Identifying areas that are at risk of frequent flooding is crucial for all communities, particularly those participating in the National Flood Insurance Program (NFIP). Properties within these areas are at risk of becoming Repetitive Loss (RL) properties, which can profoundly affect communities in a myriad of ways. RL properties can contribute to increased insurance costs and strain emergency services, so adequately tracking and proactively addressing Repetitive Losses is often a priority for communities that regularly experience flood events.

In Forerunner's work with communities across the country, we've identified many challenges with managing Repetitive Loss properties – from understanding the ISAA process to integrating Repetitive Loss data into existing datasets to meeting data security requirements, managing enforcement, and more. We created this blog to answer some of the common questions we hear! ‍

What are Repetitive Loss and Severe Repetitive Loss Properties? Repetitive Loss properties are those that have proven vulnerable to recurring flooding due to multiple NFIP losses. Over 195,000 repetitive loss properties in the United States have received claim payments of over $12 billion, which accounts for almost one-fourth of all NFIP payments since 1978. The CRS program defines a Repetitive Loss Property (RL) as "a property for which two or more NFIP losses of at least $1,000 each have been paid within any 10-year rolling period since 1978 (e.g., two claims during the periods 1978–1987, 1979–1988, etc.).." Congress defined a new subset of RL properties called "Severe Repetitive Loss Properties" to focus available resources on mitigating these properties when it passed the Flood Insurance Reform Act of 2004. Severe Repetitive Loss Property (SRL), as defined in the Flood Insurance Reform Act of 2004, is "those 1–4 family properties (and non-residential buildings) that have had four or more claims of more than $5,000 or two or more claims that cumulatively exceed the building's value."

Special note: Repetitive Loss (RL) and Severe Repetitive Loss (SRL) designations only apply to structures with NFIP flood insurance policies. A community may have structures that sustain recurring flooding but are not considered RL or SRL properties because they are not insured by NFIP policies. This becomes important when statistics on repetitive loss are used for planning and/or decision-making purposes. Repetitive Loss (RL) and Severe Repetitive Loss (SRL) designations primarily affect mitigation grant prioritization and cost share allowances. FEMA Hazard Mitigation Assistance (HMA) grants - a category which include the Hazard Mitigation Grant Program (HMGP), the Pre-Disaster Mitigation (PDM) grant program, and the Flood Mitigation Assistance (FMA) grant programs – typically require a 25% cost share match to 75% federal share for all awards. However, under the FMA program, mitigation projects for SRL-designated properties receive a 100% federal cost share, and RL-designated properties require a 10% cost match to a 90% federal share. The enhanced federal cost shares for SRL and RL properties dramatically reduce the funding burden on communities and homeowners in implementing mitigation through the FMA grant program. Further, SRL and RL properties that make up more than 50% of the properties in a submitted FMA project are prioritized and are more likely to be funded during the program's annual cycle. In addition to the FMA program, there have been some instances of the SRL designation impacting insurance rates. In 2019, FEMA implemented an additional premium on SRL properties. ‍

Why is it essential for communities to identify their Repetitive Loss properties? More than 5.3 million NFIP policies across the United States exist in more than 22,000 communities. About 160,000 of the properties covered by these policies have suffered repetitive losses as of 2015. Since 1978, approximately $9 billion has been paid to these properties, representing about one-quarter of all flood insurance claims payments. Many buildings remain uninsured despite remaining on a community's repetitive loss list. Knowing which properties have been identified as Repetitive Loss properties can help to ensure that communities plan accordingly for mitigation and future development. For communities participating in the Community Rating System (CRS), achieving a CRS Class 9 or higher is predicated on repetitive loss-focused activities including tracking rep loss properties, mapping rep loss areas, and conducting outreach. Homeowners often want a solution to their repetitive flood problems because they must continually clean up and repair their homes and can even be displaced for some time. In response, communities usually advise and assist property owners who have been flooded or have drainage problems. From a state and national perspective, mitigating repetitive loss of properties makes economic sense and reduces the financial burden on the National Flood Insurance Fund (NFIF). Reducing repetitive flood claims can help strengthen the solvency of the NFIF. But more importantly, reducing damage to repetitively flooded buildings makes communities safer. ‍

