Okay here is my take on NFIP reform efforts! THERE WILL BE NO REFORM THIS YEAR BUT A LENGTHY EXTENSION of the NFIP perhaps for 5 years. This is the fifth time in the 42 year history of the NFIP that reforms to improve the NFIP's policies and administration by statutory change will have been undercut by the programs lack of preparedness to take long-term advantage of congressional interest. The basic problem of course is that the NFIP is a land use not an insurance program.
My basic reform proposal that would infuriate the Banking Committees and would be to confine insurance availability to the 1% annual occurrence floodplain (the so-called 100 year base flood)!
THE REASON THE BANKING COMMITTEES SHOULD NOT BE THE OVERSIGHT COMMITTEES FOR THE NFIP IN CONGRESS IS THAT THEIR POLITICAL PRESSURE AND CONSTANT MANIPULATION OF THE PROGRAM TO PROMOTE THE BANKING AND HOUSING SECTORS AND LAND DEVELOPERS AND BUILDERS OPERATING IN HAZARDOUS AREAS HAS UNDERMINED THE PROGRAM AND THIS YEARS LEGISLATION WILL PROVE THIS CONCLUSION AGAIN.
W. Craig Fugate did pretty well in his House and Senate testimony but the NFIP is too counter intuitive a program to allow even someone with Administrator Fugate's background and knowledge to present the Congress with real choices. And clearly he is making legal issues out of many policy decisions that could be made under current law, probably in a decision to push accountability elsewhere as he constantly did in his Senate presentation where he often stated it was up to Congress to decide. He did not make recommendations in most instances as to what they should decide or even why their decision was necessary.
So while a long extension is helpful only very skilled and competent leadership of the NFIP and even WH level interest can save it from eventual elimination in the favor of "free" disaster relief with no mapping most if not all legislative changes this year in the Congress will undermine program solvency and result in increased disaster outlays.
Another key recommendation is to put not another insurance lawyer in charge of the NFIP but a STATE Flood Plain Manager.
For the Congress two new findings to the ones that already exist should be added.
First, mapping is the principal compliance tool of the NFIP!
Second, that the NFIP should cooperate, and collaborate to the extent possible with the Endangered Species Act of 1973!
One major error could be increasing the limits of coverage! This should be veto bait if the WH and FEMA understand the program!
Showing posts with label NFIP and flooding. Show all posts
Showing posts with label NFIP and flooding. Show all posts
Monday, June 13, 2011
Friday, June 10, 2011
WOW-W. Craig Fugate Gets IT--Disaster Relief and NFIP are INTERTWINED
The history of the NFIP and the disaster relief program are closely intertwined although neither program has ever been housed bureacratically in the same sub-agency organization. The objective of the NFIP is to reduce disaster outlays since 80% of all natural disaster outlays have historically been flood and hurricane related. The NFIP was started in part because damage from flood was an excluded peril from homeowners insurance coverage one it expanded beyond the peril of "fire" in the modern broad form policies. The original NFIP issued policy largely substituted the peril of "flood" wherever the 1041 NY Fire Policy read "Fire" as the covered peril. The result was an original concern of the property/casualty insurance underwriters that federal or state courts would expand the coverages under the fire policies and homeowners policies as they digested the new "flood" peril. This has not happened and will not.
AND ALWAYS REMEMBER THE NFIP IS A LANDUSE NOT AN INSURANCE PROGRAM!
The NFIP is up for an extension of its expiration date of September 30th of this year. I am flatly predicting a 5 year clean extension but the HOUSE has passed a version that expands coverage of te program, denigrates from the programs purposes, makes it more likely that the NFIP will not come close to solvency and in fact will become a futher drain on the federal fisc. The NFIP is in the whole about $18B largely due to Hurricane Katrina and due to expensive subsidies to the property/casualty industry that performs WYO services.
EVEN AT 42 YEARS THE NFIP IS AN EXPERIMENTAL PROGRAM AND THE PERIOD OF RECORD IS FAR TOO SHORT TO MAKE PREDICTIONS ON ITS PERFORMANCE AS OF TODAY!
What we do know is that "free" disaster relief as currently administered undercuts the purposes of the NFIP. The result is to create "free" NFIP insurance that will shift the forms of disaster relief but not solve the problems of increased outlays of disaster funds.
