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070_020_Update - D. Otto BW-12
STAFF UPDATE *et CITY COUNCIL MEETING: September 26,2013 PREPARED BY: Dianne Otto, Planning&Zoning Manager '� Biggert-Waters Flood Insurance Reform Act of 2012 (BW-12) Below is an excerpt from the Minutes of the City Council meeting of February 28,2013: Council, Officials and City Attorney Considerations& Comments • Mayor Buelterman explained the new impact of the FEMA flood insurance which increases the premium on second homes and investment properties. He would like to begin the process of working with the Planning Commission to develop ways that do not penalize property owners that might apply for variances. This would be a 25% increase in flood premiums annually until such time as it no longer subsidized by the federal government. Mr. Brown also has concerns with the cottages on the Island and how they might be affected. BW-12 background documents included with this Staff Update: A. Flood Insurance Reform Act of 2012: Impact of Changes to the NFIP(2 pages) B. Changes in the Flood Insurance Program: Preliminary Considerations for Rebuilding(4 pages) C. Summary of Contents: Biggert-Waters Flood Insurance Reform Act of 2012(5 pages) D. The Dawn of a New Day...Biggert Waters-12,part 1 (4 pages) E. Homeowner's Guide to Retrofitting(2 pages) Additional BW-12 resources are available on the internet. The full 64-page text of the Biggert-Waters Flood Insurance Reform Act of 2012 is available at: htt•://www.cadcon.com/•df/2012 HR4348 flood •ortion.•df. Excerpts from the Planning Commission Agenda and Minutes of April 16,2013: Develop ways to not penalize owners that apply for variances due to the Biggert-Waters Flood Insurance Reform Act of 2012 Mr. Parks Do we have any discussion on this? Mr. Bishop—I would like to make a motion, because of the significance and timeliness of this, that this Biggert- Waters Flood Insurance Reform Act of 2012 be tabled until our next meeting. Mr. Callahan—I would like to see it as a workshop. Mr. Parks — We could meet an hour early next month to start discussion. If we give it an hour in a workshop environment, it serves as a public hearing and it also gives us time to focus on this. Mr. Callahan—Did anybody else have any confusion as to what the Mayor has asked? Mr. Bishop Absolutely. Mr. Parks—Dianne, can we charge you with coming back with a clarification of what the Mayor would like from us? Ms. Otto—Yes. Mr. Parks - I would like a motion that we meet an hour early at the next meeting to discuss the Biggert-Waters Flood Insurance Reform Act. Mr. Bishop—So moved. Mr. Marion—Second. Mr. Parks—All those in favor,please signdy. [Vote was unanimous.] At the May 21,2013,Workshop... Attendees were: Mayor Jason Buelterman; Planning Commissioners Demery Bishop, Marianne Bramble, Rob Callahan, Tyler Marion, David McNaughton, and Monty Parks; and Dianne Otto. (Current PC member Tom Borkowski was not sworn in until June 18.) The Mayor explained his intent for the Planning Commission's task. BW-12 was discussed. Tyler Marion volunteered to report back with what other jurisdictions were doing. It was decided to invite Jimmy Brown to the next workshop to provide information about repetitive loss properties. Based on page 2 of Flood Insurance Reform Act of 2012: Impact of Changes to the NFIP, it was decided that a Community Rating System (CRS) activity would be worked on by the group to achieve additional credits toward the city's CRS rating. The group decided to meet next on Tuesday, July 16 at 6:00 pm. The July 16, 2013, Workshop was cancelled a few hours prior to 6:00 pm primarily because the Mayor and Jimmy Brown were unable to attend. Review Attachment 1 (3 pages)—5 emails exchanged August 13th regarding my request to Diane Schleicher that Jimmy Brown work with the interested Planning Commission members Review Attachment 2(2 pages)—6 emails exchanged August 28th and 29th 2 Dianne Otto From: Dianne Otto A-4 0.0 An ev. Sent: Tuesday, August 13, 2013 4:03 PM 3 pages / To: Jimmy C. Brown Cc: Diane Schleicher 5 e rr,p, I 5) Subject: FW: Planning Commission members &Community Rating System credits Attachments: CRS Manual PPI Committee.pdf; PC members 6.6.13.xls Jimmy—Attached is the contact info for the PC members. Dianne K. Otto, CFM City of Tybee Island Planning & Zoning Manager phone 912.472.5031 fax 912.786.9539 From: Diane Schleicher Sent: Tuesday, August 13, 2013 3:22 PM To: Jimmy C. Brown Cc: Skip Sasser; Mayor Hotmail; Dianne Otto; Monty Parks (mparks @helpendhunger.org) Subject: FW: Planning Commission members &Community Rating System credits Jimmy, My understanding from Step I of this CRS Manual is that you need to establish a PPI committee to work on updating the CRS credits.The planning commissioners are willing to assist you by serving on this task.Their names are as follows: • Tyler Marion • Rob Callahan • Marianne Bramble • David McNaughton • Monty Parks • Demery Bishop • Tom Borkowski (recent addition) Please continue your hard work on the CRS updates to improve the city's ratings.The planning commission members have already publicly expressed their willingness to assist at one of their meetings. Please work with their individual schedules to schedule future meetings perhaps in the late afternoon for their input.They are a great resource. Thanks, Diane P.S. Dianne Otto has all of their contact information if you don't have it. From: Dianne Otto Sent: Tuesday, August 13, 2013 2:26 PM To: Diane Schleicher Subject: RE: Planning Commission members &Community Rating System credits Diane, Like all groups, some folks have jobs and other don't. I just learned from Monty today that he quit working a few weeks ago so his schedule has changed. The PC members that attended the May 21St group meeting were: Tyler 1 Marion, Rob Callahan, Marianne Bramble, David McNaughton, Monty Parks, and Demery Bishop. Tom Borkowski had not yet been appointed. The meeting times could be decided between Jimmy and the people that are working with him. The Mayor wouldn't need to attend. My request that Jimmy head the effort is based on him being Tybee's CRS Coordinator. We just discussed this. I'll get a report ready for City Council about the direction the Planning Commission went with BW-12. Dianne K. Otto, CFM City of Tybee Island Planning &Zoning Manager phone 912.472.5031 fax 912.786.9539 From: Diane Schleicher Sent: Tuesday, August 13, 2013 1:28 PM To: Dianne Otto Subject: RE: Planning Commission members &Community Rating System credits Dianne, Is there any way that this group can meet earlier than 6 pm? Could they meeting at 3:30 or 4 pm in the afternoon?This would be better for yours,Jimmy's and Mayor Buelterman? Thanks, Diane From: Dianne Otto Sent: Tuesday, August 13, 2013 1:13 PM To: Diane Schleicher Subject: Planning Commission members &Community Rating System credits Diane, This will be a timeline explanation of a request for help with a group of Planning Commissioners that want to help with the CRS program. On June 28th Jimmy Brown and I attended the "Community Rating System Changes to the New Manual Workshop" in Savannah. The training was by Sue Hopfensperger. She is the ISO Specialist that comes to Tybee and she determines how many credits the city receives for various CRS activities. I choose to get involved with the CRS program to the extent it involves this department. I am