Comment Letter to HUD on Retaining the Federal Flood Risk Management Standard
Insurance for Good and the Coalition for Sustainable Flood Insurance (CSFI), organized by Greater New Orleans, Inc., jointly submitted comments to the U.S. Department of Housing and Urban Development on its proposal to rescind the Federal Flood Risk Management Standard (Docket No. FR-6527-P-01). View the public comment on Regulations.gov or read it below. The letter is also available as a PDF for download.
September 8, 2026
Dear Secretary Turner,
Since 2013, Greater New Orleans, Inc. (GNO, Inc.) has organized the Coalition for Sustainable Flood Insurance (CSFI), a national group of over 900 active contacts across over 35 states. CSFI brings together policymakers and policyholders alongside insurance agents, real estate agents, bankers, lenders, homebuilders, property developers, economic developers and many other interest groups towards the reauthorization and reform of the National Flood Insurance Program (NFIP).
Insurance for Good (I4G), founded in 2024, is a non-profit organization supporting communities and policymakers with evidence-based insurance solutions that align with their broader social, economic, and environmental goals. I4G curates trusted resources, provides tailored education and capacity building, supports innovation and solutions development, and undertakes research and analysis to improve policy and regulation.
CSFI and I4G are writing to jointly urge HUD to withdraw this proposed rule and retain the Federal Flood Risk Management Standard (FFRMS) adopted in April 2024, or otherwise revise the proposed rule to mitigate flood risk exposure and systemic consequences for risk transfer. Retaining the 2024 flood standard will lower risk and thus support the longer-term insurability of communities. Rescinding it would undermine this goal as well as undermine federal fiscal responsibility, as reconstructing with federal dollars in ways that do not account for growing flood risk will mean future disaster costs for the public sector and for individual Americans. While we are sensitive to the potential additional costs for construction and disaster recovery of the previous rule, homes are not affordable if you cannot afford to insure them and if future disaster losses are greater.
The proposed rule states that “construction costs resulting from the 2024 final rule would likely result in several negative outcomes, such as these costs being passed on to individual potential homebuyers.” We must, therefore, also consider insurance costs for those potential homebuyers. It is important to note that, under Risk Rating 2.0, CSFI’s analysis of FEMA data shows that on average an NFIP policy for a single-family home will cost $1,808, which represents a 103.6% increase over legacy rates [1]. As flood risks continue to rise around the country, rates will need to also increase to keep pace, unless we build in ways that lower flood damages.
Although much of the concern about flood insurance affordability has been from Louisiana, Louisiana is far from the most affected state. In terms of full-risk rates, there are 17 states with higher average rates than Louisiana. Achieving full-risk rates will increase premiums by over 50% in 41 states. Homeowners in Hawaii, West Virginia, and Connecticut will pay $3,000 or more, on average, for their flood insurance to reach full risk rates. As premiums rise, NFIP participation has fallen accordingly. NFIP peaked at roughly 5.7 million policies in 2009 and has since fallen to 4,498,470 as of June 2026 [2]. Twenty-seven states have lost more than 10% of their policies in force, just since Risk Rating 2.0 took effect [3]. While some policyholders have found lower cost coverage in the private market, this nonetheless represents a growing disaster insurance gap that will strain flood recovery. Our organizations thus also support the establishment of a federal means-tested affordability program to make flood insurance more attainable for average American homeowners.
While premium assistance would be desirable, the durable and cost-effective solution is to invest in risk reduction that can result in lower insurance premiums, as well as reduced losses. Elevation of structures is a key loss reduction measure and undertaken during construction costs a fraction of doing so later [4]. Not only does elevation result in significant savings on NFIP premiums, it reduces uninsured losses since homes built to weaker standards sustain more damage during disasters, and lose assessed value after flood events [5]. This can also harm the municipal tax bases that fund local recovery [6]. Retaining the 2024 standard protects HUD’s own portfolio, the borrowers HUD insures, and the local revenue that keeps assisted housing viable.
The FFRMS had created a new regulatory floodplain that could be the 500-year standard, a floodplain based on science, or which adds freeboard. Rescinding this standard would return the regulatory floodplain of concern to the 1 percent annual chance floodplain. That boundary describes the Special Flood Hazard Area on FEMA flood on maps, which are frequently out of date, do not include pluvial flooding, and which is, especially in areas of increasing risk, a poor proxy for risk over the term of a federally backed loan. The Congressional Budget Office estimates that expected annual flood damage to homes with federally backed mortgages will rise from $9.4 billion to $12.8 billion between the 2020 and 2050 periods, with total expected 30-year damage rising from $190 billion to $258 billion [7]. 40% to 50% of that damage occurs outside designated special flood hazard areas, where flood insurance is not required [8]. NOAA’s interagency sea level rise assessment projects 10 to 12 inches of rise along the U.S. coastline by 2050, with damaging high-tide flooding occurring more than ten times as often as it does today [9]. A standard calibrated to today’s 1 percent floodplain underwrites FHA borrowers into homes whose risk and whose premiums will grow across the life of the mortgage.
