman—and I know you have 

a great concern about this program and certainly its financial viability. But here is my point: If you for years—years—pay your flood 

insurance policy, meet your obligations, and then, God forbid, when 

the moment comes, the disaster comes, and you find yourself being 

arbitrarily and capriciously lowballed, contractors arranging to 

have lowballed amounts, and then you are forced by virtue of a 

process that makes you accept what you know is a lowball because 

you cannot wait to get your life together again, something is wrong 

with that. 

Chairman SHELBY. I agree. 

Senator MENENDEZ. So as we think about fiduciary responsibilities, which I share with the Chairman, I also think we have to 

think about these types of program changes. 

Thank you, Mr. Chairman. 

Chairman SHELBY. Senator Warren. 

Senator WARREN. Thank you, Mr. Chairman, and thank you for 

holding this hearing. Many of us worked together to draft the bipartisan Homeowner Flood Insurance Affordability Act, which gave 

homeowners some relief on the dramatic increases for flood insurance. And I was glad to be part of that process, but I am still very 

concerned about the ongoing mapping. 

Over 3 years ago, FEMA released many flood maps that our cities and towns knew were not accurate, and those mistakes have 

21 

caused real problems for Massachusetts communities. The city of 

Quincy, for example, was forced to appeal its flood maps, and the 

city was successful, and it lowered or eliminated the flood risk designation for nearly 2,000 properties. But that appeal cost the city 

about $650,000. That is money that Quincy could have used to hire 

more teachers or more firefighters or upgrade roads or programs 

for seniors. But they had to spend it on correcting FEMA’s mistake. 

And it is not just Quincy. Hull and Marshfield and Sitchuet and 

Duxbury and communities all around Massachusetts have had 

similar problems with flood maps. I understand it is a difficult 

process and that FEMA needs more resources, but this just is not 

working. 

So, Mr. Wright, FEMA has acknowledged that there have been 

costly errors because of inaccurate maps, and some communities, 

like Quincy, can stretch their budgets and pay to have those errors 

corrected. But I want to know what happens to a community that 

cannot afford to hire costly engineering consultants to review their 

maps. What happens to them? 

Mr. WRIGHT. So we work through a process that ultimately is to 

engage the community at a series of intervals, because I want to 

make sure that, to the degree that the community has information 

or things that FEMA’s map developers need to know, we get that 

information. What I do see—and we will talk generally as opposed 

to a specific community in Massachusetts—is that there are times 

by which we have lower level people in a community that are attending those meetings that do not necessarily have the viewpoint 

that is broad. Key pieces in the Massachusetts elements dealt, yes, 

with some data elements, but also with alternative models that 

could be used to deal with waive transformation. 

Senator WARREN. I am sorry, but the problem is the maps are 

wrong, and they were able to prove that ultimately. It is just that 

it cost them $650,000 for one town to prove that the maps were 

wrong. And that helped ultimately nearly—that changed the designation for nearly 2,000 properties. I am just asking the question. 

If a town believes the maps are wrong and it does not have the 

money to hire the very expensive engineering consultants the way 

Quincy did, what happens to those towns? 

Mr. WRIGHT. What happens to those towns is we have to work 

with them through that process so that I do get them that piece. 

I understand the disconnect on this, ma’am. I truly do—— 

Senator WARREN. You are telling me that you would fix it and 

that Quincy did not need to spend $650,000 for the independent engineering reviews? 

Mr. WRIGHT. So as we go through the mapping process, if they 

get us the information and those inputs along the way, we will 

change our products. In this instance—and there were some of the 

appeals that were successful for communities, others that were not 

successful along the Massachusetts—— 

Senator WARREN. All right. Look, we are just going to—I am 

going to keep saying the same thing. Challenging your maps is expensive. 

Mr. WRIGHT. I understand. 

Senator WARREN. And when it turns out that you were wrong, 

I want to know what happens to the people who cannot afford to 

22 

challenge, how they get reimbursement. Look, I pushed hard for 

communities to be reimbursed when they successfully appealed 

flood maps that turned out to be wrong. But, unfortunately, that 

provision was not included in the final bill. 

Let me ask a different question. Will FEMA support such a provision in the upcoming reauthorization bill? 

Mr. WRIGHT. So, Senator, I will commit to work with you and 

your office so that we can look at those specific elements as it goes 

forward. 

Senator WARREN. All right. Look, I will just leave it there then. 

The accuracy of flood maps should not be based on whether a community can scrape together the money for a very expensive independent review. Our cities and towns deserve a process that is fair. 

I want to ask about one other thing quickly, and that is, I am 

concerned that we are not doing enough to utilize local expertise. 

Cooperating technical partners, the CTPs, are composed of State 

agencies, regional agencies, participating communities that have 

the capability of becoming more active participants in the FEMA 

flood mapping program. And the Council’s report indicates that 

FEMA is not bringing in communities and local partners up front. 

So, Mr. Dorman, let me just ask you, what steps should FEMA 

take to collaborate with the cooperating technical partners and ensure that local communities are brought into this process earlier? 

Mr. DORMAN. Well, Senator Warren, I will say for the State of 

North Carolina that partnership with FEMA has been very positive. After Hurricane Floyd, we created a cooperating technical 

partner relationship with FEMA. We created a cooperating technical committee in the State of North Carolina that brought all 

stakeholders to the table. And as we moved across the State, we 

updated the maps and leveraged from all agencies and local governments their information and data. 

Senator WARREN. So I am glad to hear that it worked, as you put 

it, together. What I am really asking, though, is the question about 

additional steps that need to be taken where it is not—and I am 

out of time here, so I will just say the other place I would go is 

I understand that you are very stressed for resources to be able to 

do this and that this is a very expensive process. 

I will be submitting more questions for the record here, and particularly questions on behalf of the towns of Marshfield and 

Sitchuet and Duxbury. It is clear that we still have a lot of work 

to do to verify the accuracy of the flood maps and not force towns 

and homeowners to have to pay to correct maps when they are erroneous, and that we also need to expand the role of our communities in beginning the flood mapping process right from the beginning. 

Thank you, Mr. Chairman. 

Mr. DORMAN. Thank you. 

Chairman SHELBY. Mr. Wright, with all the new tools in mapping that we have, we map the world, so to speak. 

Mr. WRIGHT. Right. 