required to provide the records to show compliance with FEMA's and Tybee's regulations for new construction and substantial improvements, copies of Elevation Certificates, updated ordinances, etc. Because of the Biggert-Waters Flood Insurance Reform Act of 2012, the Mayor and Council had directed the Planning Commission to identify ways to assist residents with the increasing premiums for flood insurance. The Planning Commission immediately understood the importance of the CRS program as a means to receiving discounted flood insurance rates for home and business owners. Partly their understanding was due to the discussions of the 1-foot freeboard variance for the house that was built too low and the potential impact granting of the variance would have on Tybee's CRS Class 7 rating. Several members of the PC offered to assist with an activity that would entitle Tybee to additional CRS credits. Two meetings have been held. At one meeting the group and I met with the Mayor, and at a separate meeting PC Chair Monty Parks and I met with Jimmy Brown at 4:30 pm so he could give Monty an overview of the CRS program. The next group meeting was scheduled. Jimmy Brown and the Mayor were invited. Jimmy said he 2 could not attend the 6 pm meeting and he gave me paperwork for an Open Space Preservation activity which he suggested the group work on. The day of the scheduled meeting the Mayor emailed the group that he couldn't attend, and the Chairman called me to cancel the meeting late that afternoon. The group has since been inactive. At the June 28th workshop Sue explained many CRS activities, including the Program for Public Information. Attached are pages from the CRS Manual about it. I am emailing to request Jimmy Brown take the reins with the PC members that are willing to help with CRS activities. Whether the group works on documenting Open Space Preservation, a Program for Public Information, and/or other CRS activities, could Jimmy coordinate the necessary communications and meetings? Sincerely, Dianne K. Otto, CFM City of Tybee Island Planning & Zoning Manager phone 912.472.5031 fax 912.786.9539 3 Dianne Otto From: Dianne Otto II Z, Sent: Monday, September 09, 2013 5:52 PM 0.Gh m 2 I"� To: 'Monty Parks' ( 2. p p J eS/ Subject: FW: FEMA (.4 em Q, IS) Attachments: FW: Planning Commission members &Community Rating System credits Monty— Please review the highlighted emails below and the earlier emails that are attached. I am mighty confused by Jimmy Brown's response that the interested Planning Commission members are not going to work on an activity (or activities)that would result in credits toward Tybee's CRS rating. I have to give an update to the Mayor and City Council on September 26th, so it's important I get to an understanding of the plan going forward. What is going on? Dianne K. Otto, CFM City of Tybee Island Planning &Zoning Manager phone 912.472.5031 fax 912.786.9539 From: Diane Schleicher Sent: Thursday, August 29, 2013 4:35 PM To: Jimmy Brown External Cc: Dianne Otto; Mayor Hotmail; Jimmy C. Brown; Dianne Otto Subject: RE: FEMA Jimmy, Thanks for the update. Thanks, Diane From: Jimmy Brown [mailto jcbrown31328@ gmail.com] Sent: Thursday, August 29, 2013 4:28 PM To: Diane Schleicher Cc: Dianne Otto; Mayor Hotmail; Jimmy C. Brown; Dianne Otto Subject: Re: FEMA Diane, I met with PC Chairman Monty Parks last week And understood the PC had been requested by Council to look into how the Bigger/Waters Act would effect Tybee Island and to contact other communities nothing involves the PC with anything having to do with CRS Points, Thanks JB On Aug 29, 2013, at 4:12 PM, Diane Schleicher<dschleicher@n,cityoftybee.org>wrote: Dianne, The second meeting is fine, as planned. Thanks, Diane From: Tybeelady [mailto:tvbeelady(abellsouth.net] Sent: Thursday, August 29, 2013 3:30 PM To: Diane Schleicher Cc: Mayor Hotmail; Jimmy C. Brown; Dianne Otto Subject: RE: FW: FEMA Dianne- II can report at the second CC meeting in September about the discussions that resulted in the C members identifying they want to work on a CRS activity to cam more credits toward Tybee's CRS, -lass. If you want the report at the first meeting, let me know. Jimmy has the list of repetitve loss properties. The PC isn't addressing those. Dianne Otto Sent from my Samsung smartphone on AT&T Original message Subject:FW: FEMA From:Diane Schleicher<dschleicher@a,cityoftybee.org> To:Dianne Otto <Dotto@cityoftybee.org> Cc:Mayor Hotmail <buelterman@hotmail.com>,"Jimmy C. Brown" <JCBrown@a,cityoftybee.org> Dianne, Are you ready to report to the mayor and city council regarding the planning commission's work on FEMA? Please see Mayor 8uelterman's email below. Thanks, Diane From: Jason Buelterman [mailto:buelterman @hotmail.com] Sent: Wednesday, August 28, 2013 1:37 PM To: Diane Schleicher Subject: FEMA can you ask jimmy/dianne to give me an update on the work of TEMA and the planning commission re flood insurance. i am particularly interested in any work being done to identify repetitive loss properties and what we can do to address these. thanks. -jason This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed.If you are not the named addressee you should not disseminate,distribute or copy this e-mail.Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of The City of Tybee Island.The recipient should check this email and any attachments for the presence of viruses.The City of Tybee Island accepts no liability for any damage caused by any virus transmitted by this email.City of Tybee Island P.O.Box 2749 Tybee Island,GA 31328 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed.If you are not the named addressee you should not disseminate,distribute or copy this e-mail.Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of The City of Tybee Island.The recipient should check this email and any attachments for the presence of viruses.The City of Tybee Island accepts no liability for any damage caused by any virus transmitted by this email.City of Tybee Island P.O.Box 2749 Tybee Island,GA 31328 2 2 . • - rt Flood Insurance Reform Act of 2012 #c4Ha sS Impact of changes to the NFU) Note: This Fact Sheet deals specifically with Sections 205 and 207 of the Act. In 2012, the U.S. Congress passed the Flood Insurance Reform Act of 2012 which calls on the Federal Emergency Management Agency (FEMA), and other agencies, to make a number of changes to the way the NFIP is run. As the law is implemented, some of these changes have already occurred, and others will be implemented in the coming months. Key provisions of the legislation will require the NFIP to raise rates to reflect true flood risk, make the program more financially stable, and change how Flood Insurance Rate Map (FIRM) updates impact policyholders. The changes will mean premium rate increases for some—but not all -- policyholders over time. Background: In 1968, Congress created the National Flood Insurance Program (NFIP). Since most homeowners' insurance policies did not cover flood, property owners who experienced a flood often found themselves financially devastated and unable to rebuild. The NFIP was formed to fill that gap. To ensure the program did not take on unnecessary risks, one of the key requirements to participate in the program was that communities had to adopt standards for new construction and development. Pre-existing homes and businesses, though, could