How can communities access Repetitive Loss property data? FEMA provides NFIP Repetitive Loss (RL) and Severe Repetitive Loss (SRL) data upon request for mitigation planning, grants, or the CRS program. The data is managed in a system called PIVOT, . PIVOT stores data for each NFIP flood insurance policy, including Personally Identifiable Information (PII) such as the owners' names, addresses, policy coverages, and the dates and amounts of past claims. The PIVOT system is crucial in maintaining and updating this data, ensuring its accuracy and security. Historically, CRS-participating communities would receive RL and SRL data from their CRS specialists annually. Communities used this data to manage their RL and SRL properties, checking for accuracy and updating any changes to the list by submitting an NFIP Repetitive Loss Property Update Form, formally known as the AW_501 form. Due to PII security concerns, FEMA changed this process several years ago by establishing the Information Sharing Access Agreement (ISAA) process. Under this process, communities must have an executed ISAA with FEMA before obtaining their RL and SRL data. Typically, communities are required to have an ISAA directly with FEMA, but some states have an ISAA that allows the state to establish an ISAA with communities. To learn which process your state follows, contact your State Floodplain Administrator. While the process can differ community by community, here is a general outline of the steps typically taken to secure ISAA with FEMA:

1. Contact the Regional Flood Insurance Liaison (RFIL) at your FEMA Regional Office. Most Regions have set up an email address, making it easier for the community to make this request.

2. The RFIL will respond to the request, asking for clarifying information to develop the ISAA if needed, such as: What specific NFIP data is being requested? (RL data, SRL data, or other NFIP data) Why is the data being requested, and how will it be used? (CRS requirements, updating mitigation plans, developing grant applications, or other NFIP data to earn CRS credits) Who will use or have access to the requested data? (Person(s) must be named in the ISAA) Is the data related to a presidentially declared disaster or emergency?

3. Once these questions are answered, a draft ISAA will be created and sent to the community for review and signatures.

4. Once the community signs, the ISAA is returned to the RFIL for processing.

5. The ISAA will be reviewed and processed at the Region or FEMA Headquarters, and an executed copy will be returned to the requesting community. Once the ISAA is in place, the RFIL can provide the requested data, which will be valid for three years.

When considering developing an ISAA with FEMA, here are some useful points to remember in establishing an ISAA that fulfills your community's needs:

• Consider your future data needs. Do not limit the scope when making your ISAA request since ISAAs are usually specific to the requested data set. Consider all the possible uses that may include PII, even if they are not immediate. This comprehensive approach will ensure you receive permission to request all the data you may need within the three years of the ISAA, making your flood risk management more effective.
• Plan for access. Include all the possible individuals (signatories) who may need to request or use the data. The community's Chief Executive Officer must sign the ISAA with four additional signatories, for five per ISAA. By using as many of these slots as possible, you will not have to rely on a single point of contact to request and review the needed data.
• Account for everyone. Remember to consider including third-party vendors or consultants. If the community contracts with a vendor or consultant, like Forerunner, whose services include using or reviewing data requested in the ISAA, they will need to be included as a signature in the ISAA. This will ensure that the community can share the data with third parties and that it does not violate the Federal Privacy Act.

‍How do communities use Repetitive Loss data for mitigation and resilience? Mitigating Repetitive Loss properties often requires a multi-faceted approach that may include acquisition (buyout) processes, grant opportunities applications, and monitoring/tracking improvements and repairs. During each CRS verification cycle visit, CRS participating communities must also have current Repetitive Loss data.

• Acquisitions (buyouts) - Generally, FEMA-assisted property acquisition projects consist of a community purchasing at-risk structures from voluntary sellers and either demolishing the structures or relocating the structures to a new site outside of the hazard-prone area. The purchased property is then maintained, in perpetuity, for open-space purposes and to restore or conserve the site's natural functions.
• Mitigation Grant Opportunities - FEMA has three federal mitigation grant programs: the Hazard Mitigation Grant Program (HMGP), the Pre-Disaster Mitigation Program (PDM), and the Flood Mitigation Assistance Program (FMA). RL and SRL designations primarily affect mitigation grant prioritization and cost share allowance. To learn more about grant funding opportunities, locate and contact your State Hazard Mitigation Officer (SHMO).
• Monitoring and Tracking Improvements and Repairs - NFIP participating communities must adopt and enforce regulations and codes for development in Special Flood Hazard Areas (SFHAs). This includes tracking improvements and repairs to RL and SRL properties to determine if the proposed work qualifies as a substantial improvement or repair of substantial damage. Properly tracking improvements and repairs will assist in mitigating RL and SRL properties, improving communities' resilience to flooding.
• Repetitive Loss Area Analysis (RLAA) - A community may receive CRS credit for element FMP, a repetitive loss area analysis (element RLAA), and element SDP. A community need not have any repetitive loss properties on FEMA's list to receive SDP credit. ‍

