Federal Emergency Management Agency (FEMA) Home Elevation Policy Recs

"Federal Emergency Management Agency (FEMA) Home Elevation Policy Recommendations for Lower Plaquemines Parish, Louisiana,"

Grant McCall and Russell Greaves

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Federal Emergency Management Agency (FEMA)

Home Elevation Policy Recommendations for

Lower Plaquemines Parish, Louisiana

October 28th, 2024

Grant S. McCall, Ph.D.

Executive Director and Chief Research Scientist

Center for Human-Environmental Research

Associate Professor

Dept. of Anthropology

Tulane University

mccall@cherscience.org

Russell D. Greaves, Ph.D.

Director

Office of Contract Archeology

University of New Mexico

Research Associate

Center for Human-Environmental Research

rustygreaves@yahoo.com

Introduction

The purpose of this white paper is to summarize recent research conducted by the Center for Human-Environmental Research (CHER), published recently in the peer-reviewed journal Coastal Studies & Society (McCall et al. 2024); to propose policy recommendations for improving Federal Emergency Management Agency (FEMA) home elevation policies in Lower Plaquemines Parish and elsewhere across coastal Southeast Louisiana. In summary, our research finds that FEMA home elevation policies are having a serious negative impact on community wellbeing in Lower Plaquemines Parish and are responsible counterproductive effects that are actually increasing tropical storm vulnerability. We also find that current FEMA home elevation policies are ethically unfair, with their negative consequences inequitably concentrated among poor and minority populations. Regrettably, our findings lend credence to the increasingly widespread belief that FEMA home elevation policies are designed to put additional pressure on coastal community members and to further promote the depopulation of the coast via the extreme burdens that they impose.

Our policy recommendations include three main prongs: (1) an up-or-down home elevation grant application process that either results in the granting of sufficient funding for home elevation or a waiver of home elevation requirements for homeowners; and (2) an opt-out option for homeowners who, for various legitimate reasons, do not which to be participate in the FEMA home elevation grant application process.

As it stands, FEMA policies were obviously designed according to a “one-size-fits-all” approach aimed at more affluent coastal communities with higher home values, more resources in terms of cash, home equity, and credit, and very different vectors of natural disaster risk. Only by utilizing finer-grained, community-level information about Lower Plaquemines Parish (and communities like it) can FEMA develop effective methods for reducing both the financial and human risks posed by inevitable future major tropical storms; and only by treating community residents fairly can it induce residents to buy into such policies willingly. The looming threats to human life and wealth—as well as FEMA’s reputation and credibility as a federal agency—are too great to ignore.

Failures of Current FEMA Home Elevation Policies in Lower Plaquemines Parish

The adoption of current home elevation policies in Lower Plaquemines Parish took place in 2021—coinciding with major impacts from Hurricane Ida—through a combination of actions by FEMA and the Plaquemines Parish Council. As reported independently by several current and former parish councilors, FEMA pressured the Plaquemines Parish Council into adopting parish ordinances reflecting the most recent updates to the Flood Insurance Rating Maps (FIRM) and the Advisory Base Flood Elevation (ABFE) values related to those maps. These values effectively tell homeowners the elevation levels recommended by FEMA in order to achieve a 1% annual flooding probability. Home elevation levels naturally affect flood insurance prices, which many residents have been content to live with for some time. The most impactful change occurred, however, when the parish council adopted ordinances mandating that both new structures and those being rebuilt following damage from tropical storms and other disasters be elevated above the current ABFE values.

The changes to Plaquemines Parish ordinance have had numerous wide-ranging negative impacts on local populations, particularly those at south end of the parish. The most significant negative impacts have resulted from the fact that home elevation is directly at odds with vernacular architectural traditions and cultural housing adaptations related to local economic, social, and environmental conditions. Housing in Lower Plaquemines Parish is characterized by the prevalent utilization of mobile homes and other modular housing. Our research found that about 75-80% of homes in communities including Empire, Buras, Bootheville, and Venice belong to some form of mobile/modular housing. The advantages of this strategy include the fact that such homes are inexpensive, and this provides homeowners with flexibility in (re)locating homes onto new properties given a range of personal economic and social contingencies. Homeowners can cope with extended periods of low income by remaining in low-cost homes mobile homes (that they own), often relying on extensive networks of social support in both maintaining and repairing their homes and in otherwise getting by. During personal economic downturns or crises, homeowners may cope by selling homes and properties and finding less expensive residential options. During upturns and periods of economic windfall, such as the successful start of a new shrimping season, homeowners often make moves and upgrades to improve their living conditions. Finally, mobile/modular homes provide are a useful strategy for minimizing the costs of damage from the frequent tropical storms and other disaster events.

