Delegation Demands To Correct Flood Maps Based On New Evidence
Town of Rockport Appeal Includes Additional Scientific Proof that the New Flood Maps Are Incorrect; FEMA Agreed
Washington, DC – Today, Reps. Bill Keating and John Tierney led their colleagues in the Massachusetts Congressional Delegation in demanding that the Federal Emergency Management Agency (FEMA) suspend and amend the state’s new flood maps based on FEMA’s recent approval of the Town of Rockport’s flood map appeal. The letter was sent to Craig Fugate, Administrator of FEMA.
On December 20, 2013, the Delegation sent a letter to FEMA requesting a delay of the new flood maps based on findings in a study commissioned by Congressman Keating that indicated the flood map methodology employed by FEMA was inaccurate for our region. Specifically, FEMA utilized the Direct Integration Method (DIM), a Pacific Coast wave model, for Massachusetts as opposed to one based on the Atlantic Coast. In response to that letter, FEMA indicated that additional data needs to be submitted by the state’s communities to demonstrate that the methodology was incorrect.
Recently, the Town of Rockport did just that when they successfully appealed the new flood maps for Long Beach. In their appeal, Rockport disproved the accuracy of the DIM model by demonstrating that there was a more accurate wave model for their town called the SWAN model, which more closely reflects the Atlantic Coast wave pattern. When approving the town’s appeal, FEMA stated that “the engineering analysis data submitted in support of the appeal provides evidence that the alternate method for determining wave setup provides a scientifically correct estimate of the Base Flood Elevations for Long Beach.”
By accepting the Rockport appeal, FEMA has set a precedent that acknowledges that the SWAN model is more appropriate for the Commonwealth’s coast rather than the methodology they utilized. As such, all of the state’s new flood maps need to be delayed until they are properly adjusted.
“The Town of Rockport’s successful appeal is precedent-setting for the rest of the state,” said Rep. Keating. “It provides concrete proof that FEMA used the incorrect flood map models for our region and their approval of the appeal is acknowledgement that there is a better one. Too much is at stake for our homeowners and communities to not remedy this wrong. The current FEMA maps are overly conservative, placing people in flood zones inappropriately and costing them thousands of dollars. The only responsible thing to do is to suspend the implementation of the state’s maps until they are fixed.”
“FEMA’s decision to use a model that was untested and inaccurate for the Northeast is yet another example of its preference to do things quickly rather than properly. I am proud that the Town of Rockport, located in the Sixth District, took the initiative to seek out a more accurate mapping technique and appeal its flood maps on behalf of its constituents and hope that FEMA will recognize the unnecessary burden it has placed on so many families and businesses in Massachusetts and delay implementation of its new flood maps until they can accurately reflect the true flood risk in our communities. I will continue to fight to provide relief to residents and businesses who have been wronged by the mismanaged and unfair implementation of these maps and flood insurance rates,” said Rep. Tierney.
"We need to make sure FEMA’s flood maps are accurate, reliable, and reflect the best available scientific data,” said Senator Warren. “Rockport’s successful appeal is further evidence that the new flood maps must be fixed. The government needs to take the time to correct and implement its new maps, so that hardworking families who have played by the rules are not slammed by unaffordable and unexpected rate hikes."
"We must ensure FEMA utilizes the best science when devising these new flood maps, and we need to reimburse communities who’ve successfully appealed flawed flood maps,” said Sen. Markey. “Bipartisan legislation we just passed in the Senate includes these measures, as well as ensures we have permanently addressed the affordability of flood insurance before any crippling rate increases go into effect. Homeowners and businesses already fear how they will protect their property from going under due to rising floodwaters; they should not have to fear going under financially from unaffordable spikes in insurance premiums. I call on the House to quickly pass this important legislation that will protect our Massachusetts home and business owners.”
“It is clear from the Rockport decision that FEMA must reassess the methodology used to prepare new flood maps for the state,” said Rep. Capuano. “Many residents and businesses are being affected by the new models and FEMA must take steps to address any concerns before the maps are finalized”.
“Homeowners have a right to know that FEMA is using the best available scientific technology when drawing the flood maps,” said Rep. Lynch. “If the data that FEMA is using is not accurate, many homeowners and businesses will lose money today that they will not be able to recuperate later. We need to delay implementation of the flood maps to ensure that American homeowners will not be penalized through no fault of their own.”
“Congress must provide continued oversight and assistance to ensure clear channels of communication between local communities and FEMA so that we can ultimately arrive at the best possible results based on the most accurate scientific methods,” said Rep. Tsongas. “As a member of the Natural Resources Committee, and with several major waterways crisscrossing my district, I have long been an advocate for preserving our natural resources and supporting those who live and work around them. I have heard from concerned residents in the region and I urge action to help maintain affordable flood insurance.”