remain as they were. Owners of many of these older properties could obtain insurance at lower, subsidized, rates that did not reflect the property's real risk. In addition, as the initial flood risk identified by the NFIP has been updated over the years, many homes and businesses in areas where the revised risk was determined to be higher have also received discounted rates. This "Grandfathering" approach prevented rate increases for existing properties when the flood risk in their area increased. Fast forward 45 years, flood risks continue and the costs and consequences of flooding are increasing dramatically. In 2012, Congress passed legislation to make the National Flood Insurance Program more sustainable and financially sound over the long term. What this means: The new law eliminates some artificially low rates and discounts which are no longer sustainable. Most flood insurance rates will reflect full risk, and flood insurance rates will rise on some policies. Actions such as buying or selling a property, or allowing a policy to lapse, can trigger rate changes. You should talk to your insurance agent about how changes may affect your property and flood insurance policy. There are investments you and your community can make to reduce the impact of rate changes. And FEMA can help communities lower flood risk and flood insurance premiums. What is Changing Now? Most rates for most properties will more accurately reflect risk. Subsidized rates for non- primary/secondary residences are being phased out now. Subsidized rates for other classes of properties will be eliminated over time, beginning in late 2013. There are several actions which can March 2013 1 Federal Emergency Management Agency trigger a rate change, and not everyone will be affected. It's important to know the distinctions and actions to avoid, or to take, to lessen the impacts. Not everyone will be affected immediately by the new law—only 20 percent of NFIP policies receive subsidies. Talk to your agent about how rate changes could affect your policy. • Owners of non-primary/secondary residences in a Special Flood Hazard Area (SFHA) will see 25 percent increase annually until rates reflect true risk— began January 1, 2013. • Owners of property which has experienced severe or repeated flooding will see 25 percent rate increase annually until rates reflect true risk— beginning October 1, 2013. • Owners of business properties in a Special Flood Hazard Area will see 25 percent rate increase annually until rates reflect true risk-- beginning October 1, 2013. Owners of primary residences in SFHAs will be able to keep their subsidized rates unless or until: • You sell your property; • You allow your policy to lapse; • You suffer severe, repeated, flood losses; or • You purchase a new policy. Grandfathering Changes Expected in 2014 The Act calls for a phase-out of discounts, including grandfathered rates, and a move to risk-based rates for most properties when the community adopts a new Flood Insurance Rate Map. So if you live in a community that adopts a new, updated Flood Insurance Rate Map (FIRM), discounts—including grandfathered rates --will be phased out. This will happen gradually, with new rates increasing by 20% per year for five years. Implementation is anticipated in 2014. What Can Be Done to Lower Costs? For home owners and business owners: • Talk to your insurance agent about your insurance options. • You'll probably need an Elevation Certificate to determine your correct rate. • Higher deductibles might lower your premium. • Consider remodeling or rebuilding. • Building or rebuilding higher will lower your risk and could reduce your premium. • Consider adding vents to your foundation or using breakaway walls. • Talk with local officials about community-wide mitigation steps. For community officials: • Consider joining the Community Rating System (CRS) or increasing your CRS activities to lower premiums for residents. • Talk to your state about grants. FEMA issues grants to states which can distribute the funds to communities to help with mitigation and rebuilding. March 2013 2 • r • Changes in the Flood Insurance Program �. Preliminary Cons idera Lions for Rebuilding : FEMA Question: How has the flood insurance program changed and what does it mean to me? Answer: On July 6, 2012, a law took effect that made significant reforms to the National Flood Insurance Program(NFIP). Among other things, this law requires FEMA to take immediate steps to eliminate a variety of existing flood insurance subsidies. Under the new law, flood insurance premium rates on many properties in special flood hazard areas will increase. The new rates will reflect the full flood risk of an insured building and some insurance subsidies and discounts will be phased-out and eventually eliminated. Rates on almost all buildings that are, or will be, in special flood hazard areas will be revised over time to reflect full flood risks. Based on various conditions set forth in the law, subsidies and grandfathered rates will be eliminated for most properties in the future. Subsidies will be phased out for the following types of properties: non-primary residences, severe repetitive loss properties, business properties, and properties that have incurred flood- related damages where claims payments exceed the fair market value of the property. Policy rates will also increase based on one or all of the following circumstances: • After a change of ownership; • After there is a lapse in insurance coverage; • When a new or revised flood insurance rate map is issued; or • If there is substantial damage or improvement to a building. Q: How are flood insurance premiums changing under the new law and who will it impact? A: Starting January 1,2013,premium rates for subsidized non-primary residences will begin increasing. Rates will increase 25%per year until they reflect the full risk-rate. Later in 2013, there will be premium rate increases for additional categories of subsidized properties, including business properties, substantially damaged or improved properties, severe repetitive loss properties,and any property that has incurred flood-related damages where claim payments exceed the fair market value of the property. Rates for these additional categories of properties will phase in at a rate of 25%per year until they reflect full risk rates. Additionally, in late 2013, FEMA will begin to apply full risk rates to policies written for newly- purchased property. Beginning in 2014, premium rates for other properties, including non-subsidized properties, will increase as new or revised flood insurance rate maps become effective and full risk rates are phased in for these properties. These premium rate increases will include properties in areas that have received new or revised flood insurance rate maps since July 6, 2012 (the date of enactment Early Considerations for Rebuilding Changes in the Flood Insurance Program r;= E Prelini.tnary Considerations for Rebuilding �� FEMA of the new law). Additionally, even if you build to minimum standards today, you will be subject to significant rate increases upon remapping if your flood risk changes in the future. Q: What is a subsidized policy? A: A subsidized policy is one that does not pay the full actuarial rate and is not reflective of the true risk of flood to that property. Homes located in a high-risk