Faster, less-expensive disaster recovery cited
FEMA’s on-again, off-again tougher flood rebuilding standard for federally funded projects is now halted once again. Effective March 25, 2025, FEMA stopped implementing floodplain management requirements under the Federal Flood Risk Management Standard Policy 206-24-005 (FFRMS). The tougher standards were based on both past risk and projected climate change risk for new construction, improvements, and repairs funded by FEMA, as well as the relocation of buildings away from or above flood zones. It almost exclusively impacted government buildings and community structures, such as libraries and schools, and did not affect most homes which are still under FEMA’s “50% Rule” on repair and rebuilding that we’ve discussed at length.
FFRMS has a checkered past – first created by President Obama in 2015, revoked by President Trump in 2021, reinstated by President Biden and then removed yet again on the first day of Trump’s second term in January of this year. “Stopping implementation will reduce the total timeline to rebuild in disaster-impacted communities and eliminate additional costs previously required to adhere to these strict requirements,” according to FEMA’s recent news release.
Flash flooding of neighborhood homes. Courtesy, FEMA
There are certainly advantages to higher standards during rebuilding which we’ve discussed in previous newsletters; perhaps a more holistic approach that factors in changes in water levels and compound flooding. While previous administrations and FEMA said this ensures “greater resilience to flooding, protecting federal investments, and reducing the risk of damage and loss from floods,” one thing is for certain: stopping implementation speeds up reconstruction and cuts additional costs in the disaster rebuilding process nationwide.
Streamlining the disaster recovery process may be at the heart of the issue, seeing as the FFRMS is quite far reaching, affecting all FEMA direct actions, grants, Hazard Mitigation Assistance, and both Individual and Public Assistance. With the revocation of FFRMS, the prevailing standard will only include Title 44 Part 9 of the Code of Federal Regulations – meaning FEMA will look to 1% annual chance (1-in-100-year) floodplain and elevation for non-critical actions, and the 0.2% (1-in-500-year) floodplain and elevation for the construction of projects like hospitals. This was the default for decades, starting back in 1977, with notable revisions published in late 2014 until the FFRMS overhaul.
A few things to note: projects already underway with their Record of Environmental Consideration (REC) issued anytime between 2021 to March 25, 2025 will require no action from recipients and not see FEMA take any action. Amendments to RECs will require a new environmental review, but all projects without a completed REC will see the 100-year and 500-year projections used to determine their floodplain. Also important, the FFRMS does not apply to the National Flood Insurance Program’s mapping process and is completely separate from FEMA’s Flood Insurance Rate Maps. This means that the standard did not affect premium rates or purchase requirements, and its removal won’t either. More information on floodplain management, current requirements, and grant projects can be found on FEMA’s website.
LMA Newsletter of 3-31-25