Chairman SHELBY. Why can’t we in the U.S. map the flood 

zones? It is all based on identifying a risk, assessing the risk, as 

you talked about, and so forth, maybe mitigating it. But what is 

23 

the problem? We have been working on this for years. I have been 

on this Committee 30 years. 

Mr. WRIGHT. Yes, you have. 

Chairman SHELBY. And the Flood Insurance Program, we take a 

step forward and then a step backward. A lot of good questions 

have been asked here today. When somebody is not in a floodplain, 

never been there, and they have to pay for risk. Others do not. I 

understand all that. And there is mitigation involved. I know 

FEMA has tried to get people out of harm’s way. 

Mr. WRIGHT. We have. 

Chairman SHELBY. But with the tools we have today of mapping, 

it seems that this could be done. Is it easy? No, it is not easy. But 

it could be done. 

Mr. WRIGHT. It can be, sir, and one of the key linchpins for me 

on this, we mentioned the LiDAR, the elevation and structural 

pieces that are there, that technology has continued to evolve. The 

price points, while still very expensive—the three-dimensional elevation program, which is the interagency group across the civilian 

side of agencies that use elevation data and contribute so we do not 

duplicate anything, estimates that it would cost about $600 million 

to finish getting those data across the Nation. 

Chairman SHELBY. Let me stop you a minute. But you have paid 

out billions of dollars over time, billions and billions of dollars. 

Mr. WRIGHT. We have, and so, sir, what we have done is we are 

the largest contributor to that on an annual basis. This year alone, 

we are putting $20 million into it. Today—— 

Chairman SHELBY. But that is nothing compared to what you need, $20 million. 

Mr. WRIGHT. I agree, and I think one of the game changers on 

this is we must have an elevation data layer across the Nation that 

is accurate and credible, and with that, we will start dealing with 

risk in some different ways related to the folks who are in versus 

out and some of the automated models. I tell you, in the riverine 

area, we see as many structures move in as move out each year. 

The people who move out do not sent thank-you notes. The people 

who move in call their friends, and they complain about, ‘‘How dare 

you move me in?’’ 

We look at the issue in Louisiana. Those maps were updated in 

2012 and 2014. The 100-year was marked, as well as the 500-year. 

It is very interesting to actually look that most of East Baton 

Rouge that was affected, outside the special flood hazard area, was 

mapped as part of the—— 

Chairman SHELBY. How long has it been since Baton Rouge 

flooded like that? 

Mr. WRIGHT. I would always want to defer to locals on this, but 

my understanding is 1983 was the last time they had something 

of this magnitude. But the built environment was very different in 

1983. This is a point that, as we look at it, yes, we have got to do 

the mapping, but Mr. Edelman referenced the report we did in 

terms of the next, you know, 80-some-odd years of our program. 

When they looked at it, climate variability has an element related 

to it. But more than 30 percent of the growth in our floodplain is 

because of new construction, new construction that today is probably directly adjacent, but because they put concrete and asphalt 

24 

down, the water is no longer absorbing, and it just conveys, and it 

is causing more floods. 

Chairman SHELBY. Well, what is the answer? I mean, you know, 

this Committee here has been involved in this, and it seems like 

we are just treading water. You know, we are not going anywhere. 

We play with the program, but we have not had a comprehensive 

approach that will work, because what you are doing, you want a 

program that is accurate, right? 

Mr. WRIGHT. Right. 

Chairman SHELBY. You cannot say that this program is accurate, 

can you? Maybe in some areas. 

Mr. WRIGHT. So I will tell you that we credibly can lay out the 

pieces of that, but there are levels of precision that are there. So 

you referenced our 56 percent that meet our standards today. That 

is resource-dependent. The standards are clear, and those are credible. But, Mr. Chairman, I would assert to you that the very point 

of this hearing today gets to the crux of it. Of all the dimensions 

of the program, I do think that the mapping element has a foundation of credibility and a clear way that with the resources would 

allow us to absolutely show the risk, and with that it must then 

become the launch point, and as I described, I must transform how 

we actually show risk in premiums then. I must look toward the 

future risk in this country related to land use. And then we get to 

this fourth dimension that is there, that, yes, it is about affordability or grants and the like, but there are difficult questions for 

those who cannot afford it. 

While I am absolutely confident there is no silver bullet on that, 

I look forward to bringing to this Committee next year some framing as it relates to the data so that we can inform—— 

Chairman SHELBY. They may not be able to afford the premium. 

We understand some people just do not have the means. But, on 

the other hand, can they afford to continue to live there? That is 

a risk, too. 

Mr. WRIGHT. So one of the things that was required in the 

2014—there were elements of it in the 2012 bill, but it is very clear 

in the 2014 bill, it requires us to do the clear communication of 

risk. And so part of this evolution in my underwriting practices, we 

are re-underwriting a whole set of policies because my understanding of the direction in the statute is I must tell folks what 

their true risk is. I intend to do that with a pricing signal so that 

they understand the gap between what they are paying and what 

their full premium would be. 

Chairman SHELBY. As people continue to build in a known flood 

area, prone to flooding, they have got to put a price, when they 

start doing that, on the likelihood that there is going to be a flood 

there. 

Mr. WRIGHT. And so I think part of what we are—— 

Chairman SHELBY. How do you do that? Do you have to work 

with the zoning people? 

Mr. WRIGHT. We do have to work with the zoning people on that. 

What I find—and this may be too broad of a generalization, but to 

the degree that someone is constructing something today, 2016, in 

the high-hazard area, they are building higher and stronger. They 

are required to do so. I have got two places of concern: the area 

25 

just outside the special flood hazard area who maybe the flooding 

extends in their direction, but far more problematic for me in an 

urban context particularly is the water that used to absorb into the 

water table upstream now is flowing down. The second piece of 

that then is there is so much of the Nation’s housing stock that 

was built in the 1950s, 1960s, and 1970s. The homes that I was 

at in Louisiana were all constructed before 1980. 

Chairman SHELBY. And a lot of them were built on slabs, were 

they not? 

Mr. WRIGHT. Slab on grade. 

Chairman SHELBY. And if they flood, they do not have to flood 

much to flood the house. 

Mr. WRIGHT. Exactly. And I grew up in a slab-on-grade, 1,100- 

square-foot home. That is what so many Americans—that is what 

their experience is. 

Chairman SHELBY. It is cheaper to build. 