How can Forerunner help? We’d love to chat about how we can help! The team at Forerunner recently developed a Repetitive Loss feature designed to make it easier to manage Repetitive Loss data. The feature supports communities by consolidating, updating, and tracking repetitive loss data safely and securely. Given the data's high sensitivity, we use best-in-class security practices to protect it. Once in Forerunner, the data can only be viewed by users with appropriate permissions and is not available to the public, offering much more security than traditional spreadsheets. If you’re new to learning about Forerunner, we build software to help our partners address flood risk. As it pertains to Repetitive Loss, Forerunner empowers our partner communities to more easily track and identify rep loss properties, facilitates outreach through features like our letter generation tool, and enables better cross-departmental collaboration. Reach out to learn more.

Written by Conn Cole, Forerunner

If you or members of your local government or private company (reimbursement is not available for private entities) are able to travel and assist with mutual aid to areas affected by Hurricane Idalia, please go to Tropical Storm/Hurricane Recovery Volunteer Guidelines - Florida Floodplain Managers Association (FLfloods.org).

Your Registration will be utilized for matching you with a community that requests support during this time.

The FFMA and FDEM Mutual Aid Agreement is intended to establish a mechanism for the State to request Certified Floodplain Managers through our organization. Each entity must coordinate this State and federal assistance through county-level government.

A Brief Introduction to Elevation Certificates

Elevation Certificates (ECs) are central to the work of floodplain managers across the country. These surveyed documents contain vital details, such as lowest floor elevation. They are integral to daily floodplain management functions including enforcing floodplain compliance, calibrating flood insurance, and beyond.

Since ECs are often collected to meet National Flood Insurance Program (NFIP) requirements, it's likely that if you're a floodplain manager in Florida, you're well-acquainted with the document. Despite their ubiquity, staying on top of Elevation Certificate compliance and maintenance can be a huge burden for communities with limited resources. This is particularly true for communities in the Community Rating System (CRS), for whom maintaining accurate ECs can mean the difference between saving millions of dollars in flood insurance discounts for residents and upsetting property owners whose premiums increase significantly. The 2021 CRS Addendum raised the stakes for EC accuracy even higher, with one less complimentary review issued to help ensure that CRS communities meet the 90% accuracy threshold for staying in the program. More broadly, the context of floodplain management is also changing rapidly with big recent shifts like Risk Rating 2.0 and a new Elevation Certificate revision on the horizon. While the role of ECs will morph with an evolving NFIP, they'll likely remain an important tool for enforcing local compliance.

Our team at Forerunner spends a lot of time learning about challenges facing floodplain managers in Florida and beyond to inform the development of our floodplain management software. We help to enable the important work of partners throughout the state, like Miramar, Clearwater, Coral Gables, Hialeah, and the Florida Division of Emergency Management. We assist them in streamlining their EC workflows (among other things).

Many of our municipal and county government users historically struggled with EC management and review. To address these pain points, we built an EC Error Detection Feature that automatically checks Elevation Certificates for errors. In developing this feature, we conducted interviews with a diverse group of floodplain managers and gathered data that shed light on common EC challenges and errors encountered by communities of all sizes. Here are some of our findings:

Navigating Compliance Challenges
Through user research, we heard about several challenges that floodplain managers face when managing incoming Elevation Certificates:

● It's hard to keep track of ECs for internal record-keeping and the CRS. Some communities noted that they don't have a system for tracking ECs, and many rely on spreadsheets. Almost everyone spoke about the difficulty of maintaining up-to-date records, regardless of whether or not they had a digital tracking system in place.
Communities that reported being successful in EC management often maintained databases and spreadsheets on a schedule and they had dedicated time each week to
update EC info. Forerunner acts as an EC repository for our partner communities and we often see trends in users uploading documents at specific times. Our software also
generates CRS-specific exports to fulfill 310 requirements, so we see an uptick in exporting when it comes time for community recertification visits.
● Federal and local floodplain regulations can be difficult to communicate with residents, but keeping them informed is crucial to enforcing compliance and encouraging risk
reduction. Communities reported spending a lot of time responding to resident requests and providing documentation (like access to historic ECs) to stakeholders. Those that
invested in sharing data digitally, using public websites and automated emails, found that it alleviated some of the day-to-day burden of response. Our users have anecdotally
reported that using our white-labeled public websites is useful for providing residents with a self-service platform to access flood risk information 24/7.
● Checking ECs for accuracy and compliance to local regulations is an onerous process. Depending on internal capacity, Elevation Certificates might be reviewed by staff
members who are not trained to evaluate floodplain compliance and those with insufficient experience may face difficulties in conducting a thorough review. If ECs are
not completed correctly, communities run the risk of permitting construction in floodplains that do not adhere to regulatory standards and facing penalties from FEMA.
Once a non-compliant structure is built, enforcing changes or reversing a permitting decision can be complicated. Communities that are successful at minimizing errors
typically put into place thorough checks using multiple EC reviewers, checklists, and tools like Forerunner's EC Error Detection.

