Massachusetts Congressional Delegation Challenges FEMA’s New Flood Maps

December 20, 2013

Members of the Massachusetts Congressional delegation, led by Congressman Bill Keating, recently sent an open letter to the Federal Emergency Management Agency (FEMA). The lawmakers argued in their letter that when FEMA established the new flood maps for Massachusetts, it used “a potentially inaccurate methodology” that failed to appropriately reflect the geographic region and the unique flooding characteristics found in New England.

The methodology employed by FEMA ended up “unnecessarily adding more families to the flood maps” in the state, the Massachusetts Congressional delegation argued.

The letter, addressed to FEMA Administrator Craig Fugate, was sent on Dec. 13. In their letter, the lawmakers requested a delay in the implementation of Massachusetts’ new flood maps until they are amended to appropriately reflect the geographic region.

The letter notes that Rep. Keating, a member of the U.S. House Homeland Security Committee, requested an independent review of the maps by a scientist and engineer affiliated with UMass Dartmouth’s School of Marine Science and Technology, and Applied Coastal Research and Engineering. The review was conducted by Dr. Brian Howes and Mr. John Ramsey and specifically used the Town of Marshfield in Massachusetts as a test case.

Their findings, detailed in a white paper, indicated that FEMA applied an inappropriate methodology for the region when establishing the new flood zone maps, the Massachusetts Congressional delegation said.

The lawmakers said the FEMA methodology used the Pacific Coast model, which “does not truly reflect flooding found on the Atlantic Coastline in New England.”

Flooding on the Pacific Coastline originates from the continuous nature of the waves. On the other hand, flooding on the Atlantic Coast is most often the result of storms and surges, the Massachusetts lawmakers said in their letter.

Many Massachusetts residents and businesses are facing thousands of dollars in flood insurance premiums when the new maps are not even tailored to their region, Rep. Keating argued.

While my colleagues and I have been addressing the issue of affordability for months, this is the first time we have scientific evidence that the entire state is being subjected to maps designed for the opposite coast,” Rep. Keating said.

“The only thing to do is delay implementation. FEMA needs to reevaluate our maps in light of this new information,” Rep. Keating said.

Sen. Elizabeth Warren said families purchase flood insurance to prevent the loss of their homes, but now many families fear that the price of flood insurance could be just as devastating as any storm.

“You can’t protect someone’s home by pricing them out of it, yet that’s exactly what’s taking place around the country,” Sen. Warren said.

“We need to give the government the time it needs to make sure that FEMA’s new maps are accurate, reliable and reflect the best available scientific data, and we need to make sure that hardworking families who play by the rules can afford these policies,” Sen. Warren said.

“It is fundamental to community safety and insurance fairness to have accurate flood maps,” Sen. Ed Markey added. “FEMA should not finalize maps based on faulty science. These flood maps have huge economic repercussions for Massachusetts communities, so they must be accurate.”

Rep. John Tierney commented that following the recent redrawing of flood maps, thousands of local homeowners and businesses have learned their flood insurance costs would be rising. “While we were aware of clear shortfalls of the new maps, the recent review conducted by UMass Dartmouth has uncovered more evidence to call them into question,” Rep. Tierney said.

“I join Rep. Keating and my other Massachusetts colleagues in continuing to push for a delay of these unreasonable premium rates until we can address the scientific and affordability concerns that have arisen from the new flood maps,” said Rep. Tierney.

Rep. Stephen Lynch said he has attended community meetings and rallies in his district where affected homeowners have asserted that FEMA’s flood maps are inaccurate and draw far too many people into flood zones.

“Now, we have scientific proof that these homeowners are right. I join my colleagues in calling on FEMA to halt their flood mapping process until Massachusetts homeowners can trust that FEMA’s flood maps are accurate,” Rep. Lynch said. “There is too much at stake to allow these inaccurate maps to go forward.”