Mr. WRIGHT. It is much cheaper to build, and when someone is 

trying to do this—trying to have their own home, and so I look at 

the questions of understanding risk, how that evolves, as well as 

how to make it affordable, and part of where I am getting, Chairman Shelby, is: So how do we hold that against affordable housing 

in this country in a way—and do it explicitly? Because I think, unfortunately, in this program over the last few decades, we have allowed folks to have discounts and not know they had—and still 

complain about their price because they think it was too high, and 

then not take enough action to help people get out of harm’s way. 

It has to be in a way by which there is still a place for normal 

Americans like my parents to live. 

Chairman SHELBY. Senator Brown, do you have any questions? 

Senator BROWN. Thank you. I thought that was a very good conversation back and forth. Thank you, Mr. Chairman. I think your 

initial question was: Can’t the science figure this out? And I think 

the science, after listening to that discussion, clearly the science is 

simpler than the politics of people on the Ohio River or wherever 

in my State thinking their insurance is too high or that they 

should not have to buy it or why is the Federal Government forcing 

me to do this at this price and the difficulty of selling their house, 

who wants to buy that house then, even though homes along the 

Ohio River are pretty inexpensive. It is an area of the State, 

sparsely—depending on where, of course—populated, and so low 

home prices and higher insurance rates do not go together necessarily well. I think that is the complexity of this. 

Mr. WRIGHT. And I would add one additional point to that. To 

the degree that the prices may be a bit less, they are often bought 

by a landlord who has the means to do so, and so we have renters. 

So I look across the 5.1 million policies; only 1 percent of them, 

50,000 of them, are contents only, essentially a renter’s policy. And 

so so many of those people that I interacted with in East Baton 

Rouge may or may not have fully understood their risk. They did 

not personally have a mandate. They were not the homeowner. Yet 

they lost tens of thousands of dollars worth of their life, and they 

have far less means available to them to go put that back together 

again. That policy is actually pretty reasonably priced. 

Chairman SHELBY. How do you communicate that? 

26 

Mr. WRIGHT. Well, that goes to the point that Mr. Dorman highlighted, that we have got to get ourselves—one of the tools that we 

helped invest in, they have prototyped and proven the concept, is 

you got to show them pictures. You have got to show them three 

dimensions: here is my house, here is where the water is going to 

go, and here is the price tag of what happens. 

Senator BROWN. Give us a range of what the price—I mean understanding you cannot be precise, but what the annual insurance 

would be in a modest rental to ensure the contents. 

Mr. WRIGHT. Somewhere between—it depends on how some of 

the surcharges play out. That set aside for a moment, somewhere 

between $160 to $300. But $160 would be something that is a very 

reasonable amount of coverage. Now, depending on your means, 

that $160 could be still a substantial investment that would be a 

difficult choice for someone to make. 

Chairman SHELBY. Is this a month or year? 

Mr. WRIGHT. Per year, sir. 

Senator BROWN. Per year. 

Chairman SHELBY. That is pretty cheap. 

Mr. WRIGHT. Right? And so I start—— 

Senator BROWN. For us. 

Mr. WRIGHT. So I started looking at how then do we look at getting—honestly, if I had to hypothesize a bit about affordability, I 

think we are going to get a lot of some of these conversations, the 

people who really need the coverage that do not have, that may 

only need a few hundred dollars—— 

Senator BROWN. You said at least in your visit to Baton Rouge 

that it was 1 percent of renters that had that insurance? Or what 

did you say exactly? 

Mr. WRIGHT. So nationwide, only 1 percent of my policies are a 

contents-only policy for a renter. And I am sure that—— 

Senator BROWN. Renters in floodplains or close to floodplains. 

Mr. WRIGHT. Yeah. 

Senator BROWN. And that is flood insurance, 1 percent, or content insurance generally? It is flood insurance? 

Mr. WRIGHT. So it is flood insurance to cover contents. If you are 

a renter, you would not cover the structure, obviously. 

Senator BROWN. No, but not other kinds of rental insurance—— 

Mr. WRIGHT. Correct. 

Senator BROWN. ——to cover possessions. It is only—the flood insurance part of that is 1 percent. 

Mr. WRIGHT. And, generally speaking, across the other perils, 

flood is excluded. You can only come to National Flood practically 

to get that coverage. 

Thank you to both the Chairman and you. 

I look forward to collaborating with the Committee as we move 

forward. 

Chairman SHELBY. Thank you. The Committee is adjourned. 

[Whereupon, at 11:55 a.m., the hearing was adjourned.] 

[Prepared statements, responses to written questions, and additional material supplied for the record follow:] 

27 

PREPARED STATEMENT OF ROY E. WRIGHT 

DEPUTY ASSOCIATE ADMINISTRATOR FOR INSURANCE AND MITIGATION, FEDERAL

EMERGENCY MANAGEMENT AGENCY

SEPTEMBER 13, 2016 

Introduction 

Good morning Chairman Shelby, Ranking Member Brown, and Members of the 

Committee. My name is Roy Wright, and I am the Deputy Associate Administrator 

for Insurance and Mitigation, responsible for directing FEMA’s risk management, 

mitigation, and flood insurance programs. Thank you for the opportunity to testify 

about FEMA’s Technical Mapping Advisory Council (TMAC). 

Today, I will provide an overview of the TMAC and the reports and recommendations it has provided to FEMA since it was established in late 2014. I will also speak 

about FEMA’s strategy for implementing the recommendations, which vary in complexity and level of effort required to address them, and well as the progress we 

have made to date. The Council’s recommendations will aid FEMA in furthering our 

efforts to provide communities with the best available data and tools to make better 

informed decisions that reduce the risk and consequences of flooding nationwide. 

TMAC Background 

Under the Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12), Congress 

established the TMAC and authorized specific statutory duties. The TMAC is tasked 

to provide recommendations on how to improve, in a cost-effective manner, FEMA’s 

flood mapping program to ensure that Flood Insurance Rate Maps (FIRMs) reflect 

the best available science and utilize the best available methodologies for considering the impact of future development on flood risk. Consisting of Government and 

private sector experts from across the country and a diverse group of flood map 

stakeholders, in September 2014, the TMAC convened for its first public meeting. 

During its first year, the TMAC developed recommendations that it provided to 

FEMA through two reports in January 2016: a 2015 Annual Report and a Future 

Conditions Risk Assessment and Modeling Report. The TMAC annual report describe the Council’s activities, evaluate FIRM activities, and summarize the Council’s recommendations. 

The Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) requires 

FEMA to implement a flood mapping program, after a review by the TMAC. When 

the program is applied, it will result in technically credible flood hazard data in all 

areas where flood maps are prepared or updated. In July 2016, the TMAC submitted the TMAC 2016 Flood Mapping Program Review as required. This report included 14 recommendations to assist the agency to provide technically credible flood 

hazard data into the future. Based on this advice and my recommendation, the Administrator has certified the flood mapping program as credible. 

Composition of the TMAC is defined in BW-12 and includes four designated members and 16 appointed members. The four designated members of the Council serve 

as regular Government employees (or the designees thereof) and consist of the 

FEMA Administrator, the Secretary of the Interior, the Secretary of Agriculture, 

and the Under Secretary of Commerce for Oceans and Atmosphere. The additional 

16 members are appointed based on their demonstrated knowledge regarding surveying, cartography, remote sensing, geographic information systems, or the technical aspects of preparing and using FIRMs. To the extent possible, membership of 

the TMAC is balanced between Federal, State, local, tribal, and private sector members. There is also geographic diversity including representation from areas with 

coastline on the Gulf of Mexico, and from other areas identified by the FEMA Administrator as having a high risk for flooding. 

I would like to thank the members of the TMAC for their hard work and dedication over the past 2 years. The Council formulated recommendations to improve the 

quality of flood mapping and to ensure that the best available science and methodologies are used when considering the impacts of sea level rise and future development on flood risk. I appreciate the tremendous amount of professional expertise 

and personal commitment that each member invested to convene as a council, conduct subcommittee discussions, and research and produce the Council’s reports and 

recommendations. The Council’s recommendations will aid FEMA in furthering our 

efforts to provide communities with the best available data and tools to make better 

informed decisions that reduce the risks and consequences of flooding nationwide. 

As indicated by their name and clearly stated in the TMAC charter, the Council 

is an advisory board established to advise and make recommendations to the FEMA 

Administrator and the flood mapping program. Informed by the TMAC’s reports and 

recommendations, FEMA will determine the appropriate path forward as we evolve 

28 

based on changes in customer needs, advances in technology, and the National 

Flood Insurance Program (NFIP) reform requirements. 

TMAC’s Reports and Recommendations 

The TMAC’s 2015 Annual Report contains 22 recommendations for FEMA’s flood 

mapping program. The recommendations generally fall into three key themes: credible flood data, digital inventory and delivery, and customer-oriented products (including structure-level risk, and more options for targeted products and engagement). FEMA fundamentally agrees with all 22 of the recommendations in the 2015 

Annual Report. Over the last several months, the Agency has been working to 

evaluate each recommendation to understand resource requirements and impacts to 

inform implementation priorities, sequencing, and investments. 

Perhaps the most transformative recommendation made by the TMAC in 2015 is 

to transition from one percent (1 percent) annual chance as the basis for flood insurance ratings to a structure-specific flood frequency determination. This recommendation will require an entirely new approach to insurance rating and underwriting, including new regulatory hazard and risk products and potential impacts 

on floodplain management standards. 

In January 2016, the TMAC delivered its Future Conditions Risk Assessment and 

Modeling Report. This statutorily mandated report includes seven overarching recommendations and numerous sub-recommendations. The first recommendation calls 

for providing future conditions flood risk products, tools, and information for coastal, 

Great Lakes, and riverine areas. It is the most substantial of the recommendations 

and the remaining recommendations are largely related to the details of how this 

could be achieved, with sub-recommendations providing even more details. By recommending that FEMA add future conditions assessments, modeling and mapping, 

TMAC is recommending that FEMA drive forward both the state of the science and 

the state of application of the science on a broad scale. Transitioning from an applied science agency, to an agency that also performs scientific research, is significant. 

In July 2016, the TMAC submitted the TMAC 2016 Flood Mapping Program Review to FEMA. This report includes 14 recommendations to assist the agency to provide technically credible flood hazard data into the future. The report focuses on the 

findings of the TMAC’s review of the flood mapping program, as required by HFIAA. 

The TMAC reviewed the mapping program’s structure, process, outputs, quality 

management, and metrics and concluded that FEMA’s mapping program, when applied as designed, results in technically credible flood hazard data in areas where 

flood insurance rate maps are prepared or updated. 

The TMAC is currently working on its 2016 Annual Report. We anticipate that 

the TMAC will submit this report to FEMA in early 2017, and that it will include 

additional recommendations, as well as further guidance and insight into its previous report recommendations. 

FEMA’s Implementation Strategy 

Addressing the TMAC recommendations has been and will continue to be one of 

the top priorities for the National Flood Mapping Program. Today, I want to summarize for you our strategy for implementation, and talk about some of the priorities and investments the Agency focused on this year. Our implementation strategy 

can generally be summarized as follows: 

1. Address several technical recommendations through FEMA’s consistent, routine approach to maintain and enhance national mapping policies. 

2. Engage internal and external stakeholders and partners as FEMA determines 

the appropriate sequence of program changes that will support the implementation of the transformative mapping reforms recommended by the TMAC. 

3. Continue to make strategic investments (e.g., high resolution topography, 

structure-specific datasets, enhanced flood models) while engaging in strategic, 

long-term planning to lay the foundation for transformative new mapping polices, products and regulations. 

The reports submitted by the TMAC include some technical recommendations 

that address our ongoing program delivery, seeking refinements or improvements to 

what we already do and how we operate. Just as we did with the BW-12 legislative 

mandates for the mapping program, we are using existing program mechanisms to 

implement those changes to the extent possible. Through our regular Guidelines and 

Standards cycle, several of the TMAC’s 2015 recommendations will be implemented 

in November 2016, and an additional set of TMAC recommendations are scheduled 

for implementation in November 2017. 

29 

Over the last few years, the Agency has continued to enhance the Cooperating 

Technical Partners (CTP) program within the flood mapping program. We are using 

established CTP coordination mechanisms to address the TMAC’s CTP-related recommendations. In many ways, the work we’ve been doing to enhance the CTP program is already addressing much of what is in the recommendations. Similarly, we 

are using our Flood Risk Products Integrated Project Team (IPT) to start addressing 

the recommendations from the 2015 Annual Report about understanding user needs 

for our flood risk products. 