FEMA home elevation policies and their linkage with Plaquemines Parish ordinance clearly interfere with the set of residential strategies to the point that they often effectively freeze homeowners in their current housing context. It obviously makes buying and selling homes and properties much more difficult—frequently to the point of impossibility—and they effectively prevent individuals from moving new mobile homes onto their properties. This forces homeowners into more expensive and less flexible residential options, which are often problematic for other reasons discussed further below. For fishing community residents, who are frequently already on the edge of economic failure, the expenses and lost opportunities resulting from home elevation requirements may be straw that breaks the camel’s back.

The freezing of residential options for Lower Plaquemines Parish residents also has a range of negative social consequences for individuals living in problematic homes. For example, we noted examples of individuals dealing with drug addiction unable to leave homes inhabited by drug dealers and other addicts; victims of domestic abuse unable to homes occupied by their abusers; families with small children in mobile home parks inhabited by violent neighbors; etc. Home elevation requirements pose often insurmountable barriers to individuals attempting to deal with such problematic living situations by moving elsewhere—often via the tactic of moving a trailer onto family-owned land.

Additionally, Lower Plaquemines Parish residents universally recognize that, on the one hand, the risk of flooding within the levee system is very low, while, on the other hand, home elevation dramatically increases the risk of wind damage, which is the prevalent form of damage from tropical storms. Finally, elderly individuals, disabled individuals, and parents with small children are all deterred from living in elevated homes by the necessity of climbing stairs and the risk of falling.

Why Lower Plaquemines Parish Residents Don’t Apply for FEMA Home Elevation Grants

Many policymakers feel that adequate funding resources have been provided for Lower Plaquemines Parish residents in terms of FEMA home elevation grant programs, and they blame residents for not applying for such grants. Realistically, there are two connected reasons why Lower Plaquemines Parish residents are not inclined to apply for home elevation grants. First, in a specific sense, virtually no local residents have succeeded in getting FEMA home elevation grants. No one that we spoke to knew of any Lower Plaquemines Parish residents that had received a home elevation grant, though many knew of individuals who had been rejected. FEMA grant applications are a time-consuming and invasive process, and the overwhelming consensus was that it is a waste of time.

Second, in a wider sense, most residents have negative personal histories of interactions with FEMA and virtually all residents know of friends, neighbors, family members, etc., who have had extremely negative outcomes in applying for disaster assistance following previous tropical storms. For example, one individual that we spoke to had sought FEMA assistance after experiencing damage to their property during Hurricane Ida in 2021 and had been rejected after six appeals, as well as interventions from their congressman and the governor’s office. Local residents familiar with this case unanimously recognized that the FEMA process for assessing property damage and deciding the claim were inherently unfair, and that it was hard to imagine how such unfairness could result from anything other than retaliation for complaints. Cases such as this have a chilling effect and have resulted in a widespread belief that (1) there is little hope for fair treatment in any bureaucratic dealing with FEMA and (2) that it is better to avoid being known to FEMA through things like grant applications and risk being the subject of increased scrutiny and possible retaliation.

Many Lower Plaquemines Parish residents believe that their communities have been treated unfairly by FEMA since Hurricane Katrina in 2005, after which the agency suffered tremendous reputational damage due to the inadequacies of its response in Lower Plaquemines Parish and elsewhere across Southeast Louisiana. This perspective includes the belief that FEMA has adopted a “never again” attitude to prospect of future disasters at the scale of Hurricane Katrina and, in blaming local populations for failing to make adequate preparations, it has been seeking to use its policies and responses to disasters to pressure residents to relocate elsewhere. Hence, most residents avoid any interactions with FEMA whenever possible.

Finally, many Lower Plaquemines Parish residents have issues with language barrier, literacy, immigration status, and criminal records that prevent them from seeking grant from FEMA. Many minority residents recognize that their communities have been the targets of systemic racism and discrimination for more than a century and are disinclined to involve themselves in government programs for that reason. More generally, there are simply many who seek to avoid interactions with any government agency including FEMA and who value their privacy more than any of the potential benefits of FEMA assistance, simply wanting to be left alone.

Policy Proposal #1: Home Elevation Waivers for Denied FEMA Grant Applications

Our first proposal is the alteration of FEMA home elevation grant application procedures in the following way: If homeowners apply for FEMA home elevation grants in good faith and are denied (for whatever reason), then they should receive a waiver of FEMA home elevation requirements and Plaquemines Parish Council home elevation ordinance. On the one hand, this would be a compelling inducement for residents to actually apply for FEMA home elevation grants, which very seldom happens at present. The cost of this inducement would be low, since most Lower Plaquemines Parish residents are currently doing their best evade and/or strategically ignore home elevation requirements. Under this model, both successful and unsuccessful home elevation grant applications would benefit applicants. This model would thus level the playing field for Lower Plaquemines Parish residents, since the rejection of home elevation grant applications could no longer be used as a tool for pressuring residents into relocating nor could it reasonably be viewed that way.

