Comment Letters Needed for HUD’s Floodplain Management Proposal

Filed in Codes and Standards, Environment, Housing Finance by on December 15, 2016 0 Comments

In response to President Obama’s Executive Order 13690 and the Federal Flood Risk Management Standard (FFRMS), HUD recently proposed a new rule that expands its floodplain management requirements and fundamentally threatens access to FHA mortgage insurance programs for single-family home buyers and multifamily builders.

NAHB is urging members and HBAs to voice your concerns by submitting a comment letter to HUD by Dec. 27. We’ve created a letter template (member log-in required) that you can edit and customize on behalf of your business or your HBA.

NAHB Concerns with the Floodplain Management Proposal

  • According to the proposal, single-family homes using FHA mortgage insurance would have to be elevated an additional two feet when they are built or substantially improved within the 100-year floodplain.
  • Multifamily builders would face the added burden of the new two-foot elevation requirement when using FHA mortgage insurance for new construction or substantial rehabilitation projects both within the 100-year floodplain and in a horizontally expanded FFRMS floodplain area for which maps do not exist.
  • HUD’s new flood risk measures would also apply additional elevation and flood-proofing requirements to projects that use federal grants, such as the HOME Investment Partnerships and Community Development Block Grant programs.
  • HUD’s flawed proposal will increase construction costs and project delays for both single-family and multifamily projects. And, it is inconsistent with FEMA regulations under the National Flood Insurance Program and lacks a grandfathering provision for projects already in the pipeline.

Comment letters must be submitted online by Dec. 27.

Please note that items highlighted in yellow must be edited before your letter is submitted.

If you have any questions, please contact NAHB Environmental Policy Program Manager Owen McDonough at 800-386-5242 x8662 or NAHB Director of Multifamily Finance Michelle Kitchen at 800-386-5242 x8352.

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