Resolution 238-20151
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MONROE COUNTY, FLORIDA
MONROE COUNTY BOARD OF COUNTY COMMISSIONERS
RESOLUTION NO. 238 - 2015
A RESOLUTION OF THE MONROE COUNTY BOARD OF
COUNTY COMMISSIONERS ADOPTING FEMA P -758,
SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE
DESK REFERENCE" DATED MAY 2010 AS REQUIRED
PURSUANT TO MONROE COUNTY CODE SECTION 122 -2(C)
WHEREAS, Monroe County is currently a participating community in the National
Flood Insurance Program (NFIP) and is working on internal County policies to improve upon its
interpretation of NFIP regulations; and
WHEREAS, Monroe County desires to become eligible to enter FEMA's Community
Rating System (CRS); and
WHEREAS, Monroe County Code Section 122 -2(c), in part, requires that in interpreting
other provisions of this chapter, the building official shall be guided by the current edition of
FEMA's 44 CFR, and FEMA's interpretive letters, policy statements and technical bulletins as
adopted by resolution from time to time by the board of county commissioners;
NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY
COMMISSIONERS OF MONROE COUNTY, FLORIDA:
Section 1. Pursuant to Monroe County Code Section 122 -2(c), the Board hereby adopts
FEMA P -758, "Substantial Improvement /Substantial Damage Desk Reference" dated May 2010,
a copy of which is attached hereto.
Section 2. The Clerk of the Board is hereby directed to forward one (1) certified copy of
this Resolution to the Building Department.
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PASSED AND ADOPTED by the Board of Countf ommissioners of Monroe County,
Florida, at a regular meeting held on the 16 of September, 2015.
Mayor Danny L. Kolhage
Yes
Mayor pro tem Heather Carruthers
Yes
Commissioner Sylvia Murphy
Yes
Commissioner George Neugent
Yes
Commissioner David Rice
Yes
BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNT
AC64'—
BY: 4
Mayor htdmyj Kolhage
MONROE COUNTY ATTORNEY
APPROVED A O FORM:
STEVEN T. WILLIAMS
ASSISTANT COUNTY ATTORNEY
Date
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Preface
When buildings undergo repair or improvement, it is an opportunity for local floodplain
management programs to reduce flood damage to existing structures. More than 21,000 com-
munities participate in the National Flood Insurance Program (NFIP), which is managed by
the Federal Emergency Management Agency (FEMA) . To participate in the NFIP, communities
must adopt and enforce regulations and codes that apply to new development in Special Flood
Hazard Areas (SFHAs). Local floodplain management regulations and codes contain minimum
NFIP requirements that apply not only to new structures, but also to existing structures which
are "substantially improved (SI) " or "substantially damaged (SD)."
Enforcing the SI /SD requirements is a very important part of a community's floodplain man-
agement responsibilities. There are many factors that local officials will need to consider and
several scenarios they may encounter while implementing the SI /SD requirements. This Desk
Reference provides practical guidance and suggested procedures to implement the NFIP re-
quirements for SI /SD.
This Desk Reference provides guidance on the minimum requirements of the NFIP regulations.
State or locally- adopted requirements that are more restrictive take precedence (often referred
to as "exceeding the NFIP minimums" or "higher standards ").
SI /SD DESK REFERENCE
Acknowledgments
FEMA would like to thank the following individuals who provided information, data, review,
and guidance in developing this publication.
John Ingargiola Michael Powell
FEMA Building Science Branch Delaware Department of Natural Resources
Lois Forster
FEMA Floodplain Management Branch
Jack Anderson
FEMA Regional and Disaster Support
Branch
Jhun de la Cruz
FEMA Underwriting Branch
Lilah Haxton
FEMA Grants Policy Branch
Mary Colvin
FEMA Region II
Alan Springett
FEMA Region II
Henry Chau
FEMA Region III
Joseph Zagone
FEMA Region III
Judy Marvel
FEMA Region IV
John Plisich
FEMA Region IV
Ross Richardson
FEMA Region VI
Roger Connell
FEMA Region VII
Mark Marik
Formerly FEMA Region IX
and Environmental Control
Lisa Jones
South Carolina Department of Natural
Resources
Ken Ford
Formerly National Association of Home
Builders, Inc.
Kim Paarlberg
International Code Council, Inc.
Tom McDonald
City of Savannah, GA
Tom Richards
City of Findlay, OH
Tim Condit
Pikes Peak Regional Building Department.
CO
Bob Croft
Pikes Peak Regional Building Department.
CO
Jeannine Lewis
Pikes Peak Regional Building Department.
CO
Tom Leatherbee
Del City, OK
Christopher P. Jones, P.E.
Consultant
Rebecca C. Quinn
RCQuinn Consulting, Inc.
SI /SD DESK REFERENCE iii
ACKNOWLEDGMENTS
Jimmy Yeung
Greenhorne & O'Mara, Inc.
Hilary Kendro
Greenhorne & O'Mara, Inc.
Deb Daly
Greenhorne & O'Mara, Inc.
Julie Liptak
Greenhorne & O'Mara, Inc.
IV SI /SD DESK REFERENCE
Table of Contents
Preface .......................................................................................................... ..............................i
Acknowledgments .............................................................................. ............................... iii
Chapter 1
1
Introduction ......................................................................................... ...............................
1 -1
1.1
Overview ................................................................................................ ............................1
-1
1.2
What is Covered in This Desk Reference? ............................................ ............................1
-2
1.3
Relevant Requirements .......................................................................... ............................1
-3
1.4
Answers to Questions About SI /SD ...................................................... ............................1
-3
1.5
Where to Get Help .............................................................................. ...............................
1 -4
Chapter 2
2
The NFIP: Roles and Responsibilities ..................................................................... ...............................
2 -1
2.1
Purposes and Overview of the NFIP .................................................. ...............................
2 -1
2.2
The Community's Role ....................................................................... ...............................
2 -2
2.3
The State's Role ...................................................................................... ............................2
-3
2.4
The Federal Role .................................................................................... ............................2
-4
Chapter 3
3 NFIP Substantial Improvement/Substantial Damage: Requirements and Definitions ............. 3 -1
3.1 Overview .............................................................................................. ............................... 3 -1
3.2 Introduction to the SI /SD Requirements ......................................... ............................... 3 -1
3.3 NFIP Regulations for SI/ SD .................................................................. ............................3 -2
3.4 Selected Definitions and Terms ............................................................ ............................3 -4
3.4.1 Definitions: NFIP Regulations .................................................. ............................3 -5
3.4.2 Comparison of Definitions and Terms: NFIP and I- Codes ....:. ............................3 -6
SI /SD DESK REFERENCE v
TABLE OF CONTENTS
Chapter 4
4 Making Substantial Improvement and Substantial Damage Determinations .......................... 4 -1
4.1 Overview .............................................................................................. ............................... 4-1
4.2 Accuracy and Verification ...................................................................... ............................4 -2
4.3 Making SI /SD Determinations ............................................................ ............................4 -2
4.3.1 SI /SD Provisions in the 2006 and 2009 I -Codes ..................... ............................4 -3
4.4 Determining Costs of Improvements and Costs to Repair .................. ............................4
-4
4.4.1
Costs That Must be Included in SI /SD Determinations .......... ............................4
-5
4.4.2
Costs That May be Excluded from SI /SD Determinations ..... ............................4
-7
4.4.3
Acceptable Sources of Cost Information ................................. ............................4
-7
4.4.4
Estimates of Donated or Discounted Materials ........................ ............................4
-8
4.4.5
Estimates of Owner and Volunteer Labor ................................ ............................4
-8
4.4.6
Demolition and Construction Debris Disposal ........................ ............................4
-9
4.4.7
Clean -up and Trash Removal ................................................... ............................4
-9
4.4.8
Costs to Correct Existing Health, Safety, and Sanitary Code Violations .............4
-9
4.5 Determining Market Value .............................................................. ............................... 4-11
4.5.1 Professional Property Appraisals .............................................. ...........................4 -13
4.5.2 Adjusted Assessed Value ........................................................... ...........................4 -14
4.5.3 Actual Cash Value ..................................................................... ...........................4 -15
4.5.4 Qualified Estimates .................................................................. ...........................4 -15
Chapter 5
5 Administering Substantial Improvement and Substantial Damage Requirements ................. 5 -1
5.1 Overview .............................................................................................. ............................... 5 -1
5.2 Community Responsibilities .............................................................. ............................... 5 -1
5.3 Property Owner /Applicant Responsibilities ........................................ ............................5 -2
5.4 Important Community Actions ............................................................ ............................5 -3
5.5 Informing the Public ............................................................................. ............................5 -4
5.5.1 Permit Application Forms ......................................................... ............................5 -4
5.5.2 Websites and Handouts ............................................................. ............................5 -4
5.6 Administering the SI /SD Requirements ........................................... ............................... 5 -5
v1 SI /SD DESK REFERENCE
TABLE OF CONTENTS
5.6.1
Combinations of Types of Work ............................................. ............................... 5 -5
5.6.2
Phased Improvements ............................................................... ............................5 -6
5.6.3
Incremental Repair of Damaged Buildings .............................. ............................5 -7
5.6.4
Damaged Buildings .................................................................... ............................5 -7
5.6.5
Special Circumstances (Damaged Buildings) .......................... ............................5 -8
5.6.6
Appeals of Decisions ................................................................. ............................5 -9
5.6.7
Variances to the Requirements ................................................ ............................5 -9
5.6.8
Floodways ................................................................................... ...........................5
-11
5.6.9
V Zones ...................................................................................... ...........................5
-12
5.6.10
Coastal Barrier Resource Areas ............................................ ...............................
5 -12
5.6.11
Revisions of the FIRM .............................................................. ...........................5
-13
5.6.12
Inspections ............................................................................. ...............................
5 -13
5.6.13
Enforcement and Violations .................................................... ...........................5
-14
5.6.14
Recordkeeping .......................................................................... ...........................5
-15
5.6.15
Issuing SI /SD Determination Letters ...................................... ...........................5
-16
5.6.16
Rescinding SI /SD Determinations .......................................... ...........................5
-16
5.7 Exceeding NFIP Minimum Requirements ...................................... ...............................
5 -17
5.7.1
Community Rating System ................................................... ...............................
5 -17
5.7.2
Lower Threshold for SI /SD ..................................................... ...........................5
-18
5.7.3 .
Cumulative SI /SD ..................................................................... ...........................5
-19
5.8 Recommendations to Improve Flood Resistance ............................... ...........................5 -20
Chapter 6
6 Factors to Consider and Illustrations of Substantial Improvement and Repair of
SubstantialDamage .............................................................................. ............................frl
6.1 Overview .............................................................................................. ............................... 6-1
6.2 Factors to Consider When Evaluating Permit Applications for Improvements
andRepairs ........................................................................................... ............................6 -1
6.2.1 Pre -FIRM or Post - FIRM .............................................................. ............................6 -1
6.2.2 A Zone or V Zone .................................................................. ............................... 6-2
6.2.3 More Than One Flood Zone ................................................ ............................... 6-3
6.2.4 Residential or Non - Residential ............................................. ............................... 6-3
6.3 Bringing Substantially Improved and Substantially Damaged Buildings into
Compliance........................................................................................ ............................... 6-3
SI /SD DESK REFERENCE vii
TABLE OF CONTENTS
6.3.1
Lowest Floor Elevations ............................................................. ............................6 -4
6.3.2
Enclosures ................................................................................... ............................6
-5
6.3.3
Basements ................................................................................... ............................6
-6
6.3.4
Utility and Building Service Equipment ................................... ............................6
-6
6.3.5
Flood Damage - Resistant Materials ......................................... ...............................
6-7
6.3.6
Making Buildings Reasonably Safe from Flooding .............. ...............................
6-7
6.4 Illustrations of Improvements and Repairs .......................................... ............................6
-8
6.4.1
Rehabilitation and Remodeling ............................................... ...........................6
-10
6.4.2
Lateral Additions ...................................................................... ...........................6
-12
6.4.3
Vertical Additions ..................................................................... ...........................6
-19
6.4.4
Repair, Reinforce, or Replace Foundations ....................... ...............................
6-21
6.4.5
Repair of Damaged Buildings .................................................. ...........................6
-22
6.4.6
Reconstruction of Demolished or Destroyed Buildings ......... ...........................6
-22
6.4.7
Work on Post -FIRM Buildings .................................................. ...........................6
-22
6.4.8
Work on Buildings Where Flood Maps Have Been Revised ... ...........................6
-22
6.5 Requirements for Certain Structures ................................................... ...........................6 -23
6.5.1 Historic Structures ..................................... ............................... ...........................6 -23
6.5.2 Manufactured Homes .............................................................. ...........................6 -24
6.5.3 Accessory Structures and Certain Agricultural Structures ..... ...........................6 -26
6.6 NFIP Flood Insurance Implications .................................................... ...........................6 -27
Chapter 7
7 Substantial Damage in the Disaster Recovery Environment .................. ............................... 7 -1
7.1 Overview .............................................................................................. ............................... 7 -1
7.2 Preparing for Post - Disaster Recovery ................................................. ............................... 7 -1
7.2.1 Sources of Assistance .............................................................. ............................... 7 -2
7.3 Assessing Building Damage ................................................................ ............................... 7 -3
7.3.1 Preliminary Damage Assessments .......................................... ............................... 7 -3
7.3.2 Rapid Evaluations and Detailed Safety Evaluations ................ ............................7 -3
7.4 Using Estimates of Repair Costs and Market Values to Screen for Substantial
Damage............................................................................................... ............................... 7-4
7.4.1 Insurance Estimates of Repair Costs ......................................... ............................7 -5
7.4.2 Unadjusted Assessed Values as Estimates of Market Values .... ............................7 -6
viii SI /SD DESK REFERENCE
TABLE OF CONTENTS
Chapter 8
8 Mitigation Projects ....................................................................................... ............................8 -1
8.1 Overview .............................................................................................. ............................... 8-1
8.2 Mitigation Planning ............................................................................ ...............................
7.4.3 Replacement Cost Values as Estimates of Market Values ........ ............................7 -6
7.5
Damage Assessments for Substantial Damage Determinations ...... ...............................
7 -6
8.3.1
7.5.1 FEMA's Substantial Damage Estimator Software .................. ...............................
7 -7
7.6
Increased Cost of Compliance Coverage .............................................. ............................7
-9
7.7
Post - Disaster Permits and Inspections ............................................. ...............................
7 -11
7.8
Appeals and Variances ...................................................................... ...............................
7 -11
7.9
Post - Disaster Communications with Property Owners ................... ...............................
7 -12
8.3.6
7.9.1 Information About Clean -up and Repairs ............................... ...........................7
-12
8.4 FEMA's Mitigation Grant Programs ...................................................... ............................8
7.9.2 Information About Permits .................................................. ...............................
7 -12
Elements Common to All Grant Programs .............................. ............................8
7.9.3 Information About Increased Cost of Compliance Coverage ...........................7
-13
Pre - Disaster Mitigation Program ............................................... ............................8
7.9.4 Interactions with the Public During Damage Assessments ..... ...........................7
-13
Hazard Mitigation Grant Program ........................................... ............................8
7.9.5 Providing Substantial Damage Determination Letters to Owners ....................7
-14
Chapter 8
8 Mitigation Projects ....................................................................................... ............................8 -1
8.1 Overview .............................................................................................. ............................... 8-1
8.2 Mitigation Planning ............................................................................ ...............................
8-1
8.3 Types
of Flood Mitigation Projects ....................................................... ............................8
-2
8.3.1
Identifying Flood Mitigation Projects ....................................... ............................8
-2
8.3.2
Property Acquisition/ Demolition and Relocation .................. ............................8
-3
8.3.3
Building Elevation ..................................................................... ............................8
-3
8.3.4
Relocation ................................................................................... ............................8
-4
8.3.5
Floodproofing for Non - Residential Structures or Historic Structures ..............8
-4
8.3.6
Other Types of Projects ............................................................. ............................8
-4
8.4 FEMA's Mitigation Grant Programs ...................................................... ............................8
-4
8.4.1
Elements Common to All Grant Programs .............................. ............................8
-5
8.4.2
Pre - Disaster Mitigation Program ............................................... ............................8
-5
8.4.3
Hazard Mitigation Grant Program ........................................... ............................8
-6
8.4.4
Flood Mitigation Assistance Program .................................... ...............................
8-7
8.4.5
Repetitive Flood Claims Program ............................................ ............................8-7
8.4.6
Severe Repetitive Loss Program ................................................ ............................8
-8
8.5 Additional Information ......................................................................... ............................8
-9
SI /SD DESK REFERENCE ix
TABLE OF CONTENTS
Appendices
A. FEMA Regional Offices, NFIP State Coordinating Agencies, and State Hazard Mitigation
Offices
B. References
C Glossary and Acronyms
D Sample Notices to Property Owners, Sample Affidavits, and Other Material
E Sample Letters of Determination
Tables
Chapter 1
Table 1 -1. Desk Reference Organization ......................................................... ............................1 -2
Chapter 3
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes . ............................3 -7
Chapter 5
Table 5 -1 a. Tracking Cumulative Substantial Improvements, Determining Market Value for Each
Permit Application (shows increases in market value) ................................... ...........................5 -20
Table 5 -lb. Tracking Cumulative Substantial Improvements, Determining Market Value for Each
Permit Application (shows decrease, then increase in market value) ........... ...........................5 -20
Chapter 6
Table 6-1a. Compliance Matrix (A Zones) ....................................................... ............................6 -9
Table 6-lb. Compliance Matrix (V Zones) ...................................................... ...........................6 -10
Table 6-2. Substantial Improvement and NFIP Flood Insurance Implications ........................6 -28
Figures
Chapter 4
Figure 4-1. Make the SI /SD determination (overview) ................................... ............................4 -3
Figure 4-2. Determine the cost of work (overview) ......................................... ............................4 -5
Figure 4-3. Determine the market value (overview) ....................................... ...........................4 -12
x SI /SD DESK REFERENCE
TABLE OF CONTENTS
Chapter 6
Figure 6-1. Rehabilitation or remodel (no increase in footprint) of residential building in
an A zone - the proposed work was determined to be a substantial improvement ............... 6-11
Figure 6-2. Rehabilitation or remodel (no increase in footprint) of non - residential building
in an A zone - the proposed work was determined to be a substantial improvement . .......... 6-12
Figure 6-3. Lateral addition to a pre -FIRM building in an A zone - the proposed work is only the
addition (no work was performed on the original building and no structural modification was
made to the common wall or roof) . ............................................................... ...........................6 -14
Figure 6-4. Lateral addition to a pre -FIRM building in an A zone - the proposed work includes
an addition and work on the original building, including structural modification of the com-
mon wall or roof. The proposed work was determined to be a substantial improvement ...... 6 -14
Figure 6-5. Lateral addition to a residential building in a V zone - the proposed work includes
work on the original building. The lateral addition and improvements constitute substantial im-
provement..................................................................................................... ............................... 6-15
Figure 6-6. Lateral addition to a pre -FIRM manufactured home in an A zone - the pro-
posed work includes improvements to the existing home. The work constitutes substantial
improvement................................................................................................. ............................... 6-16
Figure 6-7. Lateral addition to a non - residential building in an A zone - the proposed work is
only the addition (no work on the existing building and no structural modification of the com-
mon wall or roof). The work constitutes substantial improvement . ............ ...........................6 -17
Figure 6-8. Lateral addition to a post -FIRM building in any flood zone (map revision has
not changed the effective BFE). All improvements or repairs to a post -FIRM building must
comply with the NFIP requirements regardless of the value of that work . .............................. 6 -18
Figure 6-9. Lateral addition to a post -FIRM building in an A zone (a map revision has increased
the BFE). The proposed work is a lateral addition with no work in the original building and no
structural modification of the common wall or roof ..................................... ...........................6 -18
Figure 6-10. Vertical addition to a pre -FIRM residential building (in any zone) - the pro-
posed work is a new uppe r story that involves structural modification. The work is a substantial
improvement................................................................................................ ............................... 6-19
Figure 6-11. Vertical addition to a pre -FIRM residential building (in any zone) - the pro-
posed work is a new lower story that involves structural modification. The work constitutes a
ubstantialimprovement . ............................................................................................................. 6 -19
Figure 6-12. Vertical addition to a pre -FIRM, non - residential building in an A zone. The work
constitutes a substantial improvement . ...................................................................................... 6 -20
Figure 6-13. New foundation or repair of foundation under a pre -FIRM (in an A zone)
residential building. The work was determined to be a substantial improvement ................. 6-21
SI /SD DESK REFERENCE xi
TABLE OF CONTENTS
Figure 6-14. The cost of NFIP flood insurance policy varies depending on how a substantially
damaged building is repaired. This illustration is for $150,000 in structure coverage with the
rates as of October 2009. The figure is for comparison purposes only . ...... ...........................6 -29
Chapter 7
Figure 7 -1. SDE data displayed using mapping software ................................. ............................7 -9
xii SI /SD DESK REFERENCE
1 Introduction
1.1 Overview
When buildings undergo repair or improvement, it is an opportunity for floodplain manage-
ment programs to reduce flood damage to existing structures. More than 21,000 communities
participate in the National Flood Insurance Program (NFIP) by adopting and enforcing regu-
lations and codes that apply to development in Special Flood Hazard Areas (SFHAs). Local
floodplain management regulations and codes contain minimum NFIP requirements that are
not only for new structures, but also for existing structures with proposed "substantial improve-
ments" or repair of "substantial damage."
Local officials in communities that participate in the NFIP must determine whether proposed
work qualifies as a substantial improvement or repair of substantial damage (referred to as
an "SI /SD determination "). If work on buildings constitutes SI /SD, then structures must be
brought into compliance with NFIP requirements for new construction, including the require-
ment that lowest floors be elevated to or above the base flood elevation (BFE). Meeting this
requirement can also be accomplished by demolition followed by construction of new buildings
that meet the NFIP requirements on the same sites or by relocating buildings to locations out-
side of the SFHA. In some cases after a disaster, communities have worked with owners to buy
damaged homes in order to demolish the buildings and preserve the land as open space. The
NFIP defines SI /SD as follows:
■ Substantial improvement (SI) means any reconstruction, rehabilitation, addition, or other
improvement of a structure, the cost of which equals or exceeds 50 percent of the market value of the
structure (or smaller percentage if established by the community) before the "start of construction" of the
improvement. This term includes structures that have incurred "substantial damage, "regardless of the
actual repair work performed.
■ Substantial damage (SD) means damage of any origin sustained by a structure whereby the cost
of restoring the structure to its before- damaged condition would equal or exceed 50 percent of the
market value of the structure before the damage occurred. Work on structures that are determined to be
substantially damaged is considered to be substantial improvement, regardless of the actual repair work
performed.
The 50 percent threshold was chosen as a compromise between two extremes. One extreme
would be to prohibit all investment in existing structures that do not meet minimum NFIP
requirements. The other extreme would be to allow structures in flood hazard areas to be
improved in any fashion without regard to the flood risk. In the first alternative, there is the
potential for causing hardship to those who have located in flood hazard areas without knowl-
edge of the risk because the structure was constructed prior to the designation of the area as
flood - prone. These individuals would not be able to improve their structures as damage or age
contributed to deterioration. The second alternative provides no mechanism to ensure that
increased investment in flood hazard areas will receive needed protection from the flood risk,
SI /SD DESK REFERENCE 1 -1
INTRODUCTION
thus contributing to the increased peril to life and property. Thus, the threshold of 50 percent
is a compromise at a half -way point and was chosen because it conforms to similar building code
and zoning standards that also use this threshold.
This Desk Reference is designed for local officials who are responsible for the administration of
local codes and regulations, including the SI /SD requirements. It also is intended for State of-
ficials who provide technical assistance to communities on the NFIP.
1.2 What is Covered in This Desk Reference?
Enforcing the SI /SD requirements is a very important part of a community's floodplain man-
agement responsibilities. There are many factors that local officials will need to consider and
several scenarios they may encounter while implementing the SI /SD requirements. This Desk
Reference provides guidance and suggested procedures to implement the NFIP requirements
for SI /SD. Table 1 -1 summarizes the content of each chapter and lists the appendices.
Table 1 -1. Desk Reference Organization
Chapter
Description
1: Introduction
Provides an overview of the Desk Reference, other relevant
requirements, and suggestions for where to obtain additional help.
2: The NFIP: Roles and
Outlines the purposes of the NFIP, offers an overview of how the
Responsibilities
program's three components work together to support the long -term
reduction of flood losses, and explains the roles and responsibilities
of communities, State agencies, and the Federal Emergency
Management Agency (FEMA).
3: NFIP Substantial Improvement/
Provides an introduction to the NFIP's SI /SD requirements and lists
Substantial Damage:
selected definitions and terms (and compares them with those of the
Requirements and Definitions
building codes published by the International Code Council, Inc. [ICC]).
4: Making Substantial Improvement
Explains how costs of improvements, costs of repairs, and market
and Substantial Damage
values are used to make the SI /SD determination, and describes ways
Determinations
to obtain or to estimate costs and values.
5: Administering Substantial
Outlines community and property owner responsibilities and
Improvement and Substantial
provides detailed guidance for local officials who are responsible for
Damage Requirements
administering and enforcing the SI /SD requirements.
6: Factors to Consider and
Describes the key aspects of bringing buildings into compliance with
Illustrations of Substantial
all of the NFIP requirements and illustrates examples of improvements
Improvement and Repair of
and repairs.
Substantial Damage
7: Substantial Damage in the
Offers suggestions to prepare for disasters, an overview of the post -
Disaster Recovery Environment
disaster process, methods to estimate costs and market values after
major disasters, and describes FEMA's Substantial Damage Estimator.
8: Mitigation Projects
Describes the most common types of mitigation projects and briefly
summarizes FEMA's five mitigation grant programs.
1 -2 SI /SD DESK REFERENCE
INTRODUCTION 1
Table 1 -1. Desk Reference Organization (continued)
Appendices
Appendix A
Description of Content
FEMA Regional Offices, NFIP State Coordinating Agencies, and State
Hazard Mitigation Offices
Appendix B
References
Appendix C
Glossary and Acronyms
Appendix D
Sample Notice to Property Owners, Worksheet, and Other Material
Appendix E
Sample Letters of Determination
1.3 Relevant Requirements
This Desk Reference provides guidance on the minimum
requirements of the NFIP regulations. State or local-
ly- adopted requirements that are more restrictive take
precedence (often referred to as "exceeding the NFIP
minimums" or "higher standards ").
Many States and communities have adopted one or more I I
of the codes in the family of codes published by the Inter-
national Code Council, Inc. (I- Codes ® ) or use the I -Codes Communities that have a building
as the basis of their own codes. These codes contain code and floodplain management
provisions for buildings in flood hazard areas, includ- regulations must administer the
ing provisions related to substantial improvement and more restrictive provisions.
substantial damage. The pertinent codes are the Interna-
tional Building Cody'' (IBC ® ), International Residential Cody`'
(IRC °), and International Existing Building Cody"' (IEBC ® ). Each references Flood Resistant Design
and Construction (ASCE 2405), the national consensus standard produced by the American So-
ciety of Civil Engineers, Inc. (ASCE).
1.4 Answers to Questions About SUSD
FEMA 213, Answers to Questions about Substantially Damaged Buildings, is a FEMA publication that
summarizes answers to certain key questions regarding substantial damage and a few questions
related to substantial improvement. This SI /SD Desk Reference provides expanded discussion
and more detailed guidance on making substantial damage determinations, along with detailed
guidance on administering the substantial improvement requirements.
The most common floodplain man-
agement requirement that exceeds
NRP minimums and also applies to
SUSD is freeboard — added height
to raise the lowest floor above the
BFE.
SI /SD DESK REFERENCE 1 -3
INTRODUCTION
1.5 Where to Get Help
Each State has a designated State Coordinating Agency for the NFIP, with an individual iden-
tified as the NFIP State Coordinator. State Coordinators provide a link between the Federal
government and local governments on matters related to floodplain management. Additional
assistance may be sought from FEMA's Regional Offices. Appendix A includes contact informa-
tion for FEMA Regional Offices, NFIP State Coordinating Agencies, and State Hazard Mitigation
Offices.
FEMA produces extensive guidance materials and publications related to floodplain manage-
ment. Many NFIP State Coordinating Agencies also publish guidance documents. Appendix
B lists references pertinent to administering the SI /SD requirements and other resources for
managing development in floodplains. FEMA publications are available from the FEMA library
at http: / / /library or by calling 1- 800 -480 -2520.
1 -4 SI /SD DESK REFERENCE
2 The NFIP: Roles and
Responsibilities
2.1 Purposes and Overview of the NFIP
The original authorizing legislation for the NFIP was passed in 1968. Congress expressly found
that "a program of flood insurance can promote the public interest by encouraging sound land
use by minimizing exposure of property to flood losses..."
Thte NFIP is intended to encourage States and local governments to recognize and incorpo-
rate flood hazards in their land use and development decisions. In some communities, this is
achieved by guiding development to areas with lower risk. When a proposal is made to develop
within a flood hazard area, application of the criteria set forth in Federal regulation (Title 44
Code of Federal Regulations [CFR] Section (§) 60.3) is intended to minimize exposure and
flood - related damage.
The NFIP is administered by FEMA, which is part of the Department of Homeland Security
(DHS). The NFIP has three main elements:
Hazard identification and mapping, in which engineering studies are conducted and
flood maps are prepared to delineate areas that are predicted to be subject to flooding
under certain conditions;
2. Floodplain management criteria, which establish the minimum requirements for com-
munities to adopt and apply to development within mapped flood hazard areas; and
3. Flood insurance, which provides financial protection for property owners to cover flood -
related damage to buildings and contents.
Federal flood insurance is designed to provide an alternative to disaster assistance and disaster
loans for home and business owners. Disaster assistance rarely comes close to covering all of
the costs to repair and clean up. While available to qualified victims, disaster loans do not sig-
nificantly ease the financial burden due to repayment terms. It is important to remember that
disaster assistance is available only after floods have been declared major disasters by the Presi-
dent of the United States. In contrast, flood insurance claims will be paid any time damage from
a qualifying flood event occurs.
Another important objective of the NFIP is to break the cycle of flood damage. Many buildings
have been flooded, repaired or rebuilt, and flooded again. In some parts of the country, this
cycle occurs every couple of years. Before communities adopted floodplain management regu-
lations, people tended to rebuild in the same flood -prone areas using the same construction
techniques that did not adequately protect the structure when the first event occurred. On the
SI /SD DESK REFERENCE 2 -1
2 THE NFIP: ROLES AND RESPONSIBILITIES
other hand, structures built to NFIP floodplain management requirements experience, on aver-
age, 80 percent less damage through reduced frequency of inundation and severity of losses.
By encouraging communities to guide development to lower risk areas, and by requiring the
elevation of new buildings and certain existing buildings, one of the long -term objectives of the
NFIP can be achieved: reducing flood damage and losses. Older buildings may be removed or
replaced, or they may be upgraded or modified with techniques that lead to little or no flood
damage.
The NFIP establishes distinct responsibilities for the Federal, State, and local levels of govern-
ment. For local officials who must administer the SI /SD requirements of their regulations and
codes, it is important to recognize how these established roles affect responsibilities for SI /SD.
As outlined in the NFIP regulations:
■ Communities are responsible for regulating all development in mapped flood hazard
areas, issuing permits, and enforcing the requirements, including SI /SD requirements for
improvements and repairs of buildings.
■ States generally are responsible for providing technical assistance to communities,
monitoring community programs, and coordinating between communities and the NFIP.
Some States also administer regulatory programs and many are engaged in flood hazard
mapping initiatives.
■ FEMA, through administration of the NFIP, promulgates the minimum regulatory
requirements, supports State programs, provides technical assistance, monitors community
programs, and produces flood hazard maps.
2.2 The Community's Role
The NFIP regulations contained in 44 CFR § 59.22 and § 60.3 outline the responsibilities that
communities must accept in order to become and remain eligible to participate in the NFIP.
The key responsibilities include:
■ Designate an agency that is charged with the responsibility to administer floodplain
management requirements
■ Determine whether proposed development activities are located in SFHAs
■ Review development proposals to ensure compliance with the requirements of applicable
floodplain management regulations and building codes
■ Require that new subdivisions and development proposals with more than 50 lots or larger
than five acres include BFEs
■ Issue or deny permits for floodplain development
■ Inspect all development in SFHAs to ensure compliance
■ Maintain records of issued permits, elevation data, inspections, and enforcement actions
■ Assist in the preparation and revision of floodplain maps
2 -2 SI /SD DESK REFERENCE
THE NFIP: ROLES AND RESPONSIBILITIES 2
■ Help residents obtain information on flood hazards, floodplain map data, and compliant
construction measures
For existing buildings that are located in SFHAs, community responsibilities include the follow-
ing, in addition to the requirements above:
■ Determine whether proposed improvements are "substantial improvements;" substantial
improvement of buildings triggers requirements for permits and compliance.
■ Determine whether work necessary to restore a damaged building to its pre- damage condition
constitutes repair of "substantial damage;" repair of substantially damage buildings triggers
requirements for permits and compliance.
Chapter 3 describes the NFIP SI /SD requirements and definitions. Chapter 4 outlines making
SI /SD determinations; Chapter 5 outlines community responsibilities that are specifically re-
lated to administering these requirements. Chapter 6 includes factors to be considered when
determining SI /SD and illustrations of substantial improvement and substantial damage. More
guidance on administering and enforcing all aspects of local floodplain management regula-
tions is found in FEMA 480, NFIP Roodplain Management Requirements: A Study Guide and Desk
Reference. Chapter 7 suggests actions that communities can take to prepare for disasters, meth-
ods communities can use to obtain the costs to restore the structure and the market value of the
structure before the damage occurred to make a substantial damage determination, and also
describes a tool that communities can use to facilitate collecting data to make substantial dam-
age determinations, FEMA's Substantial Damage Estimator.
2.3 The State's Role
Each State's governor has designated an NFIP State Coordinating Agency. This agency, often
referred to as the NFIP State Coordinator's Office, is spe-
cifically charged with being a link between Federal, State,
and local governments. The NFIP State Coordinator stays
current on NFIP issues and can advise communities on
specific provisions and any State requirements.
While the explicit role of the NFIP State Coordinator may
vary among States, the NFIP regulations [44 CFR § 60.25]
outline the following key responsibilities:
■ Encourage and provide assistance for communities to
qualify for participation in the NFIP
Some States have their own flood -
plain management statutes and
regulations, and some administer
regulatory programs pertaining to
flood hazards. State requirements
related to work on existing build-
ings must be satisfied in addition
to local requirements.
■ Guide and assist communities to develop, implement, and maintain floodplain management
regulations
■ Provide technical assistance to communities
■ Participate in training opportunities
SI /SD DESK REFERENCE 2 -3
2 THE NFIP: ROLES AND RESPONSIBILITIES
IN Assist in the delineation of flood -prone areas
■ Notify FEMA of problems with community programs, if such problems cannot be resolved
through technical assistance
2.4 The Federal Role
Several Federal agencies have programs and responsibilities that relate to flooding, managing
flood hazards, and responding to flood events. Only FEMA's role is directly pertinent to the pur-
pose of this Desk Reference.
Located at FEMA Headquarters in Washington, DC, the Flood Insurance and Mitigation Admin-
istration (FIMA) implements the three main elements of the NFIP (flood hazard identification,
floodplain management, and flood insurance). The Directorate sets National policy, issues in-
terpretations, enrolls communities in the NFIP, researches floodplain construction practices,
and administers the flood hazard mapping and flood insurance elements of the program. Spe-
cifically, FEMA develops publications to help States and participating communities fulfill their
responsibilities and to provide guidance to property owners, architects, engineers, and others
proposing to develop in the floodplain.
FEMA implements its program responsibilities through 10 Regional Offices. Each Regional Of-
fice has a Mitigation Division that works with States and communities on matters related to the
NFIP. Each Regional Office covers four to eight States and territories; together they work with
over 21,000 participating communities. The responsibilities of the Regional Offices include:
■ Assist the NFIP State Coordinating Agencies
■ Advise local officials responsible for administering floodplain management regulations
■ Assess community compliance with the minimum NFIP criteria
■ Answer questions from design professionals, builders, and the public
■ Provide information about flood insurance and respond to questions from citizens
■ Maintain and revise flood hazard maps and data
■ Provide information and training on many aspects of the NFIP, including administration of
the SI /SD requirements
■ Work with States and communities to resolve identified problems with community
programs
2 -4 S1/SD DESK REFERENCE
3 NFIP Substantial Improvement/
Substantial Damage:
Requirements and Definitions
3.1 Overview
This chapter provides NFIP regulations for substantial improvement and substantial damage,
and includes key definitions for implementing the SI /SD requirements (also see the glossary
and acronyms in Appendix Q. This chapter also compares the NFIP's terminology with terms
and definitions used in the I- Codes.
3.2 Introduction to the SIM Requirements
The NFIP includes a requirement that new buildings and substantially improved buildings be
constructed in ways that minimize or prevent damage during a flood. This requirement grew
out of the recognition that there were large numbers of buildings already located in flood-
prone areas that would continue to be subject to damage.
The purpose of the SI /SD requirements is to protect the
property owner's investment and safety, and, over time,
to reduce the total number of buildings that are exposed
to flood damage, thus reducing the burden on taxpay-
ers through the payment of disaster assistance. The SI /SD
requirements are triggered when the local official deter-
mines that the cost of repairing or improving a building
in an SFHA equals or exceeds 50 percent of the building's
market value (excluding land value).
Types of work that may trigger SI /SD requirements are
described in detail in Chapter 6 and generally include:
■ Rehabilitation or remodeling of a building with or
without modifying its external dimensions
■ Lateral additions that mayor may not involve structural
modifications of a building
■ Vertical additions
■ Repair of foundations, including replacing or ex-
tending foundations
The SI /SD requirement is simi-
lar to common zoning and code
requirements that address non-
conforming uses and structures.
The non- conformance is allowed
to continue until a triggering event
occurs, such as a change in use
or a proposal to undertake signifi-
cant physical alterations.
Understandably, owners are con-
cerned about the costs of bringing
buildings into compliance. NFIP
flood insurance policies on build-
ings located in SFHAs include
coverage that is available for build-
ings that are substantially damaged
by flood. Called Increased Cost of
Compliance (ICC), this coverage
is described in Sections 5.6.4 and
7.6.
SI /SD DESK REFERENCE 3 -1
3 NFIP SU B S TANTIAL IMPR / SUBSTANTIA L DAMA R EQU IR EMENTS AND DEFINITIONS
■ Restoration or repair of damage of any origin that is necessary to restore a building to its pre -
damaged condition
■ Reconstruction of demolished or destroyed buildings on the same site or on the same
foundation
■ Work on post -Flood Insurance Rate Map (FIRM) buildings
■ Work on existing buildings where flood zones or floodways are revised
The intent of the SI /SD requirements is not to discourage routine maintenance. If work re-
quires a permit, then the local official must review all of the work proposed and the cost of all
work must be included in the project costs, including work that might otherwise be considered
routine maintenance.
Chapter 6 describes how building characteristics and details of proposed work relate to the SI/
SD requirements of local floodplain management regulations.
3.3 NFIP Regulations for SIM
The NFIP regulations are online at http: / / NNNN- w.fema.go\ /nfip /laA , sI.slitm. The fol-
lowing excerpts of the regulations pertain to new construction and substantial improvement.