W. Craig Fugate seems to understand that while they related the NFIP and the disaster programs involve policy tradeoffs to avoid one adversely impacting on the outlays of the other---adversely impacting meaning increasing outlays of the other program when both theoretically are designed to work cooperatively.
FEW IN FEMA UNDERSTAND BOTH DISASTER RELIEF AND THE NFIP! After yesterdays performance in the Senate it is clear that Administrator Fugate does understand this which is a real accomplishment and almost the first to do sol.
The Senate acted serious about finding out more about the NFIP and Adminstator Fugate dodged many questions by offering his answers in writing in the future. Who knows if this will happen.
AT any rate it was good to see a largely substantive NFIP hearing even though the mapping program should be subject to oversight by the House and Senate Science Committees since the statutory mapping standard is to have the maps "Scientifically and technically correct"!
It was clear that neither Administrator Fugate, the Senators, or their staffs understood exactly what this standard means. And FEMA has frequently undermined this standard through its policy decisions and ignorance, even on its mapping staff.
NOAA should be charged by the PRESIDENT and assisted by NAS in examining comprehensively the NFIP mapping decision process to determine whether the standard is being met.
AND AFTER ALL AT THIS POINT THE MAPS OF THE NFIP ALSO ARE THE ENFORCEMENT ARM OF THE NFIP!
AND ALWAYS REMEMBER THE NFIP IS A LANDUSE NOT AN INSURANCE PROGRAM!
The NFIP is up for an extension of its expiration date of September 30th of this year. I am flatly predicting a 5 year clean extension but the HOUSE has passed a version that expands coverage of te program, denigrates from the programs purposes, makes it more likely that the NFIP will not come close to solvency and in fact will become a futher drain on the federal fisc. The NFIP is in the whole about $18B largely due to Hurricane Katrina and due to expensive subsidies to the property/casualty industry that performs WYO services.
EVEN AT 42 YEARS THE NFIP IS AN EXPERIMENTAL PROGRAM AND THE PERIOD OF RECORD IS FAR TOO SHORT TO MAKE PREDICTIONS ON ITS PERFORMANCE AS OF TODAY!
What we do know is that "free" disaster relief as currently administered undercuts the purposes of the NFIP. The result is to create "free" NFIP insurance that will shift the forms of disaster relief but not solve the problems of increased outlays of disaster funds.
W. Craig Fugate seems to understand that while they related the NFIP and the disaster programs involve policy tradeoffs to avoid one adversely impacting on the outlays of the other---adversely impacting meaning increasing outlays of the other program when both theoretically are designed to work cooperatively.
FEW IN FEMA UNDERSTAND BOTH DISASTER RELIEF AND THE NFIP! After yesterdays performance in the Senate it is clear that Administrator Fugate does understand this which is a real accomplishment and almost the first to do sol.
The Senate acted serious about finding out more about the NFIP and Adminstator Fugate dodged many questions by offering his answers in writing in the future. Who knows if this will happen.
AT any rate it was good to see a largely substantive NFIP hearing even though the mapping program should be subject to oversight by the House and Senate Science Committees since the statutory mapping standard is to have the maps "Scientifically and technically correct"!
It was clear that neither Administrator Fugate, the Senators, or their staffs understood exactly what this standard means. And FEMA has frequently undermined this standard through its policy decisions and ignorance, even on its mapping staff.
NOAA should be charged by the PRESIDENT and assisted by NAS in examining comprehensively the NFIP mapping decision process to determine whether the standard is being met.
AND AFTER ALL AT THIS POINT THE MAPS OF THE NFIP ALSO ARE THE ENFORCEMENT ARM OF THE NFIP!
Friday, May 6, 2011
FLOODWAYS REPRESENT POLITICAL DECISIONS NOT HYDROLOGIC CONDITIONS
From a recent news article:
"Compared to the Great Mississippi Flood of 1927 this flood is going to be a lot nastier," said Marty Pope, senior hydrologist for the National Weather Service in Jackson, Miss.
The river is predicted to crest at 64.5 feet on May 17 in the Vicksburg, Miss. area. Vicksburg has a flood stage of 48 feet, which means the river will crest more than 16 feet above normal, according to flood experts at the National Weather Service.
