By Daniel Porat
The Federal Emergency Management Agency (FEMA) and Mayor Bill de Blasio recently announced a joint plan to revise New York City’s Flood Insurance Rate Maps, stalling a flood insurance rate hike for many New York City property owners. The announcement came after FEMA accepted the City’s appeal of the agency’s preliminary flood map, which would have nearly doubled the structures covered in the mandatory zone and increased flood insurance premiums between $5,000 and $10,000 for many New Yorkers.
FEMA will delay introducing flood insurance rate increases, and will instead work with the City to develop a new map using what the City believes will be more accurate data. The agreement is a victory for the de Blasio Administration and its affordable housing initiative but may put flood-prone neighborhoods at risk by leaving in place an outdated flood map.
Flood insurance provides crucial assistance to disaster recovery efforts by helping affected residents cover the costs of damages. It is especially important in the aftermath of powerful storms, like the recent Hurricane Matthew, which are expected to increase over the next century due to climate change. Sea levels are also expected to rise due to climate change, exacerbating the effects of storms and increasing the expected damages. While flood insurance is only one tool that may be used against the disruptive effects of climate change, it is important to the survival of many New York communities where there is already extensive development in high-risk areas (some of which is relatively new).
The National Flood Insurance Program (NFIP), created when Congress passed the National Flood Insurance Act of 1968, provides flood insurance to property owners in participating cities like New York. Although a city’s participation in the program is voluntary, the program requires residents of participating cities to purchase flood insurance if they live within a Special Flood Hazard Area, defined as the area expected to experience major flooding—the “floodplain”—during a “100-year storm” (for comparison, Hurricane Sandy was a 500 to 3,500 year storm). FEMA researchers determine the 100-year floodplain, and communities are given a 90-day appeal period. FEMA’s preliminary New York City area flood map would have placed about 400,000 New York residents in the 100-year floodplain, an 83% increase from the previous map. In winning its appeal against FEMA, the City has stayed this increase.
The City based its appeal on the methodology used to create the new flood insurance rate map, which the City urged overestimated the size of the Special Flood Hazard Area, or 100-year floodplain. Specifically, the City argued that the NFIP should base insurance rates on current flood risk estimates, not future estimates. The City hired the consulting firm Arcadis to help design a 100-year floodplain map that included 26,000 fewer buildings and 170,000 fewer residents than FEMA’s original map. Regardless of the rhetoric of cooperation or the strength of the City’s methodological arguments, it is clear that the aims of FEMA and the de Blasio administration’s income equality and affordable housing goals are somewhat opposed.
The City’s climate change resiliency efforts took off in 2013 when former mayor Michael Bloomberg, unveiled an expansive $19.5 billion climate resiliency plan originally known as PlaNYC, based extensive reports generated in the aftermath of Hurricane Sandy. The de Blasio administration left the broad resiliency plan in place, but redesigned it to reflect the administration’s intention to bring 800,000 New Yorkers out of poverty or near-poverty over the next decade. The plan has also been rebranded under the Mayor’s comprehensive OneNYC. According to Mayor de Blasio, “Environmental sustainability and economic sustainability have to walk hand in hand.”
FEMA’s preliminary flood insurance rate map would have run counter to these goals by making housing less affordable for many New Yorkers who would be required to pay substantially higher flood insurance premiums. But while de Blasio’s income equality goals might tie in with other aspects of City management, such as education, it does not necessarily make sense to frame climate change resiliency in terms of affordable housing. Currently, the City’s resiliency efforts are considered relatively strong, but orienting the resiliency effort towards affordability might undo this positive trajectory.
The maps at issue also determine minimum building codes, which play a major role in resiliency. The de Blasio administration’s contention that insurance rates should be based on current risk levels does not necessarily account for rules governing new building developments, which should be based on future predictions. Furthermore, the current risk assessment does not factor in the worsening weather patterns wrought by climate change.
The agreement between the City and FEMA may eventually produce flood maps that adequately prepare the City to rebuild after inevitable natural disaster without undermining important income equality goals. Until then, the outdated map will be in effect.