The requirements state that communities shall:
§ 60.3(a)(3) Review all permit applications to determine whether proposed building sites will be
reasonably safe from flooding. If a proposed building site is in a flood -prone area, all new construc-
tion and substantial improvements shall (i) be designed (or modified) and adequately anchored to
prevent flotation, collapse, or lateral movement of the structure resulting from hydrodynamic and
hydrostatic loads, including the effects of buoyancy, (ii) be constructed with materials resistant to
flood damage, (iii) be constructed by methods and practices that minimize flood damage, and (iv)
be constructed with electrical, heating, ventilation, plumbing, and air conditioning equipment and
other service facilities that are designed and /or located so as to prevent water from entering or accu-
mulating within the components during conditions of flooding;
§ 60.3(b)(4) Obtain, review and reasonably utilize any base flood elevation and floodway data
available from a Federal, State, or other source, including data developed pursuant to paragraph
(b)(3) of this section, as criteria for requiring that new construction, substantial iMpmements or
other development in Zone A on the community's FHBM or FIRM meet the standards in paragraphs
(c)(2), (c)(3), (c)(5), (c)(6), (c)(12), (c)(14), (d)(2) and (d)(3) of this section,
§ 60.3(c)(2) Require that all new construction and substantial improvements of residential struc-
tures within Zones AI -30, AE and AH zones on the community's FIRM have the lowest floor
(including basement) elevated to or above the base flood level, unless the community is granted an
exception by the Administrator for the allowance of basements in accordance with § 60.6 (b) or (c);
§ 60.3(c)(3) Require that all new construction and substantial improvements of non - residential
structures within Zones AI -30, AE and AH zones on the community's FIRM (i) have the lowest
3 -2 SI /SD DESK REFERENCE
NFIP SU B S TANTIA L IMPR O V EMENT /SUBSTANTI D REQUIREMENTS AND DEFINITIONS 3
floor (including basement) elevated to or above the base flood level or, (ii) together with attendant
utility and sanitary facilities, be designed so that below the base flood level the structure is watertight
with walls substantially impermeable to the passage of water and with structural components hav-
ing the capability of resisting hydrostatic and hydrodynamic loads and effects of buoyancy;
§ 60.3(c)(5) Require, for all new construction and substantial improvements, that fully enclosed ar-
eas below the lowest floor that are usable solely for parking of vehicles, building access or storage in
an area other than a basement and which are subject to flooding shall be designed to automatically
equalize hydrostatic flood forces on exterior walls by allowing for the entry and exit of floodwaters.
Designs for meeting this requirement must either be certified by a registered professional engineer or
architect or meet or exceed the following minimum criteria: A minimum of two openings having a to-
tal net area of not less than one square inch for every square foot of enclosed area subject to flooding
shall be provided. The bottom of all openings shall be no higher than one foot above grade. Openings
may be equipped with screens, louvers, valves, or other coverings or devices provided that they permit
the automatic entry and exit of floodwaters;
§ 60.3(c)(6) Require that manufactured homes that are placed or substantially im roved within
Zones Al -30, AH, and AE on the community's FIRM on sites
(i) Outside of a manufactured home park or subdivision,
(ii) In a new manufactured home park or subdivision,
(iii) In an expansion to an existing manufactured home park or subdivision, or
(iv) In an existing manufactured home park or subdivision on which a manufactured home has
incurred "substantial damage" as the result of a flood, be elevated on a permanent foundation
such that the lowest floor of the manufactured home is elevated to or above the base flood eleva-
tion and be securely anchored to an adequately anchored foundation system to resist floatation
collapse and lateral movement.
§ 60.3(c)(7) Require within any AO zone on the community's FIRM that all new construction and
substantial improvements of residential structures have the lowest floor (including basement) el-
evated above the highest adjacent grade at least as high as the depth number specified in feet on the
community's FIRM (at least two feet if no depth number is specified);
§ 60.3(c)(8) Require within any AO zone on the community's FIRM that all new construction and
substantial improvements of non - residential structures (i) have the lowest floor (including base-
ment) elevated above the highest adjacent grade at least as high as the depth number specified in
feet on the community's FIRM (at least two feet if no depth number is specified), or (ii) together with
attendant utility and sanitary facilities be completely floodproofed to that level to meet the floodproof-
ing standard specified in § 60.3(c)(3)(ii);
§ 60.3(c)(10) Require until a regulatory floodway is designated, that no new construction, substan-
tial improvements or other development (including fill) shall be permitted within Zones Al -30 and
AE on the community's FIRM, unless it is demonstrated that the cumulative effect of the proposed
development, when combined with all other existing and anticipated development, will not increase
the water surface elevation of the base flood more than one foot at any point within the community.
SI /SD DESK REFERENCE 3-3
3 NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS
§ 60.3(c)(12) Require that manufactured homes to be placed or substantially improved on sites in
an existing manufactured home park or subdivision within Zones A -1 -30, AH, and AE on the com-
munity's FIRM that are not subject to the provisions of paragraph (c)(6) of this section be elevated
so that either :
(i) The lowest floor of the manufactured home is at or above the base flood elevation, or
(ii) The manufactured home chassis is supported by reinforced piers or other foundation ele-
ments of at least equivalent strength that are no less than 36 inches in height above grade and
be securely anchored to an adequately anchored foundation system to resist floatation, collapse,
and lateral movement.
§ 60.3(d) [When floodways have been designated] (3) Prohibit encroachments, including fill,
new construction, substantial improvements and other development within the adopted regulatory
floodway unless it has been demonstrated through hydrologic and hydraulic analyses performed in
accordance with standard engineering practice that the proposed encroachment would not result
in any increase in flood levels within the community during the occurrence of the base flood dis-
charge;
§ 60.3(e)(4) [When V zones have been designated] Provide that all new construction and
substantial improvements in Zones VI -30 and VE, and also Zone V if base flood elevation data is
available, on the community's FIRM, are elevated on pilings and columns so that (i) the bottom of
the lowest horizontal structural member of the lowest floor (excluding the pilings or columns) is el-
evated to or above the base flood level; and (ii) the pile or column foundation and structure attached
thereto is anchored to resist flotation, collapse and lateral movement due to the effects of wind and
water loads acting simultaneously on all building components. Water loading values used shall be
those associated with the base flood. Wind loading values used shall be those required by applicable
State or local building standards. A registered Professional engineer or architect shall develop or re-
view the structural design, specifications and plans for the construction, and shall certify that the
design and methods of construction to be used are in accordance with accepted standards of practice
for meeting the provisions of paragraphs (e)(4) (i) and (ii) of this section.
§ 60.3(e)(5) Provide that all new construction and substantial improvements within Zones V1 -30,
VE, and V on the community's FIRM have the space below the lowest floor either free of obstruction
or constructed with non - supporting breakaway walls, open wood lattice -work, or insect screening
intended to collapse under wind and water loads without causing collapse, displacement, or other
structural damage to the elevated Portion of the building or supporting foundation system. [Note:
specifications for breakaway walls not shown.]
3.4 Selected Definitions and Terms
Some of the terms used in this Desk Reference are defined in the NFIP regulations and some
have meanings that are based on common usage. This section compares the NFIP terms with
those defined and used in the administrative and flood damage- resistant provisions of the
family of building codes known as the I- Codes. The I -Codes include the International Build-
ing Code (IBC) International Residential Code (IRC), International Existing Building Code (IEBC),
3 -4 S1/SD DESK REFERENCE
NFIP SU B S TANTIA L IMPR / SUBSTANTI AL DAMA REQ U IR E M ENTS A ND DEFINITIONS 3
International Mechanical Cody', International Plumbing Code ® , the International Fuel Gas Cody', and a
number of other specialty codes.
3.4.1 Definitions: NAP Regulations
The following are the NFIP definitions of several terms used in this Desk Reference (also see
Appendix C for a glossary of related terms and definitions):
■ Floodproofing means any combination of structural and non - structural additions, changes, or
adjustments to structures that reduce or eliminate flood damage to real estate or improved real property,
water and sanitary facilities, structures, and their contents.
■ Historic structure means any structure that is:
(a) Listed individually in the National Register of Historic Places (a listing maintained by the De-
partment of Interior) or preliminarily determined by the Secretary of the Interior as meeting the
requirements for individual listing on the National Register;
(b) Certified or preliminarily determined by the Secretary of the Interior as contributing to the historical
significance of a registered historic district or a district preliminarily determined by the Secretary to
qualify as a registered historic district;
(c) Individually listed on a state inventory of historic places in states with historic preservation pro-
grams which have been approved by the Secretary of the Interior; or
(d) Individually listed on a local inventory of historic places in communities with historic preservation
programs that have been certified either.•
(1) By an approved state program as determined by the Secretary of the Interior or
(2) Directly by the Secretary of the Interior in states without approved programs.
■ Lowest floor means the lowest floor of the lowest enclosed area (including basement). An unfinished
or flood damage- resistant enclosure, usable solely for parking of vehicles, building access, or storage
in an area other than a basement area is not considered a building's lowest floor; Provided, that such
enclosure is not built so as to render the structure in violation of the applicable non - elevation design
requirements of § 60.3.
■ New construction means, for floodplain management purposes, structures for which the `start of
construction" commenced on or after the effective date of a floodplain management regulation adopted
by a community and includes any subsequent improvements to such structures.
■ Substantial damage means damage of any origin sustained by a structure whereby the cost of restoring
the structure to its before damaged condition would equal or exceed 50 percent of the market value of the
structure before the damage occurred.
■ Substantial improvement means any reconstruction, rehabilitation, addition, or other improvement
of a structure, the cost of which equals or exceeds 50 percent of the market value of the structure before the
`start of construction " of the improvement. This term includes structures that have incurred `substantial
damage, "regardless of the actual repair work performed. The term does not, however, include either.-
SI /SD DESK REFERENCE 3-5
3 NFIP SUB I MPROVEM ENT / SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS
(1) Any project for improvement of a structure to correct existing violations of state or local health, sani-
tary, or safety code specifications which have been identified by the local code enforcement official
and which are the minimum necessary to assure safe living conditions or
(2) Any alteration of a "historic structure, "provided that the alteration will not preclude the structure's
continued designation as a "historic structure. "
The definition of substantial improvement includes structures that have incurred substantial
damage. Work necessary to restore a substantially damaged building to its pre- damage condition
constitutes a substantial improvement; therefore, the NFIP regulations that refer to substantial
improvement also include substantial damage.
3.4.2 Comparison of Definitions and Terms: NFIP and I -Codes
FEMA has determined that the provisions in the I -Codes for the design and construction of
flood damage - resistant buildings are consistent with the NFIP requirements. Adoption of a
code based on one or more of the I -Codes does not, by itself, meet all of the NFIP require-
ments, largely because the model codes deal primarily with buildings and structures. To learn
more about coordinating local floodplain management regulations with the I- Codes, contact
the NFIP State Coordinating Agency or FEMA Regional Office listed in Appendix A. The Inter-
national Code Council, in coordination with FEMA published Reducing Flood Losses Through the
International Codes Meeting the Requirements of the National Flood Insurance Program for additional
guidance.
Many States and communities administer building codes that are based on the model I- Codes.
Because the model codes include provisions for SI /SD and local regulations also include SI /SD
provisions, it is important to compare terms. In communities that use both codes and regula-
tions to regulate SFHA development, officials need to be familiar with terms used in each, and
recognize that some terms are used in one but not the other. Some terms are defined while oth-
ers are simply used in context with their common meaning. Table 3 -1 compares terms that are
defined or used by the NFIP with terms used in the I- Codes. Some terms (noted "used in guid-
ance documents ") are not defined by the NFIP, but are used in this Desk Reference and various
guidance documents listed in Appendix B.
3-6 SI /SD DESK REFERENCE
NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS 3
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes
NFIP
Addition Used in the NFIP
113C
An extension or
IRC
An extension or
IEBC
An extension or
definition of "substantial
increase in floor area or
increase in floor area or
increase in floor area,
improvement"
height of a building or
height of a building or
number of stories, or
structure.
structure.
height of a building or
Common NFIP usage:
structure.
an expansion of a
building that increases
the total square footage.
Addition, minor Not defined in NFIP
Not used in the IBC;
Not used in the IRC;
Not used in the IEBC;
regulations; used in
included in definition of
included in definition of
included in definition of
guidance documents.
"Addition"
"Addition!
"Addition.'
Common NFIP usage:
an addition that, based
on a determination,
is not a "substantial
improvement"
Addition, lateral Not defined in NFIP
Not used in the IBC;
Not used in the IRC;
Not used in the IEBC;
or horizontal regulations; used in
included in definition of
included in definition of
included in definition of
guidance documents.
"Addition"
"Addition.'
"Addition.'
Common NFIP usage:
an addition that
extends beyond the
existing footprint. May
be a minor addition or
may be determined
to be a "substantial
improvement."
Addition, vertical Not defined in NFIP
Not used in the IBC;
Not used in the IRC;
Not used in the IEBC;
regulations; used in
included in definition of
included in definition of
included in definition of
guidance documents.
"Addition!
"Addition"
"Addition.'
Common NFIP usage:
an addition that extends
a building upward,
either by adding an
upper story or by
elevating the building in-
place and constructing
a new story underneath.
May be determined
to be a "substantial
improvement;" less
likely to be a minor
addition.
NFIP
National Flood Insurance Program
IBC
International Building Code
IRC
International Residential Code
IEBC
International Existing Building Code
SI /SD DESK REFERENCE 3-7
3 NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes (continued)
Alteration
Not defined in NFIP
Any construction
Any construction Any construction
regulations; used in the
or renovation to an
or renovation to an or renovation to an
NFIP definitions "start
existing structure other
existing structure other existing structure
of construction" and
than repair or addition.
than repair or addition other than a repair or
"historic structure."
that requires a permit. addition. Alterations are
Also, a change in a classified as Level 1,
Used in guidance
mechanical system that Level 2, and Level 3.
documentts. s.
involves an extension,
addition, or change
to the arrangement,
type, or purpose of the
original installation that
requires a permit.
Alteration,
Not used by the NFIP.
Not used in the IBC.
Not used in the IRC. 403.1 Scope. Level
Level 1
1 alterations include
the removal and
replacement or the
covering of existing
materials, elements,
equipment, or fixtures
using new materials,
elements, equipment,
or fixtures that serve
the same purpose.
[Note: 601.3 requires
alterations that
constitute SI to comply
with flood requirements
of the IBC.]
Alteration,
Not used by the NFIP.
Not used in the IBC.
Not used in the IRC. 404.1 Scope. Level
Level 2
2 alterations include
the reconfiguration of
space, the addition
or elimination of any
door or window, the
reconfiguration or
extension of a system,
or the installation of any
additional equipment.
(Level 2 alternations
must comply with the
requirements for Level
1 and Level 2.)
Alteration,
Not used by the NFIP.
Not used in the IBC.
Not used in the IRC. 405.1 Scope. Level
Level 3
3 alterations apply
where the work area
exceeds 50 percent
of the aggregate
area of the building.
(Level 3 alternations
must comply with the
requirements for Level
1, Level 2, and Level 3.)
3 -8 SI /SD DESK REFERENCE
NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS 3
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes
(continued)
NFIP 113C
Building, Not defined in NFIP Not used in the IBC
IRC
Not used in the IRC
IEBC
Not used in the IEBC
Elevated -In- regulations; used in (see Addition).
(see Addition).
(see Addition).
Ply guidance documents.
Common NFIP usage:
a building that is
detached from its
original foundation and
reattached to a new
elevated foundation at
the same location.
Building, Not defined in NFIP
[Existing structure
[Existing building
[Existing building
Existing regulations; used in
means] A structure
means] Existing
means] A building
guidance documents.
erected prior to the
building is a building
erected prior to the
date of adoption of the
erected prior to the
date of adoption of the
NFIP usage: a building
appropriate code, or
adoption of this code,
appropriate code, or
that pre -dates the
one for which a legal
or one for which a legal
one for which a legal
community's first
building permit has
building permit has
building permit has
n management
been issued. See also
been issued.
been issued.
regulation (see Pre
regulati
Section 1612.2.
FIRM).
Building, Not defined in NFIP
Not used in the IBC;
Not used in the IRC;
409.1 Scope. Relocated
Relocated regulations; used in
scope of IBC includes
scope of IRC includes
buildings provisions
guidance documents.
the movement of
movement of buildings.
shall apply to relocated
buildings.
or moved buildings.
Common NFIP usage:
[1202.6 requires
a building that is
relocated buildings to
detached from its
comply with the flood
original foundation
requirements of the
and moved to another
IBC.]
location with a new
foundation.
Habitable Not defined in NFIP
A space in a building
A space in a building
Terms not defined in
(Habitable regulations; used in
for living, sleeping,
for living, sleeping,
the IEBC; default to
Space) guidance documents.
eating, or cooking.
eating or cooking.
definitions in the IBC.
Bathrooms, toilet
Bathrooms, toilet
Uses allowed for
rooms, closets, halls,
rooms, closets, halls,
enclosures below the
storage or utility spaces
storage or utility spaces
base flood elevation
and similar areas
and similar areas
include parking of
are not considered
are not considered
vehicles, building
habitable spaces. [Note:
habitable spaces. [Note:
access, and storage.
habitable spaces are
habitable spaces are
not all equivalent to the
not all equivalent to the
uses allowed below the
uses allowed below the
elevated buildings in
elevated buildings in
SFHAs.]
SFHAs.]
SI /SD DESK REFERENCE 3-9
3 NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes (continued)
NFIP
Non - residential Not defined in NFIP
IBC
All occupancies other
I IRC
The scope of the
IEBC
Terms not defined in
regulations. Used in
than "Institutional
IRC includes only
the IEBC default to
NFIP regulations and
Group l," "Residential
"detached one- and
definitions in the IBC.
guidance documents;
Group R," and dwellings
two- family dwellings
see "Residential."
within the scope of the
and townhouses not
IRC (see "Residential ").
more than three stories
above -grade in height
[Note: From ASCE
with a separate means
24 -05, Non - residential
of egress and their
— any building or
accessory structures.'
structure or portion
thereof that is not
classified residential.]
Pre -RRM A building for
Not used in the IBC.
Not used in the IRC.
Not used in the IEBC.
which construction
or substantial
improvement occurred
on or before December
31, 1974, or before
the effective date of an
initial FIRM.
Post -RRM A building for
Not used in the IBC.
Not used in the IRC.
Not used in the IEBC.
which construction
or substantial
improvement occurred
after December 31,
1974, or on or after the
effective date of the
initial FIRM, whichever
is later.
Reconstruction Not defined in NFIP
Used in the IBC
Used in the IRC
Used in the IEBC
regulations; used in
definition of "Repair."
definition of "Repair."
definition of "Repair."
the NFIP definition
of "Substantial
Improvement"
Common NFIP usage:
rebuilding on same
foundation. Another
common usage
refers to ground -
up reconstruction,
including a new
foundation. In both, the
new building is treated
as new construction.
Rehabilitation Not defined in NFIP
Used only in the IBC
[Appendix J, Existing
Any work, as described
regulations; used in
flood damage- resistant
Buildings and
by the categories of
the NFIP definition
provisions
Structures] Any repair,
work defined herein,
of "Substantial
renovation, alteration
undertaken in an
Improvement.'
or reconstruction work
existing building.
Common NFIP usage
undertaken in an
existing building.
(including "remodel ") to
describe work that does
Used in the IRC flood
not increase square
damage- resistant
footage.
provisions.
3 -10 SI /SD DESK REFERENCE
NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS 3
Table 3 -1. Comparison
of Definitions and
Terms in the NFIP and I -Codes
(continued)
Renovation
NFIP
Not defined in NFIP
IBC
Used in the IBC
IRC IEBC
Used in the IRC Used in the IEBC
regulations; used in
definition of "Alteration.'
definition of "Alteration." definition of "Alteration.'
guidance documents.
Dictionary definition is
"to restore to a former
better state (as by
cleaning, repairing, or
rebuilding)."
Repair
Not defined in NFIP
The reconstruction or
The reconstruction or The restoration to good
regulations; used in
renewal of any part
renewal of any part or sound condition of
the NFIP definition
of an existing building
of an existing building any part of an existing
of "Substantial
for the purpose of its
for the purpose of its building for the purpose
Improvement"
maintenance.
maintenance. of its maintenance.
Dictionary definition
402.1 Scope. Repairs,
includes (a) act or
as defined in Chapter
process of repairing; (b)
2, include the patching
to restore by replacing
or restoration or
a part or putting
replacement of
together what is torn or
damaged materials,
broken.
elements, equipment or
fixtures for the purpose
of maintaining such
components in good
or sound condition
with respect to existing
loads or performance
requirements.
SI /SD DESK REFERENCE 3 -11
3 NFIP SU B S TANT I A L I M P ROVEMENT /SUBSTAN DAMAGE: REQUIREMENTS AND DEFINITIONS
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes (continued)
Residence)
Used (but not defined) 308 Institutional Group
R101.2 Scope.
Terms not defined in
in the NFIP regulations I. Institutional Group I
The provisions of
the IEBC; default to
and guidance includes, among others,
the International
definitions in the IBC.
documents. the use of a building or
Residential Code for
structure, or a portion
One- and Two - family
thereof, in which
Dwellings shall apply
people are cared for
to the construction,
or live in a supervised
alteration, movement,
environment, having
enlargement,
physical limitations
replacement, repair,
because of health or
equipment, use and
age are harbored for
occupancy, location,
medical treatment or
removal and demolition
other care or treatment,
of detached one- and
or in which people are
two- family dwellings
detained for penal or
and townhouses not
correctional purposes
more than three stories
or in which the liberty
above -grade in height
of the occupants is
with a separate means
restricted.
of egress and their
310.1 Residential
accessory structures.
Group R. Residential
Group R includes,
among others, the
use of a building or
structure, or a portion
thereof, for sleeping
purposes when
not classified as an
Institutional Group I
or when not regulated
by the International
Residential Code
in accordance
with Section
101.2. Residential
occupancies shall
include the following:
[NOTE. list that follows
is not shown.]
3 -12 SI /SD DESK REFERENCE
NFIP SUBSTANTIAL IMPROVEMENT /SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS 3
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes (continued)
NFIP 113C IRC ,
Residential (NOTE. The term
(continued) residential is defined
in ASCE 24 -05,
Residential — (1)
buildings and structures
and portions thereof
where people live,
or that are used for
sleeping purposes
on a transient or non -
transient basis; (2)
residential structures,
including but not limited
to one- and two- family
dwellings, townhouses,
condominiums, multi-
family dwellings,
apartments, congregate
residences, boarding
houses, lodging
houses, rooming
houses, hotels, motels,
apartment buildings,
convents, monasteries,
dormitories, fraternity
houses, sorority houses,
vacation timeshare
properties; and (3)
institutional facilities
where people are cared
for or live on a 24 -hour
basis in a supervised
environment, including
but not limited to board
and care facilities,
assisted living facilities,
halfway houses, group
homes, congregate
care facilities, social
rehabilitation facilities,
alcohol and drug
centers, convalescent
facilities, hospitals,
nursing homes, mental
hospitals, detoxification
facilities, prisons, jails,
reformatories, detention
centers, correctional
centers, and prerelease
centers.]
SI /SD DESK REFERENCE 3 -13
3 NFIP SU B S TANTI AL IMPROVE / SUBSTANTIAL DAMAGE: REQUIREMENTS AND DEFINITIONS
Table 3 -1. Comparison of Definitions and Terms in the NFIP and I -Codes (continued)
Restoration Used in the NFIP
definition of "Substantial
Damage"
Dictionary definition
includes (a) an act
of restoring or the
condition of being
restored; (b) bringing
back to a former
position or condition.
Used in the definition
of "Historic structures"
and requirements for
historic buildings.
Not used in the IRC.
Used in the IEBC
definition of "Repair."
Story Not used in the NFIP
That portion of a
That portion of a
Terms not defined in
regulations.
building included
building included
the IEBC; default to
between the upper
between the upper
definitions in the IBC.
"Lowest Floor" means
surface of a floor and
surface of a floor and
the lowest floor of the
the upper surface of the
the upper surface of the
lowest enclosed area
floor or roof next above
floor or roof next above.
(including basement).
(also see "Mezzanine"
An unfinished or flood
and Section 502.1).
damage- resistant
It is measured as
enclosure, usable solely
the vertical distance
for parking of vehicles,
from top to top of two
building access, or
successive tiers of
storage in an area other
beams or finished floor
than a basement area
surfaces and, for the
is not considered a
topmost story, from the
building's lowest floor;
top of the floor finish
Provided, that such
to the top of the ceiling
enclosure is not built
joists or, where there is
so as to render the
not a ceiling, to the top
structure in violation
of the roof rafters.
of the applicable
non - elevation design
requirements of Section
60.3.
3 -14 SI /SD DESK REFERENCE
4 Making Substantial
Improvement and Substantial
Damage Determinations
4.1 Overview
Administering the SI /SD requirements requires local of-
ficials to perform four major actions: (1) determine costs,
(2) determine market values, (3) make SI /SD determina-
tions, and (4) require owners to obtain permits to bring
substantially improved or substantially damaged build-
ings into compliance with the floodplain management
requirements. This chapter describes how to determine
whether work is a substantial improvement or a repair of
substantial damage. The first step is to review estimates of
the improvement or repair costs; this step involves decid-
ing which costs to include and exclude. Next, the market
value of the structure must be determined. There is more
The 1 -Codes include, in the adminis-
trative provisions, two requirements
pertinent to the data necessary to
make Sl /SD determinations. Appli-
cants must:
■ State the valuation of proposed
work, and
■ ;Give other data and informa-
tion as required by the building
official.
than one way to determine costs and market value, and
the local official must examine both for reasonableness and accuracy.
Communities must be prepared to explain to permit applicants how they make SI /SD deter-
minations. Local officials should develop written procedures that can help them make and
document consistent determinations and improve efficiency, especially in the post- disaster pe-
riod when large numbers of buildings may be damaged.
Chapter 5 outlines community responsibilities that are specifically related to administering these
SI /SD requirements. Chapter 6 describes factors to consider when evaluating permit applica-
tions and all aspects of bringing substantially improved and substantially damaged buildings
into compliance; it also includes illustrations of improvements and repairs.
Chapter 7 addresses handling substantial damage in the post- disaster period, with recommen-
dations for planning ahead to be prepared for the added workload and demands on staff and
resources. It describes some methods that can help communities focus their efforts when many
damaged buildings may have to be evaluated. It also describes FEMA's Substantial Damage Estima-
tor (SDE) software that communities can use to collect information about damaged buildings in
order to make substantial damage determinations.
SI /SD DESK REFERENCE 41
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
4.2 Accuracy and Verification
Costs of proposed repairs or improvements and mar-
ket values are needed to determine whether proposed
work is SI /SD. Methods for obtaining this information
are described in Sections 4.4 and 4.5, respectively. Lo-
cal officials are responsible for verifying that the data are
complete and reasonable. The local official is responsi-
ble for reviewing the validity of all cost estimates provided
by applicants, whether prepared by licensed contractors,
engineers, architects, professional cost estimators, or by
property owners. When work is repair of damage, an in-
spection visit should be made to verify that the proposed
work is all of the work that is necessary to restore the
building to its pre- damage condition.
Applicants may disagree with a
community's SI /SD determination.
In these cases, the burden is on
the applicant to provide improved
cost estimates or to obtain a pro-
fessional appraisal of market value.
The local official is responsible for
reviewing the new information. In
some cases, applicants may seek
a formal appeal of the local offi-
cial's decision (Section 5.6.6).
To be consistent, local officials should document their decisions and the documentation
should be retained in the community's permit records. A sample worksheet that can be used
to document SI /SD determinations is included in Appendix D. Maintaining good records and
documentation is especially critical if a community has elected to administer a cumulative SI/
SD requirement (Section 5.7.3).
4.3 Making S1/SD Determinations
Work on buildings ranges from routine maintenance and
minor repairs (which may not require permits) to work
that costs more than 50 percent of a structure's market
value. Local officials who are responsible for administer-
ing their floodplain management regulations or codes are
responsible for determining whether work is SI /SD. Oth-
er entities, such as insurance claims adjusters, may make
estimates of damage for purposes of adjusting damage
claims. However, an adjuster's estimate must not be used
to make SI /SD determinations because the estimates of
damage that determine the amount of a claim payment
may not include all of the costs to repair the building to
its pre- damage condition.
Consistency is important. Com-
munities should decide in advance
how they will handle significant
flood events and develop written
procedures for making decisions.
It is easier to defend SI /SD de-
terminations if all applicants are
treated the same, especially when
many buildings have been dam-
aged (see Chapter 7).
Figure 4-1 illustrates an overview of the steps in the SI /SD determination that are described in
detail in this Desk Reference. Once the cost of the work and the market value of the structure
have been determined, the local official must make a final determination. The work is SI /SD if
the ratio of the cost of work to the market value equals or exceeds 50 percent:
Cost of Improvement or Cost to Repair to Pre - Damage Condition
z 50%
Market Value of Building
4-2 SI /SD DESK REFERENCE
MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
Communities may use a combination of sources for the data needed to make SI /SD determina-
tions. For example, a community may make SI /SD determinations based on applicant - supplied
costs of repairs or improvements and community- obtained market values.
Determine Cost of Work (Section 4.4)
Determine Market Value (Section 4.5)
Divide: YES Is result Issue SVSD Require compliance
Cost of Work X50 ? determination letter (Chapter 6)
Market Value (Section 5.6.15)
NO
GIs building YES Ensure work is compliant and does not cause
post -FIRM? any aspect originally required for compliance to
(Section 6.2.1) become non - compliant
S.- (Section 6.4.7)
Encourage flood
resistance for
pre -FIRM buildings
(Section 5.8)
Figure 4 -1. Make the S1/SD determination (overview)
4.3.1 SI /SD Provisions in the 2006 and 2009 I -Codes
The IBC and IRC apply to new construction and also to alteration, movement, enlargement,
replacement, and repair of existing buildings. The IBC, the IRC, and the IEBC include SI /SD
provisions that are consistent with the NFIP's requirements. The specific code provisions are
described below:
• IBC. The IBC relies on the definitions of "substantial improvement" and "substantial damage"
in Section 1612. The code official must determine whether any alteration, repair, or addition
to existing buildings, or work associated with a change of occupancy or moved buildings, meets
those definitions. Section 1612.1 states that "all new construction of buildings, structures, and
portions of buildings and structures, including substantial improvement and restoration of
substantial damage to buildings and structures, shall be designed and constructed to resist
the effects of flood hazards and flood loads." In addition, the requirements for existing
buildings, including historic buildings, are found in IBC Chapter 34.
• IRC. The IRC contains detailed administrative provisions in Chapter 1:
R105.3.1.1 Substantially improved or substantially damaged buildings and structures in
areas prone to flooding. This section specifies that the building official shall examine
SI /SD DESK REFERENCE 43
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
applications and prepare a finding with regard to the value of the proposed work. If
the value equals or exceeds 50 percent of the market value of the building before the
damage occurred or the improvement is started, the finding is provided to the board of
appeals.
R112.2.1 Determination of substantial improvement in areas prone to flooding. This
section requires the board of appeals to determine if a proposal, referred to the board
by the building official pursuant to Section R105.3.1.1, constitutes a substantial improve-
ment (or repair of substantial damage). If the proposed work is found to be a substantial
improvement or repair of substantial damage, the work must meet the requirements of
Section R324 (Flood- Resistant Construction).
■ IEBC. The IEBC is organized based on the nature of the work: repairs; repair of damaged
buildings; alterations (Levels 1, 2, and 3); work associated with change of occupancy
classification; additions (horizontal, vertical, new /raised foundations); and relocated or
moved buildings. These characterizations of work are similar to those used in Chapter 6
(also see Table 3 -1, which lists the definitions and terms used in the IEBC). The provisions
of the IEBC that pertain to flood resistance are all triggered by a determination of whether
the work constitutes a substantial improvement or a repair of substantial damage. When
that occurs, the IEBC requires the building to be brought into compliance with the flood
damage - resistant provisions of the IBC (located in IBC Section 1612) . The IEBC also includes
provisions for historic structures that are located in SFHAs.
4.4 Determining Costs of Improvements and Costs to Repair
The term "costs of improvements" includes the complete costs associated with all of the types of
work that are described in Chapter 6. The term "costs to repair" includes the costs of all work
necessary to restore a damaged building to its pre- damage condition. Both terms include the
costs of all materials, labor, and other items necessary to perform the proposed work. Costs that
must be included are described in Section 4.4.1 and certain costs that may be excluded are de-
scribed in Section 4.4.2. Figure 4-2 illustrates the steps that local officials need to take in order
to determine costs for making SI /SD determinations.
The term "substantial damage" refers to the repairs of all damage sustained and cannot reflect
a level of repairs that is less than the amount of the damage sustained. If an owner does not
intend to repair the damaged building right away or if the owner cannot afford to make all re-
pairs immediately, the local official should inspect the property to determine whether, based on
estimates, the work required to restore it to its pre- damage condition will constitute substantial
damage. If this is the case, then the cost to repair is compared to the building's market value
and the local official should provide written notice to the owner of the substantial damage de-
termination. The local official should include in the written notice information about obtaining
permits and about the floodplain management requirements that must be met. Further, some-
times these buildings also are improved beyond their pre- damage condition. If proposed, then
the cost of improvements must be included along with the cost to repair to make the SI /SD de-
termination. Note that the substantial damage requirement applies regardless of the cause of
damage, such as wind or fire.
4 SI /SD DESK REFERENCE
MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
Review application for improvements and/
or repairs to determine nature and extent of
work, location of building, whether it is pre -
or post -FIRM (Chapters 4 and 5)
Review cost estimates and ensure
that all appropriate costs are
includedlexcluded
If post - disaster screening (Section 7.4)
indicates buildings may be
substantially damaged, use FEMA's SDE
(Section 7.5) or other method to
estimate costs
Figure 4 -2. Determine the cost of work (overview)
Determine cost of proposed Use the cost of work in the
work (Section 4.4) SI /SD determination
(Section 4.3)
The following topics related to determining costs will be
covered in this section:
• Costs that must be included
• Costs that may be excluded
• Acceptable sources of cost information
• Estimates of donated or discounted materials
• Estimates of owner and volunteer labor
• Demolition, debris, and disposal
• Clean -up and trash removal
Local officials will need to deter-
mine the necessary level of detail
for the costs of improvements and
costs of repairs from permit ap-
plicants or contractors in order to
make a SI /SD determination.
■ Cost exclusions to correct existing health, safety, and sanitary code violations
4.4.1 Costs That Must be Included in SI /SD Determinations
Items that must be included in the costs of improvement and the costs to repair are those that
are directly associated with the building. The following list of costs that must be included is not
intended to be exhaustive, but characterizes the types of costs that must be included:
■ Materials and labor, including the estimated value of donated or discounted materials
(Section 4.4.4) and owner or volunteer labor (Section 4.4.5)
■ Site preparation related to the improvement or repair (e.g., foundation excavation or filling
in basements)
■ Demolition and construction debris disposal (Section 4.4.6)
SI /SD DESK REFERENCE 4-5
4 MA SUB IMPR AND SUBSTANTIAL DAMAGE DETERMINATIONS
• Labor and other costs associated with demolishing, moving, or altering building components
to accommodate improvements, additions, and making repairs
• Costs associated with complying with any other regulations or code requirement that is
triggered by the work, including costs to comply with the requirements of the Americans
with Disabilities Act (ADA)
• Costs associated with elevating a structure when the proposed elevation is lower than the
BFE
• Construction management and supervision
• Contractor's overhead and profit
• Sales taxes on materials
• Structural elements and exterior finishes, including:
* Foundations (e.g., spread or continuous foundation footings, perimeter walls, chain -
walls, pilings, columns, posts, etc.)
Monolithic or other types of concrete slabs
* Bearing walls, tie beams, trusses
Joists, beams, subflooring, framing, ceilings
IV Interior non - bearing walls
III Exterior finishes (e.g., brick, stucco, siding, painting, and trim)
* Windows and exterior doors
It Roofing, gutters, and downspouts
ISM Hardware
9 Attached decks and porches
■ Interior finish elements, including:
It Floor finishes (e.g., hardwood, ceramic, vinyl, linoleum, stone, and wall - to-wall carpet
over subflooring)
8 Bathroom tiling and fixtures
Ot Wall finishes (e.g., drywall, paint, stucco, plaster, paneling, and marble)
Built -in cabinets (e.g., kitchen, utility, entertainment, storage, and bathroom)
Interior doors
Interior finish carpentry
Built -in bookcases and furniture
Hardware
Insulation
46 SI /SD DESK REFERENCE
MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
■ Utility and service equipment, including:
Heating, ventilation, and air conditioning (HVAC) equipment
Plumbing fixtures and piping
Electrical wiring, outlets, and switches
Light fixtures and ceiling fans
Security systems
Built -in appliances
Central vacuum systems
11 Water filtration, conditioning, and recirculation systems
4.4.2 Costs That May be Excluded from SI /SD Determinations
Items that can be excluded are those that are not directly associated with the building. The fol-
lowing list characterizes the types of costs that may be excluded:
• Clean -up and trash removal (Section 4.4.7)
• Costs to temporarily stabilize a building so that it is safe to enter to evaluate and identify
required repairs
• Costs to obtain or prepare plans and specifications
• Land survey costs
• Permit fees and inspection fees
• Carpeting and recarpeting installed over finished flooring such as wood or tiling
■ Outside improvements, including landscaping, irrigation, sidewalks, driveways, fences, yard
lights, swimming pools, pool enclosures, and detached accessory structures (e.g., garages,
sheds, and gazebos)
■ Costs required for the minimum necessary work to correct existing violations of health,
safety, and sanitary codes (Section 4.4.8)
■ Plug-in appliances such as washing machines, dryers, and stoves
4.4.3 Acceptable Sources of Cost Information
The costs of improvements and the costs to repair are necessary to make the SI /SD determina-
tion. The following are acceptable methods to determine the costs:
■ Itemized costs of materials and labor, or estimates of materials and labor that are prepared
by licensed contractors or professional construction cost estimators.
■ Building valuation tables published by building code organizations and cost - estimating
manuals and tools available from professional building cost - estimating services. These
sources can be used as long as some limitations are recognized, notably that there are local
SI /SD DESK REFERENCE 4-7
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
variations in costs and the sources do not list all types and qualities of structures. These
sources should not be used for structures that are architecturally unique, exceptionally large,
or significantly different from the classes of structures that are listed.
■ "Qualified Estimate" of costs that are prepared by the local official using professional
judgment and knowledge of local and regional construction costs. This approach is most
often used post- disaster when there are large numbers of damaged buildings and when
permits must be quickly processed.
■ Building owners may submit cost estimates that they prepare themselves. If the community is
willing to consider such estimates, owners should be required to provide as much supporting
documentation as possible (such as pricing information from lumber companies and
hardware stores) . In addition, the estimate must include the value of labor, including the
value of the owner's labor (Section 4.4.5).
FEMA developed the Substantial Damage Estimator, summarized in Section 7.5, to provide esti-
mates of building values and costs to repair. In general, this method is most often used in the
post- disaster period when local officials need to inspect large numbers of damaged structures
and make many substantial damage determinations.
4.4.4 Estimates of Donated or Discounted Materials
To help make improvements or repairs to damaged homes, some organizations and individu-
als donate materials, and some companies donate or provide materials at a discount. The value
placed on all donated or discounted materials should be equal to the actual or estimated cost
of such materials and must be included in the total cost Where materials or servicing equip-
ment are donated or discounted below normal market values, the value should be adjusted to
an amount that would be equivalent to that estimated through normal market transactions.
As part of the documentation required for a permit, the applicant should provide cost estimates
of the value of donated or discounted materials based on actual or estimated costs. This esti-
mate should be verified by the local official based on professional judgment and knowledge of
local or regional material costs. Some communities help non -profit organizations and appli-
cants make these estimates.
4.4.5 Estimates of Owner and Volunteer Labor
The situations described in Section 4.4.4 that involve donated or discounted materials may also
involve volunteer labor. Also, property owners may undertake fairly significant improvement
and repair projects on their own. In both cases, the normal "market" value or "going rate" for
labor must be included in the estimates of the cost of improvements and the costs to repair. Af-
ter significant events, labor rates may change and should be taken into account.
Labor rates vary geographically and by the nature of the work and trade required. As part of
the documentation required for a permit, the applicant should provide an estimate of the value
of owner or volunteer labor. The value placed on labor should be estimated based on appli-
cable minimum -hour wage scales for the skill and type of construction work that is done. This
4-8 SI /SD DESK REFERENCE
MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
estimate should be verified by the local official based on professional judgment and knowledge
of the local or regional construction industry wage scales. Some communities help non -profit
organizations and permit applicants make these estimates.