Other recommendations are transformative and can’t simply be assigned to an existing team or process to address. Those include the TMAC’s recommendations for 

transitioning away from mapping the one percent (1 percent) annual chance flood 

hazard, providing structure-specific risk information, digital delivery of our products, and most of the future conditions recommendations. These recommendations 

necessitate extensive research, planning, and strategizing, both internally and with 

our partners. 

These engagements are ongoing, but in the meantime we know what some of the 

foundational elements are to enable delivery on these recommendations in the future. In FY17, one of our focus areas in Risk Management is to deliver flood risk 

data that is useful for risk-based decisions. This year we will continue to make targeted investments, in coordination with the United States Geological Society (USGS) 

and the 3DEP program, that continue to move the Nation toward a national highresolution topographic dataset. We will continue to invest in enhanced modeling and 

multi-frequency returns. Being able to evaluate the frequency of flooding at a structural level using high resolution topographic data is an essential step toward structure-specific risk rating and delivery of a redesigned risk rating for the NFIP. We 

are also making strategic technological investments and changes, not just to improve digital delivery of the mapping products, but to ensure that enhancements of 

FEMA mapping products are interoperable with insurance rating mechanisms, mitigation planning initiatives, and floodplain management. 

FEMA is also exploring a more comprehensive approach to addressing future conditions mapping and the future conditions recommendations provided by the TMAC. 

The TMAC’s Future Conditions Recommendation 6, which directs the completion of 

pilot studies, provides a way to plan for and develop an initiative that can accomplish the objectives set forth in the future conditions recommendations and can be 

performed in a way that addresses the majority of the other recommendations and 

sub-recommendations found in the Future Conditions report. 

Addressing the research, development, program planning, and implementation 

questions through a series of demonstration projects will lead to an efficient and effective strategy to provide future conditions flood risk products, tools, and information. The TMAC was clear in its future conditions recommendations to FEMA that 

future conditions should be reflected in non-regulatory products at this time, and 

not on the regulatory Flood Insurance Rate Maps (FIRM). 

FEMA has already been conducting sea level rise pilot studies. We are working 

to identify the specific remaining research gaps to be able to design additional future conditions demonstration and pilot projects to address those gaps and inform 

how FEMA establishes and resources future conditions mapping initiatives. 

FEMA has emerging efforts that complement and are informed by the TMAC’s 

recommendations, such as an ongoing initiative to redesign risk rating for the NFIP. 

FEMA considers a new approach to insurance rating and underwriting crucial for 

the program, and has already started identifying the technical considerations for implementation. FEMA leadership has incorporated progress on this recommendation 

into performance plans. FEMA is currently assessing this recommendation in conjunction with the ongoing initiative to analyze technologies, data sources, and trends 

for flood risk quantification toward a long-term goal of developing a redesigned risk 

rating system for the program. These initiatives and investments will be critical as 

FEMA assesses how to move from being able to support the assessment of structurespecific flood frequencies, to eventually delivering actuarial structure-specific flood 

insurance ratings in the future. 

To support a mindful, meaningful transformation, in FY17 we will begin implementation of the 2015 Annual Report’s Recommendation 2 which calls for a national 

5-year operations plan. Our national plan will be informed by Regional 5-year plans 

to support appropriate flexibility and variance at the regional level while providing 

consistency at the national level. This 5-year plan will become a rolling plan that 

will help us bridge operations from our current status to where we want to go as 

we transform. The development of a 5-year operations plan will be supported by the 

implementation of Annual Report’s Recommendation 3, which calls for the development of program goals and metrics that will help drive investments and behaviors 

needed to transform the delivery of our flood mapping program. 

30 

The timing is right for the transformation of the National Flood Mapping Program, however we need to account for and learn from the investments we’ve already 

made—especially in the program’s evolution to Risk Mapping, Assessment, and 

Planning (Risk MAP). The status of the mapping inventory currently varies from 

Region to Region. FEMA’s Regional offices flood mapping investments each reflect 

unique circumstances, and accordingly, the Regions have varying degrees of readiness for implementing TMAC recommendations. We also have a significant number 

of projects already in process that utilize current policies and standards, so we need 

to take those projects into account as we plan our implementation of and investments in the transformational changes. 

Conclusion 

We value the work of the TMAC, and will continue to work with the TMAC and 

Congress to continually evolve the flood mapping program to meet the needs of individuals and communities to understand their flood risk and provide the foundation 

for actuarial rate setting in the NFIP. 

Again, thank you for the opportunity to testify today. I look forward to any questions the Committee may have. 

PREPARED STATEMENT OF JOHN DORMAN 

CHAIR, TECHNICAL MAPPING ADVISORY COUNCIL, AND ASSISTANT STATE EMERGENCY

MANAGEMENT DIRECTOR FOR RISK MANAGEMENT, AND DIRECTOR, NORTH CARO- LINA FLOOD RISK MANAGEMENT PROGRAM

SEPTEMBER 13, 2016 

Chairman Shelby, Ranking Member Brown, and Members of the Committee on 

Banking, Housing, and Urban Affairs; good morning and thank you for the opportunity to appear before you and provide my perspective on the 2015 Technical Mapping Advisory Council (TMAC) recommendations. I am John Dorman, North Carolina Assistant State Emergency Management Director for Risk Management, and 

Director of the North Carolina Flood Risk Management Program. I am currently 

serving as the Chair on the Technical Mapping Advisory Council. 

The English proverb ‘‘Necessity is the mother of all innovation’’ speaks well to the 

overall tenet of TMAC recommendations. FEMA has diligently overseen the generation of current flood hazard focused data and products. However, transformative 

strategies must be implemented to address needs of the program: insurance rates 

that reflect structure-anticipated flood loss; communication focused on financial loss 

as opposed to an ‘‘in or out’’ focus; and, homeowner’s understanding of and confidence in the data used for flood hazard determination and insurance premiums. 

For North Carolina, Hurricanes Floyd, Francis, Ivan, and Irene all demonstrated 

and compelled the need to implement these transformative strategies. Thus, North 

Carolina has successfully implemented the ability to generate structure-based flood 

probability; structure-based risk assessments; real-time structure-based flood impact 

and alert; and, structure-specific risk-based insurance rating. Recent events across 

the Country have again shown a lack of accuracy and awareness of structure-specific flood risks that both large storms and more localized flash flooding can present. 

