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New Chapter in the Fight Against FEMA’s Risk Rating 2.0

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Plus, NFIP vs. state-backed flood insurance

The Trump administration is fighting an ongoing effort by ten Republican-led states to ditch FEMA’s Risk Rating 2.0 flood insurance pricing, a new report throws water on the idea of shrinking the National Flood Insurance Program into separate state-run systems, and FEMA releases a best practices guide for retrofitting flood-prone homes.  It’s all in this week’s Flood Digest.

The Fight Against Risk Rating 2.0: 2023 marked the beginning of a lengthy process: Louisiana led a band of 10 Republican states, including Florida, that filed suit against the federal government for “unfair” flood insurance rate increases under FEMA’s Risk Rating 2.0 program.  Now, in a rare turn of events, the Trump administration is voicing support for the Biden-era program, asking a federal judge to dismiss the states’ lawsuit in a 126-page court filing.  The administration contends the old program was too costly, following years of artificially low flood premiums, and have cited findings from the recent FEMA Review Council report to back up its arguments.  It is worth noting that four of the key council members hail from states that filed the lawsuit: former Mississippi Gov. Phil Bryant (R); former Florida emergency management chief Kevin Guthrie; Texas Gov. Greg Abbott (R); and Texas emergency management chief Nim Kidd.

“This may be one of the first concrete actions we’re seeing as an outcome of the (council) report,” said Chad Berginnis, executive director of the Association of State Floodplain Managers, which supports Risk Rating 2.0’s rates, in an interview with E&E News.

An earlier 2024 Biden-era motion to dismiss the case was denied and both sides are scheduled to submit briefs this November, but in the meantime, the involved states have been anything but quiet.  Congressman Troy A. Carter, Sr. (D-LA) recently sent a letter to DHS Secretary Markwayne Mullin and FEMA Administrator Cameron Hamilton, among other important emergency management figures, rallying against the privatization suggestions in the FEMA Review Council report.  Rep. Carter, who leads the bipartisan Flood Resilience Caucus, offered seven policy suggestions, including the empowerment of local communities, updating Risk Rating 2.0, and two things we have long advocated for here at LMA: revising the ‘Write Your Own’ agent compensation, and a depopulation of existing NFIP policies into the private market.

Flash flooding of neighborhood homes. Courtesy, FEMA

Floods without Borders: Part of the debate from the FEMA Review Council report is whether states should take on more responsibility for flood insurance instead of relying on the federal government.  But new research from Arizona State University and Columbia University suggests that shrinking the National Flood Insurance Program (NFIP) into separate, state-run systems could actually make it harder to recover from major disasters.  Their report says this line of thinking may not only be misinformed, but incredibly detrimental to the risk pooling of the NFIP, which has historically increased financial resilience nationwide.  The idea isn’t new in the insurance landscape: a broader risk pool with different places facing different hazards means premiums generally stay lower as the overall odds of catastrophic risk are lower.  Another key takeaway: the interconnectedness of disasters irrespective of our manmade borders, via a phenomenon called “hyperclusters” coined by the researchers.  They provide the example of a hurricane causing flooding along the Gulf Coast, before causing heavy rainfall further inland.  While traditional thought might consider these separate events, they are both linked to the same atmospheric drivers, or, one hypercluster.  This perspective allows for a more nuanced and realistic picture of cascading loss and failures, and how resilience and disaster preparedness may extend far outside of any one local community.

A flood berm protecting a residence. Courtesy, FEMA

FEMA Retrofitting Guidelines: FEMA recently updated its Engineering Principles and Practices for Retrofitting Flood-Prone Residential Structures (FEMA P-259), a best practices guide to help reduce cyclical flood damage in flood-prone areas.  Essentially, buildings that predate the adoption of local floodplain management requirements are much more likely to sustain higher flood damage over time.  Retrofitting efforts, such as home elevation, relocation, barriers, dry floodproofing, and wet floodproofing can all reduce the likelihood of flood damage significantly, lowering the overall risk pool for the NFIP, and saving countless lives and dollars in the process.