4.4.6 Demolition and Construction Debris Disposal
Demolition and construction debris disposal is not the same as clean -up and trash removal (Sec-
tion 4.4.7). Virtually any type of work on a building requires some demolition. It may be as little
as removing the flooring or an interior wall, or as much as complete removal of a portion of the
building and its foundation. Demolition may be part of an improvement project and usually is
a necessary part of repairing damage. The costs of demolition, including the costs of disposal of
the resulting debris, must be included in the cost of work for the purpose of making the SI /SD
determination.
4.4.7 Clean -up and Trash Removal
Clean -up and trash removal are distinguished from demolition and construction debris dispos-
al (Section 4.4.6). Clean -up and trash removal costs are not included in the costs used in the
SI /SD determination because they are not related to the actual cost of improving or repairing
a building.
Clean -up costs include such work as draining a basement; removing dirt and mud; and cleaning,
disinfecting, and drying out buildings. Trash removal includes disposing of trash piled in the in-
terior of the building or accumulated on the lot and related costs (e.g., dumpster, hauling, and
tipping fees), as well as removal of abandoned contents and debris related to general clean -up
of the structure before the improvement or repairs can be performed.
If clean -up and trash removal are done at the same time as demolition and construction debris
disposal, a cost estimate should clearly distinguish between costs that must be included and
costs that may be excluded. Local officials can:
■ Require property owners to submit itemized costs from all contractors, clearly identifying
the costs related to trash disposal and clean -up from those related to demolition necessary
to perform the work on the building, or
■ Based on judgment and knowledge of local costs, estimate the amounts to be excluded. The
permit record should contain documentation of the basis for making this estimate.
4.4.8 Costs to Correct Existing Health, Safety, and Sanitary Code Violations
The definition of substantial improvement provides an exclusion for "[a] ny project for improve-
ment of a structure to correct existing violations of State or local health, sanitary, or safety code
specifications which have been identified by the local code enforcement official and which are
the minimum necessary to assure safe living conditions" (emphasis added).
When deciding whether to exclude the costs to correct existing cited health, safety, and sanitary
code violations, local officials must consider the following:
SI /SD DESK REFERENCE 49
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
■ Correct existing cited violations. The work must be:
ro Limited to that necessary to correct an existing violation. This means that only work that
is directly required for correction can be excluded from the costs of the proposed im-
provement or repair. All other work must be counted in the estimation of costs.
Required to correct an existing violation. This means the condition considered in vi-
olation pre -dates the application for a permit (or the date of a damage event) and,
importantly, an official who has the authority to enforce the community's health, safety,
and sanitary codes must have prior knowledge of the condition and must have verified
that it constitutes a violation.
M Required to correct an existing violation Violations of a community's health, safety, and
sanitary represent threats to public health and safety. Such conditions are considered vi-
olations only if they have been identified as violations. The mere presence of a condition
that does not conform to current codes does not qualify as a violation.
■ Identified by the local code enforcement official. To exclude certain costs from the SI /SD
determination, an official who has the authority to enforce the community's health and
sanitary codes must have knowledge of and have identified the condition, and must have
verified or determined that the condition constitutes a violation (normally, this involves
issuing a citation or other official notice). Communities might not make a routine practice
of inspecting structures in order to document and issue citations for violations. If likely
violations of health and sanitary codes are identified by the property owner or contractor
during the course of deciding what work to perform and before any improvements or repairs
are made, the costs to address those code violations may be excluded, but only if the local
official has made the determination that they can be excluded.
■ Minimum necessary to ensure safe living conditions. To qualify as excludable, the cost of
correcting existing violations must be only those costs for the work that is the minimum
necessary to address and resolve the violation. Costs of work in excess of the minimum
necessary must be included in the SI /SD determination.
For proper treatment of this substantial improvement exclusionary provision, a clear distinc-
tion must be made between violations and elements that simply do not meet the present -day
design or building code standards The following examples describe situations where the work
performed to meet code requirements must be included in SI /SD determinations and some
situations where costs may be excluded
■ Work on a building, or work associated with a change in use or occupancy, may trigger
requirements for compliance with the current code. When this occurs, the costs associated
with compliance do not qualify for exclusion because the work is not a code violation, but is
necessary to meet current code. For example, consider an applicant who applies for a permit
to perform work necessary for a change of occupancy from retail space to a restaurant,
This will trigger certain code requirements and those costs must be included in the SI /SD
determination. Costs that are related to compliance with current code requirements, but
are not related to correcting existing violations must be included
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MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
• The owner of a poorly insulated building proposes to rehabilitate it for a new occupant.
Although the building does not conform to the current code for energy efficiency, the costs
of adding insulation and other energy efficiency work must be included because the lack of
adequate insulation is not a health and safety violation.
• An owner proposes to improve a building and has applied for a permit. The owner presents
the building official with evidence of termite damage. Termite damage is discovered in the
floor joints and the joists are unable to safely support loads required by current code. The
building official verifies that it constitutes a violation and cites it as a safety code violation.
The minimum cost to correct this violation may be excluded if the violation was cited. If
other building components have sustained termite damage that is not a safety code violation,
such as damage to non - bearing wall studs and wall trim, the cost to address the damage must
be included
■ A restaurant's plumbing system is failing and bathroom fixtures are inoperable. The
condition is cited as a violation of the sanitary code. The owner proposes not only to correct
the violation but make other improvements, including adding a second bathroom. The
costs to correct the failing plumbing system and replace its fixtures may be excluded The
costs of the other improvements, including the second bathroom, must be included
• In the course of inspecting an abandoned building, the code official cites several conditions
as violations that must be corrected before the building can be reoccupied. The building
is subsequently purchased and the new owner applies for a permit to not only address
the violations, but also to rehabilitate the building. Only the costs to correct the cited
violations that are explicitly related to health, sanitary, and safety code requirements may be
excluded All other costs associated with the rehabilitation must be included in the cost of
improvements.
• The owner of a home has been notified that the home is not safe to occupy because of
violations of the electrical code provisions. Rather than perform only the required repairs,
the owner decides to completely renovate the home and submits an application that
shows all renovation costs, while excluding the costs associated with all of the electrical
work (including replacing all wiring and fixtures, installing more outlets, upgrading the
panel board, etc.). The plan reviewer should catch this discrepancy. The only costs that may
be excluded are those that are necessary to correct the violation — which means the costs
associated with the code violation must be determined before they can be excluded from
the SI /SD determination. All other costs associated with the upgrade of the electrical work
must be included
4.5 Determining Market Value
For purposes of making SI /SD determinations, local officials need to determine the "mar-
ket value" of structures in question. When work is an improvement, the market value is the
building's market value "before the `start of construction' of the improvement." When work is
repair of substantial damage, the market value is the building's market value "before the dam-
age occurred." If buildings have not been maintained and have deteriorated over time, then the
market value is determined as of the date of the application for the permit to improve or repair
the building.
S1/SD DESK REFERENCE 4-11
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
The NFIP regulations do not define "market value." Generally, market value can be explained
as the amount an owner would be willing but not obliged to accept, and that a buyer would be
willing but not compelled to pay. The term may be defined by State statutes that pertain to zon-
ing, property taxation, or real estate transactions.
Before reviewing options to determine the market value of a structure, it is important to note
two basic NFIP requirements:
■ Market value must always be based on the condition of the structure before the improvement
is undertaken or before the damage occurred.
■ Only the market value of the structure is pertinent. The value of the land and site
improvements (landscaping, driveway, detached accessory structures, etc.) and the value of
the use and occupancy (business income) are not included. Any value associated with the
location of the property should be attributed to the land, not the building.
Many communities require the permit applicant to obtain an appraisal of market value from a
qualified professional who is licensed to perform appraisals in the State or community where
the property is located (Section 4.5.1) . In addition, three other methods to estimate market
value are covered in this section:
■ Assessed value developed for property tax assessment purposes, adjusted to approximate
market value (Section 4.5.2)
• Estimates of a structure's actual cash value, including depreciation (Section 4.5.3)
• "Qualified estimates" based on the professional judgment of a local official (Section 4.5.4)
Figure 4-3 illustrates the steps local officials need to take in order to determine market values.
Additional guidance on estimating market value following disasters is provided in Chapter 7.
412 SI /SD DESK REFERENCE
• Professional appraisal (Section 4.5.1)
• Adjusted assessed value (Section 4.5.2)
Select method to estimate
• Actual cash value (Section 4.5.3)
Use market value in
SI/SD determination
market value (Section 4.5)
• "Qualified estimates" (Section 4.5.4)
(Section 4.3)
• FEMA's Substantial Damage Estimator
■
(Section 7.5)
Use post - disaster screening
to identify buildings that have
sustained substantial
damage (Section 7.4)
Figure 4 -3. Determine the market
value (overview)
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MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
4.5.1 Professional Property Appraisals
Property appraisals that are prepared by a professional appraiser according to standard prac-
tices of the profession are the most accurate and reliable method for determining market value.
Professional appraisers should be qualified to appraise the type of property (e.g., residential,
commercial, industrial) and should be licensed in the State or community in which the proper-
ty is located. Most States require professional property appraisers to be licensed and to perform
valuation work in accordance with the quality control standards found in the Uniform Standards
of Professional Appraisal Practice, which are maintained and administered by The Appraisal Foun-
dation ( http:// NA , " iv.appraisalfotindation.oi - g). In those States that require use of the standards,
local officials should check that market value appraisals prepared to support SI /SD determina-
tions have a statement regarding conformance with this standard.
Appraisal reports should identify intended users, including the property owner, who can then
submit it as part of a permit application. In addition, the appraisal should be recent enough to
reasonably reflect current market value as of the date of the permit application. When used to
determine market value for damaged buildings, the appraisal must reflect the pre- damage con-
dition. The "market approach" for determining market value works best if there are adequate
market data and recent sales of comparable properties in the vicinity. Note that using the "in-
come capitalization approach" is not acceptable because it is based on how the property is used,
and not the value of structure alone. To separate the market value of a structure from the value
of the land on which it is located, appraisers may need to do more research than is normally un-
dertaken in order to reasonably allocate the total value between the structure and the land.
The following are situations where the local official may require the applicant to provide a pro-
fessional appraisal to determine the market value of a structure:
• When it is written explicitly into the community's floodplain management regulations or
required by other local or State codes that independent appraisals shall be used for decisions
related to non - conforming use permits.
• When the estimating methods that are used post- disaster (Section 7.4) yield a market value
that indicates that the cost of proposed work closely approaches 50 percent of the structure's
estimated market value.
• When an applicant disagrees with the community's SI /SD determination.
When a professional appraisal of market value is submitted, the local official is responsible for
examining it to determine that it is reasonable for the specific characteristics of the building
and to check that it does not include the value of land, land improvements (e.g., landscaping,
paving) , and accessory buildings. The market value of a non - residential building does not in-
clude the value of the use or occupancy. If there is cause to question the appraisal (for example,
if it appears to overvalue the structure), the local official may request that another appraisal be
provided.
SI /SD DESK REFERENCE 4-13
4 MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS
4.5.2 Adjusted Assessed Value
Generally, assessed values or property assessments are determined by the State or local taxing
or assessment authority. The assessor's job is to independently estimate the market value of real
property. Assessments usually provide both land value and value of improvements, and are used
as the basis for determining property taxes. Assessments are revised or adjusted periodically to
account for changes in property values. The use of assessed value has some limitations that, if
not considered and accounted for, can produce erroneous estimates of market value. These
limitations are:
■ Appraisal cycle. How often are the appraisals done and when was the date of the last appraisal?
Market value estimates can be grossly outdated if the cycle is long and the property happens
to be in the latter stage of its cycle and has not been appraised for many years.
■ Land values. In most cases, land values and the value of improvements (structures) thereon
will be assessed separately and listed as such in the tax records. In cases where they are not
distinguished, a determination of the value of the land will have to be made and subtracted
from the total assessed value.
■ Assessment level. States and local taxing authorities vary in assessment levels (an established
statutory ratio between the assessor's estimate of value and the true fair market value).
For example, many States use an assessment level of 90 percent. In this case, the assessed
values will underestimate market values by 10 percent. In cases where the assessment level is
unacceptably low or where the projected ratio of cost of repair to market value is close to 50
percent, adjustments for assessment level must be made.
Local officials who elect to use assessed values for making SI /SD determinations should consult
the authority that prepares the assessment values to understand the limitations on use of the
data. Usually an adjustment factor is necessary because the assessed values cannot be used as a
direct equivalent for current market value. The assessor's office should provide the adjustment
factor that, when applied to assessed value, yields the "adjusted assessed value" that can then be
used as an estimate of market value. A copy of the adjustment factor justification should be re-
tained with the community's permanent records.
Adjusted assessed value may be used as a screening tech-
nique to separate out structures for which the ratio of
repair or improvement costs to market value (adjusted as-
sessed value) are obviously less than or greater than 50
percent. In post- disaster situations where no other mar-
ket value estimates are available or where the number of
permit applications is overwhelming, unadjusted assessed
values may have to suffice as the definitive estimate of
market value.
"Unadjusted assessed values" can
be used to help local officials focus
their efforts when large numbers of
SD determinations must be made,
such as after a disaster (Section
7.3.2).
An owner may appeal the use of assessed value, but the burden of proof can be placed on the
applicant who can be required to submit an independent professional property appraisal that
is prepared by a qualified appraiser.
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MAKING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE DETERMINATIONS 4
4.5.3 Actual Cash Value
Actual cash value (ACV) is the cost to replace a building on the same parcel with a new building
of like -kind and quality, minus depreciation due to age, use, and neglect. ACV does not consider
loss in value simply due to outmoded design or location factors. The concept of ACV is used in
both the insurance industry and the construction industry. In most situations, ACV is a reason-
able approximation of market value.
A number of commercial sources of construction cost information are available to support es-
timating the replacement cost of a building, including industry- accepted guides available from
companies such as RSMeans (http: / /NN NiN and the Craftsman Book Company
( http : / /NN , NN , NN�.craftsman- book.com), among others. These sources allow computation of con-
struction costs based on occupancy, square footage, quality, and regional cost variations.
Depreciation accounts for the physical condition of a structure. Depreciation does not take
into account functional obsolescence (e.g., outmoded design or construction that pre -dates
current codes) or factors that are external to the structure (e.g., reputation of schools or dis-
tance to shopping and parks). Commercially available references provide tables and formulas
to calculate physical depreciation. These tables and formulas are objective and are used by most
professionals in the fields of property appraisal and building inspection. Local officials may
consult with a qualified appraiser regarding depreciation, or additional guidance for applying
depreciation rates over time is found in FEMA P -784 CD, Substantial Damage Estimator (Section
7.5).
4.5.4 Qualified Estimates
A "qualified estimate" of a structure's market value is an estimate developed by a qualified local
official who has sufficient experience and professional judgment on which to base such esti-
mates. The local official may be in the building department or in the tax assessor's office. The
estimates should be made using the best available information, which may include recent permit
records, recent home sales, regional cost data, estimates of depreciation based on knowledge
of the pre- damage condition of buildings, and adjustments for unique or distinctive features of
individual buildings. Another way that a local official may develop qualified estimates is if pro-
fessional appraisals have been prepared for a few buildings; in that case, those results may be
used to approximate the market values of similar buildings. This approach should be used only
if the approaches described above cannot be used. Qualified estimates are most likely to be used
in the post- disaster situation after large numbers of buildings have been damaged.
SI /SD DESK REFERENCE 415
5 Administering Substantial
Improvement and Substantial
Damage Requirements
5.1 Overview
This chapter covers administrative topics, including community responsibilities and the re-
sponsibilities of property owners and permit applicants. It highlights options for informing the
public about the SI /SD requirements and the need to get permits. Several matters that arise
when reviewing permits are addressed in detail.
Chapter 4 focused on making SI /SD determinations and the data that are necessary to make
those determinations, including the cost of improvements, the cost of repairs, and the market
value of buildings. Chapter 6 includes illustrations of SI /SD, and explains certain NFIP flood
insurance implications related to SI /SD. Chapter 7 recommends ways to handle substantial
damage in the post- disaster period, especially when many buildings are damaged. Chapter 8
provides brief descriptions of common types of flood mitigation projects that may be eligible
for funding by FEMA's five Hazard Mitigation Assistance grant programs.
5.2 Community Responsibilities
When a community decides to participate in the NFIP, it accepts the responsibility to adopt,
administer, and enforce floodplain management provisions that either meet or exceed the min-
imum NFIP requirements. The following describes the responsibilities that specifically apply to
administering the SI /SD requirements:
■ Review permit applications to determine whether
improvements or repairs of buildings in SFHAs
constitute substantial improvement or repair of
substantial damage.
■ Review descriptions of
by applicants to ensure
addressed.
proposed work submitted
that all requirements are
Even if work on a building is de-
termined to not constitute SI /SD,
owners can do a lot to reduce
future flood damage. Some rec-
ommendations that local officials
may wish to encourage are listed
in Section 5.8.
■ Review cost estimates of the proposed work submitted
by applicants and determine if the costs are reasonable for the proposed work, or use other
acceptable methods to estimate the costs.
■ Decide the method to determine market value (including which method to use after an
event that damages many buildings) and identify the buildings most likely to have sustained
substantial damage.
SI /SD DESK REFERENCE 5 -1
5 ADMINISTERING SUBSTANTIAL IMPROVEMENT AND S DAMAGE REQ
■
Review market value appraisals, if submitted by applicants, to determine if the appraisals
reasonably represent the characteristics of the building and the market value of the structures
(excluding land value).
■ Determine if proposed improvements are substantial
improvements based on the costs of the proposed
work compared to the market value of the building.
■ Determine if damaged buildings are substantially
damaged based on cost estimates for repairs compared
to the market value of the building before the damage
occurred.
■ Issue a letter to the property owner to convey the
SI /SD determination. If NFIP- insured buildings
Local building officials have the au-
thority to condemn buildings that
are judged to be unfit for occupan-
cy. Judging whether to condemn a
building and making a determination
of substantial damage are separate
decisions. A condemned building
might not be substantially damaged
and a substantially damaged build-
ing might not have conditions that
warrant condemnation.
are substantially damaged by flooding, this letter is
necessary for owners to file an Increased Cost of Compliance (ICC) claim to help pay to
bring buildings into compliance (Section 7.6).
■ Retain all versions of the Flood Insurance Rate Maps (FIRMS) and allow citizens to access the
maps. The most recent map, called the "effective" map, is to be used to regulate development,
including substantial improvements. Earlier versions of the maps are necessary to verify BFE
data for post -FIRM buildings that pre -date the current effective maps.
■ Maintain in the permit file specific information on all development that occurs within the
SFHA and make this information available for public inspection. The documentation should
include the lowest floor elevations, other pertinent elevations such as for machinery and
equipment, and flood protection designs.
■ Conduct periodic field inspections during construction to ensure that development complies
with issued permits, work with builders and property owners to correct deficiencies and
violations, and check for unpermitted development.
■ Perform assessments after events that cause damage, inform property owners of the
requirement to obtain permits for repairs, and determine whether the damage qualifies as
substantial damage.
■ Coordinate with property owners and insurance adjusters regarding NFIP flood insurance
claims and ICC coverage.
5.3 Property Owner /Applicant Responsibilities
Property owners and applicants for permits have certain responsibilities that are implicit when
a community adopts regulations and building codes that apply to their properties. First and
foremost, they have a responsibility to comply with the requirements that are enforced by
communities, including floodplain management requirements. The following is a summary of
those responsibilities pertinent to the SI /SD requirements:
■ Find out if a permit is required. Most property owners — and all contractors — understand
that permits are required for some types of work. It is common for owners to specify
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ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
that contractors obtain permits. However, sometimes owners assume that contractors
automatically do so and, as a result, the work may be undertaken without permits. Legally,
the responsibility lies with the owner.
■ Submit complete information about all proposed improvements and all repairs to be
undertaken, including the costs of all work (and valuations of work that the owner or
volunteers will perform, including estimated costs of donated materials).
■ Share information from insurance claims adjusters, if requested by the local official.
■ Provide a professional appraisal of the market value of the building if requested by the local
official (or accept the market value estimation made by the local official).
■ Comply with the approved plans and limitations specified in the issued permit and the
approved construction documents.
■ Inform the local official if new work is to be added to the work already authorized by an
issued permit. New work must be reviewed to determine whether the community's floodplain
management regulations apply.
■ Contact the community to schedule inspections at the appropriate times and submit surveyed
elevation data when required by the local official.
■ Provide "as- built" surveyed elevation data (e.g., FEMA's Elevation Certificate) to the local
official to determine compliance (the Elevation Certificate also is necessary for insurance
agents to determine the appropriate rate for NFIP flood insurance policies).
■ Maintain enclosed areas below elevated buildings as compliant enclosures by not altering any
aspect required by the permit, including limitations on use for parking of vehicles, building
access, and storage.
5.4 Important Community Actions
Communities routinely process permit applications for work on existing buildings. For build-
ings located in SFHAs, work that constitutes substantial improvement triggers the requirement
to bring buildings into compliance. Some property owners may view this as an undue burden
that may cost them considerably more than the work originally proposed. Therefore, it is im-
portant that communities have a well - established process that treats all owners in a consistent
manner. This is especially important in communities that have large numbers of buildings in
their floodplains that could be damaged by a single event.
The remaining sections of this chapter will describe the following important community actions
with respect to SI /SD:
■ Informing the public (application forms, websites, handouts)
■ Administering the SI /SD requirements
■ Exceeding the NFIP minimum floodplain management requirements
■ Recommendations to improve flood resistance
SI /SD DESK REFERENCE 5 -3
5 ADMINI SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
5.5 Informing the Public
Most property owners understand that building permits are required when they want to have
work done on their buildings. However, they are rarely aware of the requirements that ap-
ply when buildings are located in SFHAs. Informing the public about the requirements may
alleviate some of the difficulties that can occur when uninformed owners apply for permits. Suc-
cessful outreach methods employed by communities include:
• Permit counter staff and inspectors are trained and familiar with the SI /SD requirements
and other requirements for development in SFHAs and they all convey the same message
when talking with property owners and contractors.
• Permit application forms or supplements to applications are designed specifically to capture
information about work proposed for buildings in SFHAs.
• Handouts at the permit counter explain floodplain requirements, including the SI /SD
requirements.
• Information is posted online about permit requirements, including SI /SD requirements in
the SFHA.
• Newsletters and brochures are used for periodic mailings, such as those described in guidance
materials developed for the NFIP's Community Rating System (Section 5.7.1) .
5.5.1 Permit Application Forms
A permit is required for almost every type of de-
velopment that is proposed in the mapped SFHA. Forms and checklists help. ensure
that all applicants are treated con -
Local permit application forms should be designed sistently. They also make it easy
to collect the information needed to make SI /SD de- for the local official to document
terminations. Permit forms should require applicants SI /SD determinations and to retain
(or their contractors) to provide detailed descriptions that documentation in permanent
of the proposed work and detailed breakdowns of the records.
costs of work, as this information is essential for mak-
ing SI /SD determinations. Some communities that have many buildings in their SFHAs
have developed detailed permit application forms to help them review proposals for work in
SFHAs, including work on existing buildings.
Appendix D includes a sample notice called "Sample Notice for Property Owners, Contrac-
tors, and Design Professionals" that includes a summary of the "50% rule," information about
property valuation, a list of items to be included and excluded in the cost of work, and a cost -
breakdown sheet. The sample notice includes two affidavits to be signed by the owner and the
contractor. The affidavits are used to confirm that the work described in an application is all of
the work that will be done.
5.5.2 Websites and Handouts
Most communities have websites designed to provide information for their citizens. Websites
often include sections to explain requirements for various permits and approvals. Some even
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ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
have online permit application capabilities. Increasingly, citizens, designers, and contractors
are turning to websites to learn about regulations and requirements. Posting information on-
line about development requirements in SFHAs is helpful for communities and their citizens.
Despite the increased use of the Internet, most communities still provide printed materials.
Many communities distribute newsletters and brochures to their citizens, including materials
related to flood hazards, flood insurance, and SFHA construction requirements.
5.6 Administering the SUN Requirements
The NFIP requires communities to review all applications for development in SFHAs and to ap-
ply their floodplain management regulations and building codes to work that is proposed on
existing buildings. Chapter 4 described making SI /SD determinations, estimating costs, and es-
timating market values. This section addresses several topics that local officials encounter when
administering floodplain management regulations and building codes pertaining to SI /SD:
■ Combinations of types of work
■ Phased improvements
■ Incremental repair of damaged buildings
■ Damaged buildings
■ Special circumstances (involving damaged buildings)
■ Appeals of decisions
■ Variances to the requirements
■ Floodways
■ V zones
■ Coastal Barrier Resource Areas
■ Revisions of the FIRM
■ Inspections
■ Enforcement and violations
■ Recordkeeping
■ Issuing SI /SD determination letters
■ Rescinding SI /SD determinations
5.6.1 Combinations of Types of Work
It is common for local officials to see applications for combinations of improvements and repairs.
In these cases, the combined cost of all work must be used to make the SI /SD determination.
For example, it is common for property owners who are making necessary repairs to dam-
aged buildings to also include elective improvements. Communities must require applicants to
SI /SD DESK REFERENCE 5 -5
5 ADMIN SUBSTANT IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
provide the estimated costs of all proposed improvements and repairs. The total cost is then
used to make the SI /SD determination, comparing it to the pre- damage or pre- improvement
market value of the building. Section 6.4 illustrates examples of types of work that local officials
may see combined in permit applications.
5.6.2 Phased Improvements
The term "phased improvement" refers to a single im-
provement that is broken into parts. For a number of
reasons, owners may wish to schedule anticipated im-
provements over a period of time, and they may request
separate permits for each phase. Local officials should
take care to ensure that phased improvements do not cir-
cumvent the substantial improvement requirements.
Concern about phased improve-
ments is one reason why some
communities adopt requirements
that accumulate the value of im-
provements over time (Section
5.7.3).
Experienced plan reviewers can usually tell if the work described in a permit application ad-
equately identifies all of the work needed to complete the improvement. One approach is to
remind the applicant that the application is a legal document and that it is the applicant's
responsibility (or the responsibility of the applicant's design professional or contractor) to ac-
curately complete the application. It is also reasonable for the local official to request that the
applicant state, in writing, that the work proposed is all of the anticipated work and that the
work can be done for the stated cost estimate.
Some communities address deliberate phasing of improvements in the permit application or
other document. Appendix D includes sample affidavits that the community may require be
signed by owners and contractors to confirm that the work described in an application is all of
the work that will be done.
Other scenarios of phased improvements include:
■ Incomplete work. Permits should not be issued for work that clearly will not result in a
building that can be occupied without additional work. For example, while a community
may decide to issue one permit for the foundation, framing, and roof of an addition, and
a second permit at a later time to complete the remaining work necessary for occupancy
(electrical, plumbing, flooring, etc.), the SI /SD determination must be made prior to
issuance of the first permit, and must consider the cost of all work regardless of the number
of permits issued.
■ Multiple permits. Some jurisdictions, especially larger cities and counties, issue separate
mechanical, electrical, plumbing, and building permits. If handled by different offices,
coordination is especially important so that the value of all work is combined for the SI /SD
determination, regardless of the number of permits issued.
■ Consecutive permits. If an application for a second permit is submitted within a short
period of time after the first permit is issued, the local official should examine whether the
work covered by the second request is related to improvements to the building. If so, then
the work must be evaluated in conjunction with the first permit to determine whether the
combination constitutes substantial improvement. The substantial improvement regulations
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ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMA REQ 5
apply to all of the work that is proposed as the improvement, even if multiple permits are
issued. Therefore, the determination of the cost of the improvement should consider all
costs of all phases of the work before issuance of the first permit.
■ Modification of issued permits. A request to modify an existing permit to add work could
retroactively trigger substantial improvement. It is common that a permit is issued to
repair a damaged structure, and the owner subsequently decides to have some additional
improvements done. Whether the community handles this as a modification of the
initial permit or issuance of a second permit, care must be taken to reevaluate the SI /SD
determination. Local officials must verify that the proposed repair work includes all of the
anticipated work, including improvements to the building.
■ Unauthorized work. If unauthorized work on a building in the SFHA is discovered, the
enforcement action taken by the community must include making an SI /SD determination.
The costs must include all of the work that has been performed, plus all of the remaining
work necessary to complete the project.
5.6.3 Incremental Repair of Damaged Buildings
"Incremental repairs" are similar to phased improvements and refer to a single repair project
that is broken into parts. When buildings have sustained damage, regardless of the cause, it
is fairly common for some owners to undertake restoration and repairs over a period of time.
Sometimes the initial work is only the minimum necessary to make the building safe enough to
reoccupy (provided reoccupancy is allowed by the community). Sometimes the owner's finan-
cial situation does not allow all of the repairs to be done at the same time.
The definition of "substantial damage" makes it very clear that the substantial damage determi-
nation must consider all costs necessary to restore damaged structures to their before - damage
condition. Even if an owner elects to perform less work or make repairs over time, the commu-
nity must require the applicant to provide an estimate of the costs to fully restore the structure.
Section 4.4 includes guidance on estimating the costs of work performed by the owner or vol-
unteers and the costs of donated or discounted materials.
5.6.4 Damaged Buildings
Most damage occurs during a single and sudden event,
such as a fire, high wind, lightning strike, falling tree,
tornado, earthquake, flood, natural gas explosion, etc.
However, buildings also may be damaged by causes that
are not related to a specific event. These causes include
soil settlement, exposure to the elements, termite infesta-
tion, vandalism, deterioration over time, and other causes.
Regardless of the cause of damage, when owners apply for
permits to repair, communities must determine whether
the building is substantially damaged.
Property owners should check their
insurance policies. Policies that
include "law and regulations" cov-
erage may cover costs associated
with complying with requirements
to bring buildings into compliance
with flood provisions in local flood -
plain ordinances or building codes.
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5 ADM I N I S TERIN G SU B S TANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
With respect to making substantial damage determinations, costs to repair must include all costs
that are necessary to repair a building to its pre- damage condition, even if the owners elect to
perform only some repairs or incremental repairs (Section 5.6.3).
If a community suffers damage to only a few buildings,
then the permits for repairs generally can be handled Issuance of an SD determination
under a community's standard permit processing proce- does not necessarily indicate that
dures. Communities that have a large number of buildings a building is unsafe, unfit for occu-
Panay, or condemned.
in their floodplains should decide in advance how best to
handle inspecting damaged buildings and making sub-
stantial damage determinations (Chapter 7). In those circumstances, FEMA's Substantial Damage
Estimator (SDE) software provides an effective and efficient approach for developing reasonable
estimates of the values of buildings and costs to repair or reconstruct buildings (Section 7.5).
Local officials should become familiar with the ICC coverage that is part of NFIP flood insurance
policies. ICC claims are only paid on buildings in the SFHA that the local official determines
to be substantially damaged or that have sustained repetitive flood damage that qualifies under
the policy. ICC can provide policyholders with up to $30,000 towards costs necessary to bring a
building into compliance with the community's floodplain management requirements. ICC is
described in Section 7.6.
5.6.5 Special Circumstances (Damaged Buildings)
Communities should be aware of a number of special circumstances that may arise when deal-
ing with damaged buildings:
■ Change of ownership. Sometimes owners sell damaged buildings in SFHAs before repairs
are undertaken. Change of ownership does not have any bearing on the substantial damage
determination. Regardless of whether the determination is made before or after the sale, it
is to be based on the value prior to the date of damage.
■ Multiple flood events. Communities may have to address damage resulting from multiple
flood events. All affected structures should be handled consistently:
N If no repairs are made to a structure after a flood, and a second flood causes additional
damage, local officials must include all costs to repair damage from both events. The
market value of the building used in making an SI /SD determination is the value prior
to the first flood. If that value cannot be determined, the market value prior to the sec-
ond flood should be used.
No If some or all repairs are made after a flood (and the cost to repair to the structure was
determined to not be substantial damage), and a second flood causes damage that must
be evaluated to determine whether the building was substantially damaged, then the
market value is the value prior to the second flood.
■ Conditions discovered in the course of doing work. Occasionally, additional damage is
discovered during the course of work that has been authorized by a permit. For example,
termite damage or other conditions may not have been identified before the permitted
work is started, but it is discovered once work is underway. Such conditions may reduce the
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ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
capacity of the load- bearing members or otherwise result in damage to the building. After
the condition is revealed, if the work that is required to address the discovered condition
triggers a change in the permit, the community must reevaluate the SI /SD determination.
The costs of the new work must be added to the cost of the improvement. The market
value of the building that was used in the original determination is used in the revised
determination.
5.6.6 Appeals of Decisions
An applicant for a permit may appeal a decision, order, or determination that was made by the
local official. This occurs most often if there is ambiguous language in a code or regulations
that leads to differing interpretations. Typically, appeals are heard by a board designated to hear
such cases, which may go by a variety of names (board of appeals, board of adjustments, etc.).
In some small communities, the function may be handled by the jurisdiction's governing body
(town council, board of selectmen, etc.).
An owner may appeal the local official's finding or determination that the proposed work con-
stitutes SI /SD. The owner may appeal an SI /SD determination on the basis of insufficient
information, errors, repair/ improvement costs that should be included/ excluded, inappropri-
ate valuations of costs for the proposed work, or an inappropriate method to determine the
market value of the building.
It is not appropriate for an owner who wishes to build in a manner that is contrary to the regula-
tions and codes to seek an appeal. In those cases, the owner would seek a variance.
5.6.7 Variances to the Requirements
A variance is a grant of relief from the terms of a land use, zoning, or building code regulation.
If granted, it allows construction in a manner that is otherwise prohibited. The burden of deter-
mining whether to grant a variance rests on the community.
The primary goals of the NFIP and local floodplain man-
agement regulations and codes are the reduction of
damage and protection of public health and safety. Be-
cause a variance from the requirements for construction
in SFHAs can create an increased risk to life and prop-
erty, local officials should carefully consider requests for
variances from flood elevation or other floodplain man-
agement requirements.
The NFIP regulations do not set forth absolute criteria
NFIP flood insurance policies on
post -FIRM buildings and substan-
tially improved buildings that do
not comply with the NFIP require-
ments, even if authorized by a
properly issued variance, are rated
according to risk. The cost will be
high if a variance allows the low-
est floor to be below the BFE (see
Figure 6 -14 in Section 6.6).
for granting variances [44 CFR § 60.6] . The regulations
outline procedures that communities must follow (see FEN 1A 480, F000dplain Management Re-
quirements: A Study Guide and Desk Reference for Local Officials for additional guidance on handling
variances). Variances shall only be issued based on the following:
■ A showing of good and sufficient cause;
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5 ADMINISTERING SUBS TANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
■ A determination that failure to grant the variance
would result in exceptional hardship (consistent with
usage related to land use and zoning, in this context a
"hardship" must be related to the land, not a financial
or personal circumstance of the owner);
■ A determination that granting the variance will not
result in increased flood heights, additional threats
to public safety, extraordinary public expense, create
nuisances, cause fraud on or victimization of the public,
or conflict with existing local laws or regulations; and
■ Evidence that the variance is the minimum necessary
to afford relief, considering the flood hazard.
As a guiding principle, a variance should pertain to the
unique characteristics of the land itself. A properly issued
variance may be granted for a parcel of land with physical
characteristics so unusual that complying with the regu-
lation or code would create an exceptional hardship for
the applicant. However, a variance should not be granted
based on the personal circumstances of an individual.
Insufficient justifications for vari-
ances to the SI /SD requirements
include:
■ Inconvenient access to an ad-
dition
■ Difficult access for those with
physical limitations
■ Too costly to comply
■ The owner does not plan to
get flood insurance
■ Building will look different
■ Building will need a waiver of
height limitations
Sometimes variances are sought because the owner or the designer believes they will not be
able to meet the community's floodplain management regulations. Usually there are alternative
ways to comply that would negate any purported justification for a variance, and local officials
should require consideration of those alternatives before acting on variance requests. Typical
characteristics of a parcel of land that might justify a variance include an irregularly shaped lot,
a parcel with unsuitable soils, or a parcel with an unusual geologic condition below ground lev-
el. However, it is unusual that any physical characteristic would give rise to a hardship that would
be sufficient to justify issuing a variance to the elevation requirement.
A community that grants a variance based on the above evidence and according to FEMA guid-
ance does not jeopardize its standing in the NFIR However, FEMA and the States periodically
evaluate how effectively communities administer their floodplain management requirements.
FEMA becomes concerned when there is a pattern of variances that suggest the practice is used
to circumvent requirements.
Communities that administer the I -Codes may handle variances to the flood provisions through
their boards of appeals. Unless the State or community has modified or replaced the adminis-
trative provisions, the IRC specifies that the building official will review information provided
with permit applications for work on buildings in SFHAs. The official will make a finding based
on the cost of the proposed work and the market value of the building and, if the results indi-
cate the work is a substantial improvement, the finding is forwarded to the board of appeals
for a final determination. Communities have a board of appeals (which might go by another
name) to hear and decide appeals of orders, decisions, or determinations made by the building
official. The IRC outlines specific responsibilities of the board when hearing matters related to
5 -10 S1/SD DESK REFERENCE
ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
structures in SFHAs, including:
■ Determination of substantial improvement in areas prone to flooding. Requires the board
of appeals to evaluate the building official's finding regarding the value of proposed
improvements to determine if the work constitutes SI /SD.
■ Criteria for issuance of a variance for areas prone to flooding. Sets forth specific criteria,
consistent with the minimum NFIP requirements, to be applied in the review and
consideration of variances to the minimum flood hazard area requirements.
5.6.8 Floodways
Local officials must examine proposals for work on build-
ings that are located in floodways to determine whether
the work constitutes SI /SD. If a building is located in a
floodway, bringing it into compliance may involve a flood-
way encroachment analysis. The NFIP regulations require
that this analysis be performed for any work that encroach-
es into a floodway [44 CFR § 60.3 (d) (3) ] . If the analysis
indicates any increase in the BFE, the local official must
not allow the proposed work.
The analysis that is performed to delineate floodways
takes into consideration existing encroachments and ob-
The NFIP defines the floodway as
the channel or other watercourse
and the adjacent land areas that
must be reserved in order to dis-
charge the base flood without
cumulatively increasing the wa-
ter surface elevation more than a
designated height. Floodways are
delineated along most waterways
that are studied using detailed
methods.
structions (including buildings) that were present at the
time the data were collected for the analysis. This means that proposals for work on existing
buildings that are located in a floodway are evaluated based on whether the exterior dimensions
(footprint) of the original buildings will be increased, as follows:
■ No change to footprint. Substantial improvement that does not expand the footprint might
be an interior -only renovation or an added story. If the actions necessary to bring the building
into compliance do not increase the exterior dimensions, a floodway encroachment analysis
is not required. Note that enclosing a deck that is below the BFE to change it to livable space
should be treated as an addition even though the work does not increase the footprint; the
addition becomes an encroachment in the floodway and an analysis must be prepared.
• Increase in footprint, substantial improvement. Ifwork that increases the footprint (including
an increase in fill, if used for elevation) involves an addition (or a combination of interior
work and an addition) is determined to be a substantial improvement, the building must be
brought into compliance. In this case, a floodway encroachment analysis is required because
the exterior dimensions will be increased. A permit for the increase in footprint cannot be
issued if the analysis indicates any increase in the BFE. An option that may decrease the
effects of encroachment is to elevate additions on open foundations (piers or columns).
• Increase in footprint, non - substantial improvement. Local officials must review all proposed
development in SFHAs and authorize the development by issuing permits. Development
includes additions that do not constitute substantial improvements. If located in a floodway,
a proposal to expand the exterior dimensions of a building with an addition that is not
SI /SD DESK REFERENCE 5 -11
5 ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
a substantial improvement must be supported with a floodway encroachment analysis.
Although the NFIP regulations do not require that the addition be elevated and meet all
other requirements of the NFIP, the addition may be a potential encroachment into the
floodway that must be evaluated. If the floodway analysis indicates any increase in the BFE,
a permit cannot be issued for the addition.
