Increased Cost of Compliance (ICC) Continued
By Doug Wagner, Division of Water
In March we discussed ICC coverage and an uncommon mitigation activity, a second-story conversion. Today we look at other allowable mitigation activities covered by ICC and some of the stumbling blocks.
ICC covers Floodproofing, Relocation, Elevation and Demolition, commonly referred to by the acronym FRED.
Floodproofing is only allowed for nonresidential structures and means “dry” floodproofing. When floodproofing structures, you must ensure the measures are operable without an outside source of electricity and/or human intervention. The property owner must submit a floodproofing certificate that is signed and sealed by a design professional in the state the property is located, once the mitigation measure(s) is/are completed. When floodproofing is done occasionally, the local administrator may fail to request the certificate once mitigation is complete. The local administrator may also fail to properly review the certificate to see that it is complete and correct. Sometimes, this may be a lack of expertise on the certificate and may require the use of outside resources such as a town, city, county engineer, or other outside consultant.
Relocation is when a structure is elevated on structural members, placed on wheels, then moved outside of the flood hazard area to an area where the risk of flooding is greatly reduced or even eliminated. One pitfall with relocation may be the cost, depending on how far the structure may need to be moved, type of structure or other factors. You should always consider the route to the new location, distance to be traveled, other obstacles that may be present, and overall aesthetics of the new site when relocating a structure. Although this is an option, many times it may be cost prohibitive for the property owner.
Elevation is simply raising a structure upward then supporting it on posts, piers, columns, or extended foundation walls and is probably the most common in Indiana. This process is easily completed for existing structures that are on a crawlspace or basement but should be completed by reputable contractors with prior experience in elevating or moving structures. For slab construction, this process is a bit more involved but can be done assuming that only the walls and roof are elevated.
The most common pitfall when elevating existing structures is omitting the fill that must be placed in the existing basement or crawlspace, so the interior grade is at or above the exterior grade on at least one side of the structure. When elevating structures, local officials are encouraged to have the property owner execute a non-conversion agreement so the newly created enclosure is not converted back to habitable space in the future.
Remember, when elevating structures with an enclosure, they can only be used for parking of vehicles, building access, and limited storage. Any equipment servicing the structure or utilities must also meet the elevation requirements (for CRS communities) or be made of flood-resistant materials. One should also consider the cost, structural capacities of existing footings, future damage potential, and overall aesthetics of the completed site. Elevating a structure also requires that an elevation certificate (EC) be completed on the completed construction where the lowest floor, foundation type, presence of flood opening/vents, if required, are recorded. The EC can then be used to determine compliance to the local ordinance and an accurate flood insurance premium rate.
The final option, and generally the least desirable, is demolition, depending on the structure’s sentimental and fair market value; however, this is a common method used for some mitigation projects where a community may want to relieve their citizens from the effects and damages caused by flooding. It adds some complexity to the process, but a property owner may be able to assign their ICC funds over to the community for these types of projects as part of the community match. Demolition projects completed using other hazard mitigation funds that require a community match generally are required to remain as open greenspace and are unable to be redeveloped. With ICC, the property owner may wish to use a portion of the funds for demolition of the existing structure and another portion to extend a new foundation to the flood protection grade (FPG). This is an attractive option for older structures of low value or structures that have been repetitively flooded.
When choosing to embark on an ICC-covered project, there can be many hurdles to cross. The community should encourage property owners to refer to Increased Cost of Compliance Coverage (FEMA 301), the Flood Insurance Manual, other FEMA publications or even a design professional to help guide them through the obstacles they may encounter. It is easier to cross the hurdles during the planning process than after the project is completed and presumed compliant.
Risk Rating 2.0
By Doug Wagner, Division of Water
What is Risk Rating 2.0? It is the transformation of the National Flood Insurance Program (NFIP) to a new rating and pricing methodology. This new methodology more closely follows insurance industry best practices and standards, and uses cutting-edge technology. This will enable FEMA to provide rates that are actuarily sound, equitable, and easier to understand, and that better reflect a property’s flood risk.
