Washington, DC – March 20, 2025 – The SmarterSafer Coalition submitted the following comment letter to the House Financial Services Committee.
Dear Chair Hill, Ranking Member Waters, Subcommittee Chair Flood, and Subcommittee Ranking Member Cleaver:
SmarterSafer is a national coalition advocating for environmentally responsible and fiscally sound approaches to natural catastrophe mitigation and public safety. We commend your leadership in recognizing the National Flood Insurance Program’s (NFIP) vital role in disaster mitigation and response and appreciate your ongoing efforts to advance its reform and reauthorization.
The NFIP provides essential insurance coverage to over 4.7 million homeowners, renters, and businesses nationwide. However, increasing flood intensity and related storm damages have placed severe financial strain on the program, resulting in substantial borrowing from taxpayers. To ensure the program’s long term sustainability, SmarterSafer urges Congress to prioritize risk assessment, mitigation, and private sector engagement in NFIP reforms.
We strongly advocate for long-term NFIP reauthorization and appreciate the stability it provides to flood prone communities. At the same time, fundamental reforms to the program are necessary. Suggested reforms include modernized flood mapping, stable financing mechanisms, and adaptable mitigation strategies that incorporate natural infrastructure. Furthermore, investing in pre-disaster mitigation is much more cost-effective than focusing on post-disaster recovery. Nature-based hazard mitigation solutions, like wetland restoration, greatly improve community resilience to flooding. According to a recent economic study by Allstate, the U.S. Chamber of Commerce, and the U.S. Chamber of Commerce Foundation, every $1 spent on climate resilience and preparedness saves communities $13 in damages, cleanup costs, and economic impacts.
Additionally, SmarterSafer maintains that the NFIP must move towards actuarial rates that more accurately reflect the flood risk associated with a specific property. We recognize the benefits of Risk Rating 2.0, fully implemented by the Federal Emergency Management Agency (FEMA) in 2023, in providing more precise and equitable premium rates, as this approach encourages proactive risk mitigation and ensures fairness for policyholders. At the same time, we urge Congress to address affordability concerns, particularly in flood-prone areas, by supporting measures that offer discounted NFIP premiums for lower-income households.
Additionally, SmarterSafer supports FEMA’s Federal Flood Risk Management Standard (FFRMS) as well as the recently finalized Department of Housing and Urban Development (HUD) rule for FFRMS, which expands the “floodplain of concern” both vertically and horizontally into a defined “FFRMS floodplain” and sets standards to determine the FFRMS floodplain, along with alternative approaches based on the best available data and information.
Furthermore, transparency in flood risk is another critical issue. Prospective homeowners and renters must have access to accurate and comprehensive flood risk data when making real estate decisions. Improved disclosure requirements will allow individuals to better understand their exposure and take appropriate precautions.
SmarterSafer remains committed to promoting policies that enhance pre-disaster mitigation and resilience while reducing the financial burdens on taxpayers. We have outlined several key legislative recommendations to achieve these goals, including but not limited to:
- Promoting Mitigation Measures – Mitigation is the best long-term defense against flooding. An NFIP reauthorization package and others should include language that authorizes the necessary funding to improve mitigation measures in areas susceptible to flooding and should place a particular emphasis on green, nature-based, and resilient infrastructure.
- Prioritizing Flood-Prone Communities – Congress should prioritize aid to flood-prone communities by passing legislation that authorizes FEMA to mandate the updating of flood data, allocate grants for infrastructure projects aimed at flood mitigation, and provide technical assistance to ensure continued progress in reducing communities’ flood risk. These actions would help lessen both the severity and financial impact of floods while facilitating quicker recovery for affected communities.
- Updating Mapping – Any NFIP reauthorization package should include measures that allocate funds to assist with updating floodplain mapping in areas susceptible to flooding. Legislation that accelerates the generation of new and modern maps, including through the use of best-available technology, will help communities better identify and communicate present and future risks. Communities impacted by flooding must be better informed of accurate levels of risk in order to plan for future disasters.
- Encouraging Private Sector Involvement – Congress should focus on encouraging private sector involvement in flood insurance and prevention by including measures in any NFIP reauthorization package that promotes private investment. This would allow for greater flexibility in coverage options, such as permitting private flood insurance to meet continuous coverage requirements and help strengthen overall flood resilience.
- Improving Resiliency Measures – Congress should focus on ensuring that federally-funded projects account for future flood risks by incorporating resilient design and mitigation measures in their planning. Any NFIP reauthorization package should include requirements for the use of regularly updated data and mapping to accurately assess flood risks for federally-funded projects while also recognizing communities that have made investments in resilient infrastructure and flood mitigation.
- Disclosing Past Flood Damage – Congress should work to pass legislation that requires disclosure of past flood damages and ongoing flood risks to home buyers and renters to ensure that residents can make an informed decision about a prospective home and adequately protect themselves from future flood risks.
- Promoting Mitigation Measures – Congress should work to pass legislation that expands flood mitigation support and access to buyouts available to NFIP policyholders through the Increased Cost of Compliance (ICC) coverage, especially for properties subject to repeat flooding.
We appreciate your dedication to NFIP reform and your ongoing bipartisan leadership on this issue. SmarterSafer stands ready to collaborate and provide insights as you work to strengthen the program for future generations.
Respectfully,
SmarterSafer Coalition
SmarterSafer is a national coalition made up of a diverse chorus of voices united in favor of environmentally responsible, fiscally sound approaches to natural catastrophe policy that promote public safety. SmarterSafer members include taxpayer advocates, environmental groups, insurance interests, housing organizations, and mitigation advocates.
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