5.6.9 V Zones
Local officials must review proposals to improve struc-
tures that are located in V zones to determine compliance
with the NFIP's V zone provisions, as well as the require-
ments for substantial improvements found in 44 CFR
§ 60.3(e). In V zones, new and substantially improved
buildings must:
■ Be elevated on open foundations (pilings or columns)
that allow floodwaters and waves to pass beneath the
elevated buildings
■ Be elevated so that the bottom of the lowest horizontal
structural member of the lowest floor is at or above
the BFE
In V zones, a registered profes-
sional engineer or architect shall
develop or review the structural de-
sign, specifications, and plans and
shall certify that the design and
methods of construction are in ac-
cordance with accepted standards
of practice to meet the V -zone
requirements.
• Have the foundation anchored to resist flotation, collapse, and lateral movement due to the
effects of wind and water loads acting simultaneously on all building components
• Have the area beneath the elevated building free of obstructions that would prevent the free
flow of floodwaters and waves during a base flood event
• Have utilities and building service equipment elevated above the BFE
• Have the walls of enclosures below the elevated building designed to break away under base
flood conditions without transferring loads to the foundation
Section 6.4 describes some of the more common exam-
ples of improvements and repairs and descriptions of how
property owners and contractors can meet NFIP require-
ments (also see Tables 6 -la and 6-1b). It is important to
note again that work on a post -FIRM building cannot be
allowed if it would make the building non - compliant with
the floodplain management requirements that had to be
met when the building was constructed.
5.6.10 Coastal Barrier Resource Areas
All substantially improved build-
ings in V zones must be elevated.
Floodproofing is not allowed in V
zones, even for non - residential
buildings.
The Coastal Barrier Resources Act of 1982, and later amendments, prohibits the NFIP from
providing flood insurance for structures built or substantially improved after October 1,
1983, in any areas designated as undeveloped coastal barriers. These areas are mapped and
designated by Congress as units of the Coastal Barrier Resource System (CBRS) and are shown
5 -12 SI /SD DESK REFERENCE
ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
on FIRMS. The FIRMS also show areas designated as Oth-
erwise Protected Areas (OPAs), which include portions
of coastal barriers that are used primarily for natural re-
sources protection and are owned by Federal, State, and
local governments or by certain non -profit organizations.
Local officials must process permit applications for re-
pairs and improvements to buildings in CBRSs and OPAs.
If the work is SI /SD, then it must comply with the mini-
Permits are required for new con-
struction and for improvements of
existing buildings in CBRSs and
OPAs. Communities are required to
administer their floodplain manage-
ment regulations even if Federal
flood insurance is not available for
new buildings and substantially im-
proved buildings in these areas.
mum requirements of the NFIR It is important to realize
that pre -FIRM buildings in CBRSs and OPAs that qualified
for NFIP flood insurance may lose that eligibility if they are substantially improved or sustain
substantial damage. Federal flood insurance may be obtained for a structure in the OPA if writ-
ten documentation certifies that the structure is used in a manner consistent with the purpose
for which the area is protected.
5.6.11 Revisions of the FIRM
In many communities, flood hazard maps have been re-
vised to reflect new floodplain studies, better flood data,
improved topographic data, new encroachments and
bridges, and for other reasons. When flood hazard maps
are revised, either the SFHAs expand in area and the
BFEs increase, or the SFHAs reduce in area and the BFEs
decrease. Map revisions may reflect changes in communi-
ty boundaries, zone designation, new floodway delineations, or changes in floodway boundaries.
Also, A zones without BFEs may be studied and shown with BFEs, or waterways that were previ-
ously unmapped may be shown with SFHAs.
Communities must maintain all versions of their Flood Insurance Studies (FISs) and flood
hazard maps. This is an important responsibility because it affects consideration of work on
buildings constructed in compliance with a map that pre -dates a current effective map. Section
6.4.8 describes repairs and improvements on post -FIRM buildings where there have been revi-
sions to the FIRM.
5.6.12 Inspections
Even when building permits and construction plans are complete, proper inspections during
construction are important to determine whether any work has deviated from the approved
permits and plans. Building inspectors need to understand the flood damage - resistant design
and construction requirements that they are to check during inspections. If deviations from the
conditions of a permit or plans are discovered early during construction, it will be easier to work
with the owner and builder to achieve compliance through corrective actions.
Using a plan review and inspection checklist can make inspections easier because the inspec-
tor has a standardized summary of floodplain management requirements. A checklist also
The NFIP expects communities to
maintain copies of all flood hazard
maps, even those that have been
replaced with revised maps. This is
especially important when work is
proposed on post -FIRM buildings.
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5 A D MI NISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
documents the inspection, which can be important if
questions arise regarding compliance.
The following inspections are recommended for build-
ings that are required to be brought into compliance with
the floodplain management requirements for new con-
struction and substantial improvements:
■ Footing or Foundation Inspection. Buildings and
additions that are elevated on solid perimeter
foundation walls create enclosures below the elevated
buildings (e.g., crawlspace or underfloor space).
Inspectors should check for the specified number, size,
The NFIP requires communities
to obtain and retain documenta-
tion of the lowest floor elevations of
new buildings and substantially im-
proved buildings. FEMA's Elevation
Certificate is designed specifically
for this purpose.
FEMA's Floodproof!ng Certificate
is designed to satisfy the documen-
tation requirements when non -res-
idential buildings are proposed to
be dry floodproofed.
and location of flood openings. The bottom of each
flood opening must be no higher than 1 foot above finished exterior grade or interior floor;
flood openings should not be confused with underfloor air ventilation openings, which are
located just under the floor level. For slab -on -grade (and stemwall) foundations, the lowest
floor inspection is also conducted at this time.
■ Lowest Floor Inspection. The best time to verify compliance with the elevation requirement
is after the lowest floor elevation is set, but before further vertical construction takes place.
An error in elevation of a foot or two may seem minor, but corrective action can be expensive
and complicated if that error is discovered after the walls and roof are in place.
■ HVAC Inspection. Verify that utilities and mechanical equipment are elevated or designed
to prevent water from entering or accumulating within the components during conditions
of flooding [44 CFR § 60.3 (a) (3) 1. Frequently overlooked items include heating, ventilation,
and cooling equipment; electrical outlets; plumbing fixtures; and ductwork that is installed
under the floor, usually in a crawlspace.
■ Enclosure Inspection. Inspect enclosures below elevated buildings to ensure that they comply
with the limitations on use (parking, building access, or storage), protection of HVAC
described above, the use of flood damage- resistant materials, and the specific requirements
based on the flood zone (openings in A zones or breakaway walls in V zones) .
■ Final Inspection. A final inspection to document compliance can be performed at the same
time as the final inspection to issue the occupancy certificate. During final inspections:
Collect the "as- built" documentation of elevations prior to the final sign -off and issuance
of occupancy certificates.
If used, complete and sign the plan review and inspection checklist and place all inspec-
tion reports in the permit file.
5.6.13 Enforcement and Violations
Proper enforcement of the floodplain management provisions is a critical part of fulfilling a
community's responsibility under the NFIP. During construction, violations of the provisions
must be resolved as soon as they are discovered and before further construction takes place.
What may first appear to be a minor violation could turn out to be a significant issue that not
5 -14 SI /SD DESK REFERENCE
ADMINI SUBS TANTIAL I M PR O V EMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
only exposes property owners and occupants to future
flood damage, but results in higher NFIP flood insurance
policies.
If the community has exhausted legal means to remedy a
violation and the owner refuses to resolve the matter and
bring the building into compliance, the community may
cite the structure as a violation in accordance with Sec.
1316 of the National Flood Insurance Act of 1968. This
The NFIP expects communities to
attempt all reasonable actions to
bring violations into compliance.
When such attempts are unsuc-
cessful, the community should
contact the NFIP State Coordinator
or the FEMA Regional Office for
advice.
provision allows the NFIP to deny flood insurance on the building that remains in violation, and
on all other insurable buildings on the property. Owners who refuse to resolve violations should
be informed that denial of flood insurance can have significant consequences: the property may
be difficult to sell; the owner may have problems with the mortgage lenders if flood insurance
cannot be maintained; and future Federal disaster assistance may be denied.
A community's standing in the NFIP depends on making a good faith effort to successfully re-
solve violations. By allowing a violation to go unresolved, the community may set a precedent,
making it more difficult to take future enforcement actions and potentially jeopardize partici-
pation in the NFIP.
5.6.14 Recordkeeping
Obtaining certain documentation and maintaining complete permit records are key respon-
sibilities for communities that participate in the NFIP. Certifications or documentation of the
following must be maintained for all new buildings constructed in SFHAs and, if applicable, for
buildings that are substantially improved:
■ The permit application form and all attachments, including the site plan
■ Documentation of the SI /SD determination
■ Community letter documenting the SI /SD determination (Section 5.6.15)
■ Floodway encroachment analyses (Section 5.6.8)
■ Records of inspections of the project while under construction such as obtaining the lowest
floor elevations, which is initially obtained after the foundation is in place but prior to
further vertical construction, and other pertinent elevations
■ Design of engineered openings that are used as alternatives to the prescriptive openings in
the walls of enclosures below elevated buildings in A zones (see FEMA Technical Bulletin
1, Openings in Foundation Walls and Walls of Enclosures Below Elevated Buildings in Special Flood
Hazard Areas)
■ In coastal high hazard areas, engineering certifications of designs and construction methods
of new and substantially improved buildings (5.6.9)
■ Designs for breakaway walls around enclosures below elevated buildings in V zones if
prescriptive solutions are not used (see FENIA Technical Bulletin 9, Design and Construction
Guidance for Breakaway Walls Below Elevated Buildings Located in Coastal High Hazard Areas)
S1/SD DESK REFERENCE 5 -15
5 ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
■ Evidence that work proposed for listed historic structures will not preclude continued listing
(Section 6.5.1)
■ Variance proceedings, including justifications and notifications to recipients (Section
5.6.7)
■ Record of final inspections of the construction project before the certificate of occupancy is
issued, such as location and size of openings, location of utilities, and "as- built" lowest floor
elevation
■ Certification of the elevation to which any nonresidential building has been floodproofed
before the certificate of occupancy is issued
Although the use of checklists is not required by the NFIP, it is a good way to document plan
reviews, inspections, and compliance. Some communities use checklists during plan reviews
to verify that appropriate flood damage - resistant provisions have been checked and found to
satisfy the applicable requirements. Similarly, the use of inspection checklists improves the con-
sistency of inspections and helps verify the flood damage - resistant requirements.
5.6.15 Issuing SI /SD Determination Letters
Local officials should convey SI /SD determinations to
property owners in an official letter. Because this letter
notifies the owners of a significant requirement, it is rec-
ommended that it be sent in a manner that documents
receipt by the addressee. Appendix E includes three
sample letters to send SI /SD determinations to property
owners. One sample is used to notify owners when a lo-
cal official determines that proposed improvements are
substantial improvements. Another sample is used to no-
tify owners when a local official determines that buildings
If substantial damage is caused
by flooding and the buildings are
insured by the NFIP, then the SD
determination letter is necessary
for owners to file ICC claims under
NFIP flood insurance policies to
help pay to bring the buildings into
compliance with the community's
floodplain management require-
ments (Sections 5.6.4 and 7.6).
have sustained substantial damage. The third sample is
used to notify owners that it has been determined that damage does not constitute substantial
damage. The local official should offer to meet with owners or representatives to explain the
various aspects required for buildings to meet the community's floodplain management regula-
tions for new buildings, explained in Chapter 6.
5.6.16 Rescinding SI /SD Determinations
Local officials use data to make findings and determinations regarding whether work consti-
tutes substantial improvement or repair of substantial damage. The data, described in detail in
Chapter 4, consist of the cost estimates of the proposed improvements or the cost estimates of
work that is required to repair damaged buildings to their pre- damage condition, regardless of
the amount of work that will be done. The data also include the market values of buildings prior
to the improvement or before the damage occurred.
5 -16 SI /SD DESK REFERENCE
ADMINI SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
Determinations usually are based on data provided by the owner, the owner's representative,
or a contractor. Other sources of repair costs and improvement costs and market value are de-
scribed in Chapter 4.
Following receipt of an SI /SD determination, property owners may appeal the determination
(Section 5.6.6) or may submit new data and request that the initial determination be rescinded.
When new data are provided, local officials should evaluate it carefully. Rescinding a determi-
nation means the owner's investment in a flood -prone area would take place in a manner that
continues the exposure of the existing structure and the investment to flood damage. Commu-
nities should thoroughly document and retain evidence of any appeals and changes to SI /SD
determinations in their permanent records.
5.7 Exceeding NFIP Minimum Requirements
Some States and communities have adopted requirements
for SI /SD that exceed the NFIP minimum requirements
to better protect their citizens and property. The NFIP
encourages communities to evaluate their own situations,
degree of flood risk, and vulnerability of their residential
and commercial properties, and to consider adopting re-
quirements that are more restrictive in order to achieve
the long -term goal of being more resistant to flood di-
sasters. The more restrictive provisions take precedence.
Many communities adopt higher standards in order to
qualify for credit under the NFIP's Community Rating
System (CRS). Section 5.7.1 is an overview of the _CRS,
a voluntary program that provides discounts on Federal
flood insurance rates.
In terms of higher standards that relate to SI /SD, the two
approaches that exceed the NFIP minimums are:
■ Lower threshold for SI /SD (Section 5.7.2)
■ Cumulative SI /SD (Section 5.7.3)
5.7.1 Community Rating System
In 2003, the Association of State
Floodplain Managers, Inc. (ASFPM)
reported that several States have
requirements that exceed the NFIP
minimum requirements for sub-
stantial improvement. In these
cases, State requirements take
precedence.
The CRS has three goals:
1 Reduce flood losses
2. Facilitate accurate insurance
rating
3. Promote awareness of flood
insurance
The NFIP established the Community Rating System to encourage activities that exceed the
NFIP minimum requirements and are effective at reducing flood damage and claims under the
NFIP. In communities that apply to the CRS and are verified as implementing certain activities,
citizens who purchase Federal flood insurance benefit from discounts on premiums ranging
from 5 percent to as much as 45 percent.
For more than 40 years, communities that participate in the NFIP have recognized flood haz-
ards in their construction and development decisions. Until 1990, the NFIP had few incentives
SI /SD DESK REFERENCE 5 -17
5 A S IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
for communities to do more than administer the minimum NFIP regulatory provisions. During
those early years, flood insurance rates were the same in every community, even though some
elected to exceed the minimum provisions.
The CRS is a voluntary program. Any community that
is in full compliance with the regulations of the NFIP is The CRS offers credits to commu-
nities that adopt more restrictive
considered to be in "good standing" and may apply for a requirements for SI /SD.
CRS classification. A community's CRS classification is a
ranking based on the credit points calculated for specific
floodplain management activities undertaken to meet the
goals of the NFIP and the CRS. There are 18 creditable
activities organized under 4 categories. One category in-
cludes more restrictive requirements for work on existing
buildings.
The discount on NFIP flood insurance premiums is only
one incentive for communities to undertake activities
credited by the CRS. The larger benefits are improved
public safety, reduced damage to property and public in-
frastructure, avoidance of economic disruption and losses,
reduction of human suffering, and protection of the en-
vironment.
CRS credits are available to com-
munities that adopt more restrictive
SI /SD requirements:
■ 43 CRS communities get credit
for a lower threshold for S1/SD
■ 289 CRS communities get cred-
it for cumulative SI /SD
(Data as of October 2009)
Additional information about the CRS can be found through the appropriate NFIP State Coor-
dinator, the appropriate FEMA Regional Office, by downloading the Coordinator's Manual at the
CRS Resource Center ( http : / /training.feina.gov /EMIWeb /(,RS), or by checking the NFIP CRS
section of FEMA's website at http: / /wiN-vv.fema.goN /nfip /crs.slitm.
5.7.2 Lower Threshold for SIM
The NFIP's threshold for determining whether proposed work constitutes substantial improve-
ment, or repair of substantial damage, is 50 percent. Compliance is required when the costs of
an improvement or the costs to repair damage equal or exceed 50 percent of a structure's mar-
ket value.
Adopting a lower threshold, such as 40 percent or 30 percent, is perhaps the easiest way to ex-
ceed the NFIP minimum requirement. The concept is simple — compliance is required when
the ratio of costs compared to market value equals or exceeds the lower percentage specified in
the community's regulations. Communities should make certain that they uniformly apply the
lower threshold to all buildings in SFHAs, even after events that cause damage to many build-
ings, regardless of the cause of the damage.
Additional guidance for regulatory language and implementation of a lower threshold for SI/
SD is found in CRS Credit for Higher Regulatory Standards, which is accessible online (http: // NvwNv.
fema.gov/ library /viewRecord.(Io %id= 2411).
5 -18 SI /SD DESK REFERENCE
ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
5.7.3 Cumulative SIM
Many pre -FIRM buildings are subject to repetitive flood damage. Because of the nature of many
flood hazard areas where repetitive flooding occurs, many of the buildings in these areas are
unlikely to sustain the level of damage that qualifies as substantial damage based on the NFIP
minimum 50 percent trigger. One way that communities can achieve long -term reduction of
flood losses is to adopt a requirement that all improvements and repairs are tracked over time
and counted towards the SI /SD determination. Another reason some communities take this ap-
proach is to capture "phased improvements," described in Section 5.6.2.
Adopting what is usually referred to as a "cumulative substantial improvement" requirement
means that buildings will be brought into compliance with flood damage - resistant standards
sooner than if the community administers the minimum NFIP requirement, which applies to
each separate application for improvements and repairs.
The following change to the definition of "substantial improvement" is an example of how
a cumulative substantial improvement requirement can be implemented (suggested new text
is underlined). A more limited approach would be to count only repairs of damage (not im-
provements) in a cumulative manner. Communities should carefully consider the period of
time to specify, whether the "life of the structure" or a specific period of time, such as 5 -, 15 -, or
30 years.
"Substantial improvement" means any combination of repairs, reconstruction, rehabilitation, addi-
tion, or other improvement of a structure taking place during [insert period of time selected by the
community the cost of which equals or exceeds fifty percent of the market value of the structure before
the work is started. This term includes structures that have incurred 'substantial damage, 'regard-
less of the actual repair work performed.
A good system for recording and accessing records is necessary to administer a cumulative SI/
SD requirement. Each time an owner applies for a permit to make improvements or repairs, the
records for that building must be checked. Obviously, this is feasible only if those records are
retained over the period of time specified in the regulations.
Tracking the cost of repairs and improvements over time is straightforward but, for the purpose
of making SI /SD determinations, the community must have a market value to compare to those
costs. Because the market value of a building changes over time, communities need to decide
how they will handle those changes. One approach is to obtain the market value each time a
permit is obtained, use it in the computation each time, and add the resulting percentages.
Communities may choose to accumulate percentages or repair/ improvement costs over a set
period of years. Table 5 -la illustrates this approach where market value increases steadily, and
Table 5 -lb illustrates this approach where the market value first decreases and then increases.
SI /SD DESK REFERENCE 5 -19
5 ADMINI SUBSTANTI IMPR O V EMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS
Table 5 -1 a. Tracking Cumulative Substantial Improvements, Determining Market Value for Each Permit Application
* In this example, the 50 percent threshold is reached with the third permit application.
* In this example, the 50 percent threshold is reached with the third permit application.
Communities will only have records of work for which permits are required. Owners may un-
dertake work that does not require a permit (e.g., patching a roof or replacing a window) and
those costs would not count towards the cumulative substantial improvement. It is not the in-
tent of a cumulative substantial improvement requirement to discourage general maintenance
and upkeep. However, if any part of the work requires a permit, then all of the proposed work
is counted in the SI /SD determination. For example, as part of a project to repair roof damage
that involves replacing rafters and underlayment, the owner may decide to replace shingles on
an undamaged portion of the roof. The cost of the re- shingling is included in the determina-
tion.
Additional guidance for regulatory language and implementation of a cumulative substantial
improvement requirement is found in CRS Credit for Higher Regulatory Standards.
5.8 Recommendations to Improve Flood Resistance
Local officials can encourage owners to improve the flood resistance of older buildings during
the course of repairs and improvements even if owners propose improvements or repairs that
do not trigger the SI /SD requirements. Improving resistance can facilitate rapid clean -up and
recovery, and reduce repair costs. Whether these actions are applicable to a specific situation
depends, in part, on the characteristics of the flood hazard and the building:
5 -20 SI /SD DESK REFERENCE
(shows increases in market value).*
Table 5 -1 b. Tracking Cumulative Substantial Improvements, Determining Market Value for Each Permit Application
(shows decrease, then increase in market value).*
ADMINISTERING SUBSTANTIAL IMPROVEMENT AND SUBSTANTIAL DAMAGE REQUIREMENTS 5
■ Replace gypsum board or wood paneling below the BFE (preferably below the BFE plus 1
foot or more) with vinyl panels that can be removed to facilitate clean -up and drying before
being reinstalled.
■ Replace insulation with closed -cell foam insulation that can be cleaned, dried, and
replaced.
■ Replace flooring and floor finishes with flood damage- resistant materials.
■ Relocate mechanical equipment out of basements or other flood -prone spaces and elevate
above the BFE.
■ Abandon the use of below -grade areas (basements) and fill them in to prevent structural
damage.
■ Install flood openings in crawlspace foundation walls and garage walls (see FEMA Technical
Bulletin 1, Openings in Foundation Walls and Walls of Enclosures Below Elevated Buildings in
Special Flood Hazard Areas) .
■ Install backflow devices in sewer lines.
■ If sufficient warning time is available from official sources, pre -plan actions to move contents
from the lower floors to the higher floors when a warning is issued.
SI /SD DESK REFERENCE 5 -21
6 Factors to Consider and
Illustrations of Substantial
Improvement and Repair of
Substantial Damage
6.1 Overview
This chapter describes the factors to be considered when evaluating permit applications for im-
provements and repairs to buildings and includes, in Section 6.4, illustrations of several types
of improvements and repairs that could trigger SI /SD determinations. Section 6.3 describes all
aspects of the NFIP floodplain management requirements that must be considered when bring-
ing SI /SD buildings into compliance. Section 6.5 describes how certain types of buildings are
addressed, including historic structures, manufactured homes, accessory structures, and certain
agricultural structures. And finally, Section 6.6 explains the NFIP flood insurance implications
related to SI /SD.
6.2 Factors to Consider When Evaluating Permit Applications for
Improvements and Repairs
Several factors must be considered when local officials
evaluate permit applications for repairs and improve-
ments to buildings:
■ Whether the building is pre -FIRM or post -FIRM
(Section 6.2.1) .
■ Whether the building is in an A zone or a V zone
(Section 6.2.2).
■ Whether the building is located in more than one
flood zone (Section 6.2.3).
It is important to emphasize that all
work must be included in an SI /SD
determination. For example, if a
small addition by itself is not a sub-
stantial improvement, but if other
work on the building is undertak-
en at the same time, the combined
work might be a substantial im-
provement (see Section 5.6.1).
■ Whether the building is residential or non - residential (Section 6.2.4).
■ The nature of the proposed repairs and improvements; Section 6.4 illustrates examples of
various types of improvements and repairs and how they must meet NFIP requirements.
6.2.1 Pre -FIRM or Post -FIRM
This chapter presents some examples of common improvements and repairs, along with descrip-
tions of measures to comply with the NFIP floodplain management requirements. For purposes
SI /SD DESK REFERENCE 6-1
6 FA T C ON S IDER AND ILLU OF SU B S TANTIAL IMPR AND REPAIR OF SUBSTANTIAL DAMAGE
of explaining these examples, this Desk Reference uses the terms "pre- FIRM" and "post- FIRM,"
which are described below.
Buildings that were constructed before the date of a community's flood hazard map are called
"pre- FIRM" because they pre -date the initial FIRM. They are referred to as "existing construc-
tion" or existing buildings. They generally pre -date the date of the community's first floodplain
management regulations. Most flood - prone, pre -FIRM buildings were built by individuals who
did not have sufficient knowledge of the hazard to make informed decisions about the flood
risk. Thus, most pre -FIRM buildings were not built with specific measures that reduce exposure
to flooding, such as elevating the floor a certain height above the flood level.
Buildings that were constructed after the date of the initial FIRM are called "post- FIRM." These
buildings were generally constructed after adoption of the community's first floodplain man-
agement regulations and thus should have been built in compliance with the NFIP floodplain
management requirements that were in effect at the time of construction.
A building constructed after the date of the initial FIRM
is considered new construction (see definition in Chapter
3). All new construction must be built in accordance with
the NFIP requirements. Regardless of the size or costs of
improvements or repairs made to post -FIRM buildings,
the building must remain fully compliant.
In summary, how proposals to make improvements or re-
pairs must be evaluated as a function of whether buildings
are pre -FIRM or post -FIRM is as follows:
All subsequent work on a post -
FIRM building must be performed
in a mariner that ensures the build-
ing's continued compliance. Work
shall not be allowed if it would make
the building non - compliant with the
floodplain management require-
ments that had to be met when the
building was constructed.
■ If a building is pre -FIRM, any proposed improvements or repairs must be evaluated to
determine whether the work is a substantial improvement or repair of substantial damage.
■ If a building is post -FIRM, any proposed improvements or repairs must be evaluated to ensure
that the improvements or repairs comply with the applicable NFIP floodplain management
requirements and to ensure that the improvements or repairs do not alter any aspect of the
building that would make it non - compliant.
6.2.2 A Zone or V Zone
The term "A zone" includes all zones shown on FIRMs as Zones A, AE, Al A30, AR, AO, A99,
and AH. A zones are shown along riverine bodies of water and along tidally- influenced bodies
of water, typically inland of V zones. V zones are flood hazard areas with high velocity wave ac-
tion where wave heights of 3 feet or more are anticipated. The term "V zone" includes all zones
shown on FIRMS as Zones V, VE, and VI N30. The basic NFIP floodplain management require-
ments for the design and construction of buildings in A zones and V zones differ somewhat.
Some of the key differences are:
■ A zone: the lowest floor, including basement, is elevated to or above the BFE.
■ V zone: the bottom of the lowest horizontal structural member of the lowest floor is elevated
to or above the BFE.
6-2 SI /SD DESK REFERENCE
FA T CO AND ILL OF SUB IMPR AND REPAIR OF SUBSTANTIAL DAMAGE 6
■ A zone: enclosures below elevated buildings must have flood openings.
■ V zone: the areas below elevated buildings are either free -of- obstructions or enclosed with
insect screening, latticework, or breakaway walls.
■ A zone: non - residential buildings may be dry floodproofed.
■ V zone: dry floodproofing is not allowed for non - residential buildings.
■ V zone: new buildings must be located landward of the reach of the mean high tide.
6.2.3 More Than One Flood Zone
Buildings that are located in more than one zone must comply with the requirements of the
more restrictive zone. For example, a building that is a substantial improvement that is in both
a V zone and an A zone must be designed and constructed to meet the V zone requirements. In
riverine A zones, similar situations may occur. A building that is affected by more than one BFE
must be elevated to the higher BFE, and a floodway analysis is required even if only a portion of
a building encroaches into the floodway.
6.2.4 Residential or Non - Residential
As noted in Section 6.2.2, the requirements for non - residential buildings vary depending on
flood zone. In A zones, non - residential buildings may be elevated or dry floodproofed. Section
6.4.1 describes dry floodproofing as a possible method of protecting non - residential buildings
in A zones that are substantially improved or substantially damaged. In V zones, substantially -
improved non - residential buildings must have the bottom of the lowest horizontal structural
member of the lowest floor elevated to or above the BFE.
6.3 Bringing Substantially Improved and Substantially Damaged
Buildings into Compliance
If a local official determines that improvements or repairs
to a building constitute SI /SD, then the building must be
brought into compliance with the NFIP floodplain man-
agement requirements for new construction in SFHAs.
The key aspects of the NFIP requirements for new con-
struction and SI /SD include:
■ Lowest floor elevations (Section 6.3. 1)
■ Enclosures (Section 6.3.2)
■ Basements (Section 6.3.3)
■ Utility and building service equipment (Section 6.3.4)
■ Flood damage- resistant materials (Section 6.3.5)
For several reasons, owners may
decide to demolish existing build-
ings. If a property owner chooses
to construct a new building on the
same site, the work is treated as
new construction and all require-
ments for new construction must
be met.
■ Making buildings reasonably safe from flooding (Section 6.3.6)
SI /SD DESK REFERENCE 6-3
6 FA T CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
The sections below describe these requirements. The examples given below each NFIP require-
ment describe measures that can be used to bring SI /SD buildings into compliance. These
examples are not an exhaustive list of possible ways to meet the NFIP requirements.
6.3.1 Lowest Floor Elevations
For SI /SD buildings that have lowest floors below the BFE,
the lowest floor must be elevated to bring the buildings
into compliance. In A zones, the lowest floor must be at
or above the BFE (non - residential buildings may be dry
floodproofed to or above the BFE), and in V zones, the
bottom of the lowest horizontal structural member of the
lowest floor must be at or above the BFE.
Measures to bring a building into
compliance may include meeting
a combination of requirements. For
example, elevating a building on a
new foundation may also require
reinforcing the continuous load path
and filling in below -grade areas.
There are several solutions that can achieve compliance.
The solution selected for any given building will depend on several factors such as flood zone,
the type of foundation, feasibility, and whether the building is residential or non - residential.
Below are examples of measures that can be taken to meet NFIP requirement to bring SI /SD
buildings into compliance:
■ Elevation -in -place (A and V zones). This measure
involves detaching the building from its foundation
and raising it onto a compliant foundation. Elevation -
in -place is most effective for buildings that are on
crawlspaces, pilings, or columns. Buildings with
basements also may be elevated (see Section 6.3.3
for measures to bring basements into compliance).
Slab -on -grade buildings have been elevated -in- place,
although the process is more complicated and
costly (these buildings may be better candidates for
conversion of the ground level to become a compliant
enclosure, described below) .
An easy -to -read publication that il-
lustrates three elevation options is
Above the Flood: Elevating Your
Floodprone House (FEMA 347).
A more technical document that
describes additional options is
Engineering Principles and Prac-
tices for Retrofitting Flood -Prone
Residential Structures (FEMA 259).
■ Conversion of the ground level to a compliant enclosure (typically in A zones). There are
instances, typically in A zones, where the first (ground) floor is subject to flooding, but the
next higher floor is above the BFE. In these cases, it may be feasible to modify the ground
level so that it becomes an enclosure that complies with the NFIP requirements. (This
option is unlikely to be applied in V zones because the vertical structural members (piers,
pilings, or columns) of older buildings rarely extend high enough.) This option requires
that the structure meet all applicable NFIP requirements, including limitations on use of
enclosures (parking of vehicles, building access, and storage). Because owners lose living
area, conversions usually are combined with the addition of an upper story or an elevated
lateral addition (Section 6.4.2).
■ Extend walls upward and raise the floor (A zones only). This measure leaves the building on
its original slab -on -grade foundation. To achieve the necessary elevation of the lowest floor,
the roof is removed and the walls are extended high enough to allow a new floor system to
6-4 SI /SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBS I AND REPAIR O S DAMAGE 6
be constructed on top of the slab, with the new floor surface at or above the BFE. The work
also may require the windows and doors to be shifted upward. In addition to replacing the
roof, the work also involves retrofitting the newly- created "crawlspace" or under -floor space
(the space between the original slab and the new floor) to be a compliant enclosure by
installing flood openings. In some cases, rather than adding a new floor system, it may be
feasible to simply add sufficient thickness to the slab to raise the floor surface to or above
the BFE.
■ Conversion of walkout basement to a compliant enclosure (A zones only). This measure is
particularly appealing if the elevation of the floor above the walkout basement is at or above
the BFE. If that is the case, converting the walkout basement to a compliant enclosure can
be done by limiting the use of the area to parking of vehicles, building access, or storage;
removing finish materials; retrofitting the enclosure walls with flood openings; and elevating
equipment and utility service. To prevent the enclosure from being a basement as defined
by the NFIP, particular attention must be paid to ensuring that the enclosure has at least one
side that is at or above grade, which may require lowering the ground surface by re- grading
along one or more of the exterior foundation walls.
■ Dry floodproofing modifications (A zone only, non - residential only). Dry floodproofing
measures must be designed and certified by a qualified registered professional engineer or
architect. Designers must consider many factors when determining whether a building can
be dry floodproofed, including the strength of the building, whether it will be subject to
buoyancy once it is made watertight, whether all possible paths for water to enter the building
can be properly sealed (floor drains, plumbing fixtures, openings through exterior walls
through which utility service is provided, etc.), and whether there is adequate warning time
if human intervention is necessary (e.g., to install barriers or closing valves). For guidance,
see ASCE 24-05, Flood Resistant Design and Construction and FEMA FIA Technical Bulletin 3,
Non Residential Floodproofing — Requirements and Certification for Buildings Located in Special Flood
Hazard Areas.
6.3.2 Enclosures
The NFIP regulations allow enclosed areas below elevated buildings provided the enclosures
meet certain requirements. The NFIP regulations for enclosures under buildings in A zones are
in 44 CFR § 60.3(c) (5), and in § 60.3(e) (5) for enclosures under buildings in V zones. Require-
ments in these sections include:
■ Limited use. In all flood zones, the use of enclosures must be limited to parking of vehicles,
building access, and storage. Crawlspaces are treated as enclosures.
■ Flood damage- resistant materials. All construction materials used below the BFE must be
flood damage - resistant materials (see FEMA Technical Bulletin 2, Flood Damage Resistant
Materials Requirements for Buildings Located in Special Flood Hazard Areas). Materials necessary
to meet fire protection code requirements are acceptable.
■ Elevated or protected utility equipment and service. Given the limitations on use, only
the minimum utility equipment and service connections necessary should be located in
enclosures under elevated buildings.
SI /SD DESK REFERENCE 6-5
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
■ Flood openings. In A zones, the walls of enclosed areas must have flood openings to allow
for the automatic entry and exit of floodwaters to minimize the potential for damage caused
by hydrostatic pressure (see FEMA Technical Bulletin 1, Openings in Foundation Walls and
Walls of Enclosures Below Elevated Buildings in Special Flood Hazard Areas) .
■ Breakaway walls. In V zones, the walls of enclosed areas must be non - supporting breakaway
walls (see FEMA Technical Bulletin 9, Design and Construction Guidance for Breakaway Walls
Below Elevated Buildings Located in Coastal High Hazard Areas) .
6.3.3 Basements
Under the NFIP, new buildings and substantially improved buildings must have their lowest
floors (including basements) elevated to or above the BFE (non - residential buildings may have
dry - floodproofed basements below the BFE). The NFIP regulations define a basement as "any
area of the building having its floor subgrade (below ground level) on all sides." If a local of-
ficial determines that work constitutes SI /SD of any building that has a basement, the building
must be brought into compliance, which includes eliminating the below -grade area.
Measures to eliminate basements below the BFE will, in part, depend on the nature of the base-
ment and surrounding ground elevations. Below are examples of measures that can be taken to
meet the requirement:
■ Fill in below -grade areas. This option is effective only if the elevation of the floor above the
below -grade area is at or above the BFE. Compliance is achieved by filling in the below -grade
area and converting the remaining headroom to a compliant enclosure.
■ Convert walkout basements to compliant enclosures. Section 6.3.1 describes how a walkout
basement can be modified to become a compliant enclosure (A zone only) .
■ Floodproof below -grade areas (A zone, non - residential only). The NFIP regulations allow non-
residential buildings in A zones to have areas that are below -grade on all sides (basements)
only if the areas are dry floodproofed. Careful evaluation of the structural integrity of a
building must be undertaken to determine if dry floodproofing measures are feasible. For
guidance, see FEMA FIA Technical Bulletin 3, Non Residential floodproofing— Requirements and
Certification for Buildings Located in Special Flood Hazard Areas.
6.3.4 Utility and Building Service Equipment
The NFIP requires that new buildings and substantially improved buildings have utilities, equip-
ment, and appliances elevated to or above the BFE, or be designed to prevent water from
entering or accumulating within the equipment components (see 44 CFR § 60.3(a) (3) provid-
ed in Section 3.3). This means that SI /SD buildings with utility and building service equipment
that is below the BFE must have the equipment either elevated or replaced with components
that are designed and installed to be flood damage- resistant. Minimal electric service is allowed
below the BFE if it is required to address life safety and electric code requirements for building
access and storage.
6-6 SI /SD DESK REFERENCE
FACTORS T CO AN ILL OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
Below are examples of measures that can be taken to meet NFIP requirements for utility and
service equipment:
■ Relocate to elevated areas. Equipment and utility service must be relocated or elevated when
buildings are elevated -in -place or if ground floors are converted to compliant enclosures.
When a basement is eliminated, any equipment that was in the basement will be relocated
to the elevated portion of the building or to an elevated addition.
■ Elevate on outside platforms. Equipment located
outside of the building, such as heat pumps and air
conditioning units, must be elevated on platforms at
or above the BFE. Platforms may be independently
supported or cantilevered from the foundation.
■ Elevate on platforms inside enclosures. If a substan-
tially improved building in an A zone has a compliant
More detail on compliant installa-
tions can be found in Protecting
Building Utilities from Flood Dam-
age: Principles and Practices for
the Design and Construction of
Flood Resistant Building Utility
Systems (FEMA 348).
enclosure, utility equipment (e.g., water heaters, water
treatment systems, and heat pumps) may be installed on platforms that raise the equipment
to or above the BFE. Note that appliances such as washers, dryers, and freezers should not be
installed in enclosures (even if elevated) because they are not compatible with the allowable
uses (parking of vehicles, building access, and storage) and they do not meet the mechanical
service equipment requirement at 44 CFR § 60.3(a) (3).
■ Provide component protection. Equipment that must be located on the floor of a compliant
enclosure in an A zone may be protected with a barrier to keep water away from the
equipment. Typical barriers are constructed of masonry or concrete to a height that is equal
to or higher than the BFE and have specially designed doors or panels that are put in place
to keep water from entering. This approach is feasible in non - residential buildings provided
there is sufficient warning time.
6.3.5 Flood Damage- Resistant Materials
The NFIP requires that flood damage- resistant materials be used below the BFE. If a building
will be elevated -in- place, materials used below the BFE must meet this requirement, including
materials used to build an enclosure. For guidance on materials, see FEMA Technical Bulletin 2,
Flood Damage - Resistant Materials Requirements for Buildings Located in Special Flood Hazard Areas.
Minimal use of certain materials that are not flood damage- resistant materials is allowed below
the BFE if specifically required to address life safety and electric code requirements for building
access and storage areas.
6.3.6 Making Buildings Reasonably Safe from Flooding
In all flood zones, substantially improved buildings must be "adequately anchored to prevent
flotation, collapse, or lateral movement of the structure resulting from hydrodynamic and hy-
drostatic loads, including the effects of buoyancy" (see 44 CFR § 60.3(a) (3) (i) provided in
Section 3.3). In addition, in V zones structures must be "anchored to resist flotation, collapse,
S1/SD DESK REFERENCE 6-7
6 FACTORS TO CONSIDER AND ILLUSTRATION O F SU B S TANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
and lateral movement due to the effects of wind and water loads acting simultaneously on all
building components" (see 44 CFR § 60.3(e) (4) (ii) provided in Section 3.3). The compliance
solution selected for any given building will depend on several factors such as the flood zone in
which it is located, the type of foundation, and whether the building is residential or non -resi-
dential.
Below are examples of measures that can be taken to meet the NFIP requirement that buildings
be reasonably safe from flooding:
■ Continuous load path. Provide for a continuous load
path by connecting the building to the foundation
and connecting the roof to the walls. If existing
connectors (bolts, nails, screws, straps, etc.) that
attach the building to the foundation are inadequate,
they should be replaced, reinforced, or augmented to
address the requirement that the building be stable
under base flood conditions.
■ Foundation bracing. Pile- or post- supported buildings
may require additional bracing. In V zones, bracing
that is perpendicular to the approach of waves is an
obstacle to the passage of waves and water under the
building, and may need to be modified to meet the
NFIP requirement to be "free -of- obstruction."