This approach would also require some moderate changes in terms of the levels of FEMA home elevation grant fundings, which at present require a burdensome amount of cost sharing from grant-receiving homeowners. While some amount of cost sharing with homeowners may be reasonable, the current levels are unrealistic particularly for owners of homes with low property values. For example, one homeowner that we spoke to who had considered applying for a FEMA home elevation grant told us that the total cost of home elevation for their property would be around $260,000 and that the FEMA home elevation grant would have provided around $200,000. This would have left a difference of $60,000, which is far more than the homeowner could have afforded and which likely exceeds the combined value of the home (a trailer valued at less than $20,000) and land combined. In short, even if this homeowner had applied successfully, they still could not have afforded to elevate their home; and so, they decided against applying. In this respect, FEMA should adjust the amount of cost shared by the homeowner according to the value of their property. For example, in the above case, if a cost share of 20% were required, that would amount to about $10,000-$15,000. In contrast, for a homeowner with a property value of $300,000, it would amount to a cost share of $60,000. In this way, more affluent homeowners with higher property values, home equity, cash resources, and borrowing options would be expected to pay more.

Policy Proposal #2: Benefit-Limited Home Elevation Waivers

Even if our first policy proposal is adopted, there are many Lower Plaquemines Parish residents who will never apply for FEMA home elevation grants under any circumstances—for the reasons listed above. For such individuals, we suggest the provision of home elevation requirement waivers (at both the FEMA and parish levels) with concomitant limitations on access to FEMA disaster assistance in the aftermath of future flooding disasters. This approach recognizes that there are many homeowners who would be very willing to accept a tradeoff in which the prospect of minimal FEMA disaster assistance in the event of flooding would be counterbalanced by a waiver of home elevation requirements. In this respect, many residents already do not expect significant FEMA disaster assistance and would happily trade the prospect of full FEMA disaster assistance for the waiver of home elevation requirements.

In our fieldwork in Lower Plaquemines Parish, we frequently heard residents say that some way of opting out of FEMA home elevation policies in exchange for limited disaster assistance would make their lives easier. Allowing residents to opt out would undermine the widespread belief that home elevation policies are an element of a broader governmental effort to depopulate the coast; and in doing so, they would improve trust in FEMA at the community level and improve housing options for homeowners.

Conclusion: Improving FEMA Policies and Community Engagement Approaches

To us, it is fairly evident that FEMA home elevation policies were not designed with Lower Plaquemines Parish in mind but rather more affluent coastal communities in places like the East or West Coast. In this regard, much of the breakdown in the application of these policies has to do with differences in property values, and dynamics of disaster risk as they relate to (1) the likelihood of catastrophic flooding and (2) the ability of homeowners to access cash and navigate bureaucracies in elevating their homes. An ethnographically informed view of Lower Plaquemines Parish would have revealed the inherent inability of residents to find resources to elevate their homes and the huge burden that home elevation requirements place on their daily lives in relation to long-established vernacular housing strategies.

In this respect, our study clearly shows the need for FEMA to take more locally informed, social scientifically based approaches in designing its flood policies. For one thing, this is true because current FEMA policies, such as those relating to home elevation in Lower Plaquemines Parish, are dangerously ineffective and are almost certainly headed for an existential-scale crisis for local homeowners and that will devastate the credibility and financial resources of FEMA. For another thing, current policies were clearly designed in relation to much more affluent coastal communities with more valuable homes, as well as residents with more financial resources and social capital to deal with major natural disasters (and influence FEMA policies). From an ethical standpoint, it is unfair and inequitable to apply such policies to poor and marginalized coastal communities in places like Lower Plaquemines Parish. Hence, in our opinion, such policies justifiably appear to Lower Plaquemines Parish community residents as an element of a broader effort to force their relocation away from the coast.

In a more general sense, FEMA cannot succeed without integrating fine-grained, community-level social scientific research—a strategy that will foster both more effective policies and enhanced vectors for outreach that promote community buy-in. Such an approach can also provide mechanisms for preventing potential retaliatory decision-making and in assuring community residents that their playing field is level. Fixing FEMA’s flood policies and its methods of developing those policies may seem like an expensive proposition, however, it pales in comparison to the potential financial catastrophes that from the combination of coastal populations forced to abandon their traditional cultural means of flood risk adaptation and without resources to adopt FEMA’s mandates. As warmer seas make tropical storms larger, more powerful, and more prone to rapid intensification, this is situation is clearly a ticking time bomb.