Minimizing Elevation Certificate Errors
Tackling Elevation Certificate errors programmatically helps to minimize human slip-ups and catch clerical mistakes that might otherwise be overlooked, but have big consequences. Part of what makes EC reviews complex is that certain requirements are triggered by the values reported in other fields. For example, if a structure is elevated (Building Diagrams 5, 6, 7, 8, and 9), its C2.a Top of Bottom Floor should be above the C2.f Lowest Adjacent Grade. Keeping track of this logic can be difficult, especially if someone isn’t reviewing ECs on a daily basis. Utilizing software can help reduce complexity and lower the amount of total time spent on EC review.

We designed Forerunner's EC Error Detection Feature to run hundreds of validation checks on ECs, so you don’t have to. We identify potential clerical, compliance, and elevation issues that need to be addressed in ECs before submitting to the NFIP or CRS. The tool surfaces potential issues ranging from urgent (like the possibility of incorrect elevations) to noncritical (like a reminder to check for a V-Zone Design Certificate). If you'd like to compare our checks to yours, feel free to use our Issues Guide as a resource. Within the Issues Guide, noncritical issues are marked as "warnings", while urgent issues are marked as "errors.”

To date, we’ve checked approximately 60,000 residential Elevation Certificates issued after 1/1/2019 for our partners. 52,695 of these Elevation Certificates had at least one flagged error. Put another way, there were errors in 87.5% of the ECs we ran our Error Detection check on. In total, our software flagged 191,576 errors, which amounts to an average rate of ~3 errors per flagged EC. Here are some of the most frequent types of problems surfaced:
● B4. Map/Panel Number does not match the Map/Panel Number provided by FEMA: Since Map/Panel numbers are long, typos are common in this field. Our Error Detection
checks EC fields against FEMA's data, which helps to minimize time spent reviewing Section B FIRM Information.
● C2.f Lowest Adjacent Grade lower than Base Flood Elevation: Unless an Elevation Certificate being submitted is for LOMA or LOMR-F purposes, the Lowest Adjacent
Grade is typically below the Base Flood Elevation. Often, surfacing this issue can uncover additional potential issues.
● Regulatory Lowest Floor below Design Flood Elevation: Because ECs are often collected to ensure enforcement of local regulations, our software checks ECs for compliance to communities' individual standards. A common issue found on the ECs we've processed thus far is that a structure's regulatory Lowest Floor is lower than the
community's Design Flood Elevation (most commonly, Base Flood Elevation + Freeboard).
● C2.e Lowest Elevation of Machinery below Design Flood Elevation: Similarly, another common issue is that the Lowest Elevation of Machinery for a structure falls below a
community's Design Flood Elevation. This can be easy to miss if you’re checking many other fields.

Depending on a community's individual context, common errors vary. We've found that communities with lower error rates typically have floodplain managers who invest in developing strong relationships with local surveyors. When this happens, requests for specific document changes and practice shifts can be passed along quickly and seamlessly. If you'd like to learn more about our EC research (we did a lot of it!), how we’re preparing for upcoming Elevation Certificate changes, or our work at Forerunner overall, please feel free to reach out to us at hello@withforerunner.com. We're always happy to have a chance to learn more about your work and share our knowledge.

Additional Resources
Forerunner's Floodplain Management Platform
Forerunner's CRS Guide
Forerunner's EC Issues Guide
CRS Elevation Certificate Training Series
CRSResources.org Trainings & Videos

Deadline to submit is Oct. 31

National Flood Insurance Program Minimum Floodplain Management Standards

FEMA published a Request for Information in the Federal Register seeking public comments on proposed changes to the National Flood Insurance Program Minimum Floodplain Management Standards.  The public comment period is from Oct. 12 – Dec. 13, 2021.

Federal Register Notice

Beginning today, FEMA seeks public comment on a Federal Register Request for Information on the National Flood Insurance Program’s (NFIP) minimum floodplain management standards.

This notice is to gather comments on opportunities to update the program’s minimum floodplain management standards to help communities become safer, stronger, and more resilient. This notice also seeks input on the program’s minimum floodplain management standards that will promote conservation of threatened and endangered species and their habitats consistent with the Endangered Species Act, Section 7(a)(1).

