Copyright: Jozef Sowa
**In-Person Listening Sessions: April 7, 2015
in Dallas, TX and April 14, 2015 in Seattle, WA**
On January 30,
President Obama issued an Executive Order that establishes a Federal Flood Risk
Management Standard (FFRMS). In setting
this new standard it expands the definition of “floodplain” from the
well-established 100 year flood elevation to the 500 year flood elevation,
potentially impacting new construction and substantial rehabilitation of
apartment properties.
This action
requires all future federal investments in and affecting floodplains to meet
the level of resilience as established by the standard. For example, the standard
includes where federal funds are used to build new structures and facilities or
to rebuild those that have been damaged.
While NMHC/NAA is
still evaluating the impact of this action on the multifamily industry, as
defined in the 1977 order, the FFRMS applies to all federal activity including:
(1) Acquiring, managing and disposing
of federal lands and facilities;
(2) Providing federally undertaken,
financed or assisted construction and improvements; and
(3) Conducting federal activities and programs
affecting land use, including but not limited to water and related land use
resource planning, regulating and licensing activities.
It is not clear if this definition includes Federal Housing Administration financed housing or subsidized properties. The relationship between this standard and the National Flood Insurance Program and insurance pricing is also in question.
Given the complexity and potential controversy over this action, federal policymakers have weighed-in seeking an extended comment period and questioning the level of stakeholder involvement in this process. The comment period has been extended to May 6, 2015.
NMHC/NAA will respond and seek additional clarification on these and other issues. The listening sessions are public meetings designed to educate and respond to specific questions on the new standard. We are encouraging our members to attend.
For details on how to register for the in-person listening sessions, please click here.
Staff Resource
Related Articles
- Real Estate Industry Coalition Letter to HUD on Federal Flood Risk Management Standard Implementation
- Housing Affordability Coalition Letter on Rising Insurance Costs
- FEMA: National Flood Insurance Program Flood Mitigation Measures for Multi-Family Buildings
- Housing Industry Letter to Congress: Government Shutdown
- NMHC-NAA Statement for House Financial Services Subcommittee Hearing on the High Cost of Insurance for Consumers