Acquiring and Mobilizing Repetitive/Severe Repetitive Loss Data

Identifying areas that are at risk of frequent flooding is crucial for all communities, particularly those participating in the National Flood Insurance Program (NFIP). Properties within these areas are at risk of becoming Repetitive Loss (RL) properties, which can profoundly affect communities in a myriad of ways.  RL properties can contribute to increased insurance costs and strain emergency services, so adequately tracking and proactively addressing Repetitive Losses is often a priority for communities that regularly experience flood events.

In Forerunner's work with communities across the country, we've identified many challenges with managing Repetitive Loss properties – from understanding the ISAA process to integrating Repetitive Loss data into existing datasets to meeting data security requirements, managing enforcement, and more. We created this blog to answer some of the common questions we hear!

‍What are Repetitive Loss and Severe Repetitive Loss Properties?

Repetitive Loss properties are those that have proven vulnerable to recurring flooding due to multiple NFIP losses. Over 195,000 repetitive loss properties in the United States have received claim payments of over $12 billion, which accounts for almost one-fourth of all NFIP payments since 1978.

The CRS program defines a Repetitive Loss Property (RL) as "a property for which two or more NFIP losses of at least $1,000 each have been paid within any 10-year rolling period since 1978 (e.g., two claims during the periods 1978–1987, 1979–1988, etc.).."

Congress defined a new subset of RL properties called "Severe Repetitive Loss Properties" to focus available resources on mitigating these properties when it passed the Flood Insurance Reform Act of 2004. 

Severe Repetitive Loss Property (SRL), as defined in the Flood Insurance Reform Act of 2004, is "those 1–4 family properties (and non-residential buildings) that have had four or more claims of more than $5,000 or two or more claims that cumulatively exceed the building's value."

Special note: Repetitive Loss (RL)  and Severe Repetitive Loss (SRL) designations only apply to structures with NFIP flood insurance policies. A community may have structures that sustain recurring flooding but are not considered RL or SRL properties because they are not insured by NFIP policies. This becomes important when statistics on repetitive loss are used for planning and/or decision-making purposes.

Repetitive Loss (RL) and Severe Repetitive Loss (SRL) designations primarily affect mitigation grant prioritization and cost share allowances. FEMA Hazard Mitigation Assistance (HMA) grants - a category which include the Hazard Mitigation Grant Program (HMGP), the Pre-Disaster Mitigation (PDM) grant program, and the Flood Mitigation Assistance (FMA) grant programs – typically require a 25% cost share match to 75% federal share for all awards. However, under the FMA program, mitigation projects for SRL-designated properties receive a 100% federal cost share, and RL-designated properties require a 10% cost match to a 90% federal share. The enhanced federal cost shares for SRL and RL properties dramatically reduce the funding burden on communities and homeowners in implementing mitigation through the FMA grant program.

Further, SRL and RL properties that make up more than 50% of the properties in a submitted FMA project are prioritized and are more likely to be funded during the program's annual cycle. In addition to the FMA program, there have been some instances of the SRL designation impacting insurance rates. In 2019, FEMA implemented an additional premium on SRL properties.

‍Why is it essential for communities to identify their Repetitive Loss properties?

More than 5.3 million NFIP policies across the United States exist in more than 22,000 communities. About 160,000 of the properties covered by these policies have suffered repetitive losses as of 2015. Since 1978, approximately $9 billion has been paid to these properties, representing about one-quarter of all flood insurance claims payments. Many buildings remain uninsured despite remaining on a community's repetitive loss list. Knowing which properties have been identified as Repetitive Loss properties can help to ensure that communities plan accordingly for mitigation and future development. For communities participating in the Community Rating System (CRS), achieving a CRS Class 9 or higher is predicated on repetitive loss-focused activities including tracking rep loss properties, mapping rep loss areas, and conducting outreach. 

Homeowners often want a solution to their repetitive flood problems because they must continually clean up and repair their homes and can even be displaced for some time. In response, communities usually advise and assist property owners who have been flooded or have drainage problems. From a state and national perspective, mitigating repetitive loss of properties makes economic sense and reduces the financial burden on the National Flood Insurance Fund (NFIF). Reducing repetitive flood claims can help strengthen the solvency of the NFIF. But more importantly, reducing damage to repetitively flooded buildings makes communities safer.

‍How can communities access Repetitive Loss property data?

FEMA provides NFIP Repetitive Loss (RL) and Severe Repetitive Loss (SRL) data upon request for mitigation planning, grants, or the CRS program. The data is managed in a system called PIVOT, . PIVOT stores data for each NFIP flood insurance policy, including Personally Identifiable Information (PII) such as the owners' names, addresses, policy coverages, and the dates and amounts of past claims. The PIVOT system is crucial in maintaining and updating this data, ensuring its accuracy and security.  

