Several letters have passed from FEMA's Region 6 office to the parish, and all of them cite a very specific passage.
An ordinance, on the books in Livingston Parish, is a key portion required for a community's participation in the National Flood Insurance Program (NFIP). Called a 'Flood Damage Prevention Ordinance' (FDPO), the law usually comes complete with recommendations - or requirements - courtesy of FEMA.
The more strict the FDPO, the more points earned for the Community Rating System (CRS), which is a tiered grading average that applies discounts to flood insurance premiums within a community. Livingston Parish was removed from the CRS in early 2019 for non-compliance, dropping from a '9' rating (5% discount) to out of the program.
Currently, in Chapter 115 called 'Floods' the Livingston Parish's FDPO states the following:
Residential construction. New construction and substantial improvement of any residential structure shall have the lowest floor (including basement), elevated to or above the base flood elevation.
Substantial improvement also goes the other way - namely, if a home was substantially damaged (over 50%) and repaired, part of the repair process would be a required elevation to the base flood elevation or higher.
Since FEMA's second letter, in May, to the parish, the organization has been fixated on their data that shows at least 4,000 homes were in Special Flood Hazard Areas (SFHA) during the Great Flood, and the parish should have inspected their damage.
The parish submitted roughly 343 inspections after the flood.
That inspection total, combined with FEMA's internal data, and multiplied by the parish's inability to produce both permits and flood elevation certificates for a large amount of homes in Livingston Parish pushed the federal organization to seek punitive measures - starting with CRS removal.
Eventually, it was determined that FEMA would not remove Livingston Parish from the NFIP, instead electing to send down a working delegation to go door-to-door with Director of Homeland Security and Emergency Preparedness Mark Harrell and his team to determine whether or not homes in SFHA areas would be interested in elevation.
The group will also be seeking out repair amounts and substantial damage determinations. The number that continues to be iterated, 4,000, is not set in stone. Should inspections and receipts prove that repairs were less than half of the value of the home (land is not included in the value) then those homes in SFHA will be offered elevation, but it will not be required.
Those homes which have substantial damage will be forced to elevate, per parish ordinance.
It should be noted that the ordinance was adopted by the parish, and is enforced by the parish.
Harrell said that FEMA was more interested in helping than hurting.
"We're just now getting funding for HMGP (Hazard Mitigation Grant Projects) three years later," Harrell explained. "If we have even just a few dozen houses that need elevation, FEMA will help us expedite funds.
"It helps homeowners swallow the pain."
HMGPs offer up to 100% funding for home elevations or acquisitions. The cities of Walker and Denham Springs, as well as the parish, have participated in the program, although funds are slow moving.
Harrell said that he wasn't sure when FEMA would come to Livingston Parish, as the organization is in the budgeting phase and no money is available for travel.
He did add, however, that the parish will be using this time to find new mitigation projects within the SFHA, to help with flood insurance costs and drainage.
Harrell also said that his department had taken control of disaster response, and a 2016 issue - where labor was short - will "not happen again," he said. Part of his corrective action plan, also submitted to FEMA, included a portion that would allow the parish to utilize state and federal assistance with labor in the wake of a disaster.
Both Denham Springs and Walker accepted help from FEMA for inspections and paperwork. The parish declined.