Work that does not require a per-
mit is generally considered to be
repairs of normal wear and tear
or routine maintenance. Property
owners or contractors should check
with local officials to determine
when work requires a permit.
Once the requirement for a permit
is triggered, all work is to be in-
cluded in the SI /SD determination,
even work that would otherwise
not require a permit.
6.4 Illustrations of Improvements and Repairs
The following sections and Tables 6-1a and 6-1b present some examples of common improve-
ments and repairs, along with descriptions of measures to comply with the NFIP floodplain
management requirements. Several of the examples describe and illustrate a specific type of
work or combinations of work that may trigger the SI /SD requirements. Examples are also giv-
en of improvements and repairs to pre -FIRM and post -FIRM buildings and what must be done
to comply with the new construction requirements of the NFIR Examples of work include:
■ Rehabilitation and remodeling (Section 6.4. 1)
■ Lateral additions (Section 6.4.2)
■ Vertical additions (Section 6.4.3)
■ Repair, reinforce, or replace foundations (Section 6.4.4)
■ Repair of damaged buildings (Section 6.4.5)
■ Reconstruction of demolished or destroyed buildings (Section 6.4.6)
■ Work on post -FIRM buildings (Section 6.4.7)
■ Work on buildings where flood maps have been revised (Section 6.4.8)
6-8 S1/SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
Table 6 -1 a. Compliance Matrix (A Zones)
Ty pes
Po st-FIRM
Rehabilitation (renovate
Compliance not required
Work shall comply and shall not be allowed to
or remodel), not SI
make the building non - compliant with any aspect
of the building that was required for compliance
Rehabilitation (renovate ,
Building required to comply
Work shall comply and shall not be allowed to
or remodel), SI
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Lateral addition and
Addition required to comply;
Addition required to comply; building required to
Rehabilitation, SI
building required to comply
comply (see Note below table)
Lateral addition, not SI
Addition not required to comply
Addition required to be elevated to at least the
elevation of the existing lowest floor
Lateral addition, SI, not
Addition required to comply;
Addition required to comply
structurally connected
building not required to comply
Lateral addition, SI,
Addition required to comply;
Addition required to comply; building required to
structurally connected
building required to comply
comply (see Note below table)
Vertical addition above
Compliance not required
Work shall comply and shall not be allowed to
building, not SI
make the building non - compliant with any aspect
of the building that was required for compliance
Vertical addition above
Building required to comply
Work shall comply and shall not be allowed to
building, SI
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Repair foundation, not
Compliance not required
Repairs shall comply and shall not be allowed to
SI
make the building non - compliant with any aspect
of the building that was required for compliance
Repair foundation, SI
Building required to comply
Building required to comply (see Note below
table)
Replace /extend
Building required to comply
Building required to comply (see Note below
foundation, SI (including
table)
"elevate -in- place ")
Repair damage, SD
Building required to comply
Work shall comply and shall not be allowed to
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Reconstruct new
Reconstructed building required
Reconstructed building required to comply (see
building on existing or
to comply
Note below table)
new foundation, SI
Note: If a map revision has resulted in a higher BFE, a post -FIRM building must comply based on the new BFE.
SI /SD DESK REFERENCE 6-9
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
Table 6 -1 b. Compliance Matrix (V Zones)
Ty pes
Post-FIRM
Rehabilitation (renovate
Compliance not required
Work shall comply and shall not be allowed to
or remodel), not SI
make the building non - compliant with any aspect
of the building that was required for compliance
Rehabilitation (renovate
Building required to comply
Work shall comply and shall not be allowed to
or remodel), SI
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Lateral addition and
Addition required to comply;
Addition required to comply, and rehabilitation
Rehabilitation, SI
building required to comply
work shall comply and shall not be allowed to
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Lateral addition, not SI
Addition not required to comply
Addition required to comply
Lateral addition, SI, not
Addition required to comply;
Addition required to comply (see Note below)
structurally connected
building required to comply
Lateral addition, SI,
Addition required to comply;
Addition required to comply; building required to
structurally connected
building required to comply
comply (see Note below table)
Vertical addition above
Compliance not required
Work shall comply and shall not be allowed to
building, not SI
make the building non - compliant with any aspect
of the building that was required for compliance
Vertical addition above
Building required to comply
Work shall comply and shall not be allowed to
building, SI
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Repair foundation, not
Compliance not required
Repairs shall comply and shall not be allowed to
SI
make the building non - compliant with any aspect
of the building that was required for compliance
Repair foundation, SI
Building required to comply
Building required to comply (see Note below
table)
Replace /extend
Building required to comply
Building required to comply (see Note below
foundation, SI (including
table)
"elevate -in- place ")
Repair damage, SD
Building required to comply
Work shall comply and shall not be allowed to
make the building non - compliant with any aspect
of the building that was required for compliance
(see Note below table)
Reconstruct new
Reconstructed building required
Reconstructed building required to comply (see
building on existing or
to comply
Note below table)
new foundation, Sl
Note: If a map revision has resulted in a higher BFE, a post -FIRM building must comply based on the new BFE.
6.4.1 Rehabilitation and Remodeling
The NFIP considers rehabilitation and remodeling to include improvements to a building that
do not affect the external dimensions nor expand the total area of the building. Rehabilita-
tion may or may not involve structural modification of the building. The local official must
review all work proposed for rehabilitation or remodeling to determine whether it constitutes a
6-10 SI /SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF S JBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
substantial improvement. If the work c)nstitutes a substantial improvement, the building must
be brought into compliance.
Rehabilitation of pre-FIRM buildings (residential)
Residential buildings that are substantially improved through rehabilitation or remodeling
must comply with all applicable NFIP floodplain management requirements for the specific
flood zone. Figure 6-1 illustrates the rehabilitation of a residential building that is located in
an A zone. The figure illustrates eleva on on a solid perimeter wall (crawlspace). Other types
of foundations may be used in A zone including pilings, columns, slabs on fill, and stem walls.
Open foundations (pilings and colum s) are required in V zones.
AFTER
BEFORE ,BFE
BFE �
1121
III
BFE // BFE I I I i 1 1 1 1 1 1 1 1 1 1 /�/��/
LI I111 11 I11 l I // ILA I
I I I Ii /
Flood Openings Masonry Perimeter Wall
Extended to Bring
Notes: Open foundations(pilings/columns) are Lowest Floor To or Above BFE
required under buildings in V zones.
Foundation types other than perimeter
walls are allowed in A zones.
Figure 6-1. Rehabilitation or remodel (no increase in footprint) of residential building in an A zone—the proposed
work was determined to be a substantial improvement.The building is brought into compliance by elevating it on
an extended perimeter foundation wall, installing flood openings, and raising the HVAC equipment onto a platform.
Rehabilitation of pre-FIRM buildings (non-residential)
Rehabilitation or remodeling work on a non-residential building that is SI/SD triggers the re-
quirement that the lowest floor be elevated (in A and V zones) or dry floodproofed (only in A
zones).
Figure 6-2 illustrates the rehabilitati of a non-residential structure in an A zone where a
structural engineering analysis indica s the building can be retrofitted with dry floodproofing
measures in compliance with the NFI requirements that require certification of the design by
a registered design professional. For dditional guidance, see FEMA FIA Technical Bulletin 3,
Non Residential Floodproofing — Require nts and Certification for Buildings Located in Special Flood
Hazard Areas. Communities that enfor building codes that refer to ASCE 24-05 for design and
construction of buildings in flood ha rd areas should be aware that ASCE 24-05 establishes
SI/SD DESK REFERENCE 6-11
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
some specific limitations for floodproofing, ' cluding limitations on warning time and the avail-
ability of adequate labor to implement floo roofing measures.
Depending on the type of foundation and o er constraints, non-residential structures that are
located in A zones may be elevated on rais foundations. In this instance, the building must
be brought into compliance with all of the pplicable floodplain management requirements,
including the type of foundation, limitation on use of enclosed areas, installation of openings
in any enclosed areas, elevation of utilities 4nd mechanical equipment, and use of flood dam-
age-resistant materials. i
In V zones, the only compliance option for on-residential buildings is elevation on open foun-
dations. Dry floodproofing is not allowed in zones.
Floodproofing Design Certificate
ARequired
•
/ /BFE
Retrofit Dry Floodproofing Required
• ,. (Special Doors and Window Panels).
�/ Floodproof to 1-foot Above BFE to
• Qualify for Post-FIRM Insurance Rating.
BFE •f
Note: Floodproofing not allowed in V zones.
Figure 6-2. Rehabilitation or remodel (no increase in footprint) of non-residential building in an A zone—the
proposed work was determined to be a substantial improvement.The building is brought into compliance by
retrofit dry floodproofing measures (certification of design by registered design professional is required).
Rehabilitation/repair of a post-FIRM building
Any repairs or improvements associated wi the rehabilitation or remodeling of a post-FIRM
building must comply with the NFIP requi ments and not alter the building in any way that
violates those requirements.
If a revised, higher BFE goes into effect and the local official determines that rehabilitation
constitutes SI/SD, the entire post-FIRM budding must be brought into compliance with the el-
evation requirement based on the revised BFE.
6.4.2 Lateral Additions
A lateral addition expands the floor area of the building. A lateral addition that involves no al-
teration of the load-bearing structure of th4 building, is attached to the building with minimal
6-12 E SI/SD DESK REFERENCE
I
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
connection, and that has a doorway as e only modification to the common wall is considered
to be "not structurally connected." A ateral addition that has its load-bearing structure con-
nected to the load-bearing structure f the base building, which typically involves significant
alternation of the common wall, is co idered "structurally connected."
If a lateral addition is proposed along with other work on the original building, all the work
must be considered in the SI/SD detertnination, regardless of the size or cost of the addition by
itself and the cost of improvements to the original building.
As described below and summarized ' Tables 6-la and
frlb, lateral additions depend on four actors: Structurally Connected and Not
Structurally Connected. A non-
"' Whether the building is pre-FIRM or post-FIRM, compliant addition that is below the
BFE and "structurally connected"
• Whether the common wall with th4 original building would transfer flood loads imposed
is modified structurally by more than installing a on it to the existing building.
doorway,
An addition that is below the BFE
• Whether the addition itself is a substantial improve- and "not structurally connected" is
ment, and expected to sustain damage, but
should not transfer loads to the ex-
II The applicable flood zone. isting building.
Lateral additions to pre-FIRM buildings (A zone, residential)
For a project that involves only a lateral addition (i.e., there will be no improvements to the orig-
inal building, the addition will not be structurally connected to the original building,and only a
doorway will be installed in the common wall between the addition and the original building):
• If the cost of the addition comp ed to the value of the original building constitutes a
substantial improvement, only the owest floor of the addition must be elevated to comply
with NFIP requirements (Figure fr ).
• If the addition is determined to not be substantial improvement,the addition is not required
to be elevated. Owners should be reminded that the addition will be subject to flooding and
encouraged to consider measures to reduce vulnerability to damage (Section 5.8).
If a proposed lateral addition project iso includes rehabilitation or remodeling of the existing
building,then the local official must consider the whole project as a combination of work. If the
local official determines that the combined cost of the project constitutes substantial improve-
ment, then both the original building and the addition must be elevated and meet all other
applicable requirements (Figure 6-4).
SI/SD DESK REFERENCE 6-13
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
No Improvement of
Original Building
Lateral Addition
- n,
BFE BFE
-
I I I I 1 1 1 1 I l I l 1
I I I I 1 1 1 I
1 I f I I I I I I I 11 1 1 1 1 I N 1
Existing Lowest Floor
Lowest Floor Elevated
To or Above BFE
Figure 6-3. Lateral addition to a pre-FIRM building in an A zone—the proposed work is only the addition (no work
was performed on the original building and no structural modification was made to the common wall or roof).The
addition constitutes a substantial improvement and it complies with all NFIP requirements.
Improvements to Original Building
Lateral
Addition
El]T _ ���..11I//_BFE
601*
//
BFE 1 , �f Lowest Floor Elevated To or Above BFE
I I I '1 '1 'I
I I I I l l l l l l 777
Figure 6-4. Lateral addition to a pre-FIRM building in an A zone—the proposed work includes an addition and
work on the original building, including structural modification of the common wall or roof.The proposed work
was determined to be a substantial improvement. The addition complies with all requirements and the building is
brought into compliance by elevating it on a compliant foundation.
6-14 SI/SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
Lateral additions to pre-FIRM buildings (V zone, residential)
Lateral additions to pre-FIRM buildings in V zones are treated differently than additions to
buildings in A zones. If a proposed addition (or combination of an addition and other improve-
ments) to a V zone building constitutes a substantial improvement, then the lowest floor of
both the original building and the addition must be elevated (Figure 6-5). The pertinent NFIP
requirement for elevating both is the "free of obstruction" requirement. The original building
must be elevated so that it will not obstruct floodwaters and waves that may damage the addition.
For more guidance, see FEMA Technical Bulletin 5, Free-of-Obstruction Requirements for Buildings
Located in Coastal High Hazard Areas.
Improvements to Original Building ..
/\N
&FFl -.\-
.Z
1. V
REF R : n'I= III IIIIIII II
•
V
® E l BFE t 0 ®I® 0 BFE
,. .. .:C.-� a,...
BFE ji E_ BFE II- --- --- -- --- -
/ Frontal il4i Frontal
Dune/--- Dune
Note: Original building is brought up to V zone standards
to meet`free-of-obstructions"requirements
Figure 6-5. Lateral addition to a residential building in a V zone—the proposed work includes work on the original
building.The lateral addition and improvements constitute substantial improvement. Both the addition and the
original building are brought into compliance by elevating to or above the BFE on an open foundation.
Lateral additions to pre-FIRM manufactured homes
Lateral additions are common impro $ments to manufactured homes and local officials must
determine whether the proposed workconstitutes substantial improvement. Costs associated
with typical porches and sunrooms may not exceed 50 percent of the market value of the home.
However, proposed additions that will be walled with siding, insulated, and used year-round
require close examination to determi whether the addition constitutes a substantial improve-
ment.
If a proposed addition to a manufactu d home constitutes a substantial improvement, the local
official must determine the applicable NFIP elevation requirements; the requirements depend
on several factors that are described i Section 6.5.2.
SI/SD DESK REFERENCE 1 6-15
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
Figure 6-6 illustrates a lateral addition to ape-FIRM manufactured home—the proposed work
includes improvements to the existing hom . The existing home in this illustration is located
outside a manufactured home park or sub ivision and the work constitutes a substantial im-
provement. Both the addition and the hom must be elevated on compliant foundations.
All substantial improvements must be carefully constructed, supported, and anchored to re-
sist flotation, collapse, and lateral movement during base flood conditions so as not to impose
unanticipated loads on the original homes. therwise, the presence of additions could increase
vulnerability to flood loads imposed on supp rting piers and anchoring,leading to damage.For
more detailed guidance on the installation f manufactured homes in SFHAs, see FEMA P-85,
Protecting Manufactured Homes from Floods and ther Hazards:A Multi Hazard Foundation and Instal-
lation Guide.
O' Improvements to Original Building
,
BFE
1. 1
._.,. = Pier
�L,--a --i - t -i _t =t -=i
Anchor y
BEFORE AFTER
Figure 6-6. Lateral addition to a pre-FIRM manufactured home in an A zone—the proposed work includes
improvements to the existing home.The work constitutes substantial improvement.The addition and the home
are elevated to or above the BFE.
Lateral additions to pre-FIRM buildings (A zone, non-residential)
If a proposed lateral addition to a non-residential building is determined to be a substantial
improvement, but there is no work proposed for the original building and the common wall is
modified only by the installation of a door, gnly the addition must be brought into compliance.
The addition must meet NFIP requiremen either by elevating the lowest floor to or above the
BFE or by dry floodproofing to that elevati n (Figure 6-7). If the addition is dry floodproofed,
the common wall must also be made watert ht.
6-16 SI/SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
\fir .f, BFE
/�
_/I •/
BFE _ _ 1_ ��'
---' Poured Concrete Foundation
Figure 6-7. Lateral addition to a non-residential building in an A zone—the proposed work is only the addition (no
work on the existing building and no structural modification of the common wall or roof).The work constitutes
substantial improvement.The addition is elevated to or above the BFE (an alternative would be to dry floodproof
only the addition, including the common wall).
Lateral additions to post-FIRM buildings (any zone, residential or non-residential)
Lateral additions to post-FIRM buildin s are new construction and must comply with the NFIP
requirements, including elevation. If a addition does not comply, then the original building
will become non-compliant. Lateral additions must not alter any aspect of the building that had
to be met when the building was constructed in compliance with the community's floodplain
management regulations. A lateral addition, regardless of its value or size, must be elevated to
at least the height of the post-FIRM building. The following summarizes these points:
• In any zone, if the BFE is unchang4d, the addition must be elevated and comply with other
applicable NFIP requirements, regardless of whether it is SI/SD (Figure 6-8).
■ In any zone, if a revised, higher BITE is in effect, a lateral addition that is not a substantial
improvement must be elevated at least as high as the original building.
• In any zone, if a lateral addition is a substantial improvement (and structurally connected),
both the addition and the building must be brought into compliance. If a revised, higher
BFE is in effect, both the original building and the addition must be elevated.
■ In A zones, if the lateral additi is a substantial improvement (and not structurally
connected), it must be elevated to he effective BFE. The effective BFE may be higher than
the BFE in effect when the buildin was built (Figure 6-9).
IIIn V zones,if a lateral addition is a s bstantial improvement (and not structurally connected),
both the addition and the original ost-FIRM building must be elevated if a revised, higher
BFE is in effect, otherwise the free-of-obstruction requirement is not met.
SI/SD DESK REFERENCE 6-17
I
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
Post-:1RM BFE
Building
Addition
!,//
/ J
! 1 //
-'
Figure 6-8. Lateral addition to a post-FIRM building in any flood zone(map revision has not changed the effective
BFE).All improvements or repairs to a post-FIRM building must comply with the NFIP requirements regardless
of the value of that work, and the work shall not compromise any of the NFIP requirements that the building was
required to meet when it was initially built.
New Lateral Addition
No Improvement of
Original Building E
Post-FIRM Building
Built to Old BFE
Lateral Addition
Elevated to
New BFE—
New BFE
I` --- ---� _ Old BFE
- 1 - - - -
Figure 6-9. Lateral addition to a post-FIRM building in an A zone (a map revision has increased the BFE).
The proposed work is a lateral addition with no work in the original building and no structural modification
of the common wall or roof.The work constitutes a substantial improvement. Because there is no structural
modification,only the addition must comply with the effective BFE which is higher than the BFE when the building
was built. If instead the proposed work includes work in the original building or structural modification,the
addition and the building must comply with the effective BFE.
6-18 SI/SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
6.4.3 Vertical Additions
A vertical addition expands the floor ar of a building by either adding an upper story above the
original building (Figure 6-10) or elevating the original building and constructing a new story be-
neath it (Figure 6-11). In both cases, it is likely that work on the load-bearing foundation will be
required to carry the added load. Vertical additions may be smaller than the building footprint,
such as a loft or bedroom, but the local official must still make an SI/SD determination.
Vertical Addition
Typically, Existing
Roof is Demolished
for Vertical Addition
EEI
il�I n BFE WOW' BFE- ---
/lil I Foundation Type
. Depends on
Flood Zone
BEFORE AFTER
Figure 6-10.Vertical addition to a pre-FIRM residential building (in any zone)-the proposed work is a new upper
story that involves structural modification.The work is a substantial improvement.The building is elevated to or
above the BFE on a compliant foundation.
IN ER
IIIIII IIIIII� I mmo!
7Nit& Vertical Addition
BFE ERI J „ill
1 �lii
l BFE -
i
illy _
ri,
1.,,
BEFORE AFTER
Figure 6-11.Vertical addition to a pre-FIRM residential building (in any zone) -the proposed work is a new lower
story that involves structural modification. The work constitutes a substantial improvement.The building and the
new lower story are elevated on a compliant foundation.
SI/SD DESK REFERENCE 6-19
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
Vertical additions to pre-FIRM buildings (residential)
If a vertical addition to a pre-FIRM residentiLl building constitutes a substantial improvement,
the original building must be elevated to or above the BFE. In addition, the foundation must
be modified or reconstructed (and below-grade areas filled in) to be compliant with applicable
NFIP requirements based on the flood zone.
Vertical additions to pre-FIRM buildings (non-residential)
Vertical additions may involve adding an upper story above a non-residential building (Figure
6-12). If a vertical addition constitutes a substantial improvement, the original building must
be elevated to or above the BFE or dry-floodproofed to the BFE (A zone only). In addition, the
foundation must be modified or reconstructed (and below-grade areas filled in) to be compli-
ant with applicable NFIP requirements based on the flood zone.
Vertical Addition
Watertight
Flood Barrier
Structure Must be
Original Building Dry Floodproofed
(Not Floodproofed BFE
When Constructed)
BFE----- --- -
Note: Design may require reinforcement
of walls and floor slab.
Figure 6-12.Vertical addition to a pre-FIRM, non-residential building in an A zone.The work constitutes a
substantial improvement. The building is brought into compliance by retrofit dry-floodproofing measures
(certification of design by registered design professional is required). Non-residential buildings can also be
brought into compliance by elevation (not shown).
Vertical additions to post-FIRM buildings
Whether a local official will need to evalua a vertical addition to a post-FIRM building to de-
termine if it is a substantial improvement is elated to whether the FIRM has been revised. If a
revised, higher BFE is in effect, or if the flo d zone changed (or floodway boundary changed),
a vertical addition that is a substantial imp vement will require that the entire building be el-
evated to the higher, effective BFE and co ly with other applicable NFIP requirements based
on the flood zone.
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FACTORS TO CONSIDER AND ILLUSTRATIONS OF SL BSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
6.4.4 Repair, Reinforce, or Replace Foundations
It is common to repair, reinforce, or replace foundations, especially for older buildings. Foun-
dation work also includes repair of damaged foundations, regardless of whether the damage is
caused by a single event (such as a flood or earthquake) or due to deterioration over time.
Work performed on a foundation, either by itself or in combination with other work on a build-
ing, may constitute SI/SD. If the work is not a substantial improvement, the structure does
not have to be elevated. However, any owner contemplating the replacement of a foundation
should investigate the potential savings on the cost of NFIP flood insurance if the building is
elevated and the new foundation complies with all of the applicable NFIP requirements. Many
owners elect to elevate flood-prone buildings to reduce flood damage. The incremental cost to
both replace a foundation and elevate a structure properly to the effective BFE may be offset by
the reduction in future damage and annual flood insurance premiums.
In some cases, property owners may elect to elevate a structure, but not to the BFE. The cost to
elevate a structure in this fashion must be included when making the SI/SD determination.
Foundation work on pre-FIRM buildings (residential)
If foundation work is determined to be SI/SD,then the building must be elevated in accordance
with all applicable NFIP requirements, depending on the flood zone. Figure 6-13 illustrates the
construction of a compliant foundation under an existing home.
AFTER
BEFORE ' "
E S
T
BFE mismINIIIIMMMMIIIIN BFE
INIIMIIIIIIIMMMENIME
I 1 1 IMP MMI-��1_■
Foundation Requires Raised Fully-Compliant
Repair Crawlspace Foundation
Figure 6-13. New foundation or repair of foundation under a pre-FIRM (in an A zone) residential building.The
work was determined to be a substantial improvement.The building is brought into compliance by elevating on a
compliant foundation.
Foundation work on pre-FIRM buildings (non-residential)
If the foundation work on a non-reside tial building is determined to be SI/SD, then the build-
ing must be elevated in accordance wi all applicable NFIP requirements, depending on the
flood zone.
SI/SD DESK REFERENCE 6-21
6 FACTORS TO CO AND ILL OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
As part of foundation work, owners of non - residential buildings in A zones may propose to
retrofit with compliant dry- floodproofing measures. Such proposals must be supported with
structural engineering analyses that indicate whether the buildings can be dry floodproofed in
compliance with the NFIP requirements. The analyses must be prepared or reviewed by a regis-
tered design professional who must sign and seal the dry floodproofing designs. For guidance.
see FEMA FIA- Technical Bulletin 3, Non Residential Hoodproofing — Requirements and Certifica-
tion for Buildings Located in Special Flood Hazard Areas. The technical bulletin includes planning
considerations regarding warning time, safety of personnel responsible for implementing the
measures, and the importance of having an emergency operations plan and a plan for regular
inspection and maintenance. ASCE 24 -05, the standard for flood damage - resistant design and
construction that is referenced by the model building codes, also includes similar requirements
and limitations on measures that require human intervention.
6.4.5 Repair of Damaged Buildings
The NFIP requirements for repair of substantially damaged buildings are the same as those
described for rehabilitation and remodeling (Section 6.4.1). However, if a proposal for repair
also includes an addition to a damaged property, the cost of the addition must be included in
the SI /SD determination. If the combination of work is a substantial improvement, then both
the addition and the original building must be brought into compliance with the NFIP require-
ments, depending on the flood zone.
6.4.6 Reconstruction of Demolished or Destroyed Buildings
Any project that involves complete reconstruction, such as rebuilding on the same foundation.
is new construction that must comply with all applicable NFIP floodplain management require-
ments. A building that is totally destroyed or so significantly damaged that it cannot be repaired
is a substantially damaged building. Sometimes an owner elects to demolish the building. In
these circumstances, if the decision is to reconstruct using the existing foundation, the recon-
structed building must meet NFIP requirements for new construction.
6.4.7 Work on Post -FIRM Buildings
All repairs, improvements or modifications to a post -FIRM building are considered new con-
struction (see definition in Chapter 3). Work on a post -FIRM building must not be allowed if
it would make the building non - compliant with the floodplain management requirements that
had to be met when the building was constructed. Tables 6-la (A zones) and 6-lb (V zones)
identify types of work on post -FIRM buildings and the compliance requirements that apply. In
some cases when an addition is involved, the original building has to be brought into compli-
ance.
6.4.8 Work on Buildings Where Flood Maps Have Been Revised
Section 5.6.11 explains that many communities have had revisions to their flood hazard maps.
The following illustrate how map revisions that change flood zone designations or modify or
add floodway delineations must be taken into consideration:
6-22 S1/SD DESK REFERENCE
FA T CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
■ If the FIRM has been revised and the SFHA has widened to include more area, that area is
now subject to the NFIP requirements. For example, areas that were previously designated
X zone may now be shown as A zone or V zone. Improvements and repairs to buildings that
were outside of the SFHA but are now in the revised SFHA must be evaluated to determine
if the work is SI /SD.
■ If the FIRM has been revised and the flood zone or BFE changed, a determination that work
is a substantial improvement requires that the building meet NFIP requirements for new
construction based on the revised flood zone and revised BFE.
■ If the FIRM has been revised and either the floodway boundaries are changed or a floodway
is newly delineated, a determination that improvements or repairs to a building are SI /SD
may require an encroachment analysis.
6.5 Requirements for Certain Structures
This section describes how SI /SD is addressed for certain types of buildings in accordance with
the NFIP floodplain management requirements, including:
■ Historic structures (Section 6.5.1)
■ Manufactured homes (Section 6.5.2)
■ Accessory structures and certain agricultural structures (Section 6.5.3)
6.5.1 Historic Structures
The NFIP gives special consideration to the unique value of designated historic buildings and
structures. Provided such structures retain their designations, communities do not have to re-
quire them to be brought into compliance if they will be substantially improved or have been
substantially damaged. Section 3.4.1 includes the NFIP's definition for "historic structures." The
term includes structures that are: (1) listed or preliminarily determined to be eligible for list-
ing in the National Register of Historic Places; (2) certified or preliminarily determined by the
Secretary of the U.S. Department of Interior as contributing to the historical significance of a
registered historic district or a district preliminarily determined to qualify as a registered histor-
ic district; or (3) designated as historic site under a State or local historic preservation program
that is approved by the Secretary of the U.S. Department of Interior. The definition does not
include structures that are merely old, those that residents refer to as historic, or those that hap-
pen to be located in historic districts.
The NFIP floodplain management requirements contain two provisions that are intended to
provide relief for historic structures located in SFHAs:
(1) The NFIP definition of "substantial improvement" includes the following exclusion for
historic structures: "Any alteration of a `historic structure,' provided that the alteration will not
preclude the structure's continued designation as an `historic structure"' The exclusion also ap-
plies to historic structures that have been substantially damaged. This provision allows
communities to exempt historic structures from the SI /SD requirements of the NFIR
SI /SD DESK REFERENCE 6-23
6 FACTORS TO C ONSIDER AND ILLUSTR O F SU B S TANTIAL IMPR AND REPAIR OF S UBSTANTIAL DAMAGE
(2) The other provision of the NFIP floodplain management regulations that provides relief
for historic structures" is the variance criteria at 44 CFR § 60.6(a). This provision states:
" Variances may be issued for the repair or rehabilitation of historic structures upon a determination
that the proposed repair or rehabilitation will not preclude the structure's continued designation as
a historic structure and the variance is the minimum necessary to preserve the historic character and
design of the structure." This provision allows communities to handle applications for work
on historic structures by issuing variances.
To address the unique needs of preserving historic structures, communities may elect to use one
of the two approaches, either granting variances or exempting historic structures from the SI/
SD requirements. Whichever approach is selected, it must be used in all cases when improve-
ments or repairs are proposed for historic structures.
Using the variance option allows communities to evaluate individual requests and place condi-
tions on the variance to make historic buildings more flood damage - resistant and to minimize
flood damage. However, such conditions should not affect the historic character and design of
the building.
It is important to note that additions to historic structures that are located in floodways require
additional attention. While additions may not have to meet the substantial improvement re-
quirements, they must still satisfy the NFIP requirements related to floodway encroachments.
A floodway encroachment analysis must be provided to demonstrate that an addition will not
cause any increase in the BFE (Section 5.6.8) .
Applications for improvements to historic structures should be accompanied by two pieces of
evidence: (1) documentation that confirms the building is designated an historic structure; and
(2) documentation that confirms the proposed work will not preclude the structure's continued
designation. Applicants can ask the appropriate qualified entity that makes such designations
to review their construction plans. A copy of the findings should be kept in the community's
permanent records.
Although compliance is not required for substantial improvement of historic structures, own-
ers should carefully consider the benefits of implementing measures to minimize flood damage.
State historic preservation agencies may have resources to help owners evaluate feasible mea-
sures. Historic buildings can be elevated on raised foundations, relocated to sites outside of
SFHAs, or retrofitted with measures that reduce risk from flooding. FEMA's Roodplain Manage-
ment Bulletin: Historic Structures (FEMA P467 -2) provides guidance for communities and owners
of historic structures.
6.5.2 Manufactured Homes
Communities that participate in the NFIP must issue permits for the placement of manufac-
tured homes in SFHAs. This includes the placement of new manufactured homes, replacement
of existing manufactured homes, substantial improvement of manufactured homes, and repair
of substantially damaged manufactured homes. This requirement applies even if the commu-
nity does not otherwise regulate the installation of manufactured homes.
6-24 SI /SD DESK REFERENCE
FACTORS TO CONSIDER AND I O F SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
The NFIP regulations define the following terms pertaining to manufactured homes:
■ "Manufactured home" means a structure, transportable in one or more sections, which is built on
a permanent chassis and is designed for use with or without a permanent foundation when attached to
the required utilities. The terra `manufactured home' does not include a `recreational vehicle.'
■ "Manufactured home park or subdivision" means a parcel (or contiguous parcels) of land divided
into two or more manufactured home lots for rent or sale.
■ "New manufactured home park or subdivision" means a manufactured home park or subdivision
for which the construction of facilities for servicing the lots on which the manufactured homes are to
be affixed (including, at minimum, the installation of utilities, the construction of streets, and either
final site grading or the pouring of concrete pads) is completed on or a ter the effective date of floodplain
management regulations adopted by a community.
• "Expansion to an existing manufactured home park
or subdivision" means the preparation of additional sites
by the construction of facilities for servicing the lots on which
the manufactured homes are to be affixed (including the
installation of utilities, the construction of streets, and either
final site grading or the pouring of concrete pads).
• "Existing manufactured home park or subdivision"
means a manufactured home park or subdivision for which
A manufactured home park is
usually owned by a single owner
who rents pads and /or units.
A manufactured home subdi-
vision is similar to traditional subdi-
visions in that each lot is individually
owned.
the construction of facilities for servicing the lots on which
the manufactured homes are to be affixed (including, at minimum, the installation of utilities, the
construction of streets, and either final site grading or the pouring of concrete pads) is completed be fore
the effective date of floodplain management regulations adopted by a community.
As described below, most manufactured home placements and substantial improvements are
subject to the same NFIP performance standards that apply to typical, site -built residential struc-
tures. A limited exception to the elevation requirements also is described below: under certain
conditions, the exception applies to the placement of manufactured homes in existing manu-
factured home parks or subdivisions.
In AE, Al -30, and AH zones, the NFIP minimum requirement at 44 CFR § 60.3(c) (6) requires
manufactured homes (including substantially improved homes) to be placed on permanent
foundations such that their lowest floors are elevated to or above the BFE. In AO zones, the re-
quirement is for lowest floors to be elevated above the highest adjacent grade at least as high as
the depth number specified on the FIRM. Manufactured homes must be securely anchored to
an adequately anchored foundation system to resist flotation, collapse, and lateral movement.
In V zones, the NFIP minimum requirement at 44 CFR § 60.3(e) (8) requires manufactured
homes (including substantially improved homes) to be placed on permanent foundations such
that the lowest horizontal structural members (generally the bottom of the chassis frame) are
elevated to or above the BFE. Manufactured homes must be securely anchored to an adequate-
ly anchored foundation system to resist flotation, collapse, and lateral movement. And, as with
other buildings in V zones, foundations must be designed to withstand flood forces.
SI /SD DESK REFERENCE 6-25
6 FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
In both A zones and V zones, the above - described requirements apply to sites that are:
• Outside of a manufactured home park or subdivision (individually owned parcels),
• In a new manufactured home park or subdivision,
• In an expansion to an existing manufactured home park or subdivision, or
• In an existing manufactured home park or subdivision on which a home has incurred
substantial damage as a result of a flood.
The exception in the NFIP regulations allows an alternative to the requirement to elevate the
lowest floors of manufactured homes to the BFE [44 CFR § 60.3(c) (12) and § 60.3(e) (8)]. The
exception is applicable only for placements or substantial improvements on lots in existing
manufactured home parks and subdivisions. It allows the chassis of a manufactured home to be
elevated on reinforced piers or other foundation elements of at least equivalent strength that
are no less than 36 inches in height above grade. Although the NFIP allows this exception, com-
munities should consider requiring full elevation in flood hazard areas where the floodwaters
are known to be swift or more than 3 feet deep because these conditions pose greater risk to
vulnerable manufactured homes and their occupants.
NFIP requirements for the substantial improvement of manufactured homes are the same as
for residential structures. Specifically, a lateral addition that is determined to be a substantial
improvement is illustrated in Figure 6-6. In this case, both the addition and the existing manu-
factured home must be elevated.
For additional information on the placement and substantial improvement of manufactured
homes in SFHAs, see FEMA P -85, Protecting Manufactured Homes from Floods and Other Hazards: A
Multi - Hazard Foundation and Installation Guide.
6.5.3 Accessory Structures and Certain Agricultural Structures
Floodplain management requirements, including the elevation and SI /SD requirements, apply
to accessory structures and agricultural structures. Whether improvements, repairs, or addi-
tions to agricultural structures are proposed, local officials must make determinations based on
costs and market values. If the work is SI /SD, the requirements apply and accessory structures
and agricultural structures must be brought into compliance.
FEMA recognizes that wet floodproofing may be appro-
priate for accessory structures (garages and sheds only)
and certain types of agricultural structures. Certain agri-
cultural structures that qualify for this treatment are those
located in wide, expansive floodplains, including farm
storage buildings, grain bins, corn cribs, and gener-
al purpose barns. All other agricultural structures must
comply with the NFIP requirements for non - residential
structures, Homes that are built on farms are not agricul-
tural structures and they must fully comply with the NFIP
Wet floodproofing means perma-
nent or contingent measures applied
to a structure and /or its contents that
prevent or provide resistance to dam-
age from flooding by allowing water
to enter the structure. For specifics,
see FEMA FIA- Technical Bulletin 7,
Wet Floodproofing Requirements
for Structures Located in Special
Flood Hazard Areas.
6-26 SI /SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF SUBSTANTIAL IMPR AND REPAIR OF SUBSTANTIAL DAMAGE 6
requirements. For additional guidance, see FEMA FIA- Technical Bulletin 7, Wet Roodproofing Re-
quirements for Structures Located in Special Flood Hazard Areas.
In accordance with the requirements for issuance of variances (Section 5.6.7), communities
may grant variances for substantial improvement of accessory structures and certain agricultural
structures to allow the use of wet floodproofing measures in lieu of elevation. However, such
variances may be granted only if the following conditions are satisfied:
■ For certain agricultural structures, the structure is used solely for the parking of agricultural
vehicles and machinery, the storage of crops, or the temporary sheltering of livestock;
■ For accessory structures, the structure is used only for parking of vehicles and storage;
■ The structure is designed and built in such a manner that results in minimal damage to the
structure and its contents, including being anchored to resist flotation, collapse, and lateral
movement;
• Flood damage- resistant materials must be used below the BFE;
• Mechanical and utility equipment must be elevated or floodproofed to or above the BFE;
• If in the floodway, the floodway encroachment requirements must be satisfied; and
• There will be no additional threats to public safety.
Communities should carefully evaluate improvements made to accessory structures and agricul-
ture structures. If a property owner intends to change the use of the structure to a residential use
or other non - residential use, then the work proposed must be evaluated to determine whether
it is a substantial improvement.
6.6 NFIP Flood Insurance Implications
The flood insurance rating structure used by the NFIP
uses three primary factors:
• Flood zone (A zone or V zone);
• Date of construction (pre -FIRM or post - FIRM),
including the date of construction of substantial
improvements; and
■ For post -FIRM buildings, the elevation of the lowest
floor compared to the BFE as evidenced by surveyed
elevation data (or for floodproofed non - residential
buildings, the height of the floodproofing relative to
the BFE).
Rates used for pre -FIRM structures
are called "subsidized" or discounted
rates. An NFIP policy can be pur-
chased without providing elevation
data that are obtained by a survey.
The NFIP requires that substantially improved or sub- I
stantially damaged buildings be brought into compliance.
NFIP flood insurance policies on those buildings are written using rates based on elevation. In
most cases, the premium will decrease when a pre -FIRM building is substantially improved and
Rates used for post -FIRM structures
(and pre -FIRM structures that are
substantially improved) are called
"elevation" rates because they de-
pend on the elevation of the lowest
floor relative to the BFE. Elevation
rates are considered to be "actuar-
ial:' To be properly rated, surveyed
elevation data are required.
SI /SD DESK REFERENCE 6-27
6 FACTORS TO CONSIDER AND ILLUSTRATI O F SU BSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE
brought into compliance. The building becomes a post -FIRM building and premiums are cal-
culated using elevation rates.
When questions arise concerning how a proposed improvement might affect a flood insurance
policy, it is always best to encourage property owners to obtain a cost estimate from an insurance
agent. Table 6-2 indicates how compliance with the SI /SD requirements affects how policies are
rated. Figure 6-14 illustrates an example of how the cost of an NFIP policy will vary, depending
on how a substantially damaged home is repaired.
Table 6 -2. Substantial Improvement and NFIP Flood Insurance Implications
6-28 SI /SD DESK REFERENCE
Description of Work
NFIP Flood Insurance Implications
Pre -FIRM
Interior renovation only, work constitutes SI;
Policy is written using post -FIRM elevation
whole building brought into compliance by
rates based on a survey of new lowest floor
elevating the lowest floor at or above the BFE.
elevation at or above the BFE.
Or
Structurally- connected lateral addition or
second story addition, work constitutes SI;
whole building brought into compliance.
Pre -FIRM
Interior renovation only, work constitutes SI;
Policy is written using post -FIRM elevation
building is NOT elevated in compliance with
rates based on a survey of new lowest
the requirements (i.e., it is a violation).
floor below the BFE, which may result in a
significantly higher flood insurance premium.