LMA Newsletter of 8-31-26

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Tags: Federal Flood Insurance, FEMA, FEMA Review Council, Flood Insurance, Flood Insurance Rates, Flood Resilience Caucus, Flooding, Floodproofing, Kevin Guthrie, National Flood Insurance Program, Private flood insurance, Risk Rating 2.0

“Keep up the great work, Lisa! I enjoy your updates!”

John Askins, Former Director
Florida Department of Financial Services, Division of Insurance Fraud

“I do not know how to say in words the heartfelt thankfulness that you took the time to listen to me, heard me, and then TOOK action to get something done after the long emotional and FINANCIAL struggle with…the hardship of paying upfront for all the repairs from Hurricane Sally. I cannot say enough of how I appreciate you, your attitude of wanting to help people and the next step to actually take action to do something is amazing.”

Ramona Speer, Realtor®
Gulf Breeze, FL

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Austin Perez, Senior Policy Advisor
National Association of Realtors®
Gulf Breeze, FL

“Lisa, I was delighted to get your newsletter. It is very professional and a great read about what’s going on. It was good to see you doing the things you’ve always done so well. You were always a great source of input when I was in the Capitol and glad to see you are still providing such great assistance.”

Frank Messersmith, former Florida state representative, 1980-1990

“Thank you Lisa for staying on top of, as well as advocating, for Florida residents and legislative reform. Your newsletters are very informative and enjoy reading the points of view.”  

Shawna Miller, Sr. Claims Quality Assurance & Compliance Manager
Florida Peninsula Insurance Company
Jacksonville, FL

“Lisa Miller is a true champion for the insurance industry, with her regular updates! We appreciate all you do and keeping us up to date on priority issues!”

Gillian Lloyd, Account Executive
Zywave
Milwaukee, WI

“You are under-thanked and under-appreciated for all the work you do for our industry but I’m one guy who really appreciates the information you gather and share.  Many times I pass it along to my clients. Many thanks.”

Dan Brown, Sr., President
Brown and Brown Insurance
Orlando, FL

“Thank you for the information. I enjoy the info that you share and in turn, I share with my daughter and her husband. Sending love and best wishes to you!”

Paula, lifelong hometown of Plant City pal

“Lisa this is another great newsletter, and we appreciate the time and energy you put into these informative updates – you are on top of these topics!”

Mike Graham, CEO
Smart Vent Products, Floodproofing.com, & Risk Reduction Plus
Juno Beach, FL

“Wow, what a dazzling amount of expertise and content, Lisa! You continue to amaze after 40-years of being amazing. Your newsletter is extraordinary. Congratulations!”

D. Joel Whalen, Associate Professor
DePaul University Kellstadt Graduate School of Business & Past President, Association for Business Communication

“A high-profile attempt to undo recent litigation reforms that helped stabilize the insurance market was successfully defeated. We’re grateful to trusted experts like Lisa Miller (former Florida Deputy Insurance Commissioner, now one of the state’s top insurance advocates) for providing ongoing updates during every legislative session.”

Whitney Ricci, President & Founder
Ricci Insurance Group
Jacksonville, FL

“I really like your newsletter. It’s informative and to the point, even to the layperson. You are absolutely an asset to your industry. Keep it up please!”

Rivers H. Buford, III, Veteran Florida legislative and regulatory leader, retired

“Lisa is truly an insurance industry dynamo who operates her business with integrity and zealous representation. She is the person that legislators call upon when they have questions regarding necessary insurance reforms. Lisa is a tireless advocate for the protection of all Floridians and their property.”

Greg Holder, Retired Judge and Attorney
Zinober Diana & Monteverde P.A.
Tampa, FL

“Just a quick note to let you know how much I have appreciated your newsletter over the years and the assistance they offer for those in the field of claims. We depend on the information more than you will ever know!”

Laurie Rasberry, Chief Claims Officer
Acorn Claims
Prosper, Texas

“What a great outreach and platform. God Bless.”

Ken Donohue, Former Inspector General
U.S. Department of Housing and Urban Development (HUD)

“I really do enjoy your newsletter – it is fantastic for the insurance industry in Florida.”

Bill Wilson, former PURE SAC Chair
PURE Insurance Company

“Your newsletter is fabulous!  I greatly appreciate the topics you expose, so that insurance professionals like myself can keep up with the latest events that affect the public we serve and ourselves.”