flood zone (i.e., zones beginning with an"A"or"V") and built before the first flood insurance rate map became effective, and that have not been substantially damaged or improved, may currently be receiving subsidized flood insurance premium rates. Talk to your insurance agent for help determining your specific situation, or for more information check the FEMA Map Service Center to view a Map showing which zones your property may be located in at www.msc.fema.gov. Q: What determines my flood risk? A: Flood risk is unique to each structure and depends upon factors such as the elevation of the property relative to predicted flood levels,the construction style of the building, and the flood risk zone. FEMA publishes flood hazard maps that show predicted flood levels and flood risk zones based on historical climate information and the best available science. Some common examples of Special Flood Hazard Areas include coastal floodplains, floodplains along major rivers, and areas subject to flooding from ponding in low lying areas. FEMA provides flood risk information to communities to adopt into their ordinances. Your community permitting official will help inform you of your community's current building standard. However, as discussed below, risk changes over time and building higher than your community's minimum requirements could result in lower flood insurance premiums and reduced flood risk. Q: How might my flood risk change or how has it already changed? A: Risk changes over time as conditions in the community change. Physical changes can affect how much water reaches flooding sources, how far the water spreads when floods occur, or the manner in which buildings and infrastructure are exposed to a flooding source. Much of the risk analysis depends on historical data and on the potential severity of flooding over time. As newer data are collected (particularly when severe, rare events occur), the expected chance or severity of flooding derived by analyzing these data changes. The scientific methods and technology used to analyze and map flood risk also continue to improve and may affect predicted flood hazard levels and floodplain boundaries. Over the past few years, FEMA has been restudying areas of the New Jersey and New York coastlines in order to update the currently effective Flood Insurance Rate Maps (FIRMs)to reflect changes to the physical, climatological, and scientific baseline that have occurred since Early Considerations for Rebuilding Changes in the Flood Insurance Program * FEMA Preliminary Considerations far Rebuilding; the prior map updates. These updated maps were set to be delivered to state and local officials in mid-2013. Since existing FIRMs for these areas were developed more than 25 years ago, and because updated FIRMs are yet to be finalized, it is vital to provide near-term Advisory Base Flood Elevations (ABFEs)to support reconstruction efforts in the near term. Therefore, FEMA is accelerating the flood risk mapping process in coastal New Jersey and New York to provide communities with advisory base flood elevations. This information is intended to help communities and property owners make informed decisions about rebuilding their homes and businesses. Ultimately, new maps will be developed that incorporate this advisory data. This may result in new, higher flood elevations or a new, higher risk flood zone designation. These flood elevations and flood risk zones affect the minimum building requirements in the communities and the flood insurance rates charged. ABFEs will be available to communities in the following areas: • New Jersey Counties: Atlantic, Bergen,Burlington,Cape May,Essex,Hudson,Middlesex, Monmouth,Ocean, and Union. • New York Counties: Bronx,Kings,New York,Richmond, Queens, and Westchester. For more information on updated flood mapping, visit www.Region2Coastal.com. Q: How can I save money on flood insurance? A: Save money on flood insurance by reducing your flood risk. Flood insurance premiums are based on flood risk. Therefore as flood risk increases, flood insurance premiums also increase. Home and business owners whose properties have been flooded must make important decisions about repairing, rebuilding, or relocating their building. One choice would be to repair or rebuild to current standards. However, if advisory base flood elevations indicate that elevations have changed, or if other factors in the future cause the flood elevations to rise, these home and business owners would be missing out on a significant opportunity to mitigate their future flood risk and thereby lower their future flood insurance premiums. One specific way for you to reduce future losses and your premium is to raise your building above the minimum required elevation standards or to floodproof your non-residential building. Flood insurance premiums are lower for buildings in high-risk areas that are elevated above minimum requirements, so rebuilding higher provides immediate flood insurance benefits. Generally,the higher a building is elevated above flood levels,the lower the cost of flood insurance. Additionally, depending on where you live, other ways to reduce premiums could include adding vents to enclosures, installing breakaway walls, or relocating your structure further from the flood source if possible. Flood zone designations can also change as flood risk changes. The flood zone that is designated for a structure can dictate the construction methods required to receive reduced flood insurance rates. For example, newly-constructed or substantially improved structures in V-zones must be Early Considerations for Rebuilding Changes: in the Flood Insurance Program ==: Prelim- nary Considerations for Rebuilding - EMA elevated on post,piers, or pilings. Because zone designations can change, FEMA recommends that those living near existing V zones consider rebuilding using posts, piers, or pilings. As new maps are developed, it is possible that structures not previously located within a special flood hazard area will be designated as such, and will therefore be required to obtain flood insurance. Under the new law, a new flood insurance policy may not be subsidized and, therefore, the owner will pay full risk rates. Residents, business owners, and community leaders should take a close look at their current flood risks and consider how those risks might change in the future. Because insurance costs will increase with rising flood risk and hazards, keeping insurance costs in check will mean being more proactive in reducing flood risk and going beyond mere compliance with federal minimum floodplain management requirements. Adopting higher standards and building back stronger and safer are key strategies for reducing the cost of flood insurance. To learn how to build safer and stronger and potentially decrease your flood insurance premiums, visit: www.fema.gov/building- science/hurricane-sandy-building-science-activities-resources. Q: Does FEMA have any programs that can help me reduce my risk and save money on flood insurance? A: Yes, there are three FEMA programs that may directly or indirectly result in flood insurance discounts to policyholders: FEMA provides hazard mitigation grants to states for activities such as structure elevation, property acquisition, and floodproofing. When completed, these activities can reduce or eliminate risk, which may result