Or
Second story addition, work constitutes SI;
Or
building is NOT elevated in compliance with
If the owner refuses to address the violation
the requirements (i.e., it is a violation).
and bring the building into compliance, the
community may cite the structure as a violation
in accordance with Sec. 1316 of the National
Flood Insurance Act of 1968, which allows the
NFIP to deny flood insurance on all insurable
buildings on the property (Section 5.6.13).
Pre -FIRM
Lateral addition not structurally connected
Policy is written using subsidized rates
(connecting door only), work constitutes SI and
because the original building is unchanged.
only the addition is elevated.
Post -FIRM
Lateral addition, regardless of value; addition
Policy is written using elevation rates based on
is not elevated, thus, the building is not in
the elevation of the lowest floor of the addition,
compliance (i.e., it is a violation).
which may result in a significantly higher flood
insurance premium.
6-28 SI /SD DESK REFERENCE
FACTORS TO CONSIDER AND ILLUSTRATIONS OF S JBSTANTIAL IMPROVEMENT AND REPAIR OF SUBSTANTIAL DAMAGE 6
Figure 6-14.The cost
Pre-FIRM Building, before of NFIP flood insurance
damage,6 feet below BFE policy varies depending
® NFIP Premium:$1,079 on how a substantially
- ---------® BFE damaged building is
Arepaired.This illustration
is for$150,000 in
' / \ structure coverage with
the rates as of October
2009.The figure is for
Substantially Damaged, repaired comparison purposes
without permit or without proper only.
iiri= SI/SD determination,
6 feet below BFE
NFIP Premium:$12,694
Ill --- ---- 9 BFE
4
7 \ ,
Substantially Damaged,
repaired and elevated to BFE
Ming Er! NFIP Premium:$998
ER
-- ---- - BFE
Lowest
fJ Floor
/ \ 7
Damaged,Substantially amage ,
1.111r1repaired and elevated to
2 feet above BFE
NFIP Premium:$347
-- ---- - BFELowestFloor
/ \ 1
SI/SD DESK REFERENCE li-"!)
7 Substantial Damage in the
Disaster Recovery Environment
7.1 Overview
Following a disaster, local officials will often have many
additional duties and face the challenge of fulfilling them Waiving permit fees and inspection
with few resources. Local officials may encounter a large fees is a common post- disaster ac-
tion taken by many communities.
number of damaged structures and a high volume of per- However, waiving fees does not
mit applications. Most property owners want to repair and waive the requirement for permits.
rebuild as quickly as possible. Sometimes there is pressure
on local officials to waive requirements that are perceived
to hamper getting back to normal, including pressure to waive the substantial damage require-
ments. Yielding to such pressure would expose people and their properties to future damage.
The recognition that returning to "normal" leads to repetitive flood damage was one of the
driving forces behind the creation of the NFIR To effectively meet the substantial damage re-
quirements of their local regulations, local officials will have to rapidly perform a large number
of inspections and substantial damage determinations.
Developing standard procedures can help communities better manage post- disaster recovery.
This chapter describes ways to estimate repair costs and market values for large numbers of
damaged buildings. Section 7.5 briefly describes FEMA's Substantial Damage Estimator (SDE).
The manuals that accompany this computer -based tool include specific recommendations for
collecting building data in advance, developing protocols, conducting inspections, and produc-
ing reports that support making substantial damage determinations and preparing substantial
damage determination letters. Using this tool, and other methods described in this chapter, can
help local officials provide reasonable and defensible substantial damage determinations.
This chapter offers guidance for communities to handle the unique challenges following a disas-
ter event and to prepare an effective and efficient response. It also includes a very brief overview
of damage assessments and building evaluations that may help local officials after disasters, and
describes some effective measures communities can take to clearly communicate the substantial
damage requirement in their floodplain management regulations and codes.
7.2 Preparing for Post - Disaster Recovery
There are several ways that communities can effectively administer their floodplain manage-
ment responsibilities in the post- disaster recovery period. Some successful actions include:
■ Brief all elected officials, as soon as possible after the event, of the community's responsibilities
to:
SI /SD DESK REFERENCE 7-1
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
V, Issue permits for repair and reconstruction,
Make substantial damage determinations for buildings that are located in the mapped
SFHA,
Explain what it means to bring a substantially damaged building into compliance with
current floodplain management standards,
Explain NFIP Increased Cost of Compliance insurance coverage (Section 7.6), and
Share the materials developed to communicate with citizens.
• Ask electric utility companies and community utility departments to turn on service only if
the owner provides a copy of a building permit or evidence that a permit is not required.
• Establish a routine to drive through affected areas to check for unpermitted construction
work and ask the police and other departments to report on activities that may not be
authorized by permit.
• Depending on the scale and severity of damage, some communities institute a full or partial
moratorium on issuing permits. Once the community has evaluated the magnitude, scope,
and general location of potentially substantially damaged structures, the community may
remove the moratorium. When mitigation projects such as floodplain buyouts, elevation -in-
place, or other measures are considered, it may be reasonable to delay rebuilding until the
pros and cons of such projects are evaluated (Chapter 8).
• Keep records in a format that allows plotting by a geographic information system (GIS)
to easily document the status of each damaged building, including those that have been
inspected, those with pending permit applications, those that have been determined to
be substantially damaged, those with permits, and those that have been inspected during
construction.
Communities that have extensive floodplains and significant numbers of flood -prone buildings
are encouraged to plan ahead to handle the workload. Despite good planning, support may
be necessary to handle large numbers of damage inspections and permit applications. In addi-
tion to support from the State and FEMA, resources may be available from other communities,
State floodplain management associations, State building code associations, and organiza-
tions that represent engineers and architects. Some States and communities develop mutual
aid agreements, interlocal agreements, or some other mechanism to facilitate this post- disaster
support. While help may be offered to perform inspections and gather data, the final SI /SD de-
terminations and permit decisions remain the responsibility of the local official in the affected
community.
7.2.1 Sources of Assistance
Many technical issues can arise when inspecting damaged buildings and making substantial
damage determinations. For matters related to the floodplain management requirements of
local regulations and building codes, local officials are encouraged to contact their NFIP State
Coordinating Agency or the appropriate FEMA Regional Office (Appendix A) . After disasters,
training or other assistance may be available from FEMA on how to use SDE such as collecting
information on damaged buildings.
7 -2 SI /SD DESK REFERENCE
SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
7.3 Assessing Building Damage
Although every disaster is unique, local officials can anticipate and prepare for many of the
activities that take place after large -scale events. This section is intended to highlight those ac-
tivities that relate to identifying substantially damaged buildings.
7.3.1 Preliminary Damage Assessments
Immediately after large -scale events that cause major damage, community and State officials
typically undertake an initial "windshield review" of the extent of damage. This survey yields a
broad characterization of the number of buildings affected and the level of anticipated damage.
It usually is a precursor to a decision regarding whether to seek a declaration of the event as a
major disaster.
Typically, this initial survey is followed by an official Pre-
liminary Damage Assessment (PDA) . PDAs are performed
by teams of representatives from FEMA and /or the State.
Local building officials and floodplain managers can par-
ticipate in PDAs, which usually are coordinated by local
emergency managers.
Preliminary Damage Assessments
are performed to broadly charac-
terize the extent of damage — they
are not equivalent to substantial
damage determinations.
The PDA augments the initial reports from communities regarding the scope, magnitude, and
impact of an event on individuals, families, businesses, and public property. The PDA teams view
the damage first -hand, assess the scope of damage, and develop gross estimates of repair costs.
The information is used to determine whether Federal disaster assistance should be requested
by the Governor and forms the basis for the disaster declaration. The PDA also identifies any
unmet needs that may require immediate attention.
Local officials charged with performing building inspections and making substantial damage
determinations may find the results of the PDA useful to identify areas where significant dam-
age has occurred and to coordinate their substantial damage inspections.
7.3.2 Rapid Evaluations and Detailed Safety Evaluations
Depending on the scope of an event and severity of dam-
age, some communities conduct a rapid evaluation of Safety evaluations are performed to
damaged areas as a preliminary step before detailed eval- identify unsafe buildings — they are
not equivalent to substantial dam -
uations are performed. age determinations.
Rapid evaluations, sometimes called "building condition
surveys," typically are based on an exterior inspection. They are conducted to:
■ Identify buildings that appear to be so damaged that they are unsafe and should not be
reentered without a detailed inspection of structural integrity, and
■ Identify buildings that appear to have damage sufficient to require a permit before they can
be repaired or reoccupied.
SI /SD DESK REFERENCE 7-3
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
These rapid evaluations can also help local officials determine the scope of an event and the
level of effort that will be required to perform building -by- building inspections, review permit
applications, collect substantial damage data, and perform inspections once recovery work is
underway.
One method for conducting rapid evaluations is described in ATC 45, Field Manual: Safety Evalua-
tion of Buildings after Windstorms and Floods. This document, produced by the Applied Technology
Council ( ATC, http: / /�NNN % is not a manual for making substantial damage de-
terminations. It provides guidelines and procedures for conducting both rapid evaluations and
more detailed evaluations to determine whether damaged buildings are safe for use or if entry
should be restricted or prohibited.
Most communities perform additional detailed safety evaluations when buildings have sustained
significant damage. The purpose of the evaluations is to identify restrictions on building access
and use. For complex buildings and many non - residential buildings, the evaluation may lead
the local official to conclude that it is appropriate for the owner to submit an independent en-
gineering evaluation. In addition to describing methods for conducting rapid evaluations, ATC
45 includes a method for conducting detailed evaluations. ATC 45 and other sources recom-
mend posting damaged buildings with one of three notices:
■ Inspected (typically a green placard). This signifies that no apparent hazard was identified,
that the original lateral- and vertical -load capacity is not significantly decreased, and there
are no restrictions on use or occupancy. It does not mean that work can proceed without a
permit.
■ Restricted Use (typically a yellow placard). This signifies that the safety of the building is
questionable or hazardous conditions exist or are believed to exist and warrant restrictions on
occupancy and reuse. Further evaluation is necessary (which may or may not be performed
by the local official).
■ Unsafe (typically a red placard). This signifies that an extreme hazard or unsafe situation is
present and there may be a significant risk of further damage or collapse. These buildings
are unsafe for occupancy or entry, except as authorized by the local official. A "red tag" is
not a demolition order, although such an order may be issued depending on subsequent
evaluations.
7.4 Using Estimates of Repair Costs and Market Values to Screen
for Substantial Damage
Some readily - available data can be used to estimate repair costs and market values. The sources
of estimates described below can be used to "screen" damaged buildings for those that are most
likely to have sustained substantial damage. Comparing readily - available information on repair
costs to readily - available information on market value can give local officials a basic picture of
which structures will require more attention and more detailed information in order to make
substantial damage determinations. While the sources of information listed below should not
be used to make final substantial damage determinations, local officials can use them to orga-
nize and focus efforts following a disaster.
7 -4 S1/SD DESK REFERENCE
SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
When using estimates in this manner, there is no firm rule to determine how close to 50 percent
is close enough to warrant requiring additional effort to improve the accuracy of the data. Each
community should decide in advance, based on its selected method of making estimates, how
close is close enough. For example, as described below, a community may decide to use easily -
obtained estimates for screening purposes. The local official may then decide that, using those
estimates, if the ratio of estimated costs compared to estimated market value is less than 40 per-
cent, no further evaluation is necessary because the work obviously does not constitute SI /SD.
Using that same logic, the community may decide that, if the ratio is greater than 60 percent, no
further evaluation is necessary because the work obviously constitutes substantial damage.
Continuing this example, the question then becomes what should the local official do when the
ratio, based on estimates, falls between the bounds of 40 percent and 60 percent. The local offi-
cial may require the applicant to provide a detailed list of costs (materials and labor) and /or to
obtain a professional appraisal of the market value of the building (Section 4.5.1) . Alternatively,
if the local official has evidence that an estimate reflects actual repair costs (or actual market
values), those estimated costs and values may be used for the final SI /SD determination.
Local officials will still be responsible for administering their standard permit requirements
and procedures for structures that fall outside the parameters of their screening efforts. In the
example above, permits will still be required for structures where the ratio is more than 60 per-
cent and those with a ratio of less than 40 percent. Local officials can reexamine the substantial
damage requirements during the review of those permit applications.
7.4.1 Insurance Estimates of Repair Costs
Property owners who have insurance will receive esti-
mates of damage from their insurance companies. For
a number of reasons, these estimates are not sufficient
for local officials to make substantial damage determina-
tions. The basis used by adjusters to estimate damage and
the costs to repair are governed by the terms of the in-
surance policy The insurance estimate ma not cover all
Only the community is legally respon-
sible for maldng SIM determinations.
Information from insurance claims
may help screen for substantial dam-
age, but cannot be used as the basis
for final determinations.
Y
costs associated with repairing a structure to its pre -dam-
age condition, which is the basis that communities must use.
After floods, adjusters who handle NFIP claims are instructed to submit an Adjuster Preliminary
Damage Assessment form to FEMA if a building appears to have been substantially damaged
(FEMA Form 81 -109, in Appendix D). The form provides information about a damaged build-
ing, including Probable Repair Cost, Building Replacement Cost Value, and Building Actual
Cash Value. Local officials can use this information for screening purposes to help identify
those buildings that should be examined more closely. Because Federal flood insurance does
not cover all damage that local officials must consider when determining substantial damage,
the reported Probable Repair Cost may underestimate the total cost to repair. In addition, the
Building Replacement Cost Value and the Building Actual Cash Value may not be equivalent to
market value. After floods, communities should contact the NFIP State Coordinating Agency or
FEMA Regional Office to determine if this information is available.
SI /SD DESK REFERENCE 7-5
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
If insurance claims data are available from property owners for buildings damaged by events
other than flooding, the same limitations apply. While local officials may find such data useful
for screening, claims data must not be used as a proxy for the costs of repair to make substantial
damage determinations.
7.4.2 Unadjusted Assessed Values as Estimates of Market Values
Section 4.5.2 describes using adjusted assessment values that are developed by applying an adjust-
ment factor to property assessment values provided by the local property assessment authority
to yield a reasonable estimate of market value. In the post- disaster period, unadjusted assessed
values may be used as estimates of building market value to quickly screen damaged buildings
to help focus attention on those for which more detailed information has to be provided.
7.4.3 Replacement Cost Values as Estimates of Market Values
Replacement cost value (RCV) means the cost to replace a building on the same parcel with a
new building that is intended for the same purpose and using comparable materials and quality
(at the present day cost of materials and labor). The concept of RCV is used by the insurance
industry and the construction industry. Definitions may vary from State to State.
RCV can be estimated easily, even when a large number of damaged buildings must be assessed.
Therefore, local officials may find it useful to use RCV to estimate market values in the post -di-
saster period to screen all damaged buildings.
The older and more deteriorated a structure is, the greater the potential for a difference be-
tween RCV and market value. Thus, local officials who use RCV estimates for screening are
advised to set a low threshold for the ratio of cost to repair to RCV, such as 30 percent. In that
case, any building that the screening indicates has a ratio value of greater than 30 percent would
be examined carefully to ensure that valid cost estimates and market values are used in the sub-
stantial damage determinations.
A number of commercial sources of construction cost information are available to support es-
timating the replacement cost of a building, including industry- accepted guides available from
companies such as RSMeans (http: / / and the Craftsman Book Company
(lit tp : / / , A , " w. crafts man- book.com), among others. These sources allow computation of con-
struction costs based on occupancy, square footage, quality, and regional cost variations.
7.5 Damage Assessments for Substantial Damage Determinations
Communities have choices about how to handle making substantial damage determinations
when many buildings have been damaged by a significant event:
■ They can proactively inspect buildings soon after the event and use available information to
estimate repair costs and market values; those data can then be used to develop substantial
damage determinations in advance of owners submitting applications with more detail; or
7-6 SI /SD DESK REFERENCE
SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
■ They can notify owners of the requirement to get permits and then wait for property owners
to apply for permits and make substantial damage determinations at that time, following
their normal permit review procedures.
The first option offers a number of benefits that should make it easier to administer the SI /SD
requirements. One benefit is to provide property owners with information about the require-
ment to bring buildings into compliance before they get very far along with their plans to repair.
Another benefit is that owners that have Federal flood insurance policies will more quickly re-
ceive the community's substantial damage determination that they need in order to submit a
claim for ICC coverage to their adjuster (Section 7.6). The second option may pose more of
a challenge to the community because many people begin repairs without getting permits. In
addition, by the time owners apply for permits, they may have hired design professionals to de-
velop plans for repairs and improvements that do not take into consideration the requirement
to bring SI /SD buildings into compliance.
7.5.1 FEMA's Substantial Damage Estimator Software
FEMA's SDE software offers a formalized approach to
develop reasonable estimates of building values and rea-
sonable estimates of the cost to repair or reconstruct
buildings. The SDE enables local officials to calculate a
reasonable and defensible estimate of whether a building
has been substantially damaged. Local officials can use
these results from the software to make substantial dam-
age determinations.
The SDE is described in the FEMA Substantial Damage Es-
timator (FEMA P -784 CD). This publication includes a
Communities may request assis-
tance with SDE:
■ FEMA offers training workshops
on SDE.
■ FEMA may deploy personnel to
help local officials use SDE after
disasters
User's Manual and a Field Workbook. Together they focus on using the SDE tool to perform
field evaluations and post -event data collection, as well as pre - planning before an event.
Originally developed for single- family homes and manufactured homes, the 2010 version of SDE
now includes a component that will allow it to be used for common non - residential structures
(e.g., office buildings, strip malls, restaurants, grocery stores, convenience stores, department
stores, schools, etc.). However, SDE is not designed for estimating damage to unique buildings
and buildings designated by State or Federal entities as "historic structures." The SDE also is an
effective tool to use even if only one or a few buildings are damaged. The SDE Field Workbook
includes worksheets that are useful even if the software is not used. SDE includes worksheets for
single /multi - family buildings, manufactured homes, and certain non - residential buildings.
While SDE can be used to evaluate damage by any cause (flood, tornado, earthquake, etc.),
flooding is the most frequently- occurring natural hazard. Therefore, the software and compan-
ion workbook focus primarily on developing inventories of flood - damaged structures.
1 Replaces and expands the 2001 version of the Residential Substantial Damage Estimator (FEMA 311) and the 2003 version of
the RSDE Workbook (FEMA 311 WB).
SI /SD DESK REFERENCE 7-7
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
The SDE software allows the user to develop damage estimates by examining individual building
elements. Users are able to estimate damage percentages for each described building element.
Using these percentages, SDE produces an aggregate "percent damage" for the structure as a
whole.
SDE is customizable, allowing users to develop estimated repair costs and market values, or to
input professional estimates or valuations. To develop estimates for repair costs and market
value, SDE is intended to be used in conjunction with an industry- accepted, construction cost -
estimating guide such as RSMeans Residential Cost Data Book, RSMeans CostWorks, and the
Craftsman' National Building Cost Manual. The SDE is designed for use by local officials or oth-
ers who have some experience and knowledge of residential and non - residential construction
costs and practices.
Building- specific attributes that affect the estimates that the software produces are inputted
by the user. The required attributes include the quality of construction (low, budget, average,
good, and excellent), foundation type, number of stories, square footage, superstructure type,
exterior finish, roof covering, and presence of HVAC systems. Additional inputs are requested
for non - residential buildings, including building use, presence of elevators, escalators, and fire
suppression systems.
Photographs of each inspected building can be uploaded and stored with the software and later
retrieved for reports. Fields allow input of latitude and longitude coordinates acquired onsite
using a handheld global positioning system (GPS) device. Figure 7 -1 shows how the data can be
displayed on geographically registered images such as digital aerial photography, Google Earth,
and NASA's World Wind.
Users can define their own reports or use one of the ten pre- determined report formats:
1. Community Report for all residential structures
2. Community Report for all non - residential structures
3. Community Report for residential structures that appear to be substantially damaged
4. Community Report for substantially damaged non - residential structures
5. Structure and Percent Damage Report for all residential structures
6. Structure and Percent Damage Report for all non - residential structures
7. Structure and Percent Damage Report for substantially damaged residential structures
8. Structure and Percent Damage Report for substantially damaged non - residential struc-
tures
9. Summary Report for all residential structures
10. Summary Report for all non - residential structures
7 -8 SI /SD DESK REFERENCE
SUBSTANTIAL D MAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
Figure 7-1. SDE data
—o of •-. it, displayed using mapping
'` t% t: software.
- 7535 River Road i
114
0
Percent Damaged 57.98
ix Date of Damage:8129f2005
a) Date of Inspection:1/27/2006 + -• ..
El_
, Cause of Damage:Flood and Wind '-, 1 • {L
lairi 4.;
- ' .71:, ... .
•
tlipir 1I
t cdrPark Road
li+w
Directions To here-From here
- ' tia11
7 _
R . ' ; .i ; 7541 River Road-
....,,
"' „5 River Roadl
- River.Road
itil
k :i ''* ..,,
The Community Reports noted above'include the following information (Structure and Per-
cent Damage Reports include only items 1, 2 and 6):
1. Community name and identification number
2. Owner first and last names, building address, community, State, and zip code
3. Basis for value of building (computed actual cash value from the SDE software, adjusted
tax assessed value, or professional appraisal)
4. Basis for costs to repair (computed damage from the SDE software,contractor's estimate,
or community estimate)
5. Type of structure (single-family, town or row house, manufactured home, or non-resi-
dential)
6. Estimate of percent damaged ( esults of comparing the estimated cost to repair to the
estimated building value)
7.6 Increased Cost of Compliance Coverage
NFIP flood insurance policies on buildings include ICC coverage. This coverage was autho-
rized by Congress to help pay the added costs of bringing buildings that are repetitively or
SI/SD DESK REFERENCE 7-9
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
substantially damaged by flooding into compliance with
the community's floodplain management requirements
for new construction.
ICC claims are paid after direct physical loss caused by
flooding and:
■ The building is determined by the community to be
substantially damaged, or
An ICC claim can be made regard-
less of whether a flood results in a
Presidential disaster declaration.
In 2010, the ICC coverage could
provide up to $30,000 towards the
cost of bringing certain flood -dam-
aged buildings into compliance.
■ If the community has adopted a "repetitive loss" or
cumulative substantial improvement provision that requires compliance based on flood
damage that occurs two times in a 10 -year period ending on the second event, where the
cost to repair the damage equals or exceeds 25 percent of the building's pre- damage market
value on each occurrence (Section 5.7.3).
ICC payments are made to help pay for the following miti-
gation options that bring buildings into compliance:
• Elevation (including freeboard if required by the
community)
• Relocation
• Demolition
■ Dry floodproofing (non- residential buildings only)
Guidance on ICC is available in FEMA 301, Increased Cost
of Compliance Coverage: Guidance for State and Local Officials.
This publication describes the coverage, conditions of eli-
gibility, and the claims process. The roles of the insurance
agent, claims adjuster, and policyholder are described.
The community's role is described in detail, including the
following:
In order for an ICC claim to be
paid:
■ Local officials must make SD
determinations and work with
owners to develop measures to
bring buildings into compliance.
■ Owners must file an ICC claim.
■ Adjusters must verify key infor-
mation and process claims.
■ The community issues permits
for the work.
• Requiring compliance with all NFIP and local requirements.
• Collecting information and making substantial damage determinations.
• Informing property owners about the requirement to bring buildings into compliance and
working with them to determine the appropriate options to achieve compliance.
• Providing the property owner /policyholder a letter with the substantial damage deter-
mination; the owner then provides a copy to the claims adjuster to process the ICC claim.
• Issuing permits and inspecting construction.
■ Performing final inspections and issuing certificates of occupancy or letters that state the
building has been brought into compliance and that no variance was granted; this evidence
is required before policyholders can receive the final installment of their ICC claim
payments.
7 -10 SI /SD DESK REFERENCE
SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
7.7 Post - Disaster Permits and Inspections
The occurrence of a disaster that affects a large number of buildings does not alter a commu-
nity's responsibility to review permit applications, issue permits, inspect construction, and cite
violations. All of those actions should be performed as usual (see FEMA 480, NFIP Floodplain
Management Requirements: A Study Guide and Desk Reference for Local Officials) . The only difference
will be the volume of work and the number of owners who will need assistance. Chapter 5 of this
Desk Reference describes community responsibilities for issuing permits and Chapter 4 offers
guidance for estimating repair costs, improvement costs, and market values.
It is important that each permit application be carefully examined. Some damage may not have
been readily apparent when post- disaster assessments were performed, some owners may de-
cide to undertake improvements at the same time as repairs, or some owners may postpone
repairs for many months. Each of these may alter the determination. Every permit file should
contain the documentation necessary to support the finding that the work does — or does not
— constitute SI /SD.
Even after a disaster, local officials should not assume that construction will proceed as spelled
out in the permit application. Follow-up inspections are vital to ensure that applicants adhere
to the permit requirements. Local officials should develop a plan to handle the increased num-
ber of permits and inspections.
7.8 Appeals and Variances
After events that cause major damage, owners often seek relief from requirements to comply
with building code and floodplain management requirements. There are two mechanisms
through which such relief may be processed: appeals and variances.
Owners may appeal decisions, orders, and determinations made by local officials, including
substantial damage determinations. Appeals are described in more detail in Section 5.6.6. Even
in the post- disaster recovery period, appeals should be handled according to the community's
established process.
Owners may request variances. A variance is a grant of relief from the terms of a land use, zon-
ing, building code, or other regulation. If granted, it allows construction in a manner that is
otherwise prohibited. Variances are described in more detail in Section 5.6.7.
The NFIP regulation at 44 CFR § 60.6 outlines procedures for granting variances; these pro-
cedures must be followed even in the post- disaster recovery period (also see FEMA 480, NFIP
Floodplain Management Requirements: A Study Guide and Desk Reference for Local Officials) . If grant-
ed, variances are to provide only the minimum relief necessary. A variance should be rare, and
granted only after due consideration.
Especially when damage was caused by flooding, it is difficult to conceive of situations where
it can be justified to waive the requirement to elevate buildings that were determined to have
been substantially damaged. Local officials are required to advise owners that, even if approved
S1/SD DESK REFERENCE 7 -11
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
by a properly granted variance, buildings that have their lowest floors below the BFE may be
rated for NFIP flood insurance using very high rates, resulting in costly premiums (see Section
6.6).
7.9 Post - Disaster Communications with Property Owners
Communications with property owners will take place throughout the post- disaster recovery
phase. Local officials should recognize that substantial damage determinations may generate a
number of questions from home and business owners, and should be prepared to respond to
these questions. This section provides local officials with guidance for communicating substan-
tial damage information, and describes the following:
■ Information about clean -up and repairs
■ Information about permits
■ Information about Increased Cost of Compliance coverage
■ Interactions during damage inspections
■ Providing substantial damage determination letters to owners
7.9.1 Information About Clean -up and Repairs
The initial contacts with property owners are typically related to cleaning up, advising them
that inspections must be conducted to determine the safety of buildings, reminding owners
not to perform any work that requires a permit until permits are obtained, and advising them
that substantial damage determinations must be made and that such determinations trigger the
floodplain management requirement to bring buildings into compliance by elevating them (or
by dry floodproofing, non - residential buildings only) . Local officials can provide information
to owners about the kinds of clean -up and repairs that may be performed prior to a substantial
damage determination, including work necessary to temporarily stabilize a building so it is safe
to enter, as well as trash removal and clean -up.
Unless there are restrictions on entering areas that have sustained major damage, most owners
and occupants start to clean up right away. There are many online sources of information to
help with clean -up work, including http: / /Nv"i8Jema.gov and http: / /ww , " , .redcross.or - g, among
others. Copies of FEMA 234, Repairing Your Flooded Home may be available from local offices of
the American Red Cross (ARC) or copies may be ordered from the FEMA publication ware-
house (see Appendix B for ordering instructions). This booklet was developed in partnership
with ARC and FEMA. FEMA has other materials related to recovering from, and coping with,
flood damaged property, available online at littp: / /tiN8 /hazard /flood /copitig.shtm.
7.9.2 Information About Permits
It is extremely important to make sure that property owners are informed about their respon-
sibilities to obtain permits for repairs following disasters. Lack of information about permit
requirements can cause many problems in the post- disaster period. FEMA's SDE Field Workbook
7 -12 S1/SD DESK REFERENCE
SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT 7
(Section 7.5.1) includes samples of a press release, a notice that can be posted in affected areas,
and a handout that can be used to alert residents that inspections will be performed and per-
mits may be required.
Communities should consider developing and providing guidance to citizens and property own-
ers on:
■ The importance of having damaged buildings inspected before repair work is started.
■ Activities that require a permit.
■ The floodplain management requirements that apply when buildings in the SFHA are
substantially damaged.
■ Activities that do not require a permit (e.g., disposing of damaged contents and carpeting;
cleaning floors, walls, and ductwork; or covering damaged roofs and windows).
■ The availability and benefits of ICC coverage that is part of NFIP flood insurance policies on
buildings in mapped SFHAs (Section 7.6). FEMA has developed a brochure that explains
ICC (FEMA F -663, Increased Cost of Compliance Brochure) (see Appendix B for ordering
instructions) .
■ The importance of hiring licensed contractors and cautions about fraudulent and unlicensed
entities that may take advantage of victims in areas that have been hit by a significant event.
■ The importance of including damage- reduction measures to minimize future flood damage,
even if such measures are not required by the community's floodplain management
regulations.
7.9.3 Information About Increased Cost of Compliance Coverage
As described in Section 7.6, local officials should remind owners who have NFIP flood insurance
policies that ICC coverage may help pay for the cost to bring buildings into compliance with
local floodplain management requirements if it is determined that the building has been sub-
stantially or repetitively damaged. The local official should also provide guidance to property
owners on mitigation options to bring buildings into compliance. Local officials should obtain
copies of FEMA F -663, Increased Cost of Compliance Brochure and distribute it to property owners
as needed.
7.9.4 Interactions with the Public During Damage Assessments
After disasters and while conducting damage assessments, local officials may be faced with many
questions from property owners and occupants. Communities are encouraged to set guide-
lines for interactions between inspectors and owners so that inspectors can efficiently perform
their work. Although some assessments may be performed without direct contact with property
owners, detailed evaluations and use of FEMA's SDE software tool typically require contact and
coordination with owners.
The inspector's job is to inspect damaged buildings and collect data. Local officials should en-
courage inspectors to refrain from speculating or discussing the likely outcome of substantial
SI /SD DESK REFERENCE 7 -13
7 SUBSTANTIAL DAMAGE IN THE DISASTER RECOVERY ENVIRONMENT
damage determinations. Because the final determination must be made by the local official, dis-
cussions in the field may contribute to misinformation and confusion.
Before they are sent out to inspect damaged buildings, a meeting should be held with all inspec-
tors to talk about the importance of consistent communication with owners and occupants. It is
a good practice to set up a single point of contact to answer questions from owners, and inspec-
tors should encourage people to call that contact. Not only does this improve the consistency of
the information provided, but it will help inspectors get their jobs done more efficiently.
Every inspector should carry an official letter that explains the purpose of the inspection and
the requirement for owners to obtain permits for repair work. Inspectors should limit their in-
teractions to collecting data. Some communities may direct inspectors to advise owners if they
observe any ongoing work that should be suspended because a permit is required. If materials
are available, inspectors can give owners a handout that explains the community's permit re-
quirements and procedures.
7.9.5 Providing Substantial Damage Determination Letters to Owners
After inspections are completed and the data evaluated
and substantial damage determinations are made, own-
ers should be provided letters with the results. Appendix
E includes examples of three letters:
■ Letter to notify property owners of a determination
that work constitutes substantial improvement
Communities that have developed
mitigation plans may hold meetings
or distribute materials to explain
mitigation options and FEMA's miti-
gation grant programs (Chapter 8).
■ Letter to notify property owners of a determination that work constitutes repair of substantial
damage
■ Letter to notify property owners of a determination that work does not constitute repair of
substantial damage
Understandably, people will have many questions about the determinations, including whether
it can be appealed, what it means to bring a building into compliance, and how they can access
the NFIP's ICC claim payment (if they have NFIP flood insurance). As noted above, designating
a single point of contact or contacts to discuss these questions with owners will ensure consis-
tency.
7-14 S1/SD DESK REFERENCE
8 Mitigation Projects
8.1 Overview
This chapter provides brief descriptions of common types of flood mitigation projects that
are eligible for funding by FEMA's five mitigation grant programs. Brief summaries of those
programs are included. Because program priorities and policies change from time to time, com-
munities that are interested in these programs should obtain current information from their
State Hazard Mitigation Offices (see Appendix A).
Many buildings that are damaged by flooding were built before communities adopted floodplain
management regulations and Flood Insurance Rate Maps. Many of these pre -FIRM buildings
have experienced repetitive flooding and some are vulnerable to significant floods and are
likely to sustain substantial damage at some time. Communities may seek mitigation grants to
address both problems.
Some of FEMA's grant programs are funded annually and can be used to support projects
in the "pre- event" period: Pre - Disaster Mitigation (PDM); Flood Mitigation Assistance (FMA);
Repetitive Flood Claims (RFC); and Severe Repetitive Loss (SRL). One program, the Hazard
Mitigation Grant Program (HMGP), is available only after major disasters are declared by the
President. Many post- disaster mitigation projects include buildings that have sustained substan-
tial damage. Projects that acquire properties, remove flood -prone buildings, and deed - restrict
the land to open space, obviate the need for owners to bring buildings into compliance. Proj-
ects involving other measures that directly affect a building, such as elevation -in -place or dry
floodproofing (non - residential buildings only in A zones), must be conducted in compliance
with the community's floodplain management regulations and codes.
HMGP and PDM are funded by general Treasury funds. FMA, RFC, and SRL are authorized un-
der the NFIP and are funded by income collected by the NFIP. The NFIP- funded programs are
focused primarily on mitigating flood losses sustained by NFIP- insured buildings, specifically
those that have received multiple flood insurance claims, called repetitive loss properties.
8.2 Mitigation Planning
In accordance with 44 CFR Part 201, State and local governments and Indian Tribal govern-
ments must have hazard mitigation plans as a condition for receiving hazard mitigation grants.
The most common types of projects used to mitigate flood losses are described in Section 8.3
and FEMA's mitigation grant programs are briefly described in Section 8.4.
Mitigation planning refers to a process that leads a planning committee through a framework of
steps to develop a mitigation plan. The primary objective of the planning process is to facilitate
development of strategies that will reduce damage, protect people and property, and improve
resistance to natural hazards. The process involves four basic steps:
SI /SD DESK REFERENCE 8 -1
8 MITIGATION PROJECTS
1. Organize resources
2. Identify hazards and assess risks
3. Develop a mitigation plan
4. Implement the plan and monitor progress
While eligible applicants for FEMA grant programs must have FEMA- approved mitigation plans,
the benefits of mitigation planning go beyond simply qualifying for those funds. States, com-
munities, higher education institutions, and other entities that undertake mitigation planning
also consider the value of actions that improve disaster resistance by modifying programs and
policies, such as adoption of more restrictive development standards, and initiating efforts to
inform citizens about risks and steps they can take to reduce damage.
FEMA's guidance documents related to mitigation planning are online at http: / /w" , " , .fema.
gov /plan /rnitplanning /index.shtm.
8.3 Types of Flood Mitigation Projects
This section provides brief descriptions of the most common types of mitigation projects that
are implemented to reduce exposure to flooding. In practice, a single project may involve using
one or more of these project types.
8.3.1 Identifying Flood Mitigation Projects
While mitigation planning is the first step, each property needs to be evaluated individually to
determine which method is appropriate. Communities that engage in flood mitigation projects
have many factors to evaluate before identifying the most effective type or types of activities that
will both solve their problems and also meet other community objectives. Only communities
can make those decisions, although many States help communities evaluate the many factors to
consider. FEMA offers several tools to facilitate decision - making:
■ National Flood Mitigation Data Collection Tool (FEMA 497) . This tool was developed for
nationwide use to gather information about flood -prone structures in order to determine
potentially appropriate long -term mitigation measures. The goal is a standardized, systematic
approach to collecting and interpreting property data and mitigation project development.
While the focus of the tool is data collection for repetitive loss properties, it can be used to
gather information related to flood risk, building construction, and building value for any
structure.
■ Reducing Damage from Localized Flooding. A Guide for Communities (FEMA 511) . This non.
technical guide is intended to help local officials and others understand what can be done
to reduce localized flood damage. It focuses on a community's capability to minimize its
existing localized flood problems and avoid future problems. It outlines the types of actions
that can be taken, explains why they are important and what their potential benefits are, and
points the reader to other sources.
8 -2 SI /SD DESK REFERENCE
MITIGATION PROJECTS 8
■ Selecting Appropriate Mitigation Measures for Floodprone
Structures (FEMA 551) . This manual provides
guidance for interpreting data collected with the
National Flood Mitigation Data Collection Tool and other
sources, in order to develop detailed proposals for
flood mitigation projects. The manual assumes that
areas that are considered high priority for mitigation
have been identified and the community is evaluating
which types of mitigation measures will address specific
problems. It identifies technical issues associated with
mitigation measures and includes references to other
documents that provide more detailed guidance.
8.3.2 Property Acquisition /Demolition and Relocation
FEMA 511 and FEMA 551 describe
measures that reduce flood damage.
Some of those measures may not
result in full compliance and cannot
be used to satisfy the requirement to
bring substantially - damaged build-
ings into compliance. Some of the
measures described may not be eli-
gible for FEMA grant funding.
FEMA and the States have encouraged communities to acquire and remove flood -prone build-
ings since the early 1990s. A property acquisition project involves the purchase of properties
that have sustained flood damage or that may be subject to severe or repetitive flooding. Eligi-
ble acquisition projects are those where the property owner voluntarily participates. Buildings
are either demolished or physically removed. Local and /or State governments agree to deed
restrict the property so that it remains in open space in perpetuity to fulfill natural and benefi-
cial floodplain functions. Acquisition projects can be planned to meet compatible objectives,
including passive recreation, environmental education, or wetlands mitigation.
8.3.3 Building Elevation
An elevation project involves detaching a building from its foundation and placing it on an
NFIP- and code - compliant, taller foundation. The structure must be elevated as required by
local regulations to be at or above the BFE or the post- disaster advisory BFE, if applicable.
Although the costs and elevation methods vary, buildings with all types of foundations have
been elevated, including those on crawlspaces, piers, or pilings. The cost to elevate a structure
can vary greatly, depending on the elevation method used, condition of the structure, and the
height above grade and other construction requirements. Elevation methods that require sig-
nificant demolition or the construction of new living space may not be eligible for Federal grant
funds. Communities interested in property elevation should consult their State Hazard Mitiga-
tion Office and FEMA's program guidance.
Communities consider elevation instead of acquisition projects for many reasons: for buildings
that are structurally sound; to avoid disconnected, publicly -owned lots; for buildings in areas
with extensive floodplains where alternative sites are not available; and for buildings in highly
attractive areas. While elevation -in -place projects reduce flood damage, other flood - related risks
and needs continue. Communities will still have to provide warnings, residents will still have to
be evacuated, emergency shelters will have to be opened, and lives will be disrupted.
SI /SD DESK REFERENCE 8-3
8 MITIGATION PROJECTS
8.3.4 Relocation
If flood -prone buildings are structurally sound, and if acceptable receiving sites are close by, a
relocation project may be viable. Physically relocating buildings to sites outside of the SFHA
reduces the risk of future flood damage and the vacated land can be retained in open space. Re-
locating a building is similar to elevation -in -place because the building must be detached from
its foundation and placed on a new foundation. The difference is the process and equipment
required to move a building over the distance and terrain to the receiving site.
8.3.5 Floodproofing for Non - Residential Structures or Historic Structures
Dry floodproofing involves sealing non - residential struc-
tures to be watertight so that floodwaters do not enter the
building during base flood conditions. Modifications may
include structural strengthening of walls, special doors
and closures for other openings, application of waterproof
membranes, measures to handle seepage, and other mea-
sures. A structural evaluation is necessary to determine
whether a structure can withstand anticipated flood loads,
especially hydrostatic pressure and buoyancy. Currently,
only non - residential structures and residences that are
listed as historic structures may be dry floodproofed.