“Our Commonwealth has seen a dramatic jump in flood insurance premiums at a time when residents and businesses are already struggling to make ends meet,” said Rep. Kennedy. “Given FEMA’s approval of Rockport’s appeal, there is no question FEMA must amend our state’s flood maps to be both accurate and fair.”
“FEMA must use a realistic, regionally-appropriate flood map model for Massachusetts, and I’m proud to stand with our delegation to push the Agency to do so,” said Rep. Clark. “Thousands of Massachusetts families are directly impacted by any change FEMA considers. We must ensure we’re using the most accurate, science-based models available, so that families are not unfairly burdened by rising insurance premiums based on faulty data.”
Below is the text of the delegation’s letter.
February 10, 2014
The Honorable W. Craig Fugate
Federal Emergency Management Agency
500 C Street, SW
Washington, D.C. 20472
Dear Administrator Fugate:
In response to your letter dated December 20, 2013, you indicated that additional data needs to be provided to the Federal Emergency Management Agency (FEMA) on behalf of the communities in the Commonwealth to demonstrate that the methodology used to prepare the new flood maps was inaccurate for our region.
It has come to our attention that the Town of Rockport successfully appealed the new flood maps for Long Beach using a physics-based methodology (SWAN model) to compute wave set-up, rather than the empirical approach utilized for the original FEMA analysis for Essex County (i.e. the Direct Integration Method or DIM). In response to the Rockport appeal, FEMA states that “the engineering analysis data submitted in support of the appeal provides evidence that the alternate method for determining wave setup provides a scientifically correct estimate of the Base Flood Elevations for Long Beach.” According to the documents submitted by Applied Coastal Research and Engineering, Inc., FEMA’s proposed Direct Integration Method (DIM) method used to determine wave setup was not appropriate. It is our understanding that the DIM methodology used to calculate the wave setup for this region was developed specifically for the Pacific Coast. While it is true that the FEMA document Atlantic Ocean and Gulf of Mexico Coastal Guidelines Update (2007) indicates that the DIM method is an acceptable approach for coastal Flood Insurance Studies in the eastern United States, more recent work funded by FEMA for the U.S. Mid-Atlantic coast in Region III chose to utilize a more rigorous physics-based approach that yielded lower wave setup values than predicted by DIM.
As we have expressed to you before, we believe that the DIM approach – when used for our region – yields overly conservative results, unnecessarily adding more families to the flood maps. On the other hand, the effect of using a sophisticated (physics-based) SWAN model yields more accurate results for our region given that the nature of flooding is most often the result of Nor’easters. This is especially of concern for our region, as the coast does not consist of a straight shoreline and the storm waves often attack the shoreline at an oblique angle; two complicating factors that are not accounted for by the DIM methodology, but can be accounted for by the two-dimensional SWAN modeling approach. Included in the attached supporting documents, a letter from FEMA dated January 16, 2014, indicates that FEMA accepted this methodology for Long Beach (Rockport) and the Board of the Selectmen accepted the amended maps.
In this way FEMA appears to have created a precedent in approving Rockport’s appeal using the SWAN model to compute wave setup that has shown to be more accurate than the DIM methodology, and we believe that the Commonwealth’s remaining counties should be held to the same standard. Based on the new evidence regarding FEMA’s acceptance of the Rockport appeal for Long Beach, we ask that FEMA work with us on a plan to amend the Commonwealth's flood maps utilizing the physics-based modeling approach that is more appropriate for our geographic region; we ask that you suspend the new flood maps until a decision is made to amend them; and that you inform us in writing by (March 7, 2014) of FEMA's proposed plan, including a draft timeline, to correct flood maps for the Commonwealth.
Thank you for your urgent attention to this important issue.
Elizabeth Warren, US Senator
Edward J. Markey, US Senator
William R. Keating, Member of Congress
John F. Tierney, Member of Congress
Richard E. Neal, Member of Congress
James P. McGovern, Member of Congress
Michael E. Capuano, Member of Congress
Stephen F. Lynch, Member of Congress
Niki Tsongas, Member of Congress
Joseph P. Kennedy III, Member of Congress
Katherine M. Clark, Member of Congress
Enc: Town of Rockport, FEMA, Appeal Letter, 1/16/14
Town of Rockport, Board of Selectmen, Letter Accepting Map Changes, 1/13/14
Town of Rockport FEMA Flood Map Appeal, Applied Coastal Research and Engineering, Inc., 11/1/13
University of Massachusetts Dartmouth School for Marine Science and Technology and Applied Coastal Research and Engineering, Inc., Technical Memo, 12/03/13
 Blanton, Brian, et al. FEMA Region III Storm Surge Study
Coastal Storm Surge Analysis: Computational System, Report 2: Intermediate
Submission No. 1.2. U.S. Army Engineers Research and Development Center (Kitty Hawk: 2011).