in lower flood insurance rates. To learn more about Hazard Mitigation grants visit www.fema..ov/hazard-miti.ation-assistance. The Community Rating System (CRS) offers insurance premium discounts(up to 45%)for individuals in communities implementing floodplain management practices that exceed the minimum requirements of the NFIP. By implementing CRS floodplain management best practices, flood losses are reduced,public safety is enhanced, and the cost of flood insurance is decreased. To learn more about CRS visit http://www.fema.gov/national-flood-insurance program/community-rating-system. Current NFIP flood insurance policyholders in high-risk areas also known as Special Flood Hazard Areas (SFHAs), might get up to $30,000 to help pay the costs to bring their home or business into compliance with their community's floodplain ordinance if their structure has been declared substantially damaged from a flooding event. This insurance coverage is known as Increased Cost of Compliance and can help pay the cost of floodproofmg, elevation, relocation, or demolition. In some cases, ICC funds can be used as a non-federal cost share for other FEMA grants. Each of these options will reduce risk, which could result in lower flood insurance rates. Early Considerations for Rebuilding a. ( SPQ9es) Summary of Contents Biggert-Waters Flood Insurance Reform Act of 2012 H.R. 4348 Conference Report Title III (Pages 521-576) Signed by the President July 6, 2012 (compiled by ASFPM Vice Chair Bill Nechamen and Merrie Inderfurth,Washington Liaison—using Congressional committee Section-by-Section) in addition to bill language. The authority of the National Flood Insurance Program(NFIP)is extended for 5 years until September 30, 2017. The bill contains many reforms and changes,many of which are already generating questions as to intent, interpretation and implementation. While a summary is helpful,reading the actual bill text is recommended. Flood Insurance Removes subsidized rates(pre-FIRM rates)for the following classes of structures and allows rates to increase by 25%per year until actuarial rates are achieved: The effective date is July 1, 2012. • Any residential property that is not the primary residence of an individual • Any severe repetitive loss property • Any property that has incurred flood related damages that cumulatively exceed the fair market value of the property • Any business property • Any property that after the date of the Bill has incurred substantial damage or has experienced "substantial improvement exceeding 30 percent of the fair market value of the property. • Any new policy or lapsed policy, or any policy for a newly purchased property. • Any policy for which the owner has refused a FEMA mitigation offer under HMGP,or for a repetitive loss property or severe repetitive loss property. o Severe Repetitive Loss means four or more claims payments of over$5,000 or two claims that exceed the value of the property. Increases the limit for annual rate increases within any risk classification of structures from 10 percent to 20 percent. Effective date is July 1, 2012. Defines Severe Repetitive Loss properties for single family residences as 4 or more claims, each for more than$5,000 and cumulatively more than$20,000. For multi-family residences,the Director may provide a definition by regulation. Allows for premium payments either annually or in more frequent installations. Places limits on a bank's force placement of flood insurance. Forced placed insurance would be cancelled and the premiums refunded upon proof of a borrower's existing flood insurance coverage. 1 When flood maps change, a property that has higher rates as a result of a new map shall have the new rates phased in over a five-year period at 20%per year. .Premium rate adjustments due to map changes take effect on the effective date of the new map. Lender penalties for non-compliance with mandatory flood insurance purchase requirements is increased from$350 to$2000 per violation, and the limit of fines for any lending institution over a calendar year is removed. It was $100,000. Minimum annual deductibles on claims are changed to$1500 for coverage up to $100,000 and$2000 for coverage over$100,000 for pre-FIRM properties, and$1,000 and$1,250 for below and above$100,000 coverage for post-FIRM properties. Rates must be set to cover the average historical loss year, including catastrophic loss years, in accordance with generally accepted actuarial principles. (That would also increase rates since the increase in flood damages has meant that rates do not cover the historical average loss year.) Requires FEMA to establish a National Flood Insurance Reserve Fund of at least one percent of the total potential loss exposure. This fund would be built by 7.5%of the reserve ratio required each year. Allows FEMA to report to Congress if such goals cannot be met and to explain the reasons. Requires a ten-year repayment plan for the current insurance fund debt and also requires a report and repayment plan whenever FEMA has to borrow funds to pay NFIP claims.. Clarifies that private flood insurance may satisfy flood insurance coverage requirements if it meets certain standards.. Allows state sponsored nonbinding mediation of flood insurance claims disputes, and would require NFIP representatives to participate. Amends the Real Estate Settlement Procedures Act(RESPA)to require explanation of the availability of flood insurance under the NFIP or through private insurance for properties both in and out of Standard Flood Hazard Areas (SFHAs). Establishes reporting requirements associated with reimbursement of expenses for Write Your Own (WYO)insurance companies. Directs the FEMA Administrator to develop a methodology for calculating expense reimbursement within 180 days and to issue a rule within 12 months. Establishes a process involving the National Oceanographic and Atmospheric Administration(NOAA)to allocate tropical storm and hurricane damages between wind and water damage. (This is Subtitle B of Title III and is entitled"Alternative Loss Allocation". This is derived from previously introduced legislation known as"The Coastal Act". It's provisions are found on pages 576-585.) Mapping Establishes a Technical Mapping Advisory Council with membership coming from a wide range of professions, including federal agencies and state and local mapping partners. The Council would advise 2 FEMA on improving accuracy, on standards that should be adopted for flood maps, data and map maintenance and on funding needs and strategy. . It would also develop recommendations within 1 year for future conditions mapping, including impacts of sea level rise and future development on flood risk. FEMA is required to incorporate such recommendations into the ongoing review and updating of flood maps. Establishes an on-going National Flood Mapping Program. Requires that flood maps show 100-year and 500-year floodplains for all populated areas and areas of possible population growth, as well as areas with residual risk behind levees or below dams. Also requires mapping of the level of protection provided by flood control structures. Requires that new flood maps use the most accurate topography and elevation data available. Also requires acquisition of new ground elevation data when necessary. Requires development of flood data on a watershed basis. Requires FEMA