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-------- Original Message --------
John Hayes
Director
National Oceanic and Atmospheric Administration
National Weather Service
1325 East-West Highway
Silver Spring, Maryland 20910
3 September 2008
Dear Mr. Hayes:
Thank you for the substantive input by the office of NOAA's National Weather
Service (letter dated 22 August 2008).
On 8 August 2008, efforts were made to engage the Federal Emergency Management
Agency (FEMA), National Oceanic and Atmospheric Administration (NOAA), National
Weather Service (NWS) in a discussion that impacts every coastal community
in the United States. The focus issue was coastal development
challenges that have allowed direct waterfront construction under the classification
of a non-coastal high hazard area, ignoring FEMA National
Flood Insurance Program (NFIP) standards outlined in the guideline "Reducing Flood Losses through the International Code Series"
(FEMA Library) and restrictions in state building code associated with construction
in coastal high hazard areas.
--------------------------------
This exercise has demonstrated that flood zone classifications
encompass loopholes exploited for justification of permits granted for
non-conforming coastal construction projects. The problem is not exploitation
of flood zones (to support the business model of the insurance industry that
has recorded record profits in recent years), but adherence to state and
local building codes for construction in coastal high hazard areas, that
already exist.
See: Are Hurricanes Or Wall Street Losses
Driving Premium Increases? CNBC Didn't Like My Answer: Huffington Post,
3 September 2008.
FEMA has emphasized that this is the responsibility of states and municipalities.
Efforts are now underway to ensure that the financial burden caused
by any flood zone changes, will be met by full compensation by states and
municipalities.
--------------------------------
Though NOAA/NWS has emphasized that these problems fall under the auspices
of FEMA, tools to address risk analysis and mitigation discussions include
the NOAA Risk and Vulnerability Assessment Tool (RVAT),
the National Weather Service program StormReady!
and FEMA Hurricane Preparedness resource materials.
The Saffir-Simpson Hurricane Scale (SSHS) and historical tracks encompass
the reference point for (1) the potential risk associated with severe weather,
and (2) construction standards for all direct waterfront development that
is subject to direct impact by these forces. Non-conforming NFIP construction
in coastal high hazard areas is now a focus point for risk analysis and mitigation
analysis in every U.S. coastal community.
Variables include:
1. Recognition of the challenge presented by new construction
of direct waterfront properties in Coastal High Hazard Areas, in the context
of the threat presented by storms and hurricanes (Categories: 1-5).
Hurricane Classification
|
| Strength |
Wind Speed
(kt) |
Wind Speed
(mph) |
Pressure
(millibars) |
Pressure
(inches Hg) |
Storm Surge
(ft.) |
| Category 1 |
65-82
kt |
74-95
mph |
>980
mb |
>28.94 in.
|
4-5
ft.
|
| Category 2 |
83-95
kt |
96-110
mph |
965-979
mb |
28.50-28.91
in.
|
6-8
ft.
|
| Category 3 |
96-113
kt |
111-130
mph |
945-964
mb |
27.91-28.47
in.
|
9-12
ft.
|
| Category 4 |
114-135
kt |
131-155
mph |
920-944
mb |
27.17-27.88
in.
|
13-18
ft.
|
| Category 5 |
>135
kt |
>155
mph |
<919 mb |
<27.16 in.
|
>18
ft.
|
| Tropical Cyclone Classification |
| Tropical Depression |
20-34 kt or 23-39 mph |
| Tropical Storm |
35-64 kt or 40-73 mph |
| Hurricane |
65+ kt or 74+ mph |
2. Risk analysis of the non conforming structures by certified engineers
that can provide projections for potential impact in the event of a hurricane
, that includes surge and wave impact, beach erosion, compromise of the substructures
and displacement of waves to surrounding properties.
3. Remedy that includes full modifications to the non-conforming
structure, that will minimize damage to surrounding properties and coastal
community.
In deepest appreciation, for your assistance in support of community and
family prepareness during the 2008 Hurricane Season. Please forward
any additional supportive materials to my attention, for inclusion on the
HRI Legal Resource and Assistance Center Environmental Protection
web site.
S.M.Apatow
cc: Conrad Lautenbacher, Director, National Oceanic and Atmospheric
Administration
Ralph Swisher, Project Officer, FEMA (Former Director of the Community and
Family Preparedness Program)
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