With these needs ever apparent, I believe TMAC has constructed recommendations 

that, if implemented, will transform the program and improve our Nation’s resiliency to flooding. Below are four recommendations of the TMAC that I believe are 

key to transformative improvements: 

First, fundamental to accurate flood hazard identification and risk assessment, is 

accurate, high-resolution ground elevation data. Recent developments in data collection technologies offer the more accurate and efficient collection of ground elevation 

data. Technology like the Geiger LiDAR sensors collect data at both a higher altitude and higher accuracy allowing for faster acquisition time and reduced costs of 

acquiring and processing LiDAR data. This higher resolution data also allows the 

opportunity to meet the needs of other stakeholders so that cost sharing objectives 

can be achieved. 

Second, the transition from a 100-year floodplain delineation and flood elevation 

to a structure-specific annual chance flood frequency is critical to raise awareness 

that every property has some level of flood risk—26 percent of flood damages are 

on properties outside the 100-year floodplain delineation. The recent events in Louisiana demonstrate the importance of altering our Nation’s mentality that one is 

safe if they live outside of the line depicted on a map and raise awareness of flood 

probability at the structure level. 

Third, the transitioning focus to structure-based risk assessment. This increased 

level of detail that calculates structure-specific per cent annual chance of flooding 

31 

and estimated annualized damage calculations can inform mitigation decisions and 

create more accurate risk-based insurance premiums. This will directly result in 

mitigation actions to reduce losses, lessen the financial burden on the Federal Government to help communities recover from disasters and create a more fiscally 

sound FIMA. 

Finally, we must transition to a dynamic, queried display of data, models, maps, 

and risk assessments. The way we communicate as a Nation is changing, and we 

need to create a more robust database that enables data to be dynamically queried 

and displayed on a Web page. Floodplain modeling and mapping is an ever changing 

science, based largely on statistics and changes in land use and topography. We 

need to create an efficient method to quickly and efficiently update flood hazard and 

risk information and provide that information at the fingertips of end users on all 

types of digital devices. 

It is important to note that all or some of the four transformative recommendations have been successfully implemented in four States. These recommendations 

are not just ideas but proven concepts in production today. 

Thank you again for the opportunity to address this Committee on this important 

topic. I am honored to be able to provide testimony based on our experience with 

the FEMA and with the NFIP as the Committee considers the most efficient methods to prevent or reduce flooding losses. 

I would be happy to answer any questions that you may have. 

32 


91316001.eps
33 


91316002.eps
34 

PREPARED STATEMENT OF SCOTT K. EDELMAN 

VICE CHAIR, TECHNICAL MAPPING ADVISORY COUNCIL, AND SENIOR VICE PRESIDENT, AECOM 

SEPTEMBER 13, 2016 

Good morning Chairman Shelby, and Members of the Subcommittee. I am Scott 

Edelman, Senior Vice President of AECOM. I have spent my career solely focused 

on solving our Nation’s water related opportunities and challenges. I appreciate this 

opportunity to appear today before the Committee on Banking, Housing, and Urban 

Affairs. 

I have been involved with creating maps for FEMA since 1981, and am privileged 

to be serving as Vice Chair on the Technical Mapping Advisory Committee established by the 112th Congress. 

We, as a Nation, have simply endured too much pain and suffering due to floods. 

I believe that Roy Wright’s strong support and encouragement of the TMAC has 

resulted in two reports that show a path to the next evolution of the NFIP. In the 

future, I believe that if the recommendations of the TMAC reports are supported 

by Congress and the Administration, we can make significant strides to reduce both 

the pain and suffering that our citizens are enduring at a record level, and the burden these unprecedented events continue to drain resources from our United States 

Treasury. 

Of the 29 recommendations contained in the TMAC 2015 reports, I believe that 

the three most important priorities and potential benefits are: 

1. The reintroduction of a 5-year rolling plan—to allow leveraging of Federal dollars; 

2. The movement to structure-based risk assessments—to create a safer Nation; 

and 

3. Preparing the Nation for future conditions—to stop building new problems. 

First, the reinstatement of a 5-year rolling plan allows the leveraging of local and 

State dollars. FEMA cannot make the Nation a safe place alone. The operating principals of FEMA’s Whole Community doctrine is critical as applied to flood-related 

mitigation. Flood waters know no jurisdictional boundaries as they devastate lives 

and property, and therefore we need to fully engage local communities and make 

these shared responsibilities more apparent to all. When Congress funded Map Modernization in 2003, FEMA produced the Multi-Year Flood Hazard Identification 

Plan, MHIP. MHIP addressed every county in the Nation with when and how much 

anticipated funding would be available. The result was an enterprise-wide approach 

to maximize the return on Federal investments in which FEMA served as the Chief 

Risk Officer to those investment in the studies, and communities felt strong local 

ownership of the studies and results. This approach better aligned FEMA with State 

and local efforts to reduce losses of life and property. 

Second is structure-based risk assessments. We must change the perception that 

if I am just on the other side of the 100-year flood line I am safe. Too much time 

is spent trying to justify the movement of the flood line by a few feet when in actuality the risk of flooding the structure only has changed ever so slightly. Much of 

the problem is due to uncertainty of the flood line itself. 

• To my knowledge, this is the only product that engineers produce and communicate to the public that deals with averages and not what is safe. 

• We also have a great deal of uncertainty within the calculations. In all actuality, the current 100-year average line shown on the flood insurance maps is 

perhaps closer to a safe design level of a 10-year event. 

Moving to a structure-based risk assessment begins to change the conversation 

from one focused on ‘‘in vs. out’’ to one that starts to communicate levels of risk. 

We must also take affordability and grandfathering with sunset clauses into account 

for our most vulnerable communities and constituents. 

Third, we need to prepare the Nation for the future. GAO asked FEMA to evaluate the impact of future conditions on the National Flood Insurance Program. The 

report concluded that by the year 2100 on average our floodplains will increase by 

45 percent nationally, the number of polices will increase by 80 percent and our average loss per policy will increase by 50 percent based on today’s dollars. This is 

an immense challenge to our country. We need to encourage local communities to 

adopt higher standards on a volunteer basis understanding that the higher standards results in less loss of life. Many communities have done this including Mecklenburg County and the City of Charlotte, NC. Based on their adoption of future 

conditions flood elevations, Mecklenburg County has estimated savings from flood 

35 

damages from a single 100-year event to be over $150 Million. We need to stop 

building future problems so we can finally concentrate on mitigation of existing 

problems. 

