Repetitive Loss Area Analysis – Why a Community Might Need One

A Repetitive Loss Area Analysis (RLAA) documents areas that have or will likely experience repeated flood losses. The analysis includes collecting information on specific buildings to understand the cause of flood damage at each site. It also includes identifying mitigation strategies for each building. 

In contrast to planning for flood risks for an entire community, the RLAA takes a specific look at individual buildings and sites. The intent is to mitigate repeated flood damage of individual structures. Once the RLAA is developed, the mitigation strategies can be used to convene partners, obtain grant funding, and take actionable steps to manage risk.

In addition to being a beneficial tool to mitigate risk, communities participating in the Community Rating System (CRS) can receive credit for preparing a RLAA. To receive credit, the analysis must follow specific guidelines. The number of properties identified with a repetitive loss risk will determine how detailed the RLAA needs to be.  

What is Repetitive Loss

Under the CRS, a structure that has had two or more claims within any 10-year period since 1978 of more than $1,000 paid by the National Flood Insurance Program (NFIP) is considered a repetitive loss structure. A subset of repetitive loss structures – called severe repetitive loss (SRL) – are those that have experienced four or more claims of $5,000 or more, or that have had at least two claims that combined exceed the building’s value. Federal funding mechanisms may provide mitigation options for SRL properties.

Repetitive loss is determined regardless of property ownership, whether the building is insured, or whether mitigation has occurred. 

Why Develop a Repetitive Loss Area Analysis?

Communities that develop a RLAA can provide solutions to homeowners. Often these individuals are experiencing displacement, or continued efforts to repair their homes after flood events. Providing mitigation assistance can benefit these individuals - and communities as a whole - by making buildings safer.  

The Federal Emergency Management Agency (FEMA) creates a list of repetitive loss properties annually for all communities that participate in the CRS. They also create a list for any community interested in participating. Obtaining an updated repetitive loss list will assist communities in identifying flood mitigation options. 

In addition, for communities that participate in the CRS and have 50 or more identified repetitive loss properties, a RLAA is required. Continued analysis and updates will ensure success in the CRS program.

5-Step RLAA Process

Communities that have at least one unmitigated repetitive loss property can prepare a RLAA and receive credit under the CRS. These communities need to develop a map of the repetitive loss area. Once this area is identified, there is a 5-step planning process required to receive CRS credit for development of the RLAA. 

Step 1 – Property Owner Outreach. The community must notify all identified repetitive loss property owners about the upcoming analysis. This includes encouraging the property owners to participate in the process. Communities can choose how to engage with property owners – such as conducting neighborhood meetings, open houses, mailings, questionnaires, etc. This step must be completed before the next steps. 

Step 2 – Agency and Other Stakeholder Outreach. The community must reach out to agencies and other stakeholders that may have valuable information such as plans, studies, maps, and reports that inform flood hazard analysis and mitigation in the community. Documentation of the outreach and what type of information was obtained must be kept. 

Step 3 – Data Collection. Each building must be evaluated for the cause of repetitive flooding and needed mitigation. This evaluation can be conducted from public right-of-way, or onsite with owner permission. Data must at minimum include a description of drainage patterns around the buildings, the building foundation, and the condition of the structure overall. Other data can be collected to provide a more thorough understanding of the building and context. 

Step 4 – Mitigation Alternatives. This step looks at the multitude of mitigation options available, and creates a realistic plan for the individual building. FEMA identifies six mitigation categories that can be chosen from, or combined to create a solution:

• Prevention: Includes activities that will keep the flooding situation from getting worse –  things like land acquisition, regulations, or planning activities. 
• Property Protection: Includes activities such as promoting flood insurance, encouraging relocation of a building, or elevating or retrofitting a building. Initiated by a property owner or community. 
• Natural Resource Protection: Includes activities that maintain the natural state of properties, such as protecting or restoring wetlands or coastlines. 
• Structural Projects: Includes activities that physically keep floodwaters away from the building, such as building floodwalls, modifying flood channels or constructing reservoirs. 
• Public Information: Includes activities that provide education, such as outreach to property owners and residents, information on websites and social media, as well as working with development and real estate communities to provide flood hazard information. 
• Emergency Services: Includes activities that facilitate response and recovery following a flood event. These include operational flood warning systems that can help residents prepare for flood events. 

Step 5 – Documentation. The findings of the entire RLAA must be assembled into one report for each repetitive loss area. Following a public comment period, the RLAA must be adopted by the local governing body through a formal resolution. 

Follow-Up

Once the RLAA is adopted, communities participating in the CRS must complete an Annual Evaluation Report indicating the status of identified mitigation measures. This must be provided with annual recertification. Additionally, during cycle verifications, the community must update their analysis or provide an addendum to the existing analysis. 

How Forerunner Can 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.

We can also help with a few things specific to the RLAA. First, when you are reaching out to repetitive loss property owners, we can help you generate a custom RLAA letter to notify them about the upcoming analysis. The letters will be saved in Forerunner so that you can add to your record of documentation. Additionally, if your community has a RLAA map as a result of the RLAA, we can add it to the platform. You can view with the RLAA map layer turned on or off, making it easy to track the data and documentation for each of the repetitive loss properties.

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.