The City of Key West, Florida

The Southernmost City in th Continental United States

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Floodproofing Alert!

Is Your Business Floodproofed?

New insurance requirements now in effect. 

Annual recertification of floodproofing measures is now required for flood insurance renewal.  Which requires specific documentation and plans related to the original installation.  In many instances, the documentation you now possess won't be adequate. 

Absent this paperwork, the sticker-shock at renewal time will likely be drastic. Without this extensive documentation, your new flood insurance rate will be as if your building is below flood levels and hasn't any floodproofing. 

The renewal bill for one floodproofed business - a tourist attraction - went from $3,000 to $16,000 because the newly required documentation wasn't ready.  Another business - a corner grocery store - saw their bill jump from $2,400 to $11,000.

Gathering the proper documentation may take 3-6 months, and FEMA wants this information 90-days before the renewal date.

If you haven't already contacted your flood insurance agent, you should do so right away.

The following is an excerpt from the Flood Insurance Manual outlining the documentation now required for annual renewal of flood insurance based upon floodproofing:  Floodproofing Insurance Renewal

Note:  The last step calls for annual inspection/certification by the City.  However, the City has no jurisdiction to enforce provisions of the Flood Insurance Manual, nor does it have the resources for such annual inspections.  Staff has been informed, that while this appears as one of the necessary steps, it's not actually being required for renewal. 

What's Happening

Why?

FEMA discovered many supposedly floodproofed buildings were still submitting flood insurance claims for relatively minor flood events which the floodproofing should have prevented.

It discovered that in many instances:

  • The original engineering either wasn't competent or wasn't performed
  • When the flood came, no one knew where the flood panels were located
  • The flood panels had warped in storage and no longer fit properly
  • Gaskets had deteriorated allowing water to pass along the panel edges
  • No backflow valve had been installed, causing sewerage to backup into the building through toilets and drains
  • After floodproofing had been installed, holes had been drilled though walls/floors for wiring or plumbing, allowing water to bypass the floodproofing measures and enter the building. 
What Now?

FEMA wants to have their own engineers review your engineer's work.  It needs 90 days to accomplish this review, hence their requirement the documentation be submitted 90 days prior to policy renewal.

What's the Problem?

During years past, much of the documentation (certificates, plans, photographs etc.) wasn't required for floodproofing inspections.  Hiring a professional Engineer was considered a sign of competency, and went unchallenged and unreviewed. 

In many instances, a building's exterior was properly floodproofed, but the need for a backflow valve was overlooked.  The pressure from flood waters pushed sewerage back through the system in reverse, filling otherwise floodproofed buildings with raw sewage - not only flooding, but contaminating the entire building. FEMA requires proof a backflow valve has been installed or the floodproofing credit will be cancelled.

In some cases, floodproofing was only required up to the flood level, known as the Base Flood Elevation (BFE).  Current rules require floodproofing to an additional one-foot above BFE.

Unless floodproofing was accomplished during the past three years and received a final inspection by the City's Building Department, most owners won't have the level of documentation required today.  Here's a link to a floodproofing checklist used by City staff, that's handy to see what's required: Floodproofing Checklist

What do I do?

Contact the Engineer who originally designed the building's floodproofing measures.  Their name and contact information should be at the bottom of the FEMA Floodproofing Certificate.  If the Engineer isn't still in business, you'll need to contact another that deals with floodproofing (City staff can't recommend an Engineer).

Have the Engineer inspect the floodproofing to ensure it's adequate.  This may require the Engineer reverse-engineer existing floodproofing to ensure it'll perform correctly.  They'll also need to inspect the building's walls and floors to ensure no new openings have been created that will allow water to bypass the floodproofing measures.  They'll also check to see that backflow valve is present.

Plans need to be drafted for the regular inspection and maintenance of the floodproofing measures, along with instructions and training of staff on how and when to install the floodproofing panels. These plans can be written by anyone.  See:  Guidelines for drafting Inspection, Maintenance & Implementation plans

Keep this documentation handy.  We're hearing this will be an annual requirement when your flood insurance policy comes up for renewal.

For more information on see our section on: Floodproofing

City Floodplain Administrator, Scott Fraser: 305-809-3810 sfraser@keywestcity.com