When defining the FFRMS floodplain, our organizations also support Congressional support for updating and improving FEMA flood maps. The National Flood Insurance Reform Act of 1994 requires that FEMA assess the need to revise and update all flood maps every five years. According to First Street, 75% of FEMA flood maps are older than five years and 11% date back to the 1970s and 1980s [10]. A 2017 report from the Department of Homeland Security’s Office of Inspector General, “FEMA Needs to Improve Management of Its Flood Mapping Programs,” found that as of December 2016 only 42% of the total flood map miles in FEMA’s inventory were updated and valid [11]. These facts imply that HUD’s use of Flood Insurance Rate Maps (FIRMs) and Flood Insurance Studies (FISs) as floodplain data sources will preclude success in HUD’s mission. It is likely that these outdated, invalid maps underestimate current flood risk.
According to the Association of State Floodplain Managers (ASFPM)’s 2020 report on “Flood Mapping for the Nation,” since 1969 the U.S. has invested $6.6 billion ($10.6 billion in 2019 dollars) in flood hazard mapping, resulting in nearly $22 billion in losses avoided [12]. However, only about one-third of the nation’s streams have been mapped. ASFPM estimates the cost to complete flood mapping in the U.S. at $3.2 billion to $11.8 billion in total, or $107 million to $480 million annually [13]. Ultimately, floodplain mapping is a sound investment that saves lives, reduces flood losses, and keeps communities thriving, all at a 2-to-1 cost benefit for taxpayers.
We appreciate the proposed rule’s consideration of cost savings: “expected annual construction cost savings of $4.5 million to $85 million.” However, this estimate is misleading if it does not also account for future costs due to changes in flood damages and higher insurance premiums. Both insured and uninsured flood damages are critical to include in any cost benefit analysis, and both have an impact on federal expenditures. The HUD Inspector General estimates that HUD allocates an average of roughly $5 billion per year for post-disaster recovery, totaling $109.8 billion since 2001 [14]. Moreover, the NFIP is already saddled by $22.525 billion of debt, costing the program about $619 million annually in debt service payments to the U.S. Treasury [15]. Without accounting for changes in these expenditures caused by the proposed rule, we do not believe that cost savings are complete.
The 21st Century ROAD to Housing Act, enacted July 11, 2026, directs substantial federal effort toward expanding housing supply through newly authorized and reformed HUD programs. HUD’s imminent investment is best protected by ensuring the units it produces remain insurable and habitable for their full useful life. Units that cannot be affordably insured do not durably expand supply of affordable housing for Americans.
CSFI and I4G respectfully request that HUD withdraw the proposed rule and retain the April 23, 2024 final rule, or make revisions to the pending proposal to better consider insurability effects. Again, we reiterate the importance of risk mitigation in preserving insurability, as well as preserving the fiscal health of the suite of federal disaster programs. We would welcome the opportunity to serve as a resource to the Department on the insurance and affordability implications of federal flood standards, and we thank you for your consideration.
Respectfully submitted,
Peter Waggonner
Vice President of Policy & Sustainability
Coalition for Sustainable Flood Insurance, Greater New Orleans, Inc.
Helen Wiley
Director of Programs
Insurance for Good
Endnotes:
[1] FEMA, “Cost of Flood Insurance for Single-Family Homes under NFIP’s Pricing Approach” (October 23, 2025).
[2] Coalition for Sustainable Flood Insurance, "CSFI Analysis – NFIP Participation” (September 8, 2026).
[3] Coalition for Sustainable Flood Insurance, "CSFI Analysis – NFIP Participation” (September 8, 2026).
[4] Gnan, E., et al. “Economically optimizing elevation of new, single-family residences for flood mitigation via life-cycle benefit-cost analysis,” Frontiers in Environmental Science 10:889239 (2022).
[5] Federal Emergency Management Agency, Building Science Branch. (2020). Building codes save: A nationwide study — Losses avoided as a result of adopting hazard-resistant building codes. U.S. Department of Homeland Security.
[6] Gourevitch, J. D., Kousky, C., Liao, Y., Nolte, C., Pollack, A. B., Porter, J. R., & Weill, J. A. (2023). Unpriced climate risk and the potential consequences of overvaluation in US housing markets. Nature Climate Change, 13(3), 250–257.
[7] Congressional Budget Office, “Flood Damage and Federally Backed Mortgages in a Changing Climate” (November 13, 2023).
[8] Congressional Budget Office, “Flood Damage and Federally Backed Mortgages in a Changing Climate” (November 13, 2023).
[9] Sweet, W.V., et al., “2022 Sea Level Rise Technical Report,” NOAA and interagency Sea Level Rise and Coastal Flood Hazard Scenarios and Tools Task Force (February 2022).
[10] First Street, “Understanding FEMA Flood Maps and Limitations” (March 19, 2019).
[11] U.S. Department of Homeland Security Office of the Isnpector General, “FEMA Needs to Improve Management of Its Flood Mapping Programs” (September 27, 2017).
[12] Association of State Floodplain Managers, “Flood Mapping for the Nation” (March 9, 2020).
[13] Association of State Floodplain Managers, “Flood Mapping for the Nation” (March 9, 2020).
[14] U.S. Department of Housing and Urban Development Office of the Inspector General, “Disaster Recovery Division Biannual Report” (April 11, 2026).
[15] Congressional Research Service, “National Flood Insurance Program Borrowing Authority” (March 10, 2026).