Some important dates with the new program are Oct. 1, 2021 and April 1, 2022. Beginning Oct. 1, new policies will be rated using this methodology. Existing policy holders will have the option to continue with their existing rating or take advantage of the methodology that may offer them an immediate decrease in their premium. After April 1, 2022 all policies will be subject to the new rating methodology.
This new system does not remove the statutory limit on annual rate increases of flood insurance policies. Currently, most policy types cannot have an annual premium increase of more than 18%.
For more details, such as what to expect on rates increasing or decreasing by state, what is changing, and what is not changing, visit FEMA’s website: https://www.fema.gov/flood-insurance/work-with-nfip/risk-rating
Other questions regarding the new program and methodology can be directed to FEMA here: FEMA-RR2.0-Support@fema.dhs.gov
Keep in mind there is a 30-day waiting period on all new flood insurance policies. Don’t wait until the flood event has begun to purchase flood insurance. There are a few exceptions to the 30-day waiting period. Flood insurance is the best tool available to protect and help a property owner recover more readily and completely in the event of a flood.
Swimming Pools in the Floodplain
By Doug Wagner, Division of Water
Many homeowners enjoy the convenience and relaxation of having a swimming pool in their yard. Remember that when the location of a proposed swimming pool is in a Special Flood Hazard Area (SFHA), permitting and construction may be challenging. If being constructed in communities that participate in the National Flood Insurance Program (NFIP), pools require an SFHA development permit regardless of other permits that may or may not be required.
There are different requirements for pools in the SFHA than for buildings or structures; however, some general requirements apply to all. First, you will need to evaluate each application on an individual basis and ask several questions. Is the location in the fringe or the floodway? Is there a separate structure where equipment will be housed? Is the pool inside a building? Where is any equipment located? Where will any chemicals be stored? Is there a fence or deck surrounding the pool? Is the pool above-ground or in-ground type? Is the pool portable or permanent?
If the proposed pool will be located in the floodway, any fill, excavation, or placement would require a permit from the DNR Division of Water. If the pool is to be placed in the fringe, only a local permit would be required; however, you must be aware of the local ordinance requirements such as elevation of equipment or utilities and compensatory storage.
Requirements will also vary depending on whether the pool is inside a building or outside, with the equipment in a separate structure. If the pool is inside an existing pre-FIRM residential structure, the local permitting office will need to determine if the project is a substantial improvement. If the improvement is a substantial improvement, then the building protection requirements of the floodplain ordinance will apply.
If the pool is being added to an existing post-FIRM residential structure, the elevation of the pool cannot make a compliant structure non-compliant with your SFHA ordinance. Keep in mind that an in-ground pool floor would be considered the lowest floor of the structure (provided it is located on the lowest level of the building)
If the pool is to be part of new construction of a building or a substantial improvement to a building, an elevation certificate (EC) will be required to verify compliance. If the pool is outdoors, no EC is necessary. For nonresidential structures, the owner would also have the option to dry-floodproof the structure to achieve compliance as long as there is a floodproofing certificate completed by a design professional. If the equipment or other service utilities for the pool are outdoors, you will need to ensure that they are flood-damage resistant or elevated to the flood-protection grade.
Next, you will want to see where the pool chemicals will be stored so there is no contamination or disbursement of them in the event of a flood. Chemicals for pools are best stored in an area outside of the SFHA.
Finally, you will look at any decks or fences associated with the pool. Fences are required by building code for in-ground pools located outside a building but not for above-ground pools. For above-ground pools, building codes require a removable ladder to limit access. Having a deck next to the pool may require a lockable gate to prevent unwanted access.
It is generally a good idea to use multiple permits for the installation of pools. Since the regulations vary among the various components, you can issue one permit for the structure that houses the equipment and another for the pool, for example. This will make the requirements of each component easier to understand and follow for the permit applicant.
