by Justin Gundlach & Jessica Wentz
By changing sea levels, coastlines, and patterns of precipitation, climate change is literally shifting the ground under the National Flood Insurance Program (NFIP), administered by the Federal Emergency Management Agency (FEMA). Even as floodplains in many parts of the country (especially on the coasts) have grown, however, FEMA has never formally addressed the question of whether the NFIP induces development in floodplains, nor has FEMA developed standard protocols for informing communities and policyholders about how climate change could affect the risks they face from floods.
FEMA seemed poised to move on both of these issues several years ago, when it initiated a programmatic environmental review of the NFIP for that purpose, among others. Unfortunately, with its recently published Draft Nationwide Programmatic Environmental Impact Statement (DNPEIS) for the NFIP, FEMA appears to have reversed course. Specifically, FEMA DNPEIS ignores the impacts of the NFIP on floodplain development and thus also ignores how the NFIP has put communities and homeowners on a collision course with climate-related flood risks. Furthermore, FEMA’s DNPEIS fails to consider potential strategies to mitigate risks associated with flooding and climate change, such as providing advisory mapping information about sea level rise and possible future flood risks. This latter point is notable also because it runs counter to FEMA’s obligation under the Biggert-Waters Flood Insurance Reform and Modernization Act to consider and implement recommendations of the Technical Mapping Advisory Council (TMAC) – a body established to guide FEMA on matters related to the NFIP – which include providing such mapping information to communities and policyholders.
The Sabin Center has submitted comments to FEMA explaining why the National Environmental Policy Act (NEPA) requires it to consider the effects of the NFIP on floodplain development, and outlining the various climate change-related considerations that should be addressed in the final EIS. In particular, we urge FEMA to:
- Consider how climate change may exacerbate flood risk in areas currently covered by the NFIP and evaluate whether any changes in the NFIP are warranted in light of this analysis (e.g., FEMA may conclude that it is necessary to increase insurance premiums in coastal areas to account for heightened flood risk).
- Adopt some of the recommendations issued by the Technical Mapping Advisory Committee, such as that FEMA develop guidance and technical support tools to help local planners and individual property owners prepare for the effects of climate change. For example, we urge FEMA to adopt the TMAC’s recommendation to provide advisory maps showing how sea level rise scenarios will affect flood risk in coastal areas.
- Incorporate existing sea level rise and flood risk projections prepared by other federal agencies as well as state and local authorities into its evaluation of climate change impacts and possible response measures.
Our comments are available here.