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Understanding the New HUD Federal Flood Risk Management Standard (FFRMS) Rule: Key Considerations for Building Officials
In April 2024, the Department of Housing and Urban Development (HUD) finalized a rule aimed at strengthening floodplain management and the protection of wetlands across the United States. This new rule, which implements the Federal Flood Risk Management Standard (FFRMS), introduces critical changes that will impact how building officials, developers, and property owners approach construction and flood risk management, especially in areas prone to flooding.This article highlights three essential aspects of the HUD FFRMS rule that building officials need to understand and prepare for:
1.
The HUD rule introduces a preference for using the Climate Informed Science Approach (CISA) to define the floodplain for HUD-funded projects. CISA relies on the latest hydrologic and hydraulic data to determine flood risks, offering a more accurate and forward-looking perspective compared to the traditional Flood Insurance Rate Maps (FIRMs). This approach is particularly valuable in areas where climate change has altered historical flood patterns, making older maps less reliable.While CISA is preferred, it is not yet mandated for all projects. In cases where CISA data is not available, HUD provides alternatives, such as the Freeboard Value Approach (FVA), which adds an additional safety margin above the 100-year flood elevation, or using the 500-year flood elevation as a baseline. These alternatives ensure that projects remain resilient to flood risks even without CISA data.
Building officials should familiarize themselves with the Federal Flood Standard Support Tool (FFSST), which aids in determining the appropriate floodplain using CISA, FVA, or the 500-year floodplain. Additionally, as CISA data becomes more widely available, it will be important for local governments to integrate this data into their floodplain management practices.
2.
A significant update in the HUD rule is the revision of the Minimum Property Standards (MPS) related to flood hazard exposure. Starting January 1, 2025, new construction in Special Flood Hazard Areas (SFHAs) must have the lowest floor elevated at least two feet above the base flood elevation (BFE). This requirement applies to one- to four-unit mortgaged properties insured by the Federal Housing Administration (FHA).This 2-foot freeboard requirement is an important resilience measure that aims to protect new homes from rising floodwaters, reducing the risk of damage and loss. Building officials in communities that do not already have a similar freeboard requirement should consider updating their local codes to align with this new standard. Failure to do so could potentially limit access to FHA financing for new homebuyers in these areas.
Given the widespread use of FHA loans, which are a major source of financing for first-time homebuyers, ensuring compliance with this standard is crucial for maintaining the financial accessibility of housing in flood-prone areas.
3.
The new HUD rule also introduces stronger requirements for notifying property owners, buyers, developers, and tenants about flood hazards. These notification requirements are designed to ensure that all parties involved in property transactions are fully informed about the risks associated with the property's location in a floodplain.Key components of these notification requirements include:
- Flood Insurance: Information about the requirement or option to obtain flood insurance.
- Floodplain Elevation and Infrastructure: Disclosure of the floodplain elevation, proximity to flood-related infrastructure (such as dams and levees), and evacuation routes.
- Historical Flood Claims: Information on previous flood insurance claims filed on the property.
- Lease Acknowledgements: For rental properties, new and renewal leases must include acknowledgments signed by residents, indicating they have been informed about the flood risks and the availability of flood insurance for personal property.
TBCF Summary
As flood risks continue to rise due to climate change and other factors, the implementation of HUD’s FFRMS rule is a crucial step towards enhancing flood resilience across the country. Building officials play a key role in ensuring that these new standards are integrated into local practices, helping to protect communities from the devastating impacts of floods.By understanding and applying the CISA methodology, enforcing the 2-foot freeboard requirement, and ensuring comprehensive flood hazard notifications, building officials can contribute to reducing flood-related losses and safeguarding the homes and lives of those in flood-prone areas.
For more detailed information, building officials should refer to the full text of HUD’s final rule and stay updated with the latest guidance from HUD on these new standards.