The type of feedback that is most useful to the agency includes feedback that:

• Identifies opportunities for the agency to improve the NFIP’s minimum floodplain management standards for land management and use
• Identifies specific program components that promote conservation of threatened and endangered species and their habitats
• Refers to specific barriers to community participation
• Aligns the program with the improved understanding of flood risk and flood risk reduction approaches
• Identifies better incentives for communities and policyholders, particularly for ESA-listed species and critical habitats
• Offers actionable data
• Specifies viable alternatives to existing approaches that meet statutory obligations

  Written comments can be submitted from Oct. 12 – Dec. 13, 2021 on the Federal eRulemaking Portal, Docket ID: FEMA-2021-2024. Please follow the instructions on the webpage for submitting comments and contact the Regulations Help Desk if you have technical issues.

  Contact Us

  If you have any questions, please contact Office of External Affairs:

• Congressional Affairs at (202) 646-4500 or at FEMA-Congressional-Affairs@fema.dhs.gov
• Intergovernmental Affairs at (202) 646-3444 or at FEMA-IGA@fema.dhs.gov
• Tribal Affairs (202) 646-3444 or at FEMA-Tribal@fema.dhs.gov
• Private Sector Engagement at (202) 646-3444 or at nbeoc@max.gov

Follow Us

Follow FEMA on social media at: FEMA Blog on fema.gov, @FEMA or @FEMAEspanol on Twitter, FEMA or FEMA Espanol on Facebook, @FEMA on Instagram, and via FEMA YouTube channel.

Also, follow Administrator Deanne Criswell on Twitter @FEMA_Deanne.

FEMA Mission

Helping people before, during, and after disasters.

Deadline to submit is Oct. 31

The Association of State Floodplain Managers (ASFPM) Foundation (Foundation) was established in 1996 as the charitable arm of ASFPM. Importantly, the Foundation acts as a forward-looking catalyst for ASFPM, its Chapters, and members to advance projects, education, and policy initiatives that promote actions leading to reduced flood risk and resilient communities.

The Foundation is a premiere advocate for the floodplain management profession and serves as a voice for floodplain management practitioners, suppliers, and service providers nationwide, and in some cases globally.  The Foundation has played a key role in the development of the Certified Floodplain Manager (CFM) certification program, which is foundational to establishing and maintaining the credibility of floodplain managers across the country. The Foundation continues to support the profession in many ways that bolster the CFM program. The following describes but a few of these important initiatives:

• In February 2020, the ASFPM Foundation released a report titled “Urban Flooding: Moving Towards Resilience,” to document important discussions by world class experts who attended the Foundation’s 6^th assembly of the Gilbert F. White National Policy Forum. The report showcases the in-depth engagement on urban flooding issues by more than 100 experts from local, state, and federal agencies; professional associations; environmental groups; and private organizations.  The report can be downloaded from the ASFPM Foundation website.
• The ASFPM Foundation announced the award of its 2020-2022 Future Leaders Scholarship to Elizabeth Lacey at the ASFPM Virtual Conference in June 2020. Elizabeth is entering her third year in the Civil Engineering Honors Program at Colorado State University in Fort Collins, Colorado.  She is the second student of what we hope are many more to come to receive this $20,000 per year scholarship with the goal of developing future leaders in the floodplain management field. Elizabeth’s acceptance message can be found on the ASFPM Foundation Website.
• The ASFPM Foundation provided funding for, and partnered with ASFPM Flood Science Center to develop” Flood Mapping for the Nation Report” and “Understanding and Managing Flood Risk: A Guide for Elected Officials.” Both of these documents provide valuable information to floodplain management practitioners and can be found on the ASFPM Flood Science Center website.
• The ASFPM Foundation again partnered with FEMA Region VIII and Earth Force to sponsor the 2020 Rocky Mountain Environmental Hazards Challenge, now referred to as the Rise Challenge. This is an annual competition that combines project-based learning with the latest research in science, technology, engineering, and mathematic (STEM) education.

Donations are the primary source of funding for the ASFPM Foundation.  We cannot emphasize enough the importance of your contributions in helping us to sustain our current initiatives and develop new ones. The goal of reducing suffering and losses and improving a community’s ability to become safer and stronger in the aftermath of increasingly catastrophic flooding events is at the forefront of everything we do. Importantly, we also promote sustainable management of the nation’s floodplains and watersheds.  For more information regarding the ASFPM Foundation and how you can donate, please contact George Riedel, Foundation Donor Coordinator, at George@aspfmfoundation.org.