to notify property owners when their properties are included in, or are removed from an area covered my mandatory insurance purchase requirements. Also requires notification of Senators and House Members whose States or Districts are affected by map changes. There is an authorization of$400,000,000 for flood mapping per year for fiscal years 2013—2017. (This is an authorization level—not to be confused with actual annual appropriations.) Formalizes a Scientific Resolution Panel to arbitrate when a community has received an unsatisfactory ruling with respect to an appeal of a revised flood insurance rate map. Appeals must be based on technical or scientific data. Removes limitations on state contributions to updated flood mapping. (Previously,there was a limit of a 50% state contribution to the costs of new flood maps. This has resulted in some states in states developing mapping data but FEMA being unable to use it to produce new maps.) Requires a study on federal interagency coordination of flood mapping, including collection and utilization of data among all governmental users. Mitigation Programs Consolidates NFIP funded mitigation programs (Repetitive Flood Claims, Severe Repetitive Loss Properties,Flood Mitigation Assistance)into a single program. The combined National Flood Mitigation Fund is to be funded at $90 million per year. (While the old Flood Mitigation Assistance and pilot Severe Repetitive Loss program were funded at up to $40 million per year each and the Repetitive Flood Claims program at up to $10 million,the SRL program has never been fully utilized in part due to its complexity. The new program simplifies and combines the three previous programs and includes the following: Allows the required Flood Mitigation Plan to be part of a community's multi-hazard mitigation plan. Removes beach nourishment as an allowed mitigation activity. Adds elevation,relocation or floodproofing of utilities as allowed mitigation activities. 3 Adds demolition and rebuild as an allowed mitigation activity. Specifically notes the capacity for"direct"grants if the Administrator, after consulting with the State and community, determines that neither has the capacity to manage the mitigation grant. Caps the use of mitigation grant funds for state mitigation plan development at $50,000 and at$25,000 for a community. Provides for denial of grant funds if not obligated(paid out)in 5 years. (This is due to Congressional concern about unobligated balances.) Specifically restates 2004 Reform bill provision prohibiting offsetting collections to fund these mitigation programs. Restructures federal share requirement: Up to 100%for severe repetitive loss structures. (4+Claims of over$5000 or 2+claims exceeding value of structure) Up to 90% for repetitive loss structures. (2 claims over 10 years averaging at least 25%of value of structure) Up to 75% for other approved mitigation activities. Levees Establishes a Flood Protection Structure Accreditation Task Force in cooperation with the Corps of Engineers. The Task Force is charged with better aligning the information collected by the Corps of Engineers' Inspection of Completed Works Program with FEMA's flood protection structure accreditation requirements. The Task Force must develop a process that allows data collected for either purpose to be used interchangeably, and to allow data collected by the Corps of Engineers under the Completed Works Program to be used to satisfy the FEMA accreditation requirements. (This is not meant to reduce the level of public safety and flood control provided by accredited levees. However the Task Force is charged with considering changes to the information collected by the Corps of Engineers and the FEMA flood protection accreditation requirements.) FEMA and the Corps of Engineers must implement the measures developed by the Task Force within one year and complete implementation within two years. Allows for flood insurance premiums to reflect premiums in fully protected areas in communities that are deemed to have made adequate progress in the reconstruction or improvement of a flood protection system. Flood In Progress Determinations FEMA is required to develop a process for determining when a flood event has commenced for the purpose of flood insurance coverage. (Generally a new policy becomes active in 30 days unless purchased as part of a real estate closing. Due to recent long lasting floods,particularly in the Mississippi and Missouri basins, where flooding can begin upstream more than a month before downstream areas 4 flood, there has been confusion as to the meaning of"flood in progress"as related to coverage under newly purchased flood insurance policies.) Studies. An assortment of studies are required including: • Analysis of increasing the maximum residential and commercial structures, including the availability in the private marketplace of flood insurance in amounts that exceed current NFIP coverage limits. • Annual program financial reports, including efforts to purchase substantially damaged properties and detailed analyses of the nature of losses. • A GAO report on Pre-FIRM structures,including length of ownership, income of owners, comparison of flood losses to those of post-FIRM structures,the cost of subsidies to pre-FIRM structures, and options for eliminating subsidies. • A GAO report on the three largest contractors FEMA uses to administer the NFIP. • A study by the National Academy of Sciences on graduated risk behind levees. • A separate FEMA and GAO study of reinsurance and privatization of the NFIP. • A GAO study on business interruption and additional living expenses coverage. • A FEMA study of amending the legislation to use national recognized building codes as part of the floodplain management criteria. • A FEMA—National Academy of Sciences study of encouraging maintenance of flood insurance and methods for establishing an affordability framework for flood insurance, including targeted assistance. • A Federal Insurance Office study of the current market for natural catastrophe insurance in the United States, including issues of affordability. Building Code Enforcement Allows use of Community Development Block Grant funds for increasing staffing and training for local building code enforcement, and to provide flood hazard and flood insurance information to residents. 5 b. (LI p cl e , 0Ik'i1 „; r'- Ir �� - The Dawn ___„: _ ____ __ ___ __ _ _____,____ ___ _____„,..._ _ . , _..........;,1 of A New Dy . . . BIGGERT-WATERS-12 PART 1 3.,,.; ice,c • . a 4 +�_ • _,.__ Y endy Lathrop and Barton Some of the changes to come out of BW-12 Crattie did an excellent have already occurred and many more are Me h,# job describing the Biggert- yet to come—those being implemented in the 1-,ic1 vC 1!°'.'" � �' Waters Flood Insurance coming months of this calendar year:Probably glcod Insurance Reform Act ::4� 1 4> .