Cynthia Hoehn, Independent Property & Casualty Personal Lines insurance agent
Clermont, FL

“Lisa is a wealth of knowledge and produces some very useful content. I read her newsletter every week, it has great content, and I learn a lot. Thank you for being such an advocate Lisa and educating all of us.”

Tim O’Keefe, Director
KW Property Management & Consulting
Fort Lauderdale, FL

“Thank you, Lisa, for your tireless work on behalf of the industry and the citizens of Florida. This post is incredibly comprehensive and helpful. Stay safe my friend.”

Mel Russell, President & CEO
Russell Insurance Consulting
St. Petersburg, FL

“I wanted to write to tell you that this newsletter is the best in the industry. I look forward to it every week! Thank you for all that you do.”

Rebecca Leadbeater, Regulatory Compliance Analyst
Frank Winston Crum Insurance
Clearwater, FL

“I absolutely loved your AM Best Interview – watched it twice! You have always been so impressive and inspiring to the insurance profession. The interview packed so much information into just a few minutes. Thanks for sharing. Please don’t stop, we all enjoy your insight.”

John Burkholder, Principal
Municipal Partners, LLC
2016 Public Risk Manager of the Year

“Another great Newsletter on Florida industry this week.  Your service and advocacy in Florida is very important to keeping me updated and apprised of the Florida insurance laws, trends and overall environment.  Something similar is very much needed in Louisiana, too.”

Jennifer Tedesco, Esq., Claims Director
Pharos Claims Services
Orlando, FL

“Great article on Risk Rating 2.0!”

Austin Perez, Senior Policy Representative for Federal Housing, Valuation, Insurance and Commercial Issues
National Association of Realtors
Washington, D.C.

“Lisa, thank you for sending your newsletter to me. It keeps me up with news I can use. I hope all is well with you and wish you continued success.”

George E. Kelly, Jr.
GK Consulting LLC
Hartford, CT

“Just a quick note to say I always enjoy reading your newsletter. I have found many occasions to share it with family and friends who can’t understand why their insurance is expensive, as well as fellow employees. It is a great source of information in general, and especially helpful during the hectic times when work requires that I focus more narrowly on the task at hand, as it helps me keep sight of the big picture.”

Adam Marmelstein, Director of Agency & Market Services

“I have followed your weekly newsletter and podcasts and now have a full appreciation for what you bring to this industry.  You are an inspiring force, plain and simple.  I wanted you to know that you make a difference.  Thank you for all you do!”

Jeffrey Karam, CPCU
Bradenton, FL

“Thank you for all you do for the industry and the Verisk team. We are forever grateful and excited for the future. Getting your insight in my inbox is exactly what I need!”

John Haddad, Director of Product - XactAnalysis
Verisk Claims

“Just wanted to say that I thoroughly love your newsletter. It’s is always informative and insightful to the ins and outs of our industry.  You are an inspiration and an important asset in the insurance world.  Keep up the great work!” 

Cynthia Scott, President
University Insurance Group
Davie, FL

“The great thing about reading your newsletter Lisa, is that I can 100% trust that the info in it is completely accurate. Thank you for the time that you invest in this newsletter to keep everyone informed on new things going on in the industry.”

Lori Hall, Business Development Manager
Haag

“Keep informing and fighting!”

Mary Ann Medina, VP Client Partnerships
Charles Taylor
Lake Mary, FL

“Lisa, you will always be a public servant and your newsletters have shared valuable information to many. These newsletters are not five minute follow up reports. You’ve been to these disasters first hand and understand people lose everything and the elderly are the most vulnerable. It’s truly sad. Thank You for being sincere, when most are looking for ratings.”

John Greer, retired from construction, Plant City

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Ana Regina Myrrha, Agency Principal
American Insurance Point
Orlando, FL

“Congrats on your 17- year anniversary at Lisa Miller & Associates®!  You have created an awesome legacy and helped numerous companies, agents, and clients!  Enjoy listening to your podcasts and reading your newsletter!  Best way to keep up with what is happening in the FL insurance world.”

William McArthur, VP of Claims
Claims Adjustment Group (CAG)

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