Thursday, January 20, 2011


Driven by the huge outlays in Hurricane Katrina that have yet to be fully analyzed either by program officials or academicians or interested parties such as the ASFPM (Association of State Flood Plain Managers), GAO or others including Congress and its committees it looks like the NFIP has reached the launch pad for reform. Whether that happens of course will perhaps await the addition of fuel to the rocket. So here is some fuel that is repetitive in part with past posts but breaks some new ground.

First, the program must never, repeat NEVER, pay claims for any hazards it does not map. I believe this is already the statutory hurdle for claims but apparently the program continues to believe it can offer cheap coverage for flood-related structural failures, flood-related mudslides, flood-related erosion and on and on without mapping these hazards. WRONG IMO.
Second! No offer of federal flood insurance outside of designated V zones, or A zones on NFIP maps. Leave that to the private insurance business and STATES and their local governments.

Third! Enhance mandatory compliance by lenders by forcing all properties in all coastal counties as designated by the CZMA to have flood insurance whether mapped or not. This would force the in and out of the flood insurance determination industry and agents to stop playing games with the program. Yes there is some high ground in the coastal counties and perhaps unfair but these counties represent the major risk to the program now even with the total collapase of the real estate market in some areas.
This would help with forecasts of sea level rise, climate change and other factors and as all should know the NFIP needs the rest of this century to prove that it is a better approach than free federal disaster relief, administered without real environmental restraints, and increasingly politicized from any cost benefit analysis standpoint. But hey am reforming the NFIP not the federal disaster program which seriously needs both study and reform.
Fourth! Take all coast flood plain mapping away from the NFIP and its contractors and staff and give it to NOAA with its much vaster capability in storm surge analysis, SPLASH and SLOSH modeling and expertise. FEMA has destroyed its own technical mapping staff and its knowledge base long ago and even newly appointed Sandra Knight, PhD would recognize how week her staff is technically. Even the contractors seldom put first tier engineers and scientists on NFIP mapping efforts anymore.

Okay folks that is for a start!