�,b] "� F Reform Act of 2012 the biggest attention getter,at least as it (what I lovingly refer to concerns the American public at large,is the `I' y µ ?' as BW-12) and its impact on land surveyors in rate increases in the National Flood Insurance - ~" � .0"l the Vol 9,No 8 edition of The American Surveyor. Program(NFIP)—rate increases which will be y� ---' I am not totally sure that anyone realizes yet the implemented pursuant to the BW-12 legislation full impact of this legislation not only to survey- and that are intended to more closely reflect the ors,but lenders,home owners,business owners, "true flood risk"of the structure being insured. insurance agents and anyone remotely involved The rate increases will affect some,but not all,of in the flood insurance business. the NFIP policyholders. Top:When a community As different parts of BW-12 are implemented locates recreational facili- by FEMA,surveyors are going to see a rise in New Rate Increases on the Horizon for Many ties along the river,it helps requests for Elevation Certificates.Consequently, Flood Insurance Policy Holders of Older Buildings when they are designed it is important that surveyors not only stay According to FEMA,"the new law encourages to flood. The Augusta informed about how BW-12 affects flood insur- Program financial stability by eliminating some Riverfront Amphitheatre ance premiums,but also know the mitigation artificially low rates and discounts."Except during flooding along the options that home and business owners can do for mainly primary residential homes,flood Savannah River,July 2013. to offset non-compliant structures located in a insurance premiums for structures built before Photo by Tent z Wane, high-risk Special Flood Hazard Areas (SFHAs). the community's first Flood Insurance Rate Map By Terri L Turner, AICP, CFV Displayed with permission• The American Surveyor•Vol. 10 No.9•Copyright 2013 Cheves Media•www.Amerisurv.com )1 — - -- — (known as pre-FIRM)that currently property will see 25 percent rate could be very profound.For that reason, receive subsidized premiums will now increase annually until rates reflect a number of experts and organizations move toward full risk rates."Actions true flood risk-beginning October have encouraged damaged home and such as buying a[pre-FIRM]property, 1,2013. business owners to"rebuild safer,higher allowing a policy to lapse,or purchasing • (It is important to note that each and stronger" a new policy can trigger rate changes. property's risk is different.Some More intense and frequent storm Rates for most properties will more policyholders may reach their true risk events are increasing the risk to future accurately reflect risk.Subsidized rates rate after a couple years of increases, flood damages in a lot of areas.For that for non-primary/secondary[pre-FIRM] while other policyholder increases may reason higher flood ordinance standards, residences are being phased out now go beyond five years to get to the full stronger building codes,and Advisory Subsidized rates for certain other risk rate required by the new law.) Base Flood Elevations(ABFEs) after classes of[pre-FIRM]properties will be flood disaster events are becoming the eliminated over time,beginning in late Primary[pre-FIRM]residences norm,rather than the exception. [October]2013." in SFHAs will be able to keep their "Not everyone will be affected subsidized rates unless or until: Digging out of a Financial Hole immediately by the new law-only Of course,these rate increases will have 20 percent of NFIP policies receive • The property is sold(subsidized a plus side,as well,hopefully bringing subsidies",FEMA reports. rates cannot be assigned to the new the NFIP out of the 25 billion dollar hole Those property owners affected by owner); (post-Sandy)it has gotten itself into since rate increases include: • The policy lapses; Katrina,and making the NFIP more • The structure suffers severe or sustainable and financially stable over time. • Owners of subsidized policies on repeated flood losses;or Push-back to the BW-12 legislation [pre-FIRM]non-primary/secondary • A new policy is purchased. has already begun in a number of residences in a Special Flood Hazard states and with a number of pieces of Area(SFHA)will see 25 percent New and renewal policies within these legislation,specifically aimed at the increases annually until rates reflect classifications on or after the enactment affordability issue.As recently as April true risk-began January 1,2013. of BW-12 will be issued at full-risk rates of this year,organizations like the About 400,000 non-primary homes starting October 1,2013. Association of State Floodplain will move toward actuarial rates. Further,the changes to grandfathering Managers (ASFPM)have weighed in on • Owners of subsidized policies on rates (for those that had been affected the affordability issue(floods.org/index. [pre-FIRM]properties that have by map changes) are expected to be asp?menulD�51#Flood_Insurance_ experienced severe or repeated implemented in late 2014 and will be Affordability),but it's anybody's guess flooding or that have been substan- phased out over 5 years,with a 200/0 right now what Congress will do over tially improved will see 25 percent per year increase to reach full risk rates, the next few months.Not knowing rate increase annually until rates according to FEMA. whether any of these Ouster's-last-stand- reflect true risk-beginning October (Reference:bw12_sec-205 207_ type legislative mechanisms will work,it 1,2013. factsheet4_132013[1].pdf;bw_time- is best to prepare now for the inevitabili- • Owners of subsidized policies on line_table_04172013[1].pdf;and h-gac. ties of the future. [pre-FIRM]business/non-residential corn/community/water/time/fast/meetings/ properties in a Special Flood Hazard fast_2013-04-17_presentation.pdf) Homeowners and Businesses Owners Area(SFHA)will see 25 percent As of January 1,2013,Preferred Risk Can Prepare Now for the New Rates rate increases annually until rates Policies (PRPs)issued on properties Extensive media coverage of events reflect true flood risk-beginning newly mapped into high-risk areas like Katrina,Rita,Irene,and Sandy October 1,2013. may continue beyond the previously has hopefully taught the American • Owners of subsidized policies designated two-year period until FEMA public that Mother Nature does not on[pre-FIRM]severe repetitive completes its analysis and implements a read flood maps and that flooding can loss properties consisting of 1-4 revised premium structure put in place and will occur outside of the specified residences will see 25 percent rate with BW-12,but these are expected to be "line on the flood map".Additionally, increases annually until rates reflect completely eliminated,along with grand- testimonials from these same flood true flood risk-beginning October fathering,by late 2014.Meanwhile, events have hopefully dispelled the 1,2013. FEMA will be increasing PRP Extension notion that if a home or structure • Owners of any[pre-FIRM]property premiums by 20%,starting October 1, does flood that flood insurance and that has incurred flood-related dam- 2013. (floodsmart.gov) community support agencies will"make age in which the cumulative For policy holders in areas affected them whole again".Flooding is,and amounts of claims (payments) by recent storm and disaster events,the continues to be the nation's#1 natural exceeds the fair market value of the new flood insurance policy rate increases disaster with homeowners having a Displayed with permission• The American Surveyor•Vol.10 No.9•Copyright 2013 Cheves Media•www.Ameriunucom Under the Flood Insurance Reform Act of 2012,You Could Save More than $90,000 over 10 Years if You Build 3 Feet above Base Flood Elevation* PREMIUM AT 4 FEET BELOW PREMIUM AT PREMIUM AT 3 FEET ABOVE BASE FLOOD ELEVATION BASE FLOOD ELEVATION BASE FLOOD ELEVATION $9,500/year $1,410/year $427/year $95,000/10 years $14,100/10 years $4,270/10 years y r \ L_ 4aar '4;\ 7 og — --1 _mil= B F E Hp �� B F E BFE 's 5fil,IlSli1 l'ill1iliii c,c- crags-[cicll f chit.,Doi II1114icI, l:()1111:111'0.AI: (Iii.gir in?111r1(ll9'ali'r,4.) ir1111',SIIItiylc 1,711111),11114.'