Historically, CRS-participating communities would receive RL and SRL data from their CRS specialists annually. Communities used this data to manage their RL and SRL properties, checking for accuracy and updating any changes to the list by submitting an NFIP Repetitive Loss Property Update Form, formally known as the AW_501 form. Due to PII security concerns, FEMA changed this process several years ago by establishing the Information Sharing Access Agreement (ISAA) process.

Under this process, communities must have an executed ISAA with FEMA before obtaining their RL and SRL data. Typically, communities are required to have an ISAA directly with FEMA, but some states have an ISAA that allows the state to establish an ISAA with communities. To learn which process your state follows, contact your State Floodplain Administrator.  

While the process can differ community by community, here is a general outline of the steps typically taken to secure ISAA with FEMA:

1. Contact the Regional Flood Insurance Liaison (RFIL) at your FEMA Regional Office. Most Regions have set up an email address, making it easier for the community to make this request.
2. The RFIL will respond to the request, asking for clarifying information to develop the ISAA if needed, such as:

• What specific NFIP data is being requested? (RL data, SRL data, or other NFIP data)
• Why is the data being requested, and how will it be used? (CRS requirements, updating mitigation plans, developing grant applications, or other NFIP data to earn CRS credits)
• Who will use or have access to the requested data? (Person(s) must be named in the ISAA)
• Is the data related to a presidentially declared disaster or emergency?

3. Once these questions are answered, a draft ISAA will be created and sent to the community for review and signatures. 
4. Once the community signs, the ISAA is returned to the RFIL for processing. 
5. The ISAA will be reviewed and processed at the Region or FEMA Headquarters, and an executed copy will be returned to the requesting community. Once the ISAA is in place, the RFIL can provide the requested data, which will be valid for three years.

When considering developing an ISAA with FEMA, here are some useful points to remember in establishing an ISAA that fulfills your community's needs: 

• Consider your future data needs. Do not limit the scope when making your ISAA request since ISAAs are usually specific to the requested data set. Consider all the possible uses that may include PII, even if they are not immediate. This comprehensive approach will ensure you receive permission to request all the data you may need within the three years of the ISAA, making your flood risk management more effective. 
• Plan for access. Include all the possible individuals (signatories) who may need to request or use the data. The community's Chief Executive Officer must sign the ISAA with four additional signatories, for five per ISAA. By using as many of these slots as possible, you will not have to rely on a single point of contact to request and review the needed data. 
• Account for everyone. Remember to consider including third-party vendors or consultants. If the community contracts with a vendor or consultant, like Forerunner, whose services include using or reviewing data requested in the ISAA, they will need to be included as a signature in the ISAA. This will ensure that the community can share the data with third parties and that it does not violate the Federal Privacy Act. 

‍How do communities use Repetitive Loss data for mitigation and resilience?

Mitigating Repetitive Loss properties often requires a multi-faceted approach that may include acquisition (buyout) processes, grant opportunities applications, and monitoring/tracking improvements and repairs. During each CRS verification cycle visit, CRS participating communities must also have current Repetitive Loss data.

• Acquisitions (buyouts) - Generally, FEMA-assisted property acquisition projects consist of a community purchasing at-risk structures from voluntary sellers and either demolishing the structures or relocating the structures to a new site outside of the hazard-prone area. The purchased property is then maintained, in perpetuity, for open-space purposes and to restore or conserve the site's natural functions.

• Mitigation Grant Opportunities - FEMA has three federal mitigation grant programs: the Hazard Mitigation Grant Program (HMGP), the Pre-Disaster Mitigation Program (PDM), and the Flood Mitigation Assistance Program (FMA). RL and SRL designations primarily affect mitigation grant prioritization and cost share allowance. To learn more about grant funding opportunities, locate and contact your State Hazard Mitigation Officer (SHMO).

• Monitoring and Tracking Improvements and Repairs - NFIP participating communities must adopt and enforce regulations and codes for development in Special Flood Hazard Areas (SFHAs). This includes tracking improvements and repairs to RL and SRL properties to determine if the proposed work qualifies as a substantial improvement or repair of substantial damage. Properly tracking improvements and repairs will assist in mitigating RL and SRL properties, improving communities' resilience to flooding. 

• Repetitive Loss Area Analysis (RLAA) - A community may receive CRS credit for element FMP, a repetitive loss area analysis (element RLAA), and element SDP. A community need not have any repetitive loss properties on FEMA's list to receive SDP credit.

‍How can Forerunner help?

We’d love to chat about how we can help! The team at Forerunner recently developed a Repetitive Loss feature designed to make it easier to manage Repetitive Loss data. The feature supports communities by consolidating, updating, and tracking repetitive loss data safely and securely. Given the data's high sensitivity, we use best-in-class security practices to protect it. Once in Forerunner, the data can only be viewed by users with appropriate permissions and is not available to the public, offering much more security than traditional spreadsheets.

If you’re new to learning about Forerunner, we build software to help our partners address flood risk. As it pertains to Repetitive Loss, Forerunner empowers our partner communities to more easily track and identify rep loss properties, facilitates outreach through features like our letter generation tool, and enables better cross-departmental collaboration. Reach out to learn more.