Swimming Pools in the Floodplain, A Code Inspector’s Perspective
By Craig W Wagner, Chief Building Inspector, Columbia City/Whitley County Planning and Building Department
Swimming pool installations in Indiana are regulated by the Indiana Swimming Pool Code (InSPC), 675 IAC Article 20 for Class 1 pools (commercial) and are considered as primary structures along with their associated dressing, restroom, shower, maintenance, and water feature structures that must meet the appropriate pool, building, plumbing, mechanical and electrical codes. Residential (Class 2) pool requirements are in Section R326 of the Indiana Residential Code (InRC), 675 IAC 14, except for the associated electrical installations that must follow the Indiana Electrical Code, IAC 675 17, Article 680. These documents regulate the actual construction of the pool structures but do not address the issues that arise when the pools are installed in flood-prone areas. Information on placing pools in flood-prone areas generally comes from the DNR Division of Water or from the Local Floodplain Administrator (LFA) or, in the case of a Class 2 residential pool, the InRC. The InRC lists ASCE 24 as an alternative document for design of pool installations in flood-prone areas, but the InSPC does not, so check with the Plan Review Division of the Fire Protection and Building Safety Commission for approval to use that document for the design of Class 1 pools.
Pools constructed in a floodway must first receive approval from the DNR before an LFA can issue construction permits. Pools constructed in the flood fringe are reviewed and are issued permits by the LFA according to the DNR guidelines and local ordinance requirements.
In the floodway, pools must be constructed in such a way to resist assumed flood pressures and water effects on the pool structure. Fences and other associated features installed around pools in a floodway must be anchored to resist flood water pressure or be designed to break away from structures (if attached) to minimize damage to the structure. Concrete slabs must be designed and installed on solid materials in a way to minimize the effects of flood water scouring around and under the slab, which may cause failure. Slabs should be independent of any buildings so buildings are not damaged if severe scouring undermines the slab. If there is slab failure, replacement must be installed by qualified pool installation personnel to assure compliance with the equipotential bonding requirements (InEC Sec. 680.26) in pool deck areas.
Class 1 pools are required to be equipped with a hydrostatic relief valve [675 IAC 20-2-3, Sec. 3(a)] in the lowest area of the floor, so in case the pool is empty, and the water table below rises, the water pressure in the pool structure will equalize and reduce the chance of damage from flotation. This is not a specific requirement for residential pools, but the code generally states the structures must be constructed to resist flotation, (R322.1.2). Above-ground pools and associated decks must also be evaluated to determine if the pool or deck has sufficient strength to resist flood water pressure, since these types of pools are generally self-supporting and not designed to resist exterior forces and pressures. Decks constructed around above-ground pools may require additional anchoring if not sufficiently anchored in the ground in flood-prone areas.
Pools constructed inside buildings also require attention to design because the floor of the pool may be the lowest usable floor and elevation of that pool floor, [2 feet above the base flood elevation (BFE)] is required. Structures such as equipment buildings or supply storage buildings must follow the standard requirement for elevation 2 feet above the BFE and flood openings/vents may be required. Construction materials that may be submersed during flood events must be water resistant—this could include framing, flooring, and siding materials. Materials, supplies, chemicals, etc., that are subject to damage from water must be stored 2 feet above the BFE.
Electrical installations also need to be considered so panels, junction boxes, receptacles, pool heaters, switches, and similar electrical components of the pool installation that are not designed for installation below water are 2 feet above the BFE.
Building inspectors need to develop an open relationship with floodplain administrators to assure that the pools installed in their communities meet the requirements of not only the building and pool codes, but also the flood resistant requirements of Indiana and the local jurisdiction.
Upcoming Training Opportunities
(Information from FEMA, ASFPM, and other websites)
Association of State Floodplain Managers (ASFPM)
ASFPM has an online training program, and training is added regularly. See https://www.floods.org/training-knowledge-center/ for more information.
FEMA’s Emergency Management Institute (EMI)
In-person classes are resuming at EMI after most had been canceled or held virtually during the last year. EMI offers many courses through webinar training opportunities. For additional information on EMI classes and webinars, please visit EMI’s training calendar website at https://training.fema.gov/emicourses/schedules.aspx and its course catalog at https://www.firstrespondertraining.gov/frt/npccatalog/EMI.