-tile■I} 'Ir?ll.Inn. ullln oil a Ita'clltcni aL'4 fe.ti f+cI[Po, ba;r iliitnl lilt*.flitln 1BFF};at RI},anti al 5 No alWM'BEE (Raiillc 11t'r 1 FM.\ finr.I 11,11I,41r: /11.11[1.[A.S_P4.rf[111.r 1,?O111,T11t'1111i:LraLIici1 alNIA :1.1t1'c,rl am a S1a14dlarrl Nal7Ullal 114.,[151[1'411r;11'ill'Prlrgralkk ig'P.EP1 :h.I1it1:IJ[ "A primary way to reduce or avoid future flood losses is to raise your building above the Base Flood Elevation(BFE) BASE FLOOD practices can be found at youtu.be/ V2Tw8nVRH1c. FEMA/NFIP's Build Back Safer and ELEVATION (BFE) • Third,flood mitigation techniques Stronger brochure after Hurricane Sandy. ><,r<w.4i. />enuinessip .r eyfema The elevation shown on the Hood should be explored.These methods brodaure_ewejnalpdf Insurance Rate Map(FIRM)for can include: sigh-risk flood zones("A"and"V„ Raising the structure above the 1-in-4 chance(or greater depending on Base Flood Elevation(BFE)—this the area) of flooding within the span of zones)indicates the water surface will reduce flood insurance a 30-year mortgage.Just a few inches of elevation resulting from a flood that premiums and potentially save water inside a structure can cost tens of has a 1 percent annual chance of 85 percent or more in the cost thousands of dollars in damage–damage equaling or exceeding that level in of a flood insurance policy and, a standard homeowners policy does not any given year subsequently,save thousands of cover.Yet,thousands of Americans have dollars over the life of a home lost their home,all of their possessions, or business.In many cases,the and their lifetime investment in the blink cost of elevating the structure of an eye,as a disastrous flood event • First, (and that's where the survey- will be saved in a few years occurs at their doorstep. ors come into play)an Elevation through reduced flood insurance According to Dennis Mileti,Professor Certificate needs to be secured for premiums (see the FEMA Emeritus at the University of Colorado the structure to assess the true flood illustration above). at Boulder where he served as the risk of the property and to deter- Adding flood openings to the Director of the Natural Hazards Center mine the correct flood insurance walls of the structure below the and as Chair of the Dept of Sociology, policy rate for the structure. Finished Floor Elevation(FFE) "People are more likely to take actions • Second,meeting building code It should be noted that flood if you show that those actions can cut requirements and following current openings are required not only their losses if something happens".With best practices will reduce potential by the NFIP,but also by the that in mind,home owners and business risk to future flood loss.Best national,state and local building owners should talk to their insurance practices involve building above codes,in any enclosed area, agent about how changes might affect code and can include elevation of below the base flood elevation their property and their flood insurance utilities such as hot water heaters, subject to flooding. policy.There is a lot that these property air conditioning units and furnaces. Flood openings/flood vents owners can do to be prepared: A great video on some of these best allow for flood waters to auto- Displayed with permission• The American Surveyor•Vol.10 No.9•Copyright 2013 Chews Media•www.Amerisurucom — . �' f _ 1 -'7 r- ! 1t /�64tj iJriibi#+** ►.d1�' I. �.�- �ly� •ice tilt!/ 4 Foundation flood vents,that allow for the _ automatic entry and exit of floodwaters, , - ° `�_—`' I' protect building foundations during a flood event;SmartVent Foundation Flood Vent—the only FEMA-accepted _ and ICC_ES Certified Flood Vent on the market today;www.smartvent.com. a • matically flow into and = out of enclosed areas and lessen the risk • of structural damage caused by the pressure of floodwaters on exterior walls during a flood event.If flood openings/flood vents are not present,the building's liability from miscalculating insurance,and Today's Surveyor in structural integrity is at risk and potentially non-compliant flood Relation to Bi is ert-Waters., the National Flood Insurance openings is eliminated with Program mandates that the risk SmartVents.Each SmartVent of collapse or failure must be has a label on it identifying the A special thanks is extended to Larry insured against. ICC-ES report number,the Larson,ASFPM,and Bruce Bender SmartVent foundation flood model number and the area of and Gary Heinrichs,ASFPM Flood vents are a great mitigation certified coverage—usually 200 Insurance Committee,who graciously (new construction and retrofit) square feet for each SmartVent provided technical editing for the BW- product that can lower flood flood opening. 12 information provided in this article. risk.In retrofit situations, Other mitigation techniques when a structure is not in can include: Terri L Turner,AICP, CFM, is compliance with flood opening Using breakaway walls the Development Administrator/ requirements,and SmartVents below the Finished Floor Floodplain Manager/Hazard Mitigation are installed,the makers of Elevation(F1'E)in V Zones Specialist for the City of Augusta SmartVent estimate an average (zones with velocities associ- (GA) Planning and Development 830/0 savings in flood insurance ated with flood waters) Department. Prior to coming to the premiums for property owners. For commercial structures, "Planning World", Terri spent 16 SmartVent also takes great floodproofing below the years working for civil engineering pride in being the only FEMA- Base Flood Elevation(BFE) and surveying firms and knows Accepted and ICC-ES Certified the importance of surveying to any Flood Vent nation-wide on the A property owner can either pay now development project.Terri is currently market today. in higher standards for new construc- also the Region 4 Director and the Tom Little,Vice President lion,mitigation techniques or retrofit No Adverse Impact (NAI) Committee of SmartVent states that the applications or pay later with increased Co-Chair of the Association of State "return on the investment for flood insurance premiums. Floodplan Managers(ASFPM). the install is experienced in less Next month,in part 2 of this Terri spends much of her free time than 2 years,so it becomes a"no article,we will explore Community touring the nation speaking on sound brainer"for the property owner Investments in Reducing Flood floodplain management, hazard to use our product." Insurance Premiums,the continuing mitigation, climate change adaptation, As an added bonus for problem with A Misinformed Public, and sustainabiity and resiliency surveyors, the elimination of especially when it comes to their flood initiatives for local governments. Displayed with permission• The American Surveyor•Vol.10 No.9•Copyright 2013 Cheves Media•wurw.Amerisurv.com 4o E ( 2 pages) U 1_ o ..„mimilitail.„. i' g ›- (--.1 4"1"1" --_.... 4 41 A Z:i 6: kan cz i w ( ) Cr) o N _ oF x,� f� .---i- , . 0,.,5 f24 co � , ,...,, E ,i( ,- t, ,�� �o w P 119, - , 0 i t 4J CO I-I-->= a c . 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