Change in FEMA rules needed

By Matt Pace, Bolivar property owner
December 15, 2014

Commissioner Dennard,
I purchased my first piece of property on the Bolivar Peninsula back in 1987. I have also been writing coastal flood insurance in Texas for nearly 40 years now. The recent issue with FEMA’s enforcement of floodplain regulations is a concern to all of us and needs to be addressed in order for the area to maintain flood insurance eligibility. That is the immediate challenge that we face in the near future. But, there is also a more long-term solution to the problem———we need to get FEMA to change their rules a bit concerning ground level enclosures below the Base Flood Elevation (BFE) or what is actually the 100 year flood expectation level. This change in the guidelines could be the real fix to the problem in the long range.

In my experiences with FEMA and the National Flood Insurance Program (NFIP), it seems that their two biggest concerns with construction below the BFE level are:
#1—No “habitable living area” allowed, since permanent habitation at ground level is discouraged; and,
#2—In order to minimize any obstruction to water flow beneath a structure in a storm surge, then anything built below the BFE is to be generally small and is to be built using breakaway walls.

I feel that these two requirements are reasonable for FEMA to require of us in order to minimize possible loss of life or property in future floods or storm surge. However, where I feel that FEMA is being very unreasonable in their guidelines is that they do not allow residents to even have a half-bath built below BFE. To me, if a small bathroom is built (with only a toilet and a sink) and if it is enclosed by breakaway walls, then what additional harm does this cause? FEMA already allows us to build a larger enclosed area below if it is to be used for “parking or storage only” and also if it is built with breakaway walls. So what additional harm is done by simply having a small toilet and a sink within a small enclosure with breakaway walls? As far as this enclosure being considered a “habitable living area”, well I don’t know about your experiences, but I really don’t know any people who really care to live in a half-bath anyway!

Not being allowed to build a half-bathroom at ground level then forces all of us to have to go upstairs time and time again just to find a bathroom. If we can convince FEMA to allow a half-bath at ground level that is built with break-away walls, then this will go a long way towards resolving this issue. It just makes no sense not to allow this small exception to their rules. Forgive the language here, but perhaps the rallying-cry for this cause should be: “We don’t want to habitate…we simply want to urinate” !

In any case, this change in the rules is reasonable and it needs to be actively pursued with FEMA. Anything that you can do to help towards this end will be greatly appreciated. I know that I will be actively lobbying for this change and the more folks that we can get on this bandwagon, then the better chance we will have to get this done.

Thanks in advance for helping us pursue this badly needed change to the flood guidelines.

Sincerely, Matt Pace
Tricoast Insurance Services, Inc./ Insgroup, Inc.
9225 Katy Freeway, Suite #110, Houston, TX 77024
Mailing Address: P.O. Box 19929, Houston, TX 77224
Mpace@tricoast.net
http://www.tricoast.net
http://www.insgroup.net/

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7 Responses to “Change in FEMA rules needed”

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  3. Matt says:

    SAMPLE LETTER THAT EACH COULD SEND TO OUR CONGRESSMEN:

    There is a critical issue that really needs to be addressed very soon regarding FEMA’s rules that forbid ground level bathrooms under elevated coastal beach homes in Galveston County. The current FEMA flood guidelines for enclosures beneath elevated homes built in coastal areas seem to have two main overriding themes:
    #1—No “habitable living area” is allowed, since permanent habitation at ground level is discouraged;
    and
    #2—In order to minimize any obstruction to water flow beneath an elevated structure in a storm surge, then anything built below the Base Flood Elevation (BFE) is generally to be small and is to be built using breakaway walls. (The “BFE” is actually the 100 year flood expectation level.)

    I feel that these two requirements are very reasonable for FEMA to require of us in order to minimize possible loss of life or property in future floods or storm surge. However, where I feel that FEMA is being unreasonable in their guidelines is that they do not allow residents to even have a half-bath built below the BFE. FEMA already allows homeowners to build a larger enclosed area below BFE if it is to be used for “parking or storage only” and also if it is built with breakaway walls. So what additional harm is done by simply having a small toilet and sink within a small enclosure built with breakaway walls? FEMA tells me that this may create an obstruction to water-flow, but this is not the case at all. The walls would still breakaway in a storm surge and a small toilet would create very little obstruction to water-flow. And as far as this enclosure being considered a “habitable living area”, well I don’t know about your experiences, but I really don’t know any people who really care to live in a half-bath anyway! Not being allowed to build a half-bathroom at ground level then requires all of us (and even the elderly and the disabled) to be forced to climb a long set of stairs time and time again just to find a bathroom. It seems to make no sense to us that FEMA would not allow this one small exception to the rules. The only factor that I can even think would possibly be an objection here is pollution risk. But when you really think about it, what is the difference between a flushed toilet that is elevated 15-20 feet above the ground versus a flushed-toilet at ground level? Either way, the waste was already dumped into a sewer line or a septic tank.

