LIVINGSTON - The parish offices received a letter from FEMA - it wasn't favorable.
It said that the parish has to adjust several aspects of its disaster response process, or potentially lose FEMA grant funding, as well as access to flood insurance through the NFIP.
Director of Homeland Security and Emergency Preparedness Mark Harrell made the contents of the letter clear on May 23rd at ordinance committee, while the membership discussed a potential 'freeboard' addition to the parish's building code.
Harrell said that FEMA had 'slapped the parish on the wrist' for treatment of substantially damaged property, while also urging the committee to pass 'freeboard' as a part of appeasing FEMA and improving floodplain management.
'Freeboard' is a requirement that any new structure be built above base flood elevation (BFE) equal to the amount of the freeboard passed by the council. A one foot requirement was passed at the council's first June meeting.
Just a few weeks before, the parish had been informed they were removed from the 'Community Rating System' (CRS) - a cumulative point measurement which offers insurance discounts for residents inside a particular area, 5% per point.
Livingston Parish boasted a '9' rating and, according to FEMA worksheets on policy value with the discount, the parish loses $300,000 annually from the economy for loss of that rating.
The contents of the letter outline the results of a Community Assistance Visit (CAV), which are conducted regularly by floodplain management and insurance specialists.
The results of the CAV were outlined:
- Substantive program deficiencies and violations related to repair permits and substantial damage determinations during post-flood disaster recovery
- The Parish's Flood Damage Prevention Ordinance (FDPO) needs amending
- Further review is necessary concerning 27 sites of recent floodplain development
Harrell was aware of the deficiencies in the 'substantially damaged' assessment and permitting process. In a News interview on May 24th, Harrell said that the parish simply wasn't equipped to handle an event on the magnitude of the flood of 2016.
Harrell's proposal was to bring the permitting process in a post-disaster scenario to his office, and use state-level assistance through disaster response methods which would provide extra labor to administer inspections and file paperwork.
The new plan and process should be sufficient for FEMA to put the parish on even footing with FEMA again.
According to the FEMA letter, the parish submitted 123 sites in the 'substantial damage book,' and 220 sites in the condemnation book - for a total of 343 sites.
FEMA's challenge centers around those results.
"Based on available information from the 2016 flooding event, including NFIP policy and claims data, and home inspections related to FEMA's Individual Assistance program, we estimate the Parish should have conducted at least 4,000 substantial damage related inspections on structures in the 'Severe Flood Hazard Areas' (SFHA) with damages estimated to be more than 50 percent of their value," the letter said.
"An even larger number of structures would require repair permits," the letter explained.
Harrell said that the update to the FPDO and the parish's post-disaster inspection process will be sent to FEMA first for critique, before he presents it to the parish council for adoption as an ordinance.
According to FEMA, their relationship with communities to provide flood insurance is a trade. In return for insuring structures against a disaster, local authorities must 'adopt and enforce floodplain management regulations through a local FDPO which must meet or exceed the NFIP's minimum criteria.'
FEMA goes on to say that, to date, Livingston Parish residents and business have received $540,000,000 in NFIP claim payments. The letter then turns the other cheek and states that a failure to comply will jeopardize the availability of FEMA funds for grants - which Harrell specified to the parish council.
It also says that failure to comply will also jeopardize the availability of flood insurance.
The current audit is still in process, as the letter also requests permits and flood elevation certificates attached to 27 structures that were visited by the CAV team which were in severe flood hazard areas. Those records were due by Sunday, June 23rd (30 days after reception of the first letter).