New York City has filed a technical appeal of the Preliminary Flood Insurance Rate Maps (FIRMS). FIRMS are official maps of a community that displays the floodplains which FEMA then uses to determine your base flood elevation or risk premium zone. FIRMS display areas that fall within the 100-year flood boundary. Areas that fall within this boundary are called “special flood hazard areas” (SFHAs). SFHAs are labeled as Zone A, Zone AO, Zone AH, Zones A1-A30, Zone AE, Zone A99, Zone AR, Zone AR/AE, Zone AR/AO, Zone AR/A1-A30, Zone AR/A, Zone V, Zone VE, and Zones V1-V30. FIRMS are also used to set rates of insurance against risk of flood.
New York City has filed a technical appeal of the Preliminary Flood Insurance Rate Maps (FIRMS). FIRMS are official maps of a community that displays the floodplains which FEMA then uses to determine your base flood elevation or risk premium zone. FIRMS display areas that fall within the 100-year flood boundary. Areas that fall within this boundary are called “special flood hazard areas” (SFHAs). SFHAs are labeled as Zone A, Zone AO, Zone AH, Zones A1-A30, Zone AE, Zone A99, Zone AR, Zone AR/AE, Zone AR/AO, Zone AR/A1-A30, Zone AR/A, Zone V, Zone VE, and Zones V1-V30. FIRMS are also used to set rates of insurance against risk of flood.
In their June 2015 appeal, counsel for New York City Mayor’s Office identified a flaw in FEMAs determination of FIRMs:
The impact of the technical and scientific errors identified in the City’s analysis is significant. Specifically, FEMA’s Preliminary FIRMs overstate Base Flood Elevations (BFEs) by more than 2 feet in many areas across New York City and misrepresent the Special Flood Hazard Area (SFHA) by 35 percent, unnecessarily putting approximately 26,000 buildings and 170,000 residents in the SFHA.
What’s the impact of this?
First, homeowners in the SFHA who invest in their homes could end up building or rebuilding to excessive heights at extra cost, with additional impacts on neighborhood character. Second, many homeowners in the SFHA would be asked to pay flood insurance premiums based on incorrect BFEs, causing an affordability challenge. And third, many homeowners that would otherwise not be in the SFHA, would be required to pay for flood insurance at higher rates, further exacerbating that affordability challenge.
For the full 180 page appeal click here.
Many homeowners and businesses underpaid or not paid at all from their Sandy damage are still feeling the pain trying to get back on their feet. FEMA feels it’s a good idea to let the policyholder make up for their shortcomings by arbitrarily creating maps to force more people to pay flood premiums. For now, this appeal process could take years to complete, but thankfully in the meantime, the maps will not change.
I leave you with another relatable baseball quote from Hall of Famer Leo Durocher, underlying the confusing process the NFIP creates these flood maps: “Baseball is like a church. Many attend, few understand.”
Many policyholders are included in the new FIRMs, few understand why.