    Coastal residents desperately need this simple exception to their guidelines and we ask that you help us in getting this change implemented as soon as reasonably possible. It is a badly needed exception to their guidelines. Thanks for your attention to this very important matter and feel free to contact me at any time with questions.
    Sincerely,

  4. Matt says:

    FEMA says that any changes will need to be approved by Congress first. Here is a link to finding Senators and House Reps:
    http://outcry.com/

  5. Craig Lang says:

    There is a logical solution which would be considered a compromise between FEMA and the property owners of Bolivar Peninsula. The bathrooms that have been planned for our beaches need to be on the ground for accessibly and I’m sure they will be required to connect to the sewer system since FEMA funds are being used for the Public Sewer System. Therefore the FEMA Guidelines should allow for first floor plumbing for bathrooms and kitchens if the property owner is connected to the Public Sewer System. That’s an incentive for property owners to connect to the sewer system. If you don’t want to connect to the Public Sewer System or it’s not available at your property, you can install a “ZERN” Gate Valve and Back Flow Preventer, and install plumbing at ground floor elevation like the other FEMA Districts.

    This would encourage residents outside the Public Sewer System limits to install the required valve if they wanted ground floor plumbing. The cost to connect to the Public Sewer System is the same as the installed cost of the required valve. If you don’t want ground floor plumbing, you don’t have to do anything, no cost.

    New construction permits within the Public Sewer System limits would be required to connect to the Public Sewer System. If your existing septic tank or aerobics tank fails, they cannot be replaced and property owner would be required to connect to the Public Sewer System.

    This also encourages Public Sewer Connections because the connection to the Public Sewer System is less than the repair.

    Now, lets talk about a common sense solution to ground floor living space. The FACTS are:

    If you enclose your ground floor area under your house with “Break-A-Way” walls, that’s OK…!!! If you enclose an area under your Beach House, it is your Garage/Storage Space, and we all fill up our Storage Space. None of my friends have an empty Garage or Storage Space. It will get filled up with miscellaneous items, tools, lawn equipment, golf carts, beach toys, fishing equipment, maintenance items and cars? If you live in the enclosed area under your house, you don’t fill your “Living Space” full of unnecessary items. So when that flood comes along, and the walls Break-A-Way there is LESS Clean-Up with Living Space vs Storage Space. Oh and don’t forget you’re connected to a Public Sewer System that FEMA built, so I’m sure it’s safe for the environment. FEMA doesn’t insure any property below base flood elevation (BFE). Doesn’t cost FEMA anything!

    All we are asking is for “Our” FEMA Districts to do the same as all the other FEMA Districts that govern Coastal Counties, allow Living Space on the Ground Floor. The guidelines should be the same for the East Coast, West Coast and ALL of the Gulf Coast. Why is it OK to build on the ground on every coast of the United States except for the Texas Gulf Coast? We’re not asking for FEMA to insure it. It’s going to cost me more in Taxes because Living Space is Taxed at a higher rate than Storage Space. The County and State makes additional dollars and property owners get the full use of their property.

  6. Brenda says:

    One thing that does get the attention of any large department is a sudden large influx of both letters and emails. These tie up staff time, they are irritating to deal with, they draw attention in a situation where all the staff members are being swamped with so many diverse challenges coming from all directions at once.

    My suggestion is that we all printout Matt’s letter. On a cover letter, write “I agree completely! Please help us making this simple and important change” – in your own words, of course. Just something short. This is a long enough letter anyway. But it’s so well said.

    Sign your cover letter, STAPLE it to Matt’s letter and mail it to:
    William Craig Fugate, Administrator
    Federal Emergency Management Agency (FEMA)
    500 C Street S.W.
    Washington, D.C. 20472

    The more letters sent, the more likely this will draw the attention of the right folks.

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