Responding to Criticisms of Federal Flood Protection Standards

President Obama signed an executive order that updated the nation’s flood protection standards on January 30. The standards will guide the decisions that federal agencies make when designing, building, or funding public infrastructure and other projects. The previous standard required federal projects to be designed to the elevation of the 100-year flood (a 100-year flood has a 1 percent chance of occurring in any given year). The executive order gives agencies the flexibility to select one of three, more protective standards.

  • The 100-year flood level plus two feet of elevation for standard projects and three feet of elevation for critical projects;
  • The 100-year flood level plus a projection of how much higher flood elevations may rise in response to climate change; or
  • The 500-year flood level (a flood with a 0.2 percent chance of occurring in any given year).

This common sense and much needed improvement to our standards drew this quote from Sen. David Vitter of Louisiana (a state that has a bit of a history with devastating floods).

“I understand your efforts to provide these standards are another ‘give’ to your far-left environmental base, which views your climate policy efforts as a way to scare the public into expanding the federal government’s role in the lives of all Americans.” (January 26, 2015 letter from Sen. David Vitter to President Obama)

Sen. Vitter’s quote notwithstanding, the general reaction has largely been positive. Fiscal conservatives recognize that upgrading the standards will save money over the long-term by reducing damages from floods, hurricanes, and extreme storms. Conservation groups realize that upgrading the standards provides new opportunities for green infrastructure and the use of natural systems to reduce flood risk that provide habitat, water quality improvements, and other co-benefits. And risk management professionals have long dealt with the reality that our flood protection standards do not match up with the true risk of flooding—risks that are increasing as sea levels rise and precipitation patterns change in response to climate change.

But there have also been criticisms. In this blog, I’m taking the opportunity to respond to some common ones and set the record straight.

The new standards will cause an increase in National Flood Insurance Program premiums for businesses and homeowners.

No, this will not be the case. The executive order establishes a new set of standards for new federal projects built in floodplains or that are built there using federal funding.

The premiums that homeowners and business owners pay for flood insurance are based on their risk of flooding, as indicated on FEMA’s flood maps (also known as “flood insurance rate maps"). The new standards do not magically update any of FEMA’s flood insurance rate maps. Since no maps are updated by virtue of this executive order, nobody’s flood insurance rates will go up. (there are problems with the flood maps, discussed below, but the new standards will not fix those)

Finally, it’s much more likely that the improved standards would lower the cost of flood insurance, if property owners elected to follow them. Flood insurance rates are significantly reduced when properties are built in a way that reduces their vulnerability to flooding.

The new standards will increase the costs of federal projects and cost jobs.

Over the long-term, the new standards will significantly reduce the costs of storm recovery and rebuilding infrastructure that is damaged or destroyed in a flood. Between 1980 and 2014, floods cost the US economy an estimated $260 billion. According to a report by the National Academy of Sciences, dollar losses due to tropical storms and floods have tripled over the past 50 years and currently comprise approximately half of all natural disaster losses. The federal government has been picking up a larger share of recovery and rebuilding costs as well, which puts the burden on the taxpayers. Clearly, the old standard is not providing us with adequate protection and is costing the nation a lot of money.

Will building things to a higher standard raise upfront construction costs? Maybe. If a major infrastructure project is being built in a floodplain, it probably will cost more to build it to higher level of flood protection. But it probably won’t have to be rebuilt after it’s damaged by a flood, which is more expensive. Plus, the new standards should encourage project managers to consider moving the project to higher ground, where it is less at risk of flooding and where less flood protection would be required. This could save capital costs and decrease the possibility of flood damage.

Other states and local jurisdictions have already implemented similar standards. New Jersey recently adopted the 500-year floodplain elevation as the standard that new wastewater treatment plants and drinking water treatment plants need to build to in order to be eligible for state financial support. New York also applied a similar standard as the President’s executive order for water infrastructure repairs funded by the state in the wake of Superstorm Sandy. Cities across the country have similarly adopted standards more stringent than the proposed standard including Dallas (100-year + three feet) and Nashville (100-year flood + four feet).

Current federal standards for floodplain management are already protective enough.

Not even close.

Our existing flood protection standards are based on the assumption that the 100-year flood is the event magnitude we should design for. But we presume that we know how big a 100-year flood actually is and that tomorrow’s 100-year flood is the same magnitude as today’s. Both presumptions are wrong.

Future flood risks are going to be much higher due to climate change. Along our coastlines scientists are projecting that sea levels will rise 2 to 6 feet by the end of the century. This will put a great deal of public and private property under water and an even larger number of properties will become susceptible to flooding when severe coastal storms, hurricanes, and storm surges occur. Along the nation’s inland rivers, flood risks are also expected to rise. AECOM published a study commissioned by FEMA that found that flood prone areas along the nation’s rivers could increase by 45%, with increases of 100% on rivers in the Pacific Northwest and tributaries to the Great Lakes. On average coastal areas are expected to see a 55% increase in size of areas prone to flooding, mostly along the Eastern seaboard.

Our understanding of current flood frequencies and risks is incomplete at best. So-called 20-year floods happen more frequently than once every twenty years; 100-year floods happen more frequently than once a century; and so on. Studies have looked at how we estimate flood frequencies and pointed out that something is amiss in those estimates. Most of our flood protecting standards are based on these flawed assumptions of flood risk—assumptions to do not match the current reality and don’t even contemplate the future reality.

President Obama’s Executive Order seeks to update the standards so that federal agencies make a safer assumption about future flood risks and don’t simply rely on the 100-year flood as the standard. This is the right move for the nation. Until we start building things that are designed to be resilient to current and future conditions, we’re just setting ourselves up for disaster.