8.3.6 Other Types of Projects
Compliance with the NFIP require-
ments cannot be achieved by using
wet floodproofing measures in which
floodwater is allowed to enter a
building. An owner may elect to im-
plement these measures unless a
determination finds the work would
constitute substantial improvement.
Other types of projects may reduce flood damage, but are not direct solutions for individual
buildings that are substantially improved, unless the SFHA is revised:
■ Stormwater management. Stormwater management or drainage improvements can
reduce the frequency and severity of flooding, but a property owner cannot propose such
improvements in place of bringing a substantially damaged building into compliance. The
exception is if a drainage project results in a revision of the SFHA in which the building is
located, which may mean the building is no longer in the SFHA.
■ Minor localized flood reduction projects. For larger buildings or groups of buildings, one
option may be to install or modify culverts, floodgates, or minor floodwall systems that
protect an individual structure. Engineering analyses are necessary to determine if these
measures are feasible and to determine their impacts on flood elevations. Only if a project
qualifies for a map revision that removes areas from the SFHA would buildings no longer be
subject to the SI /SD requirements. To be eligible under FEMA's FMA, SRL, and RFC grants,
the mitigation activity must protect structures that are insured by the NFIP.
8.4 FEMNs Mitigation Grant Programs
FEMA administers five mitigation grant programs. Fact sheets for the programs are available
online at http: / /wNtitiv.fema.goN media /tact _ sliects /mitigation.slitm. A chart that compares
8 -4 SI /SD DESK REFERENCE
MITIGATION PROJECTS 8
the programs (authorities, purpose, priorities, available funds, applicant and subapplicant
eligibility, eligible project types, cost -share requirements, eligible management costs, planning
requirements, application and review procedures, and deadlines) and links to descriptions of
each program are found at http: / /NNNA /government /grant /hma /grant resources.
shun, which also lists other resources to support mitigation planning and mitigation projects.
8.4.1 Elements Common to All Grant Programs
All of FEMA's grant programs have certain required elements in common:
■ Application submission. State emergency management agencies or similar offices of the
States may apply directly to FEMA. Local governments and other applicants must submit
applications through the State as subapplicants. Depending on the grant program
applications may be ranked by the State, FEMA, or a national evaluation panel.
■ Mitigation plan requirements. All States must have
a FEMA- approved hazard mitigation plan. Except
for the RFC program, local governments and Indian
Tribal governments also must have FEMA-approved
hazard mitigation plans.
■ FeasibiHtyandeffectivenessrequirement. Projects must
be both technically feasible and effective at mitigating
Each year, FEMA issues guidance
for each grant program. Some priori-
ties and limitations may change from
year to year. Communities that are
interested in these programs should
contact their State Hazard Mitigation
Officers (Appendix A).
the flood hazard. Engineering analyses and project
plans and specifications may be required to demonstrate feasibility and effectiveness.
■ Cost - effectiveness requirement. Hazard mitigation assistance grants only fund cost - effective
mitigation projects. A benefit -cost analysis is a well - established method for quantitatively
comparing benefits and costs of projects.
■ Environmental and historic preservation. Applicants must answer a series of environmental
and historic preservation review questions. All projects must meet the requirements of
applicable Federal, State, Indian Tribal, and local laws, implementing regulations, and
Executive Orders.
■ Flood insurance requirement. For structures that will remain in the SFHA after a mitigation
project is implemented, flood insurance policies must be maintained after the project is
completed.
■ Non - Federal match. Recipients must provide the non - Federal share of the costs and cover
all costs that are determined to be ineligible for funding by the grants. Many communities
require property owners to cover these costs and some States may provide matching funds.
8.4.2 Pre - Disaster Mitigation Program
The PDM program is a nationally competitive program that provides funds to States, local
governments, and Indian Tribal governments for implementation of cost - effective hazard miti-
gation activities that complement a comprehensive mitigation program. The program provides
applicants with an opportunity to raise risk awareness and reduce disaster losses through use of
SI /SD DESK REFERENCE 8-5
8 MITIGATION PROJECTS
grant funds to develop all- hazard mitigation plans and flood mitigation plans and to implement
mitigation projects.
Each year's funding level is determined by Congress. A limit is placed on the maximum amount
that a single project can receive and recipients must provide a cost -share of at least 25 percent of
a project's eligible costs. In addition to supporting development of mitigation plans, PDM funds
can be used for flood mitigation projects, including:
■ Elevation of existing public or private structures to at least the BFE or higher, if required by
FEMA or if required by State or local regulations
■ Voluntary acquisition and demolition or relocation of structures and real property for
conversion to open space in perpetuity
■ Relocation of public and private structures outside of the SFHA
■ Dry floodproofing non - residential buildings and certain residences that are listed as historic
structures
■ Stormwater management projects to reduce or eliminate long -term risk from flood
hazards
■ Localized flood reduction projects
■ Protective measures for utility infrastructure to reduce or eliminate flood damage
8.4.3 Hazard Mitigation Grant Program
HMGP funds are available following a Presidential disaster declaration. Eligible applicants
include States, local governments, Indian Tribal governments, and some private non -profit or-
ganizations. Communities may apply for HMGP assistance on behalf of affected individuals and
businesses, and all funds must be used to reduce or eliminate losses from future disasters. FEMA
allows a portion of the funds to be used to support development of mitigation plans. At a mini-
mum, recipients must provide a cost -share of at least 25 percent of a project's eligible costs.
HMGP provides each State that receives a major disaster declaration an amount of funding
that is determined on a formula that is based on a percentage of funds spent by FEMA under
the Public Assistance and Individual Assistance programs. Under the formula, States with ap-
proved Standard State Mitigation Plans receive 15 percent for the first $2 billion of estimated
aggregate amounts of disaster assistance, 10 percent for disaster assistance amounts between $2
billion and $10 billion, and 7.5 percent for amounts between $10 billion and $35.333 billion.
States with approved Enhanced State Mitigation Plans receive 20 percent for the first $2 billion
of estimated aggregate amounts of disaster assistance and the same percentages when assistance
amounts exceed $2 billion.
HMGP funds can be used for eligible activities that reduce damage from any natural hazard. Ex-
amples of flood mitigation projects that have been funded include:
■ Elevation of existing public or private structures to at least the BFE or higher, if required by
FEMA or if required by State or local regulations
8 -6 SI /SD DESK REFERENCE
MITIGATION PROJECTS 8
IN Voluntary acquisition and demolition or relocation of structures and real property for
conversion to open space in perpetuity
■ Relocation of public and private structures outside of the SFHA
■ Dry floodproofing non - residential buildings and certain residences that are listed as historic
structures
■ Stormwater management projects to reduce or eliminate long -term risk from flood hazards
■ Localized flood reduction projects
■ Protective measures for utility infrastructure to reduce or eliminate flood damage
Eligible subgrantees submit grant applications to the State, which sets mitigation priorities,
performs technical reviews, and offers technical assistance. FEMA conducts the final eligibility
review to ensure that all projects are compliant with Federal regulations, including the Federal
law that requires States and communities to have FEMA- approved mitigation plans in place pri-
or to receipt of HMGP project funds.
8.4.4 Flood Mitigation Assistance Program
The FMA program provides funding to States and communities for measures that reduce or
eliminate the long -term risk of flood damage to buildings, manufactured homes, and other
structures that are insured by the NFIR Each State's allocation is based on its percentage of
NFIP policies. Subapplicants must be participating in the NFIP (not suspended or withdrawn).
The program provides grants for mitigation planning and projects with the goal of reducing in-
surance claims, especially repetitive claims. All applicants must have a FEMA- approved hazard
mitigation plan. At a minimum, recipients must provide a cost -share of at least 25 percent of a
project's eligible costs. The non - Federal cost share may be reduced to 10 percent if the State
has a FEMA-approved mitigation plan that also addresses how the State has and will continue to
reduce the number of severe repetitive loss properties. Examples of eligible projects include:
■ Elevation of existing public or private structures to at least the BFE or higher, if required by
FEMA or if required by State or local regulations
■ Voluntary acquisition and demolition or relocation of structures and real property for the
purpose of creating open space
■ Relocation of structures outside of the SFHA
■ Dry floodproofing of existing non - residential structures and certain residences that are
listed as historic structures
■ Minor localized flood reduction projects where 50 percent of the structures that directly
benefit from the mitigation activity are insured by the NFIP
8.4.5 Repetitive Flood Claims Program
The RFC program is designed to reduce or eliminate the long -term risk of flood damage to
structures that are insured by the NFIP and have received one or more NFIP flood insurance
SI /SD DESK REFERENCE 8-7
S MITIGATION PROJECTS
claim payments. RFC funds may only be used in a State or community that is participating in
the NFIP and that cannot meet the requirements of the FMA due to lack of cost share or lack of
capacity to manage grants. RFC grants are awarded to applicants on a nationwide basis without
reference to State allocations, quotas, or other formula -based allocations. All grants are eligible
for up to 100 percent Federal assistance.
Eligible mitigation activities include:
• Elevation of existing public or private structures to at least the BFE or higher, if required by
FEMA or if required by State or local regulations
• Voluntary acquisition and demolition or relocation of structures and real property for the
purpose of creating open space
• Relocation of structures outside of the SFHA
• Dry floodproofing of existing non - residential structures and certain residences that are
listed as historic structures
• Minor localized flood reduction projects where 50 percent of the structures that directly
benefit from the mitigation activity are insured by the NFIP
Awards are prioritized to fund projects that create the greatest amount of savings to the NFIP
based on benefit -cost analyses. A FEMA approved State /Tribal standard or enhanced hazard
mitigation plan is required for eligibility. A local mitigation plan is not required.
8.4.6 Severe Repetitive Loss Program
The SRL program provides funds to assist States, Indian Tribal governments, and local govern-
ments that participate in the NFIP to implement projects that reduce or eliminate long -term
flood risks to certain properties, thus reducing claims paid by the NFIP. To be eligible, a prop-
erty must qualify under the statutory definition that requires that it:
• Be a residential property currently insured by the NFIP, and
• Have incurred flood losses that resulted in either (1) four or more flood insurance claim
payments that each exceeded $5,000 with at least two of the payments occurring within a 10-
year period, or (2) two or more flood insurance claims payments that cumulatively exceeded
the value of the property
The SRL requires a specific consultation process that includes property owner notification and
information gathering. Applicants are required to follow the specific process to make mitiga-
tion offers. SRL property owners who decline a formal offer under the SRL program will be
subject to an increase in their insurance premiums.
SRL funds are allocated annually to States, Territories, and Indian Tribal governments based
on the number of severe repetitive loss properties in their respective jurisdictions, with cer-
tain "target states" receiving 90 percent of available funds. "Non- target states" compete for the
remaining 10 percent of available funds. Grants may provide up to 75 percent of a project's
8 -8 SI /SD DESK REFERENCE
MITIGATION PROJECTS 8
eligible costs. The non - Federal cost share may be adjusted to 10 percent if the State has a FEMA-
approved mitigation plan that also addresses how the State has and will continue to reduce the
number of severe repetitive loss properties. Eligible SRL activities include:
■ Voluntary acquisition and demolition or relocation of structures and real property for the
purpose of creating open space.
■ Relocation of structures outside of the SFHA.
■ Elevation of existing public or private structures to at least the BFE or higher, if required by
FEMA or if required by State or local regulations.
■ Floodproofing measures only for residences that are listed as historic structures.
■ Minor localized flood reduction projects where 50 percent of the structures that directly
benefit from the mitigation activity are insured by the NFIR
■ Mitigation reconstruction, which involves the demolition and rebuilding of structures. It
is allowed only when traditional elevation methods are not feasible. Grant - eligible costs
are limited. Applicants should check with their State Hazard Mitigation Office for current
guidance.
8.5 Additional Information
FEMA's mitigation assistance programs provide the opportunity to help communities and prop-
erty owners address substantially damaged structures. While the programs differ based on their
statutory requirements, they share a common goal of reducing loss of life and property due to
natural hazards, including flooding. To learn more, visit FEMA's websites referenced above or
contact the appropriate State Hazard Mitigation Officer (Appendix A).
SI /SD DESK REFERENCE 8-9
A FEMA Regional Offices, NFIP
State Coordinating Agencies,
and State Hazard Mitigation
Offices
FEMA Offices
The addresses and telephone numbers of FEMA Headquarters and the 10 FEMA Regional Of-
fices are listed below. Staff members of the Regional Office for your area can give you more
information about retrofitting, hazard mitigation, and the National Flood Insurance Program.
t, •
d
GUAM
[a r
.t 1c
FEMA HEADQUARTERS REGION I — CT, MA, ME, NH, RI, VT
500 C Street, SW. 99 High Street, Sixth Floor
Washington, DC 20472 Boston, MA 02110
(202) 646 -2500, (800) 621 -FEMA (3362) (617) 956 -7506
TTY (800) 462 -7585
SI /SD DESK REFERENCE A -1
A FEMA REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES
REGION II — NJ, NY, PR, VI
26 Federal Plaza, Suite 1337
New York, NY 10278 -0002
(212) 680 -3600
REGION VII — IA, KS, MO, NE
9221 Ward Parkway, Suite 300
Kansas City, MO 64114 -3372
(816) 283 -7063
REGION III — DC, DE, MD, PA, VA, WV
615 Chestnut Street
One Independence Mall, Sixth Floor
Philadelphia, PA 19106 -4404
(215) 931 -5608
REGION IV — AL, FL, GA, KY, MS, NC, SC, TN
3003 Chamblee Tucker Road
Atlanta, GA 30341
(770) 220 -5200
REGION V — IL, IN, MI, MN, OH, WI
536 South Clark Street, Sixth Floor
Chicago, IL 60605 -1521
( 312) 408 -5500
REGION VI — AR, LA, NM, OK, TX
Federal Regional Center
800 North Loop 288
Denton, TX 76209 -3698
(940) 898 -5399
REGION VIII — CO, MT, ND, SD, UT, WY
Denver Federal Center, Building 710
P.O. Box 25267
Denver, CO 80255 -0267
(303) 235 - 4800
REGION IX — AZ, CA, HI, NV, American Samoa,
Guam, Commonwealth of the Northern Mariana
Islands, Republic of the Marshall Islands,
Federated States of Micronesia
1111 Broadway, Suite 1200
Oakland, CA 94607 -4052
(510) 627 -7100
REGION X — AK, ID, OR, WA
Federal Regional Center
130 228" Street, SW.
Bothell, WA 98021 -8627
(425) 487 -4600
On October 1, 2009, as part of FEMA's Digital Vision initiative, FEMA discontinued general dis-
tribution of paper mapping products, including Flood Insurance Rate Maps (FIRMS) and Flood
Insurance Study (FIS) reports. Electronic copies of FIRMS and FIS reports are available from
the FEMA Map Service Center online at http: / /insc.fema.gov. For additional information, call
the FEMA Map Service Center toll -free at 1- 877 - 336 -2627 or contact them by mail at the follow-
ing address:
FEMA Map Service Center
PO Box 1038
Jessup, MD 20794 -1038
NAP State Coordinating Agencies
ALABAMA
Department of Economic and Community
Affairs
Office of Water Resources
401 Adams Avenue, Suite 434
P.O. Box 5690
Montgomery, AL 36103 -5690
Phone: (334) 353 -0853, (877) 252 -9283
Fax: (334) 242 -0776
http: / /wNN��.adeca.alabama.gov /water/
ALASKA
Alaska Department of Community and
Economic Development
550 West 7`h Avenue, Suite 1770
Anchorage, AK 99501 -3510
Phone: (907) 269 -4500
http: / /"iN \•.coinmerce.state.ak.us/
A -2 SI /SD DESK REFERENCE
FEMA RE O NFIP S COORDINATING AGENCIES, AND STA HAZARD MITIGAT OFFICES A
ARIZONA
Arizona Department of Water Resources
3550 North Central Avenue
Phoenix, AZ 85012 -2105
Phone: (602) 771 -8657
Fax: (602) 771 -8691
lrttp: / /ti , x� , NN•.azwater.gov/
ARKANSAS
Arkansas Natural Resources Commission
101 East Capitol, Suite 350
Little Rock, AR 72201 -3823
Phone: (501) 682 -3969
Fax: ( 501) 682 -3991
http / /NA -Nv.anrc.arkansas.gov/
CALIFORNIA
California Department of Water Resources
2825 Watt Avenue, Suite 100
Sacramento, CA 95821
Phone: (916) 574 -1475
Fax: (916) 574 -1478
http: / /NNi�
COLORADO
Colorado Water Conservation Board
1313 Sherman Street, Room 721
Denver, CO 80203
Phone: (303) 866 -3441
Fax: (303) 866 -4474
http: / /cwch.state.co.us/
CONNECTICUT
Department of Environmental Protection
79 Elm Street
Hartford, CT 06106
Phone: (860) 424 -3537
Fax: (860) 424 -4075
http: / /N� , NN-NA , .ct.gov /dep/
DELAWARE
Department of Natural Resources and
Environmental Control
89 Kings Highway
Dover, DE 19901
Phone: (302) 739 -9921
Fax: (302) 739 -6724
http : / /w , NNtiN�.dnrec.delaNN , are.gov/
DISTRICT OF COLUMBIA
Department of the Environment
Watershed Protection Division
51 N Street, NE., Room 5021
Washington, DC 20002
Phone: (202) 535 -2248
Fax: (202) 535 -1364
http: / /app.doh.dc.goN
administration _offices /environinerntal /wa-
tershed /watershed _ division.shtm
FLORIDA
Division of Emergency Management
2555 Shumard Oak Boulevard
Tallahassee, Florida 32399 -2100
Phone: (850) 413 -9816
http : / /ti�
GEORGIA
Department of Natural Resources
7 Martin Luther King, Jr., Drive, Suite 440
Atlanta, GA 30334
Phone: (404) 656 -6382
Fax: (404) 656 -6383
http: / /tip , " , .gadnr.org /
GUAM
Guam Department of Public Works
Post Office Box 2877
Agana, Guam 96910
Phone: (671) 646 -3131
Fax: (671) 649 -6178
http: / /NNE , Nv.dpw.guam.gov
HAWAII
Hawaii Department of Land and Natural
Resources
1151 Punchbowl Street
P.O. Box 373
Honolulu, HI 96809
Phone: (808) 587 -0267
Fax: (808) 587 -0283
http: / /hawaii.gov /dlnr/
SI /SD DESK REFERENCE A-3
A FEMA REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES
IDAHO
Department of Water Resources
322 East Front Street
Boise, ID 83720
Phone: (208) 287 -4928
Fax: (208) 287 -6700
littp: / /NN
ILLINOIS
Illinois Department of Natural Resources
Office of Water Resources
One Natural Resources Way
Springfield, IL 62702 -1271
Phone: (217) 7824428
Fax: (217) 785 -5014
http: / /dnr.state.il.tis /ONA'R/
INDIANA
Indiana Department of Natural Resources
402 W. Washington Street, Room W264
Indianapolis, IN 46204 -2748
Phone: (317) 234 -1107
Fax: (317) 233 -4579
http: / / /dnr/
IOWA
Iowa Department of Natural Resources
Wallace State Office Building
Des Moines, IA 50319
Phone: (515) 281 -8942
Fax: (515) 281 -8895
http: / /wti "AT.ioNN
KANSAS
Department of Agriculture
109 SW 9`'' Street, 2 °d Floor
Topeka, KS 66612 -1283
Phone: (785) 296 -5440
Fax: (785) 296 -4835
http: / /
KENTUCKY
LOUISIANA
Louisiana Department of Transportation
and Development
Office of Public Works
Floodplain Management Section
1201 Capitol Access Road
P.O. Box 94245, Capitol Station
Baton Rouge, LA 70804 -9245
Phone: (225) 274 -4354
Fax: (225) 274 - 4351
http: / dotd.state.Ia.us/
MAINE
State Planning Office
184 State Street (street)
38 State House Station (mailing)
Augusta, ME 04333 -0038
Phone: (207) 287 -8063
Fax: (207) 287 -6489
http: / /wNA /spo/
MARYLAND
Department of the Environment
1800 Washington Boulevard, Suite 430
Baltimore, MD 21230
Phone: (410) 537 -3775
Fax: (410) 537 -3751
http: / /ww
MASSACHUSETTS
Department of Conservation and Recreation
Flood Hazard Management
251 Causeway Street, Suite 700
Boston, MA 02114
Phone: (617) 626 -1406
Fax: (617) 626 -1349
http: / /wwiv.mass.gov /dcr/
MICHIGAN
Department of Environmental Quality
525 West Allegan Street
P.O. Box 30473
Division of Water
14 Reilly Road
Frankfort, KY 40601
Phone: (502) 564 -3410
Fax: (502) 564 -9003
http: / /
Lansing, MI 48909 -7958
Phone: (517) 373 -7917
Fax: (517) 373 -9965
http: / /v, , NNiN , .michigan.gov /deq
A-4 SI /SD DESK REFERENCE
FEMA REG OFF NFIP S TAT E COO RDINATI NG A AND STATE HAZARD MITIGATION OFFICES A
MINNESOTA
Department of Natural Resources
500 LaFayette Road, Box 32
St. Paul, MN 55515 -4032
Phone: (651) 259 -5713
Fax: (651) 296 -0445
http: / /wNNA - .dnr.state.mn.us/
NEVADA
Division of Water Resources
901 South Stewart Street, Suite 2002
Carson City, NV 89701
Phone: (775) 684 -2884
Fax: (775) 684 -2811
http: / /water.nN.gov/
MISSISSIPPI
Emergency Management Agency
Office of Mitigation
1 Mema Drive
P.O. Box 5644
Pearl, MS 39208
Phone: (601) 933 -6884
Fax: (601) 933 -6805
http: / /NNAN
MISSOURI
State Emergency Management Agency
2302 Militia Drive
P.O. Box 116
Jefferson City, MO 65102
Phone: (573) 526 -9141
Fax: (573) 526 -9198
http: / /sema.dps.mo.gov/
MONTANA
Montana Department of Natural Resources
and Conservation
Floodplain Management Program
1424 9" Avenue
Helena, MT 59620 -1601
Phone: (406) 444 -6654
Fax: (406) 444 -0533
http://drnrc.mt.goN
plain /default.asp
NEBRASKA
Department of Natural Resources
301 Centennial Mall South
Lincoln, NE 68509 -4876
Phone: (402) 471 -3932
Fax: (402) 471 -2900
http: / / ne.gov/
NEW HAMPSHIRE
Office of Energy and Planning
4 Chenell Drive, 2 nd Floor
Concord, NH 03301
Phone: (603) 271 -1762
Fax: (603) 271 -2615
http: / /N , , , NA , xv.nli.gov /oep/
NEW JERSEY
Department of Environmental Protection
401 East State Street
P.O. Box 419
Trenton, NJ 08625
Phone: (609) 984 -0859
Fax: (609) 984 -1908
http: / /v , NN , iN , . state.nj.us /dep/
NEW MEXICO
Department of Homeland Security and
Emergency Management
13 Bataan Boulevard
P.O. Box 1628
Santa Fe, NM 87504 -1628
Phone: (505) 476 -9617
Fax: (505) 471 -9695
http: / /NN , iN , NN , .nmdhsein.oi - g/
NEW YORK
Department of Environmental Conservation
625 Broadway
Albany, NY 12233 -3507
Phone: (518) 402 -8146
Fax: (518) 402 -9029
1ittp: / /N8- w ".dec.ny.gov/
SI /SD DESK REFERENCE A-5
A FEMA REGIONAL O NFIP S TAT E COORDINATING A GE N CIES, AND STATE HAZARD MITIGATION OFFICES
NORTH CAROLINA
Department of Crime Control and
Public Safety
Division of Emergency Management
1812 Tillery Place, Suite 105
Raleigh, NC 27604 -1356
Phone: (919) 715 -5711
Fax: (919) 715 -0408
http: / /1A'"1N'.ncem.org/
PENNSYLVANIA
Department of Community and
Economic Development
Commonwealth Keystone Building
400 North Street, 4t' Floor
Harrisburg, PA 17120 -0225
Phone: (717) 720 -7396
Fax: (717) 783 -1402
http: / /Nvw,v.newpa.com/
NORTH DAKOTA
State Water Co
900 East Boulevard Avenue
Bismark, ND 58505 -0850
Phone: (701) 3284898
Fax: (701) 328 -3747
http: / /www.swc.state.nd.us/
OHIO
Department of Natural Resources
2045 Morse Road, Building B-2
Columbus, OH 43229
Phone: (614) 265 -6752
Fax: (614) 265 -6767
http: / /w"
OKLAHOMA
Water Resources Board
3800 North Classen
Oklahoma City, OK 73118
Phone: (918) 581 -2924
Fax: (405) 530 -8900
http: / /w " , xv.owrb.ok.gov/
OREGON
Department of Land Conservation
Development
635 Capitol Street, NE, Suite 150
Salem, OR 97301 -2540
Phone: (503) 373 -0050
Fax: (503) 375 -5518
http: / /w, , "
PUERTO RICO
Planning Board
Centro Gubernamental Roberto
Sanchez Vilella
P.O. Box 41119, Minillas Station
Santurce, PR 00940 -90985
Phone: (787) 727 -4444
Fax: (787) 268 -6858
http: / /wv, , Nv jp.gobierno.pr/
RHODE ISLAND
Emergency Management Agency
645 New London Avenue
Cranston, RI 02920
Phone: (401) 462 -7048
Fax: (401) 944 -1891
http: / /w , ",w.riema.ri.gov/
SOUTH CAROLINA
Department of Natural Resources
1000 Assembly Street, Suite 345C
P.O. Box 167
Columbia, SC 29201
Phone: (803) 734 -9120
Fax: (803) 734 -9106
http: / /ti -"iv.dnr.sc.gov/
SOUTH DAKOTA
Office of Emergency Management
118 West Capitol Avenue
Pierre, SD 57501
Phone: (605) 883 -3238
Fax: (605) 773 -3580
http: / /v -N,M�.ocni.sd.gov/
A - 6 SI /SD DESK REFERENCE
FEM REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES A
TENNESSEE
Department of Economic and Community
Development
Tennessee Tower Building
312 8`h Avenue North, I oth Floor
Nashville, TN 37243 -0607
Phone: (615) 741 -2211
Fax: (615) 741 -0607
http:// NN' ww .state.tn.tis /ecd /bizdeN
TEXAS
Water Development Board
1700 North Congress Avenue
P.O. Box 13231
Austin, TX 78711 -3231
Phone: (512) 463 -3509
Fax: (512) 475 -2053
h ttp: / /�,%1 , , , Nv. twdb.state. tx. us/
UTAH
Department of Public Safety
Division of Comprehensive Emergency
Management
State Office Building, Room 1110
Salt Lake City, UT 84114
Phone: (801) 538 -3332
Fax: (801) 538 -3772
http: / /tiiN -"
VERMONT
Department of Environmental Conservation
103 South Main Street, Building 10 N
Waterbury, VT 05671
Phone: (802) 241 -1554
Fax: (802) 244 -5141
http:// N1 'ww .anr.state.vt.tis /dec /dec.litm
VIRGIN ISLANDS
Department of Planning and Natural
Resources
C.E. King Airport, Terminal Building
2 °d Floor
St. Thomas, VI 00802
Phone: (340) 774 -3320
Fax: (340) 775 -5706
http: / /iNi� , Nv.dpnr.gov.vi/
VIRGINIA
Department of Conservation and Historic
Resources
Division of Dam Safety and Floodplain
Management
203 Governor Street, Suite 206
Richmond, VA 23219
Phone: (804) 786 -3914
Fax: (804) 371 -2630
h ttp: / /NN , NN , Nv. dcr.vi i n ia. gov/
WASHINGTON
Department of Ecology
P.O. Box 47690
Olympia, WA 98504 -7600
300 Desmond Drive, SE
Lacey, WA 98503
Phone: (360) 407 -6796
Fax: (360) 407 -6902
h ttp: / /wAvNv. ecy.wa. gov/
WEST VIRGINIA
Division of Homeland Security and
Emergency Management
Capitol Building 1, Room EB -80
1900 Kanawha Boulevard
Charleston, WV 25305 -0360
Phone: (304) 965 -2331
Fax: (304) 965 -3216
http: / /NN
WISCONSIN
Department of Natural Resources
101 South Webster
Madison, WI 53702
Phone: (608) 266 -8037
Fax: (608) 266 -3093
http: / /dnr.wi.gov/
WYOMING
Office of Homeland Security
Herschler Building, 1st East
122 West 25t Street
Cheyenne, WY 82002
Phone: (307) 777 -4910
Fax: (307) 635 -6017
lit tp:// NvN' ohontelands ectn /ntairn.
aspx
SI /SD DESK REFERENCE A-7
A FEMA REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES
State Hazard Mitigation Offices
ALABAMA
Alabama Emergency Management Agency
5898 County Road 41
P.O. Drawer 2160
Clanton, AL 35046 -2160
(205) 280 -2200
http: / /w "
COMMONWEALTH OF THE NORTHERN MARIANA
ISLANDS
Emergency Management Office
P.O. Box 10007
Saipan, Mariana Islands 96950
(670) 322 -9529
COLORADO
ALASKA
Alaska Department of Homeland Security
and Emergency Management
P.O. Box 5750
Ft. Richardson, AK 99505 -5750
(907) 428 -7000
http: / / , A , "iN , .ak- piepared.com
AMERICAN SAMOA
Emergency Management Coordinating
Office
P.O. Box 1086
Pago Pago, American Samoa 96799
(684) 699 -6415
ARIZONA
Division of Emergency Management
5636 E. McDowell Road
Phoenix, AZ 85008
(602) 244 -0504
http: / /
ARKANSAS
Department of Emergency Management
Bldg. 9501
Camp Joseph T. Robinson
North Little Rock, AR 72199
(501) 683 -6700
http: / /iA
CALIFORNIA
California Emergency Management Agency
3650 Shriever Avenue
Mather, CA 95655
(916) 845 -8510
http: / /
Division of Emergency Management
9195 East Mineral Avenue
Suite 200
Centennial, CO 80112
(720) 852 -6600
http: // dola .colorado.goN7 /dem /index.html
CONNECTICUT
Department of Emergency Management
and Homeland Security
25 Sigourney Street
6th Floor
Hartford, CT 06106 -5042
(860) 256 -0800
http: / /tiiA-%v.ct.gov /demhs /site /defatilt.asp
DELAWARE
Delaware Emergency Management Agency
165 Brick Store Landing Road
Smyrna, DE 19977
(302) 659 -3362
http: / /deina.delaware.gov
DISTRICT OF COLUMBIA
Homeland Security and Emergency
Management Agency
2720 Martin Luther King Jr. Avenue, SE
Washington, DC 20032
(202) 727 -6161
http: / /dcema.(1c.9ov /dcema /site /default.
asp
FLORIDA
Florida Division of Emergency Management
2555 Shumard Oak Boulevard
Tallahassee, FL 32399
(850) 413 -9816
http: / /wwtv.floridadisaster.org
A -8 SI /SD DESK REFERENCE
FEMA REGIONAL OFFICES, NFIP STATE CO ORDINATING AGEN AND STATE HAZARD MITIGATION OFFICES A
GEORGIA
Georgia Emergency Management Agency
935 East Confederate Avenue, SE
P.O. Box 18055
Atlanta, GA 30316
(404) 635 -7000
http: / /wN8w.geina.state.ga.us
GUAM
Guam Homeland Security /Office of Civil
Defense
221B Chalan Palasyo
Agana Heights, Guam 96910
(671) 475 -9600
HAWAII
Hawaii Department of Emergency
Management
650 South King Street
Honolulu, HI 96813
(808) 723 -8960
http: / /ti , NN1N , .honolulu.gov /dem
IDAHO
Idaho Bureau of Homeland Security
4040 Guard Street
Building 600
Boise, ID 83705 -5004
( 208) 422 -3040
http: / /wvv%% , .bhs.idaho.gov /Pages /Contact.
aspx
IOWA
Iowa Homeland Security and Emergency
Management Division
7105 NW 70th Avenue
Camp Dodge, Bldg. W4
Johnston, IA 50131
(515) 725 -3231
http: / / NNiN N , .iowahomelandsecturity.org
KANSAS
Kansas Division of Emergency Management
2800 Southwest Topeka Blvd.
Topeka, KS 66611 -1287
(785) 274 -1409
http : / /iN /kdem/
KENTUCKY
Kentucky Division of Emergency
Management
100 Minuteman Parkway Bldg. 100
Frankfort, KV 40601 -6168
(502) 607 -1682
h ttp: / /NN kye m. ky. gov
LOUISIANA
Louisiana Office of Homeland Security
and Emergency Preparedness
7667 Independence Blvd.
Baton Rouge, LA 70806
(225) 925 -7500
http: / /gohsep.la.gov
ILLINOIS
Illinois Emergency Management Agency
2200 South Dirksen Parkway
Springfield, IL 62703
(217) 782 -2700
http: / / -" /iema/
INDIANA
Department of Homeland Security
Indiana Government Center South
302 West Washington Street, Room E -208
Indianapolis, IN 46204
(317) 232 -3986
http: / /N%ANw.M.gov /(ills
MAINE
Maine Emergency Management Agency
72 State House Station
45 Commerce Drive
Augusta, ME 04333
(207) 624 -4400
http: / /�NiN /enema/
MARYLAND
Maryland Emergency Management Agency
5401 Rue Saint Lo Drive
Reisterstown, MD 21136
(410) 517 -3625
http: / /NNiNiN /MEN A /in-
dex
SI /SD DESK REFERENCE A -J
A F EMA REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES
MASSACHUSETTS
Massachusetts Emergency Management
Agency
400 Worcester Road
Framingham, MA 01702 -5399
(508) 820 -2000
http: / / , A , NN , iv.state.ma.us /enema
NEBRASKA
Nebraska Emergency Management Agency
1300 Military Road
Lincoln, NE 68508 -1090
(402) 471 -7421
http: / / , AiN , N� , .nema.ne.gov
NEVADA
MICHIGAN
Emergency Management and Homeland
Security Division
Michigan Department of State Police
4000 Collins Road
Lansing, MI 48909 -8136
(517) 333 -5042
http: / /tip , " , .inichigan.gov /msp
MINNESOTA
Minnesota Homeland Security and
Emergency Management
444 Cedar Street, Suite 223
St. Paul, MN 55101 -6223
(651) 201 -7400
http: / / , A , " , " , .hsein.state.mn.us/
MISSISSIPPI
Mississippi Emergency Management Agency
P.O. Box 5644
Pearl, MS 39288 -5144
(601) 933 -6362
http: / /N8
MISSOURI
Missouri State Emergency Management
Agency
2302 Militia Drive
P.O. Box 116
Jefferson City, MO 65102
(573) 526 -9100
http:// /semapage.htm
MONTANA
Montana Disaster and Emergency Services
P.O. Box 4789
Ft. Harrison, MT 59636 -4789
(406) 324 -3000
http: / dma.mt.gov /des
Nevada Division of Emergency Management
2478 Fairview Drive
Carson City, NV 89701
(775) 687 -0300
http: / /wNN , NN , .dem.state.nv.us
NEW HAMPSHIRE
New Hampshire Department of Safety
Homeland Security and Emergency
Management
33 Hazen Street
Concord, NH 03305
(603) 271 -2231
http: / /w /safety /divisions /sheen
NEW JERSEY
New Jersey Office of Emergency
Management
P.O. Box 7068
West Trenton, NJ 08628 -0068
(609) 538 -6050
http: / /wiA /njoe,in/
NEW MEXICO
New Mexico Department of Homeland
Security and Emergency Management
P.O. Box 27111 -87502
13 Bataan Blvd.
Santa Fe, NM 87504
(505) 476 -9600
http: / /w , " , " , .nmdhsem.oi-g
NEW YORK
New York State Emergency Management
Office
1220 Washington Avenue, Suite 101
Building # 22
Albany, NY 12226 -2251
(518) 292 -2301
http: / /w " , " , .semo.state.ny.us/
A-1 0 SI /SD DESK REFERENCE
FEMA R EG I ONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZAR MITIGATION OFFICES A
NORTH CAROLINA
North Carolina Division of Emergency
Management
4713 Mail Service Center
Raleigh, NC 27699 -4713
(919) 733 -3867
http: / /NNAN '1N'.nce11).org
NORTH DAKOTA
North Dakota Emergency Management
P.O. Box 5511
Fraine Barrecks Lane, Bldg. 35
Bismarck, ND 59506 -5511
( 701) 328 -8181
http: / /x % , xN��.nd.gov /des
OHIO
Ohio Emergency Management Agency
2855 West Dublin - Granville Road
Columbus, OH 43235 -2206
(614) 889 -7150
Imp: / /ema.ohio.gov
PUERTO RICO
Puerto Rico Emergency Management
P.O. Box 966597
San Juan, PR 00906 -6597
(787) 724 - 0124
http:// NNM 'N1 - .goblerno.pr /AEMEAD /Inicio
RHODE ISLAND
Rhode Island Emergency Management
Agency
645 New London Avenue
Cranston, RI 02920
(401) 946 -9996
http: / /Nti , NNiN , .riema.ri.gov
SOUTH CAROLINA
South Carolina Emergency Management
Division
2779 Fish Hatchery Road
West Columbia, SC 29172
(803) 37 -8500
http: / /lA�TNv.scemd.org
OKLAHOMA
Oklahoma Emergency Management Agency
2401 Lincoln Blvd.
Suite C51
Oklahoma City, OK 73105
(405) 521 -2481
http: / /w , NN -" /OEM
OREGON
Office of Emergency Management
3225 State Street
Salem, OR 97309 -5062
(503) 378 -2911
http: / /ANiN-NA /OMD /OEM /index
shtml
PENNSYLVANIA
Pennsylvania Emergency Management
Agency
2605 Interstate Drive
P.O. Box 3221
Harrisburg, PA 17110-9463
(717) 651 -2001
http : / /AN - NN , NN , .penia.state.pa.us
SOUTH DAKOTA
South Dakota Division of Emergency
Management
118 West Capitol Avenue
Pierre, SD 57501
( 605) 773 -3178
http: / /ti , xA , xN , .oem.sd.gov
TENNESSEE
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, Tennessee 37204
(615) 741 -0001
http: / /tip , NN , .tnema.org
TEXAS
Texas Division of Emergency Management
P.O. Box 4087
Austin, TX 78773 -0220
(512) 424 -2138
http : / /NA , NN , i� , .txdps.state.tx.iis /dery /pages /in-
dex.htm
SI /SD DESK REFERENCE A -11
A FEMA REGIONAL OFFICES, NFIP STATE COORDINATING AGENCIES, AND STATE HAZARD MITIGATION OFFICES
UTAH
Utah Division of Emergency Services
and Homeland Security
State Office Building, Room 1110
Salt Lake City, UT 84114 -1710
(801) 538 -3400
http: / /��
VERMONT
Vermont Emergency Management Agency
Department of Public Safety
Waterbury State Complex
103 S. Main Street
Waterbury, VT 05671 -2101
(802) 242 - 8721
http: / /
VIRGINIA
WASHINGTON
Washington Military Department
Emergency Management Division
Bldg. 20, MS TA -20
Camp Murray, WA 98430 -5122
( 253) 512 -7000
http: / /w , NN'tv.eind.wa.gox , /
WEST VIRGINIA
West Virginia Division of Homeland Security
and Emergency Services
Building 1, Room EB -80
1900 Kanawha Blvd., East
Charleston, WV 25305 -0360
(304) 558 -5380
http: / /1A
WISCONSIN
Department of Emergency Management Wisconsin Emergency Management
10501 Trade Court 2400 Wright Street
Richmond, VA 23236 -3713 Madison, WI 53707 -7865
(804) 897 -6500 (608) 242 -3232
http:// ww" gency.com /index.cfiii http : / /einei
VIRGIN ISLANDS
Virgin Islands Territorial Emergency
Management
2 -C Contant, A -Q Bldg.