The flood waters will reach more than a foot above the Yazoo Backwater Levee near Yazoo City, Miss. and this will flood thousands of acres of farmland, said Pope.
There were major floods on the Mississippi in 1927, 1937, 1973, 1993 and 2008. The 1927 flood caused up to 1,000 deaths and left 600,000 homeless. Floodways were adopted as a response.
Camillo said it was too early to estimate expected damage from the 2011 flooding. He noted that much has changed since the 1927 flood, including the structure of the levees and the addition of dozens of reservoirs throughout the Mississippi River basin and floodways.
The Mississippi has four floodways: Birds Point and three spillways in Louisiana.
"There is a very good possibility that we would operate three floodways ... and we have never done that before," Camillo said."
Camillo is the Chief Historian of the Mississippi River Commission.
What do I mean when I indicate that flood-ways are political decisions not hydrologic decisions. Fluid dynamics underpin hydrology and are complex but nothing could be as labyrithian as the politics of flood-ways their designation and enforcement. Witness recent court decisions on the USACOE decision to blow the Bird's Point Levee in several places.
Why? WELL to grossly over simplify designation of a floodway is where the high velocity waters during flood stage will go. By increasing channel efficiency in several ways the water will seek the path of least resistance. Thus, if on one side of the river a flood wall is constructed the river will flow over the town on the other side without the flood wall. Or perhaps a community chooses to improve hydraulic efficiency by mowing down forest and paving over the main channel thus improving channel efficiency and speeding the water downstream. The problem of course is that the Mississippi and its levee system is not a system at all an various political decisions over time have left USACOE holding the bag. Well this time they really will be holding it. Perhaps opening the MORGANZA spillway and opening the Old River Control Structure sending waters to where the Mississippi river would like to head naturally. And save NOLA of course but goodbye Morgan City and others.
Well the die are cast and now only the passage of the next few weeks will see how this plays out.
Whatever the situation Old Man River will keep on rolling along!
"Compared to the Great Mississippi Flood of 1927 this flood is going to be a lot nastier," said Marty Pope, senior hydrologist for the National Weather Service in Jackson, Miss.
The river is predicted to crest at 64.5 feet on May 17 in the Vicksburg, Miss. area. Vicksburg has a flood stage of 48 feet, which means the river will crest more than 16 feet above normal, according to flood experts at the National Weather Service.
The flood waters will reach more than a foot above the Yazoo Backwater Levee near Yazoo City, Miss. and this will flood thousands of acres of farmland, said Pope.
There were major floods on the Mississippi in 1927, 1937, 1973, 1993 and 2008. The 1927 flood caused up to 1,000 deaths and left 600,000 homeless. Floodways were adopted as a response.
Camillo said it was too early to estimate expected damage from the 2011 flooding. He noted that much has changed since the 1927 flood, including the structure of the levees and the addition of dozens of reservoirs throughout the Mississippi River basin and floodways.
The Mississippi has four floodways: Birds Point and three spillways in Louisiana.
"There is a very good possibility that we would operate three floodways ... and we have never done that before," Camillo said."
Camillo is the Chief Historian of the Mississippi River Commission.
What do I mean when I indicate that flood-ways are political decisions not hydrologic decisions. Fluid dynamics underpin hydrology and are complex but nothing could be as labyrithian as the politics of flood-ways their designation and enforcement. Witness recent court decisions on the USACOE decision to blow the Bird's Point Levee in several places.
Why? WELL to grossly over simplify designation of a floodway is where the high velocity waters during flood stage will go. By increasing channel efficiency in several ways the water will seek the path of least resistance. Thus, if on one side of the river a flood wall is constructed the river will flow over the town on the other side without the flood wall. Or perhaps a community chooses to improve hydraulic efficiency by mowing down forest and paving over the main channel thus improving channel efficiency and speeding the water downstream. The problem of course is that the Mississippi and its levee system is not a system at all an various political decisions over time have left USACOE holding the bag. Well this time they really will be holding it. Perhaps opening the MORGANZA spillway and opening the Old River Control Structure sending waters to where the Mississippi river would like to head naturally. And save NOLA of course but goodbye Morgan City and others.
Well the die are cast and now only the passage of the next few weeks will see how this plays out.
Whatever the situation Old Man River will keep on rolling along!
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