My passion is not solely on the science but the need to help the Nation with this 

long-standing challenge and the billions of tax dollars that are unnecessarily wasted 

because of poor land use decisions and the attempt to tame or ignore Mother Nature. I want to again thank the Committee for this opportunity. I urge Members 

of the Committee to refer to the two TMAC reports for more details as a formal part 

of our testimony. 

I would be happy to answer any questions that you may have. 

36 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR TOOMEY 

FROM ROY E. WRIGHT 

Q.1. In July 2013, FEMA issued new mapping procedures for nonaccredited levees. I was pleased to see that some non-accredited 

levee systems would be recognized as reducing flood hazard. Unfortunately, I still hear from frustrated Pennsylvanians who feel that 

local flood control structures are either completely ignored or treated unfairly by FEMA. 

What progress has FEMA made on including non-accredited levees in its FIRMs? 

How has FEMA informed communities of its new policies towards non-accredited levees? 

How can communities protected by non-accredited levees ensure 

that FIRMs accurately reflect the flood hazard reduction those levees offer? 

A.1. Answer not received in time for publication. 

Q.2. I understand that FEMA is in process of updating its claims 

appeals process. 

Can you provide an update on where that stands? 

A.2. Answer not received in time for publication. 

Q.3. Besides claims appeals, my office receives a steady volume of 

request for help in appealing FIRMs. This may be because the 

highly technical nature of the appeals process can be difficult and 

confusing. 

Are any efforts underway to improve mapping appeals? If so, 

what issues are being considered, and when can we expect to see 

changes implemented? 

A.3. Answer not received in time for publication. 

RESPONSES TO WRITTEN QUESTIONS OF 

SENATOR MENENDEZ FROM ROY E. WRIGHT 

Q.1. As I mentioned above, FEMA’s systems and oversight over its 

Write Your Own insurance companies and other contracts were severely lacking in the aftermath of Superstorm Sandy. From insurance companies lowballing Sandy survivors, to a broken appeal 

process that was a virtual black hole for policyholders, the claims 

process after Sandy exposed fundamental problems with the NFIP 

that demand a comprehensive overhaul. 

As you know, I’ve worked for the past several years to first expose and then address the most egregious shortcomings. 

Can you give the Committee a sense of the reforms that have 

been made since the aftermath of Sandy and if they are adequate 

to prevent another debacle like we saw after Sandy? 

Should the people of New Jersey be confident that they won’t 

have to go through the same ordeal they did after Sandy when the 

next storm strikes? 

A.1. Answer not received in time for publication. 

37 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARREN 

FROM ROY E. WRIGHT 

Q.1. Will FEMA allow attenuation of wave setup in back-bay or inland areas to be guided through the use of high water marks 

(HWMs) that are available for the Blizzard of 1978 storm in the 

Towns of Scituate, Marshfield, and Duxbury? This historical storm 

has been shown to produce storm surge levels at or above the 1 

percent-annual-chance stillwater level for these areas. The HWMs 

would be used (with judgment) to assess the hydrodynamics and 

propagation of surge into the enclosed estuarine areas. This is the 

same method that was used for the successful appeals of the Preliminary 2013 FIS study for the Towns of Scituate, Marshfield, and 

Duxbury. 

A.1. Answer not received in time for publication. 

Q.2. The U.S. Army Corps of Engineers (USACE) was authorized 

by Congress in January 2013 in the Disaster Relief Appropriations 

Act of 2013 (Public Law 113-2) to conduct the North Atlantic Coast 

Comprehensive Study (NACCS). A core component of the NACCS 

study was a numerical modeling effort that produced updated 

storm surge and wave annual-exceedance probabilities for extreme 

coastal storm events for the Mid- to North-Atlantic region, from 

Virginia to Maine. The NACCS study provides a characterization 

of both synthetic tropical storms and historical extratropical storms 

that can contribute to probable coastal flood hazards in the New 

England area. The NACCS study also makes use of two-dimensional (2-D) hydrodynamics and wave models to capture the spatial 

variability in storm surge and wave conditions along the complex 

coastline of Massachusetts. Modeled 1 percent annual chance water 

levels and wave heights from the NACCS study represent an improvement to the methodologies used by FEMA to produce the Nov. 

4, 2016 Flood Insurance Rate Maps (FIRMs) for the Towns of 

Scituate and Marshfield, and the Cape Cod Bay shoreline of 

Duxbury. Will FEMA allow the use of 1 percent annual chance 

SWELs and significant wave heights from the NACCs study to be 

used as input conditions for the WHAFIS and wave run-up analyses? 

A.2. Answer not received in time for publication. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR SCHUMER 

FROM ROY E. WRIGHT 

Q.1. Mr. Wright, as you are aware, New York City has submitted 

a technical appeal disputing FEMA’s Preliminary maps and I know 

that—FEMA has set up an independent review board to review the 

City’s appeal. 

First, can you provide an update on the status of the independent review board’s analysis? Where do things stand and when 

do you expect to for the board to make a determination? 

Second, is FEMA prepared to revise the New York City maps accordingly if it is determined by the board that the preliminary 

maps are not as accurate as they should have been? 

A.1. Answer not received in time for publication. 

38 

Q.2. Mr. Wright, I have asked that you take steps to ensure that 

FEMA has and exercises the necessary authority to properly oversee the WYO carriers, third-party service providers and any firms 

that they may all hire. 

I was pleased to see that you acted quickly in responding to the 

New York AG’s investigation and recommended that the engineering firm HiRise be disbarred from participating in the program. 

However, do you plan to seek to disbar any WYOs or firms they 

may have hired based on their actions in the aftermath of Sandy? 

What information or developments are necessary for FEMA to 

take such action? 

What is the timeframe for making such a determination with regard to seeking disbarment of WYOs or other firms? 

Further, what about the legal counsel hired by the WYOs to represent their interests in cases filed by Sandy victims? Do you plan 

to seek to prohibit any of these firms from being able to handle future litigation matters on behalf of the WYOs based on their actions in handling cases that arose from Sandy? 

A.2. Answer not received in time for publication. 

Q.3. Mr. Wright, can you provide me an update on the Sandy 

Claims Review Process? 

Additionally, I’d like to know more about one specific piece of the 

process. It has been raised with my office that FEMA adjusters in 

the Sandy Claims Review Process are relying on the original engineering reports from suspect engineering firms, like HiRise, as a 

basis for determining what homeowners should be paid through 

this re-review process. 

First, is that true? 