Other Trainings and Conferences
Indiana Association for Floodplain and Stormwater Management (INAFSM) Conference: The INAFSM Conference scheduled for Sept. 15-17 at Old National Events Plaza in Evansville. INAFSM is currently accepting abstracts and award nominations for the event. The award nominations deadline is May 28, and the abstract submission deadline is May 31. This will be an excellent training opportunity for Floodplain Administrators and other local officials to expand their floodplain and stormwater knowledge bank. For further details on the event, go to https://www.inafsm.net/2021-annual-conference. To learn more about INAFSM or to become a member, go to their website https://www.inafsm.net/.
STATE TRAINING OPPORTUNITIES
NFIP and Floodplain Manager Basics
The DNR Division of Water will be discussing the National Flood Insurance Program (NFIP) and Floodplain Manager Basics during a three-hour webinar on Wednesday, May 19, at 9 a.m. ET. There is no fee for the webinar, and registration is not required. The webinar will cover the overall context of floodplain management, floodplain mapping, NFIP regulatory standards, regulatory administrative procedures, flood insurance, flood hazard mitigation, and natural and beneficial functions. For those who wish to take the CFM exam, this training is provided as an enhancement or refresher only—it is not intended to teach the exam. To attend the webinar, follow the meeting link below to join at the time of the presentation. There are no CEC credits offered for this workshop.
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CFM EXAM OFFERING – June 9, 2021
Are you ready to be Indiana’s next Certified Floodplain Manager (CFM)?
The DNR Division of Water will again proctor the CFM exam on Wednesday, June 9, at the Indiana Government Center South in Indianapolis (Conference Room 22) at 9 a.m. Attendance will be limited to the first 22 applicants.
To take the CFM exam, you must complete and submit the CFM Program Application Package to the Association of State Floodplain Managers (ASFPM). The forms are available on the ASFPM website, floods.org, under the Certification Program tab. The fee is $100 for ASFPM members and $480 for non-members.
You may submit your application for ASFPM membership at the same time you apply to take the exam. To be accepted to take the exam at this scheduled time, you must submit your completed application and pay the appropriate fee to ASFPM by May 25. No walk-ins will be allowed unless authorized by the ASFPM executive office. For further information about the exam, contact Doug Wagner at dwagner1@dnr.IN.gov.
Elevation Certificates and Letters of Map Change
The DNR Division of Water will be discussing the Elevation Certificate and Letters of Map Change during a two-hour webinar on Tuesday, June 15 & 22 at 2 p.m. ET; Wednesday, June 16 & Thursday, June 24 at 9 a.m. ET. This workshop will discuss the proper completion and review of the Elevation Certificate. We will also discuss the various Letter of Map Revision forms and when to use each of the forms. The workshop is open to all who wish to attend; however, surveyors and local floodplain administrators are strongly encouraged to attend. There is no fee for the webinar; however, registration is required to ensure you receive the materials. You can register for the workshop here: EC & LOMC Registration.
Other Upcoming Events and Training
For other upcoming events and training hosted by the DNR Division of Water, check out our new events and training page on our website. We will be posting training videos and other opportunities there as they are developed or scheduled.
Indiana Department of Homeland Security
Please visit the Indiana Department of Homeland Security’s training calendar for upcoming courses and trainings at https://oas.dhs.in.gov/hs/training/public/calendar.do
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THANK YOU
Thanks to those contributing to this issue: Kenneth Smith, Jon Eggen, Anita Nance, Darren Pearson, Craig Wagner, Marty Benson, Scott Roberts, Don Kaczorowski, and Ed Reynolds.
Editor – Doug Wagner
The work that provides the basis for this newsletter was supported by funding under a cooperative agreement with the Federal Emergency Management Agency. The author and publisher are solely responsible for the accuracy of the statements and interpretations contained in the publication. Such interpretations do not necessarily reflect the views of the federal government.
Waterlines is produced quarterly as a public service by the DNR Division of Water.
Waterlines is available on the web at dnr.IN.gov/water.
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