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HUD FFRMS Rule: Floodplain Management and Protection of Wetlands

Author: Joe Rossi, ANFI, CFM

In an era of increasing climate change impacts and more frequent extreme weather events, the protection of floodplains has become paramount to ensuring the safety and sustainability of communities across the country. The U.S. Department of Housing and Urban Development (HUD) has recently proposed a groundbreaking rule known as the Floodplain Management and Protection of Wetlands - Minimum Property Standards for Flood Hazard (HUD FFRMS) to address these critical issues and align their standards with executive orders in the past that establish the Federal Flood Risk Management Standard (FFRMS). The rule strengthens floodplain management standards by requiring higher elevations for new or substantially improved multifamily structures. To do this, it expands the floodplain for building elevation requirements and strongly suggests flood insurance in non-regulated areas. However, it has also brought concern from stakeholders about the cost to affordable housing to comply with the proposed requirements along with other concerns.

The HUD FFRMS rule aims to modernize and strengthen the existing floodplain management standards to better align with current flood risk assessments. To do this, HUD, in the proposed rule, suggests that they will expand the floodplain by requiring developers to follow three approaches to determine if a project must comply with new HUD elevation standards:

  1. Climate Informed Science Approach (CISA), which uses yet to be determined mapping tools and/or maps to determine the floodplain based on climate science.

  2. 0.2 Percent-Annual-Chance Flood Approach (500-year Floodplain Approach): For non-critical HUD actions, where CISA maps or other types of CISA analysis are not available, but FEMA has defined the 0.2-percent-annual-chance floodplain, the FFRMS floodplain would be defined as those areas that FEMA has designated as within the 0.2-percent-annual-chance floodplain.

  3. Freeboard Value Approach (FVA): If neither CISA nor FEMA-mapped 0.2-percent-annual-chance floodplain data is available, for HUD non-critical actions, the FFRMS floodplain would be defined as those areas that result from adding an additional two feet to the base flood elevation as established by the effective FEMA FIRM or FIS.

Should a structure fall into the new floodplain as defined above, HUD would require the structure to be elevated at or above the newly determined flood elevation or the FEMA BFE, whichever is higher. Additionally, the structure would have to comply with existing building codes and regulations which may have even high standards.

The main goals of the HUD FFRMS standard are to reduce flooding to structures and reduce flood insurance costs. Currently, the rule “strongly suggests” flood insurance be purchased in non-regulated areas but does not go as far as to require it in the FFRMS that is not regulated by the Special Flood Hazard Area (SFHA).

There are concerns from stakeholders around the rules affordability and multifamily vulnerability. In one comment letter, it is noted, “Raising FHA’s standard by two feet would conflict with 46 state freeboard decisions, discourage some code improvements or mitigation investments, and create a particular hardship for homeowners who recently retrofitted to a lower standard”

Some commenters don’t think the FFRMS rule goes far enough with one comment saying, “New construction that would be impacted by flooding and require funds for rehabilitation and repair – likely more than once – should be avoided”

The HUD FFRMS proposed rule signifies a significant step forward in enhancing floodplain management to safeguard communities from the devastating impacts of flooding. By updating standards, HUD aims to build a more resilient and sustainable future for the nation. However, achieving these goals will require collaboration, flexibility, and continued innovation to address the challenges posed by climate change, affordability, and its effects on flood hazards. As the rule advances, stakeholders must work together to strike a balance between development and environmental conservation to ensure the well-being of present and future generations.

About the Author: Joe is the Chair of the MA Coastal Coalition

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