Second, has FEMA gone back to see if these engineering reports 

were ever changed or manipulated to alter the conclusions made 

regarding the actual damage sustained in Sandy? 

Third, can you tell me what is FEMA doing to ensure that the 

engineering reports used as a basis for making determinations in 

the Sandy Claims Review Process are based on accurate reviews of 

the damage to these homes? Finally, have any of the WYOs that 

hired these suspect engineering firms been asked to or required to 

pay for new engineering reports to be filed? Are any of them doing 

so? 

A.3. Answer not received in time for publication. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR KIRK 

FROM ROY E. WRIGHT 

Q.1. The NFIP rate plan is outmoded and does not reflect insurance industry best practices. For example, the Institute for Business and Home Safety (IBHS), as well as catastrophe modelers, 

have pointed out the differences between riverine flooding and 

storm surge. Since riverine flooding is generally inland and storm 

surge is generally coastal, most experts believe there is an unjustified disparity in the rates charged to policyholders in the 30 zones 

across the country, not to mention the disparity created by the significant subsidization of premiums charged to many policyholders. 

39 

Are some policyholders paying too much while others are paying 

too little, independent of the subsidies built into the program? 

How do your propose modernizing the NFIP rate plan to eliminate this disparity? 

A.1. Answer not received in time for publication. 

Q.2. Reinsuring NFIP exposure can transfer risk from taxpayers to 

the private market, provide financial stability, and facilitate private market competition. There has been much discussion about 

how robust and competitively priced the catastrophe risk market is 

at this time, but the price and availability of reinsurance changes 

with the weather and other market conditions, resulting in yearto-year volatility. This volatility could place the NFIP in jeopardy, 

and private carriers could be discouraged from entering the market. Longer-term reinsurance arrangements not only limit volatility, but can also facilitate more robust data analytics and pricing 

sophistication for the flood events that are most challenging for the 

private market. 

How do you perceive the role of reinsurance as a tool to reduce 

the Federal Government’s exposure to loss, and to encourage private insurers to write direct flood coverage? 

I understand that you are currently negotiating reinsurance coverage for the coming year. Are you investigating the availability 

and potential benefits of longer term reinsurance coverage? 

A.2. Answer not received in time for publication. 

Q.3. Presumably Congress will reauthorize the NFIP next year and 

the NFIP will continue to be the primary flood insurance market 

for homeowners and businesses. In the meantime, FEMA can take 

important steps to improve the program with its existing authority. 

For example, FEMA should look to industry best practices to improve customer communications so there is better public understanding of the underwriting and rating processes, and up-front 

clarity on which losses are covered and which losses are not. FEMA 

also has the authority to issue bulletins and other guidance so that 

FEMA’s claim handling and engineering investigation requirements are objective and transparent. By meeting customer needs 

and expectations, and by providing clear guidance to insurance 

companies participating in the NFIP, there will be less policyholder 

frustration, fewer complaints and less litigation. 

What is FEMA doing to make the program more customer-centric 

and how is FEMA communicating with the Write Your Own carriers to improve the customer experience? 

A.3. Answer not received in time for publication. 

Q.4. FEMA recently proposed removing the Write Your Own 

(WYO) Financial Assistance/Subsidy Arrangement from the Code of 

Federal Regulations (CFR) so FEMA can negotiate individual contracts with the insurance companies that serve as FEMA’ s agents 

for the sale and administration of flood insurance policies. 

Do you believe that some WYO companies perform better than 

others and, if so, what measures will you take when negotiating 

new contracts to make sure that better performing companies remain in the program? 

40 

Since you will be negotiating individual contracts, are you concerned that contracts with different companies on different terms 

could create competitive imbalances? 

A.4. Answer not received in time for publication. 

Q.5. You have stated that the Arrangement would be removed from 

the CFR, but will continue to be available on the FEMA website. 

Your WYO partner companies currently rely on the fact that their 

contractual relationship with FEMA under the Arrangement conforms to Federal law, which makes clear that the Federal Government assumes liability for losses under NFIP policies. 

Why would the Arrangement continue to be accessible if a new 

and presumably different contract is to be negotiated with each 

WYO carrier? Will the current Arrangement apply in any way to 

the new individualized contracts and, if so, are there any legislative or regulatory changes necessary to ensure that the new contracts conform to federal law so the essential nature of the WYO 

relationship is not disrupted? 

A.5. Answer not received in time for publication. 

41 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

FEMA—‘‘TECHNICAL MAPPING ADVISORY COUNCIL OVERVIEW’’ 


91316003.eps 91316004.eps
42 


91316005.eps 91316006.eps
43 


91316007.eps 91316008.eps
44 


91316009.eps 91316010.eps
45 


91316011.eps 91316012.eps
46 


91316013.eps
47 

LETTER SUBMITTED BY TOM SALOMONE, 2016 PRESIDENT, NATIONAL 

ASSOCIATION OF REALTORS®


91316014.eps
48 


91316015.eps
49 

LETTER SUBMITTED BY CHAD BERGINNIS, EXECUTIVE DIRECTOR, 

ASSOCIATION OF STATE FLOODPLAIN MANAGERS 


91316016.eps
50 


91316017.eps
51 


91316018.eps
52 


91316019.eps
53 

LETTER SUBMITTED BY CHAD BERGINNIS, EXECUTIVE DIRECTOR, ASSOCIATION OF STATE FLOODPLAIN MANAGERS AND JAMES M. 

DRINAN, JD, EXECUTIVE DIRECTOR, AMERICAN PLANNING ASSOCIATION 


91316020.eps
54 


91316021.eps
55 

JOINT LETTER SUBMITTED BY AMERICAN BANKERS ASSOCIATION, 

AMERICAN INSURANCE ASSOCIATION, COUNCIL OF INSURANCE 

AGENTS AND BROKERS, FINANCIAL SERVICES ROUNDTABLE, THE 

INDEPENDENT INSURANCE AGENTS AND BROKERS OF AMERICA, 

NATIONAL ASSOCIATION OF MUTUAL INSURANCE COMMITTEES, NATIONAL ASSOCIATION OF PROFESSIONAL INSURANCE AGENTS, AND 

PROPERTY CASUALTY INSURERS ASSOCIATION OF AMERICA REGARDING THE PRINCIPLES FOR FLOOD INSURANCE REAUTHORIZATION 


91316022.eps
56 


91316023.eps
57 


91316024.eps