Builder

BUILDERONLINE.COM BUILDER 69

Her

man

Ferrar

A

lthough greater flood resilience in vulnerable areas

is a goal we can all support, a pending HUD proposal

is ill-advised, would drive up the cost of housing,

and could even prevent the construction of much

needed affordable housing. It also would disrupt the housing

market’s sensitive recovery.

HUD has proposed that new and substantially rehabilitated

FHA-financed multifamily housing located within an

expanded flood plain as defined by the new Federal Flood

Risk Management Standard (FFRMS) be elevated 2 feet

above the 10 0-year base flood elevation (the highest level

water would reach in a 10 0-year flood event). HUD is also

applying the same elevation requirement to new and sub-

stantially rehabilitated single-family homes within the cur-

rently defined flood plain through revisions to its minimum

property standards.

HUD issued the proposal in response to an executive order

establishing the FFRMS and exhorting federal agencies to take

actions to reduce the risk of flood loss and minimize the impact

of flooding on taxpayer-funded structures and facilities.

As expected, HUD is applying the new flood risk manage-

ment requirements to its HOME and Community Development

Block Grant programs, but, arguably, the FHA mortgage insur-

ance programs should be beyond the direct intent of the exec-

utive order, and there is no requirement for HUD to establish

such a measure for those activities. There are also numerous

flaws in its proposal, not the least of which is that the single-

family component is inconsistent with the requirements of

FEMA’s National Flood Insurance Program. In essence, HUD

is acting outside its area of expertise and second-guessing the

experts at FEMA who have the knowledge, funding, and tools

to best address flood risk.

Complicating the situation, existing flood maps will be

inadequate for the purpose of applying the new HUD stan-

dards to multifamily properties. And HUD’s suggestion to use

Google Earth to determine if a property is within the FFRMS

flood plain is ill-considered and will lead to inaccuracies,

delays, and increased project costs. Moreover, FEMA cautions

that map services like Google Earth “do not necessarily meet

its standards for base map accuracy.”

Elevating the housing affected by the HUD

proposal will increase construction costs and

may result in higher prices and rents or make

construction infeasible. As many of these prop-

erties are affordable housing, increasing hous-

ing costs for these homeowners and tenants is

surely a disservice. Historically, agencies such

as the Department of Veterans Affairs, USDA,

and GSEs Fannie Mae and Freddie Mac have

followed HUD’s lead in such matters. As such,

this misguided set of requirements could

quickly become the market standard.

The HUD proposal is bad policy and bad

governance. The agency’s time and effort

would be better spent identifying ways to im-

prove housing affordability and devising cost-

effective ways to ensure that the nation’s

housing is more flood resilient—that’s what

NAHB will tell HUD in its formal comments.

The comment period ends Dec. 27, and I

encourage members who will be affected by

this requirement to submit comments as well.

Help spread the word about great career

opportunities in residential construction

with six new trade-specific posters.

The free posters can be customized

with specific company or HBA information.

They also can be enlarged to be used

as banners at career fairs, educational

conferences, or community events.

BY ED BRADY

HOME INNOVATION RESEARCH LABS 70

DIETZ’S ECONOMY 72

CHAIRMAN’S LETTER /

HUD PROPOSAL IS BAD POLICY

NAHB does not support HUD’s flood plain proposal as written

Ed Brady

NAHB Chairman

of the Board

CAREER PATH

DOWNLOAD ONLINE

Access the construction career posters

and other resources in the Building a

Skilled Labor Workforce section online

at nahb.org/workforce.

NAHB NOTES

DECEMBER 2016