St. Thomas, VI 00820
(340) 774 -2244
WYOMING
Wyoming Department of Homeland Security
122 West 25th Street
Herschler Building, 1st Floor East
Cheyenne, WY 82002
(307) 777 -4663
http:// wyohomelarndsecurity .state.wy.us/
mam.aspx
A-12 SI /SD DESK REFERENCE
B References
FEMA publications are available for download free of charge at http: / /ti�v.fema.gov /library.
Publications can also be obtained in hardcopy format from the FEMA Distribution Center by
submitting an order by regular mail, phone, or fax, Monday through Friday, between 8 a.m. and
5 p.m. Eastern Standard Time. Please provide the FEMA publication number, title, and quantity
of each publication requested, along with your name, address, zip code, and daytime telephone
number.
FEMA Distribution Center
P.O. Box 430
Buckeystown, MD 21717
1- 800 -480 -2520
240- 699 -0525 (fax)
ASCE /SEI 7 -05, Minimum Design Loads for Buildings and Other Structures. Reston, VA: American
Society of Civil Engineers/ Structural Engineering Institute, 2005.
http: // cedb .asce.org /cgi /NA�'NA ?0500267
ASCE /SEI 24-05, Flood Resistant Design and Construction. Reston, VA: American Society of Civil
Engineers/ Structural Engineering Institute, 2005.
http: / /cedb.asce.org /cgi /NA'W"'display.cgir0500268
ATC 45, Field Manual: Safety Evaluation of Buildings after Windstorms and Floods. Redwood City,
CA: Applied Technology Council, 2004.
http: / /H , xN - vN , .atcouncil.org /pdfs /ATC45toc.pdf
FEMA, CRS Credit for Higher Regulatory Standards. Washington, DC: Federal Emergency Manage-
ment Agency, 2006.
http: / /training.fema.gov /EMI Aeb /CRS /2006 %20Model %20 430 %20Higher %20Stanclards.pdf
FEMA 55, Coastal Construction Manual (3rd Edition). Washington, DC: Federal Emergency
Management Agency, 2000.
http: / /"NNANN /rebuild /mat /fema55.shtm
FEMA P -85, Protecting Manufactured Homes from Floods and Other Hazards: A Multi - Hazard Founda-
tion and Installation Guide, Second Edition. Washington, DC: Federal Emergency Management
Agency, 2009.
http: / / NA , NNiN , . f'ema .gov /library /viewRecord.do�i(1=1577
FEMA 213, Answers to Questions about Substantially Damaged Buildings. Washington, DC: Federal
Emergency Management Agency, 1991.
h ttp: / /NNiNiN .gov / librai /x dorid =1636
SI /SD DESK REFERENCE B -1
B REFERENCES
FEMA 234, Repairing Your Flooded Home. Washington, DC: Federal Emergency Management
Agency, 1992.
http: / / /library /viewRecord.do %id =1418
FEMA 259, Engineering Principles and Practices of Retrofitting Flood Prone Residential Structures.
Washington, DC: Federal Emergency Management Agency, 2001.
http: / /wNNiN /library /viewRecoi =1645
FEMA 301, Increased Cost of Compliance Coverage. Guidance for State and Local Officials. Washing-
ton, DC: Federal Emergency Management Agency, 2003.
http: / /NN /library /viewRecoi %id =1532
FEMA P -312, Homeowner's Guide to Retrofitting: Six Ways to Protect Your Home from Flooding, Second
Edition. Washington, DC: Federal Emergency Management Agency, 2009.
http: / /wxN , " , .fema.gov /library /viewRecoi =1420
FEMA 347, Above the Flood: Elevating Your Roodprone House. Washington, DC: Federal Emergen-
cy Management Agency, 2000.
http: / / /viewRecoi =1424
FEMA 348, Protecting Building Utilities from Flood Damage: Principles and Practices for the Design and
Construction of Flood Resistant Building Utility Systems. Washington, DC: Federal Emergency Man-
agement Agency, 1999.
http: / /www.fema.gov /library /viewRecoi =1750
FEMA F -084, Answers to Questions about the National Flood Insurance Program. Washington, DC:
Federal Emergency Management Agency, 2006.
http: / /NN /business /nfip /ganda.shttii
FEMA P- 467 -2, Floodplain Management Bulletin: Historic Structures. Washington, DC: Federal
Emergency Management Agency, 2008.
http: / /tiiNM /library /viewRecoi =3282
FEMA 480, NFIP Floodplain Management Requirements: A Study Guide and Desk Reference. Washing-
ton, DC: Federal Emergency Management Agency, 2005.
http: / /NNiN- w.feina.gov /library /viewRecoi =1443
FEMA 497, National Flood Mitigation Data Collection Tool. Washington, DC: Federal Emergency
Management Agency, 2008.
http: / /NNM /librar /viewRecord.do ?id =1447
FEMA 499, Home Builder's Guide to Coastal Construction: Technical Fact Sheets. Washington, DC:
Federal Emergency Management Agency, 2005.
llttp: / /ti , \siv.fema.gov /librar /viewRecord.do %id =2138
B SI /SD DESK REFERENCE
REFERENCES B
FEMA 511, Reducing Damage from Localized Flooding. A Guide for Communities. Washington, DC:
Federal Emergency Management Agency, 2005.
http: / / iAiNAN , . fema .gov /library /viewRecord.do %id =1448
FEMA 551, Selecting Appropriate Mitigation Measures forHoodprone Structures. Washington, DC:
Federal Emergency Management Agency, 2007.
http: / /NNi8w.fema .gov /library /viewRecord.do�id =2737
FEMA F -663, Increased Cost of Compliance Brochure. Washington, DC: Federal Emergency Man-
agement Agency, 2007.
http: / /NN - NN , xc. fema. gov /library /N =3009
FEMA P -784 CD. FEMA Substantial Damage Estimator. Washington, DC: Federal Emergency
Management Agency, 2010.
FEMA Form 81 -31, Elevation Certificate. Washington, DC: Federal Emergency Management
Agency, 2009.
http: / / NN - NATiv.fema.gov /pdf /nfip /elvicert.pdf
FEMA Form 81 -65, Floodproofing Certificate. Washington, DC: Federal Emergency Management
Agency, 2009.
h ttp: / /ti -iNiN , . feina. gov /pdf / m /ft�81 -65. pdf
FEMA, NFIP Technical Bulletin Series. Washington, DC: National Flood Insurance Program.
http: / /NN fema. gov /plan/ prevent /floodplain /techbul.shtm
FEMA Technical Bulletin 0: User's Guide to Technical Bulletins. 2009.
FEMA Technical Bulletin 1: Openings in Foundation Walls and Walls of Enclosures Below Build-
ings Located in Special Flood Hazard Areas. 2008.
FEMA Technical Bulletin 2: Flood Damage - Resistant Materials Requirements for Buildings Located
in Special Flood Hazard Areas. 2008.
FEMA FIA -TB -3: Non Residential Floodproofing — Requirements and Certification for Buildings Lo-
cated in Special Flood Hazard Areas. 1993.
FEMA FIA -TB -4: Elevator Installation for Buildings Located in Special Flood Hazard Areas. 1993.
FEMA Technical Bulletin 5: Free -of- Obstruction Requirements for Buildings Located in Coastal High
Hazard Areas. 2008.
FEMA FIA -TB -6: Below -Grade Parking Requirements for Buildings Located in Special Flood Hazard
Areas. 1993.
SI /SD DESK REFERENCE B -3
B REFERENCES
FEMA FIA -TB-7: Wet Floodproofing Requirements for Structures Located in Special Flood Hazard
Areas. 1993.
FEMA FIA TB -8: Corrosion Protection for Metal Connectors in Coastal Areas for Structures Located
in Special Flood Hazard Areas. 1996.
FEMA Technical Bulletin 9: Design and Construction Guidance for Breakaway Walls Below El-
evated Coastal Buildings. 2008.
FEMA FIA- TB-10: Ensuring that Structures Built on Fill in or Near Special Flood Hazard Areas are
Reasonably Safe From Flooding. 2001.
FEMA FIA- TB -11: Crawlspace Construction for Buildings Located in Special Flood Hazard Areas
(NFIP Interim Guidance). 2001.
FEMA FIA -15, NFIP Community Rating System: Coordinator's Manual. Washington, DC: Federal
Emergency Management Agency, 2002.
http: / / NN , NN , NN , . fema .gov /library /vieNs'Record.do %id =1741
FEMA 9 -0372, Reducing Flood Losses Through the International Codes ®: Meeting the Requirements of
the National Flood Insurance Program. Washington, DC: International Code Council, Inc., 2007.
http: / / fema .gov /library /vieNN %id =2094
IBC, International Building Code Washington, DC: International Code Council, Inc., 2009.
http: / /wiNiN /Store/ pages /product.aspx�id= 3000x09
IEBC, International Existing Building Code ® . Washington, DC: International Code Council, Inc.,
2009.
http: / /ti - " , x8 , .bookmarki.corn/ 2009 - International- Existing - Building- (;ode -Soft-
p/9781580017374.htm
IRC, International Residential Code ® . Washington, DC: International Code Council, Inc., 2009.
http : / /w , " - "�.intei - iiationalcodes. net / 2009 - international- residential- codes.shtml
National Flood Insurance Program, Program Description. Washington, DC: Federal Emergency
Management Agency, 2002.
http: / /w fema. gov /library /viewRecord.(Io�id =1480
The Appraisal Foundation, Uniform Standards of Professional Appraisal Practice (USPAP), 2010.
http:/ tiiNiN
U.S. Government Printing Office. Title 44, Code of Federal Regulations, Emergency Manage-
ment and Assistance (Parts 59 and 60; Part 210).
littp: / /ecf - .gpoaccess.goN /t/ text / text -idx �sid= 68742042ab4d6255237I ef4f'a697f404 &c =ec
fi tpl=/ ecfrbrowse /Title44 /44tab_02.tp1
B-4 SI /SD DESK REFERENCE
C Glossary and Acro
Glossary
Key terms and definitions are addressed in Chapter 3. The following are additional terms used
in this Desk Reference.
F.1
Accessory structure — A structure that is on the same parcel of property as a principal structure,
the use of which is incidental to the use of the principal structure.
Agricultural structure — A structure used exclusively for agricultural purposes such as storage of
farm machinery and equipment, grain bins and silos, corn cribs, and general purposes barns for
feeding and raising livestock. Homes located on farms are not agricultural structures.
B
Base flood — The flood having a 1- percent chance of being equaled or exceeded in any given
year, commonly referred to as the "100 year flood." The base flood is the national standard used
by the NFIP and all Federal agencies for the purposes of requiring the purchase of flood insur-
ance and regulating new development.
Base flood elevation (BFE) — The elevation of the base (1- percent annual chance or 100 -year)
flood compared to a specified datum, usually the National Geodetic Vertical Datum of 1929, or
the North American Vertical Datum of 1988.
Basement — Any area of a building having its floor subgrade (below ground level) on all sides
Breakaway wall — A wall that is not part of the structural support of the building and is intended
through its design and construction to collapse under specified lateral loading forces, without
causing damage to the elevated portion of the building or supporting foundation system.
D
Determination, SI /SD — The result of comparing the costs of a proposed improvement (or costs
to repair substantial damage) to the market value of a structure for the purposes of determin-
ing whether the resulting ratio equals or exceeds a certain percentage (50 percent in the NFIP
minimum requirements).
E
Elevation Certificate — FEMA Form 81 -31, a form developed by FEMA to collect surveyed el-
evations and other information about a building that is necessary to obtain flood insurance.
The Elevation Certificate and instructions are available online at http: / /NNN� , " , .fenia.gov /library/
viewRecord.do�id =1383.
SI /SD DESK REFERENCE GI
C GLOSSARY AND ACRONYMS
Enclosure or enclosed area — Areas created by a crawlspace or solid walls that fully enclose areas
below elevated buildings that are below the BFE.
F
Federal Emergency Management Agency (FEMA) — The Federal agency that, in addition to car-
rying out other activities, administers the National Flood Insurance Program.
Flood Insurance Rate Map (FIRM) — The official map of a community on which FEMA has de-
lineated both the SFHAs and the risk premium zones applicable to the community.
Flood opening — An opening in a foundation or enclosure wall that allows automatic entry and
exit of floodwaters (see FEMA Technical Bulletin 1 for descriptions of "non- engineered open-
ing" and "engineered opening ") .
Floodway — The channel of a river or other watercourse and the adjacent land areas that must
be reserved in order to discharge the base flood without cumulatively increasing the water sur-
face elevation more than a designated height.
Floodproofing — Any combination of structural and non - structural additions, changes, or ad-
justments to structures that reduce or eliminate flood damage to real estate or improved real
property, water and sanitary facilities, structures, and their contents.
Hoodprroofing Certificate — FEMA Form 81 -65, a form developed by FEMA that is to be complet-
ed, signed and sealed by a licensed professional engineer or licensed architect to certify that
the design of the floodproofing and the proposed methods of construction are in accordance
with the requirements. The Hoodproofing Certificate is available online at http: / /
library /viewRecord.do ?id= 1600.
Historic structure — Any structure that is:
(a) Listed individually in the National Register of Historic Places (a listing maintained by the
Department of Interior) or preliminarily determined by the Secretary of the Interior as
meeting the requirements for individual listing on the National Register;
(b) Certified or preliminarily determined by the Secretary of the Interior as contributing to
the historical significance of a registered historic district or a district preliminarily deter-
mined by the Secretary to qualify as a registered historic district;
(c) Individually listed on a state inventory of historic places in states with historic preserva-
tion programs which have been approved by the Secretary of the Interior; or
(d) Individually listed on a local inventory of historic places in communities with historic
preservation programs that have been certified either:
G2 SI /SD DESK REFERENCE
GLOSSARY AND ACRONYMS C
(1) By an approved state program as determined by the Secretary of the Interior or
(2) Directly by the Secretary of the Interior in states without approved programs.
Hydrodynamic load - The load imposed on an object, such as a foundation element or enclo-
sure wall, by water flowing against and around it.
Hydrostatic load - The load imposed on an object, such as an enclosure wall, by a standing mass
of water.
New construction - Structures for which the "start of construction" commenced on or after the
effective date of a floodplain management regulation adopted by a community and includes
any subsequent improvements to such structures.
P
Post -FIRM — A building for which construction or substantial improvement occurred after De-
cember 31, 1974, or on or after the effective date of an initial Flood Insurance Rate Map (FIRM),
whichever is later.
Pre -FIRM — A building for which construction or substantial improvement occurred on or be-
fore December 31, 1974, or before the effective date of an initial FIRM.
I
Registered Design Professional — An individual who is registered or licensed to practice their
respective design profession as defined by the statutory requirements of the professional regis-
tration laws of the State or jurisdiction in which the project is to be constructed.
0
ti
Special Flood Hazard Area (SFHA) — An area delineated on a Flood Insurance Rate Map as be-
ing subject to inundation by the base flood and designated as Zone A, AE, Al -A30, AR, AO, AH,
A99, V, VE, or Vl -V30.
Substantial damage — Damage of any origin sustained by a structure whereby the cost of restor-
ing the structure to its before damaged condition would equal or exceed 50 percent of the
market value of the structure before the damage occurred.
Substantial improvement — Any reconstruction, rehabilitation, addition, or other improve-
ment of a structure, the cost of which equals or exceeds 50 percent of the market value of the
structure before the "start of construction" of the improvement. This term includes structures
that have incurred "substantial damage," regardless of the actual repair work performed. The
term does not, however, include either:
SI /SD DESK REFERENCE G3
C GLOSSARY AND ACRONYMS
(1) Any project for improvement of a structure to correct existing violations of State or lo-
cal health, sanitary, or safety code specifications which have been identified by the local
code enforcement official and which are the minimum necessary to assure safe living
conditions or
(2) Any alteration of a "historic structure," provided that the alteration will not preclude the
structure's continued designation as a "historic structure."
V
Violation — The failure of a structure or other development to be fully compliant with the com-
munity's floodplain management regulations.
G4 SI /SD DESK REFERENCE
GLOSSARY AND ACRONYMS C
Acronyms
A
ACV
actual cash value
ADA
Americans with Disabilities Act
ASCE
American Society of Civil Engineers, Inc.
ASFPM
Association of State Floodplain Managers, Inc.
ATC
Applied Technology Council
B
BFE base flood elevation
C
CBRS Coastal Barrier Resource System
CFR Code of Federal Regulations
CRS Community Rating System
D
DHS Department of Homeland Security
F
FEMA Federal Emergency Management Agency
FHBM Flood Hazard Boundary Map
FIA Federal Insurance Administration
FIRM Flood Insurance Rate Map
FIS Flood Insurance Study
FMA Flood Mitigation Assistance (grant program)
SI /SD DESK REFERENCE G5
C GLOSSARY AND ACR
G
GIS geographic information system
GPS global positioning system
H
HMGP Hazard Mitigation Grant Program
HVAC Heating, ventilation, and air conditioning
IBC International Building Cody'
I -Codes The family of codes published by the International Code Council, Inc.
ICC Increased Cost of Compliance (NFIP flood insurance coverage)
ICC International Code Council, Inc.
IEBC International Existing Building Cody''
IRC International Residential Cody"'
N
NFIP National Flood Insurance Program
W
OPA Otherwise Protected Area
P
PDA Preliminary Damage Assessment
PDM Pre - Disaster Mitigation (grant program)
G6 SI /SD DESK REFERENCE
GLOSSARY AND ACRONYMS C
R
RCV
replacement cost value
RFC
Repetitive Flood Claims (grant program)
RLP
Repetitive Loss Property
S
SDE Substantial Damage Estimator
SEI Structural Engineering Institute
SFHA Special Flood Hazard Area
SI /SD substantial improvement /substantial damage
SRL Severe Repetitive Loss (grant program)
SI /SD DESK REFERENCE G7
D Sample Notices to Property
Owners, Sample Affidavits, and
Other Material
These samples are offered to illustrate specific points in the Desk Reference. States and commu-
nities should examine them carefully before use.
■ Sample Substantial Improvement/ Damage Notice to Property Owners (see Sections 5.5.1
and 5.6.2.)
■ Substantial Improvement Worksheet for Floodplain Construction (for additions,
rehabilitations, improvements or damage repairs; see Section 6.4)
■ Adjuster Preliminary Damage Assessment (FEMA Form 81 -109; see Section 7.4. 1)
SI /SD DESK REFERENCE D -1
Sample Notice for Property Owners, Contractors, and Design
Professionals
[This example is based on the NFIP minimum requirements.]
TO: Property Owners, Contractors, and Design Professionals
FROM: Local Official
SUBJECT: Notice for Work on Existing Buildings in Special Flood Hazard Areas
Substantial Improvement / Substantial Damage Worksheets
The Community's floodplain management regulations and codes specify that all new buildings
to be constructed in Special Flood Hazard Areas (SFHAs) (regulated floodplains) are required
to have their lowest floors elevated to or above the base flood elevation (BFE). The regulations
also specify that substantial improvement of existing buildings (remodeling, rehabilitation, im-
provement, or addition) or buildings that have sustained substantial damage must be brought
into compliance with the requirements for new construction. Please note that a building may be
substantially damaged by any cause, including fire, flood, high wind, seismic activity, land move-
ment, or neglect. It is important to note that all costs to repair a substantially damaged building
to its pre- damage condition must be identified.
There are several aspects that must be addressed to achieve compliance with the floodplain
management requirements. The requirements depend on several factors, including the flood
zone at your property. The most significant compliance requirement is that the lowest floor, as
defined in the regulations/ code, must be elevated to or above the BFE. Please plan to meet with
this department to review your proposed project, to go over the requirements, and to discuss
how to bring your building into compliance.
Our regulations define these terms:
Substantial damage means damage of any origin sustained by a structure whereby the
cost of restoring the structure to its before damaged condition would equal or exceed 50
percent of the market value of the structure before the damage occurred.
Substantial improvement means any reconstruction, rehabilitation, addition, or other
improvement of a structure, the cost of which equals or exceeds 50 percent of the market
value of the structure before the "start of construction" of the improvement. This term
includes structures that have incurred "substantial damage," regardless of the actual re-
pair work performed. The term does not, however, include either:
(1) Any project for improvement of a structure to correct existing violations of
State or local health, sanitary, or safety code specifications that have been identi-
fied by the local code enforcement official and that are the minimum necessary
to assure safe living conditions or
SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS 1 of 7
(2) Any alteration of a "historic structure," provided that the alteration will not
preclude the structure's continued designation as a "historic structure."
To make the substantial improvement determination or the substantial damage determination,
we compare the cost of the proposed improvement or repairs to the market value of the build-
ing (excluding land, accessory structures, and landscaping). If the resulting ratio equals or
exceeds 50 percent, the existing building must be brought into compliance with the floodplain
management requirements for new buildings.
Cost of Improvement or Cost to Repair to Pre - Damage Condition
>_ 50%
Market Value of Building
Please note:
■ You must provide an estimate of the cost to perform the proposed improvements or repairs.
If your building has been damaged, the cost estimate must include all work required to
repair the building to its pre- damage condition. The cost estimate must include all labor
and materials. If the work will be done by a contractor, the contractor's overhead and profit
must be included. If the work will be done by the owner or volunteers, market rates must be
used to estimate the cost of materials and the value of labor. Attached to this notice is a list
of costs that must be included and costs that are excluded. After we review the cost estimate,
we may require that it be broken down to show all materials and labor estimates.
■ You must provide a market value appraisal of the building that is prepared by a professional
appraiser according to standard practices of the profession. We will review the appraisal
to determine that it accurately describes your building and does not include the value of
the land, accessory buildings, and landscaping. Alternatively, we will use the tax assessment
value of your building as the estimate of the market value of the building before the work is
performed.
If you have any questions regarding this information, please contact
Attachments:
Requirements for Applications for Permits for Substantial Improvements and Repair of
Substantial Damage
Costs for Substantial Improvements and Repair of Substantial Damage
Owner's Affidavit
Contractor's Affidavit
2 of 7 SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS
Requirements for Applications for Permits for Substantial Improvements and
Repair of Substantial Damage
Please contact if you have questions about the substantial improvement and sub-
stantial damage requirements. Your building may have to be brought into compliance with the
floodplain management requirements for new construction.
Applications for permits to work on existing buildings that are located in Special Flood Hazard
Areas must include the following:
■ Current photographs of the exterior (front, rear, sides)
■ If your building has been damaged, include photographs of the interior and exterior;
provide pre- damage photos of the exterior, if available
■ Detailed description of the proposed improvement (rehabilitation, remodeling, addition,
etc.) or repairs
■ Cost estimate of the proposed improvement or the cost estimate to repair the damaged
building to its before - damage condition
■ Elevation certificate or elevation survey
■ You may submit a market value appraisal prepared by a licensed professional appraiser or we
will use the tax assessment value of the building
■ Owner's affidavit (signed and dated)
■ Contractor's affidavit (signed and dated)
SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS 3 of 7
Costs for Substantial Improvements and Repair of Substantial Damage
Included Costs
Items that must be included in the costs of improvement or costs to repair are those that are
directly associated with the building. The following list of costs that must be included is not in-
tended to be exhaustive, but characterizes the types of costs that must be included:
■
■
■
■
■
■
■
■
■
■
Materials and labor, including the estimated
value of donated or discounted materials
and owner or volunteered labor
Site preparation related to the improvement
or repair (foundation excavation, filling in
basements)
Demolition and construction debris disposal
Labor and other costs associated with
demolishing, moving, or altering
building components to accommodate
improvements, additions, and making
repairs
Costs associated with complying with any
other regulation or code requirement that
is triggered by the work, including costs
to comply with the requirements of the
Americans with Disabilities Act (ADA)
Costs associated with elevating a structure to
an elevation that is lower than the BFE
Construction management and supervision
Contractor's overhead and profit
Sales taxes on materials
Structural elements and exterior finishes,
including:
* Foundations (e.g., spread or continu-
ous foundation footings, perimeter walls,
chainwalls, pilings, columns, posts, etc.)
Monolithic or other types of concrete
slabs
■ Structural elements and exterior finishes
(cont.):
Windows and exterior doors
Roofing, gutters, and downspouts
Hardware
ft Attached decks and porches
■ Interior finish elements, including:
Floor finishes (e.g., hardwood, ce-
ramic, vinyl, linoleum, stone, and
wall -to -wall carpet over subflooring)
Bathroom tiling and fixtures
* Wall finishes (e.g., drywall, paint, stuc-
co, plaster, paneling, and marble)
Built -in cabinets (e.g., kitchen, utility,
entertainment, storage, and bathroom)
Bearing walls, tie beams, trusses
Joists, beams, subflooring, framing,
ceilings
Interior non - bearing walls
' Exterior finishes (e.g., brick, stucco, sid-
ing, painting, and trim)
IN Interior doors
Interior finish carpentry
Built -in bookcases and furniture
Hardware
Insulation
■ Utility and service equipment, including:
HVAC equipment
! Plumbing fixtures and piping
r Electrical wiring, outlets, and switches
Light fixtures and ceiling fans
tA Security systems
Built -in appliances
:* Central vacuum systems
Water filtration, conditioning, and re-
circulation systems
4 of 7 SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS
Excluded Costs
Items that can be excluded are those that are not directly associated with the building. The fol-
lowing list characterizes the types of costs that may be excluded:
■ Clean -up and trash removal
■ Costs to temporarily stabilize a building so
that it is safe to enter to evaluate required
repairs
■ Costs to obtain or prepare plans and
specifications
■ Land survey costs
■ Permit fees and inspection fees
■ Carpeting and recarpeting installed over
finished flooring such as wood or tiling
■ Outside improvements, including
landscaping, irrigation, sidewalks, driveways,
fences, yard lights, swimming pools,
pool enclosures, and detached accessory
structures (e.g., garages, sheds, and gazebos)
■ Costs required for the minimum necessary
work to correct existing violations of health,
safety, and sanitary codes
■ Plug -in appliances such as washing
machines, dryers, and stoves
SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS 5 of 7
Owner's Affidavit: Substantial Improvement or Repair of Substantial Damage
Property Address:
Parcel ID Number:
Owner's Name:
Owner's Address /Phone:
Contractor:
Contractor's License Number:
Date of Contractor's Estimate:
I hereby attest that the description included in the permit application for the work on the exist-
ing building that is located at the property identified above is all of the work that will be done,
including all improvements, rehabilitation, remodeling, repairs, additions, and any other form
of improvement. I further attest that I requested the above - identified contractor to prepare
a cost estimate for all of the work, including the contractor's overhead and profit. I acknowl-
edge that if, during the course of construction, I decide to add more work or to modify the
work described, that the [ insert community] will re- evaluate its comparison of the cost of work
to the market value of the building to determine if the work is substantial improvement. Such
re- evaluation may require revision of the permit and may subject the property to additional re-
quirements.
I also understand that I am subject to enforcement action and /or fines if inspection of the prop-
erty reveals that I have made or authorized repairs or improvements that were not included in
the description of work and the cost estimate for that work that were the basis for issuance of a
permit.
Owner's Signature:
Date:
Notarized:
6 of 7 SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS
Contractor's Affidavit: Substantial Improvement or Repair of Substantial Damage
Property Address:
Parcel ID Number:
Owner's Name:
Owner's Address /Phone:
Contractor:
Contractor's License Number:
Date of Contractor's Estimate:
I hereby attest that I have personally inspected the building located at the above - referenced
address and discussed the nature and extent of the work requested by the owner, including all
improvements, rehabilitation, remodeling, repairs, additions, and any other form of improve-
ment.
At the request of the owner, I have prepared a cost estimate for all of the improvement work
requested by the owner and the cost estimate includes, at a minimum, the cost elements identi-
fied by the [community] that are appropriate for the nature of the work. If the work is repair of
damage, I have prepared a cost estimate to repair the building to its pre- damage condition. I
acknowledge that if, during the course of construction, the owner requests more work or modi-
fication of the work described in the application, that a revised cost estimate must be provided
to the [ insert community] , which will re- evaluate its comparison of the cost of work to the market
value of the building to determine if the work is substantial improvement. Such re- evaluation
may require revision of the permit and may subject the property to additional requirements.
I also understand that I am subject to enforcement action and /or fines if inspection of the prop-
erty reveals that I have made or authorized repairs or improvements that were not included in
the description of work and the cost estimate for that work that were the basis for issuance of a
permit.
Owner's Signature:
Date:
Notarized:
SAMPLE NOTICE FOR PROPERTY OWNERS, CONTRACTORS, AND DESIGN PROFESSIONALS 7 of 7
Substantial Improvement Worksheet for Floodplain Construction
(for reconstruction, rehabilitation, addition, or other improvements, and repair of damage from any cause)
Property Owner:
Address:
Permit No.:
Location:
Description of improvements:
Present Market Value of structure ONLY (market appraisal or adjusted
assessed value, BEFORE improvement, or If damaged,
before the damage occurred), not Including land value: $
Cost of improvement -
Acual cost of the cuesbuWon" (see items to Includelexclude)
"Include volunteer labor and donated supplies."
Ratio = Cost of kmprovemnt (or Cost to Repair) X 100
Market Value
If ratio is 50 percent or greater (Substantial Improvement), entire structure including the existing
building must be elevated to the base flood elevation (BFE) and all other aspects brought into compliance.
Important Notes:
1. Review cost estimates to ensure that all appropriate costs are included or excluded.
2. If a residential pre -FIRM building is determined to be substantially improved, it must be elevated to or above the BFE. If a
non - residential pre -FIRM building is substantially improved, it must be elevated or dry floodproofed to the BFE.
3. Proposals to repair damage from any cause must be analyzed using the formula shown above.
4. Any proposed improvements or repairs to a post -FIRM building must be evaluated to ensure that the improvements or
repairs comply with floodplain management regulations and to ensure that the improvements or repairs do not alter any
aspect of the building that would make it non - compliant.
5. Alterations to and repairs of designated historic structures may be granted a variance or be exempt under the substantial
improvement definition) provided the work will not preclude continued designation as a "historic structure."
6. Any costs associated with directly correcting health, sanitary, and safety code violations may be excluded from the cost of
improvement. The violation must have been officially cited prior to submission of the permit application.
Determination completed by:
Date:
DEPARTMENT OF HOMELAND SECURITY
NATIONAL FLOOD
O.M.B. No. 1660 -0005
FEDERAL EMERGENCY MANAGEMENT AGENCY
ADJUSTER PRELIMINARY DAMAGE ASSESSMENT
INSURANCE PROGRAM
Expires September 30, 2010
Privacy Act Statement
The information requested is necessary to process the subject loss. The authority to collect the information is Title 42, U.S. Code, Section 4001 to 4028. It is
voluntary on your part to furnish the information. However, omission of an item may preclude processing of the form. The information will not be disclosed outside
of the Federal Emergency Management Agency, except to the servicing agent, acting as the government's fiscal agent; to claims adjusters to enable them to confirm
coverage and the location of insured property; to certain Federal, State, and Local Government agencies for determining eligibility for benefits and for verification of
nonduplication of benefits; to the Department of Justice for purposes of litigation or as required by law; and to State and Local agencies for acquisition and relocation
related projects, consistent with the National Flood Insurance Program and consistent with the routine uses described in the program's system of record. Failure by
you to provide some or all of the information may result in delay in processing or denial of this claim and/or application.
Paperwork Burden Disclosure Notice
Public reporting burden for this form is estimated to average 15 minutes per response. The burden estimate includes the time, effort or financial resources expended
by persons to generate, maintain, retain, disclose, or provide information to the Mitigation Division or its agent. You are not required to respond to this collection of
information unless a currently valid OMB control number and expiration date is displayed in the upper right comer of the these forms. Send comments regarding the
accuracy of the burden estimate and suggestions for reducing the burden to: Information Collections Management, Department of Homeland Security, Federal
Emergency Management Agency, 500 C Street, S.W., Washington, DC 20472, Paperwork Reduction Project (1660- 0005). NOTE: Do not send your completed
form to this address. Send completed forms to: NFIP Bureau & Statistical Agent, Certification Coordinator, P.O. boa 310, Lanham, MD 20703-0310.
WYO COMPANY
DATE OF LOSS
ADJUSTER
FICO NUMBER
This form is to be used for advisory purposes in helping FEMA and communities identify potential substantially damaged buildings. The adjuster will use
"replacement cost" when completing this form; however, the community is required under the National Flood Insurance Program to use "market value" in
determining substantial damage.
PLEASE PRINT LEGIBLY
POLICY HOLDER
777NUMB ER
PROPERTY ADDRESS (include zip code)
"PROBABLE REPAIR COST
BUILDING REPLACEMENT COST VALUE
BUILDING ACTUAL CASH VALUE
5
$
POLICY HOLDER
POLICY NUMBER
PROPERTY ADDRESS (include zip code)
"PROBABLE REPAIR COST
BUILDING REPLACEMENT COST VALUE
BUILDING ACTUAL CASH VALUE
5
S
POLICY HOLDER
POLICY NUMBER
PROPERTY ADDRESS (include zip code)
"PROBABLE REPAIR COST
BUILDING REPLACEMENT COST VALUE
BUILDING ACTUAL CASH VALUE
5
S
* *This is an estimate of the cost to repair the building to its pre —flood condition.
rrmr% rvnn o i — i v7, vl i yr KtrLAItZo ALL YKtviL)uzo W1 I IUNb. F-674
Privacy Act Statement
The information requested is necessary to process the subject loss. The authority to collect the information is Title 42, U.S. Code, Section 4001 to
4028. It is voluntary on your part to fumish the information. However, omission of an item may preclude processing of the form. The information
will not be disclosed outside of the Federal Emergency Management Agency, except to the servicing agent, acting as the government's fiscal agent;
to claims adjusters to enable them to confirm coverage and the location of insured property; to certain Federal, State, and Local Government
agencies for determining eligibility for benefits and for verification of agencies for acquisition and relocation - related projects, consistent with the
National Flood Insurance Program and consistent with the routine uses described in the program's system of record. Failure by you to provide some
or all of the information may result in delay in processing or denial of this claim and/or application.
PAPERWORK BURDEN DISCLOSURE NOTICE
Public reporting burden for the collection of information titled Claims for National Flood Insurance Program (NFIP) is estimated to average 6 hours
per response. The burden estimate includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data
needed, and completing and submitting these forms. You are not required to respond to this collection of information unless a currently valid OMB
control number and expiration date is displayed in the upper right comer of the these forms. Send comments regarding the accuracy of the burden
estimate and suggestions for reducing the burden to: Information Collections Management, Department of Homeland Security, Federal Emergency
Management Agency, 500 C Street, S.W., Washington, DC 20472, Paperwork Reduction Project (1660- 0005). NOTE: Do not send your
completed form to this address.
FEMA Form No.
Title
Burden Hours
81-40
Worksheet - Contents - Personal Property
81-41
Worksheet - Building
81-41A
Worksheet - Building (Cont'd)
81-42
Proof of Loss
81-42A
Increased Cost of Compliance
81-43
Notice of Loss
81-44
Statement as to Full Cost to Repair or Replacement
Cost Coverage, Subject to the Terms and Conditions
of this Policy
81 -57
National Flood Insurance Program Preliminary Report
81 -58
National Flood Insurance Program Final Report
81 -59
National Flood Insurance Program Narrative Report
81 -63
Cause of Loss and Subrogation Report
81 -96
Manufactured (Mobile) Home/Travel Trailer Worksheet
81 -96A
Mobile Home/Travel Trailer Worksheet (Continued)
81 -98
Increased Cost of Compliance (ICC) Adjuster Report
81 -109
Adjuster Preliminary Damage Assessment
81 -110
Adjuster Certification Application
2.5 Hours
2.5 Hours
1.0 Hours
.08 Hours
2.0 Hours
.07 Hours
.10 Hours
.07 Hours
.07 Hours
.08 Hours
1 Hour
.50 Hours
.25 Hours
.42 Hours
.25 Hours
.25 Hours
E Sample Letters of Determination
■ Letter to Notify Property Owners of a Determination That Work Constitutes Substantial
Improvement
■ Letter to Notify Property Owners of a Determination That Work Constitutes Repair of
Substantial Damage
■ Letter to Notify Property Owners of a Determination That Work Does NOT Constitute
Repair of Substantial Damage
SI /SD DESK REFERENCE E -1
Sample Letter to Notify Property Owners of a Determination That
Work Constitutes Substantial Improvement
Notice of Substantial Improvement Determination (Residential)
Dear Property Owner:
We have reviewed your recent application for a permit to [describe proposed improvement /ad-
dition] your existing home that is located in a mapped Special Flood Hazard Area. As required
by our floodplain management regulations and /or building code, we have determined that
the proposed work constitutes substantial improvement of the building. This determination
is based on a comparison of the cost estimate of the proposed work to the market value of the
building (excluding land value). When the costs equal or exceed 50 percent of the market value
of the building, the work is substantial improvement.
As a result of this determination, you are required to bring the building into compliance with
the flood damage - resistant provisions of the regulations and /or code [cite pertinent sections].
We would be pleased to meet with you and your designated representative (architect /builder)
to discuss how to bring your home into compliance. There are several aspects that must be ad-
dressed to achieve compliance. The most significant requirement is that the lowest floor, as
defined in the regulations/ code, must be elevated to or above the base flood elevation (BFE)
[or the elevation specified in the regulations/ code]. You may wish to contact your insurance
agent to understand how raising the lowest floor higher than the minimum required elevation
can reduce NFIP flood insurance premiums.
Please resubmit your permit application along with plans and specifications that incorporate
compliance measures. Construction activities that are undertaken without a proper permit are
violations and may result in citations, fines, or other legal action.
Sample Letter to Notify Property Owners of a Determination That
Work Constitutes Repair of Substantial Damage
Notice of Substantial Damage Determination (Residential)
Dear Property Owner:
We have reviewed your recent application for a permit to repair your existing home that was
damaged by [insert cause of damage] . The building is located in a mapped Special Flood Haz-
ard Area. As required by our floodplain management regulations and /or building code, we
have determined that the building has been substantially damaged. This determination is based
on a comparison of the cost estimate of the work required to restore the building to its pre -
damage condition to the market value of the building (excluding land value). When the cost
to repair equals or exceeds 50 percent of the market value of the building, the work is repair of
substantial damage.
As a result of this determination, you are required to bring the building into compliance with
the flood damage- resistant provisions of the regulations and /or code [cite pertinent sections].
We would be pleased to meet with you and your designated representative (architect /builder)
to discuss how to bring your home into compliance. There are several aspects that must be ad-
dressed to achieve compliance. The most significant requirement is that the lowest floor, as
defined in the regulations/ code, must be elevated to or above the base flood elevation (BFE)
[or the elevation specified in the regulations /code]. You may wish to contact your insurance
agent to understand how raising the lowest floor higher than the minimum required elevation
can reduce NFIP flood insurance premiums.
If the damage was caused by flooding and if you have a flood insurance policy from the Nation-
al Flood Insurance Program, you should contact your adjuster to discuss the Increased Cost of
Compliance (ICC) coverage. This coverage may provide a claim payment to help pay for work
required to bring your home into compliance. Your adjuster can explain that the ICC claim may
also be used to pay certain costs associated with demolishing and rebuilding your home, or mov-
ing your home to a site outside of the floodplain.
Please resubmit your permit application along with plans and specifications that incorporate
compliance measures. Construction activities that are undertaken without a proper permit are
violations and may result in citations, fines, or other legal action.
Sample Letter to Notify Property Owners of a Determination That
Work Does NOT Constitute Repair of Substantial Damage
Notice of Determination (Residential)
Dear Property Owner:
We have reviewed your recent application for a permit to repair your existing building that was
damaged by [insert cause of damage]. The building is located in a mapped Special Flood Haz-
ard Area. As required by our floodplain management regulations and /or building code, we
have determined that the work proposed to repair the damage does not constitute repair of
substantial damage. This determination is based on a comparison of the cost estimate of the
work required to restore the building to its pre- damage condition to the market value of the
building.
Please be advised that we will make another determination if you elect to perform work oth-
er than what is necessary to repair the damage, such as additional renovations or upgrades or
building an addition. Construction activities that are undertaken without a proper permit are
violations and may result in citations, fines, or other legal action.
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FEMA P -758
Catalog No. 09037 -1