Rep. Niki Tsongas said, “As a member of the Natural Resources Committee, and with several major rivers and waterways crisscrossing the Third District (in northeastern and central Massachusetts), I have long been an advocate for not only preserving these natural resources but also supporting those who live and work around them. I have heard from concerned residents in the region and I urge action to help maintain affordable flood insurance.”

“Our Commonwealth has seen a dramatic jump in flood insurance premiums at a time when residents and businesses are already struggling to make ends meet,” Rep. Joseph Kennedy said. “It is our hope FEMA will consider the information contained in this new report and work with us to ensure Massachusetts has flood maps that are both fair and accurate.

Below is the text of the delegation’s letter:

December 13, 2013

The Honorable W. Craig Fugate
Federal Emergency Management Agency
500 C Street, SW
Washington, D.C. 20472

Dear Administrator Fugate:

In an effort to continue our advocacy on behalf of the many residents that have been living in our coastal communities for generations, we request your immediate assistance in addressing concerns over the Federal Emergency Management Agency’s (FEMA) new flood maps for Massachusetts.

Though the Biggert-Waters National Flood Insurance Reform Act of 2012 (Biggert-Waters) aimed to improve the actuarial soundness of the National Flood Insurance Program and introduce important reforms, significant unintended consequences have arisen throughout implementation.

Having heard from numerous homeowners that have seen their premiums rise dramatically due to change in flood zone determination, we have grave concerns that absent reconsideration of FEMA’s flood zone maps for Massachusetts, many homeowners and business owners are potentially facing unfair and unaffordable rate increases.

It has come to our attention that the new flood maps being enlisted to predict coastal flood levels for Massachusetts were implemented using a potentially inaccurate methodology for our region. Unfortunately, these new maps serve as a directive for much more expensive flood insurance rates for many residents and business owners. The attached supporting documents, from an independent review by scientists and engineers from the University of Massachusetts Dartmouth School for Marine Science and Technology and Applied Coastal Research and Engineering, Inc., indicate that the broad application of the methodology used by FEMA in determining the development of the 2013 flood maps appears to have been inappropriate for our geography.

Specifically, FEMA used a model called Direct Integration Method (DIM) to determine “wave setup,” a phenomenon where water levels along a coastline are elevated due to breaking waves pushing water against the shore. It is our understanding that this model was created to meet specific needs of the Pacific Coast, including very long wave periods, and where storm surge is not significant. On the East Coast, storm surges tend to govern storm damage and the shorter wave periods do not generate wave setup similar to the Pacific Coast. According to the independent review, the effect of using a simplified wave setup methodology, rather than more sophisticated (physics-based) tools to predict the level of flooding, yields overly conservative results, unnecessarily adding more families to the flood maps.

Using potentially incorrect technology or data, FEMA has encumbered residents and business owners with faulty insurance premiums that can reach as high as $18,000 to $50,000 in some parts of the Commonwealth. Given the significance of this economic impact on families and businesses it is imperative that FEMA work swiftly to address these concerns.

In light of the new evidence regarding the incorrect methodology, we ask that FEMA work closely with us to take a number of steps:

1. We ask that you work with us on a remedy to amend the Commonwealth’s flood maps utilizing the correct methodology for our geographic region.

2. We ask that you put in place a complete suspension of the new flood maps until a decision is made to amend them.

3. We also ask that you notify us in writing by (February 1, 2014) of FEMA’s proposed plan, including a draft timeline, to rectify flood maps for the Commonwealth. We hope that your office will keep our staff regularly apprised of the agency’s progress in this regard.

Simply put, we must get the maps right. The economic livelihood of the people of Massachusetts depends on it. Thank you for your prompt attention to this important issue.

William R. Keating, Member of Congress
Elizabeth Warren, United States Senator
Edward J. Markey, United States Senator
Richard E. Neal, Member of Congress
James P. McGovern, Member of Congress
John F. Tierney, Member of Congress
Michael E. Capuano, Member of Congress
Stephen F. Lynch, Member of Congress
Niki Tsongas, Member of Congress
Joseph P. Kennedy III, Member of Congress

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