Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input

Background

Initial Impact on Agencies and Regulation

The Federal Flood Risk Management Standard (FFRMS) established under Executive Order 13690 significantly reshaped the manner in which federal agencies approached floodplain management and infrastructure development. It required agencies to incorporate climate-informed science when assessing floodplains for federal projects. This was a notable shift from relying solely on historical data, emphasizing instead a predictive and adaptive approach that considered future flood risks in light of climate change. Departments such as Housing and Urban Development (HUD) and the Federal Emergency Management Agency (FEMA) began modifying their regulatory frameworks to comply with this enhanced resilience strategy, integrating new flood risk assessments into their project planning processes.

Operational Adjustments and Planning

Agency operations across the executive branch experienced shifts as a result of this order. The directive led to the adoption of higher flood elevation standards for federally funded projects, which affected critical infrastructure planning. Agencies had to modify their strategies to ensure that newly planned or renovated structures were situated two to three feet above the base flood level, depending on whether they were deemed non-critical or critical. This impact extended to federal grants and loans for infrastructure projects, where compliance with FFRMS became a prerequisite for funding approval.

Community and Environmental Considerations

The order also incorporated social and environmental dimensions by emphasizing stakeholder involvement from state and local governments in its development and implementation phases. This collaborative approach was designed to ensure that policy was directly informed by those with local expertise and firsthand experiences of flood risk. Social policy adjustments included prioritizing the protection of natural floodplain functions and encouraging the use of nature-based solutions to increase flood resilience. This paradigm shift attempted to balance infrastructure development with ecological preservation, reflecting an integrated approach to disaster risk management.

Reason for Revocation

Policy Shift under the Trump Administration

The revocation of the 2015 executive order on August 15, 2017, by President Donald Trump can be seen as part of a broader ideological shift away from federal environmental and climate change policies embraced by the previous administration. The Trump administration adopted a deregulatory stance that prioritized economic growth and infrastructure development over environmental regulations that were viewed as burdensome. This shift was encapsulated in the rolling back of several Obama-era directives aimed at addressing climate change, reflecting a pivot towards policies that favored immediate economic gains over long-term environmental stewardship.

Regulatory Burden and Economic Development

A key rationale for the revocation was the belief that the 2015 flood risk standard introduced excessive regulatory burdens that stifled economic development and infrastructure projects. By raising the standards above the base flood elevation, the order was seen as demanding costly adjustments to building requirements, contributing to delays and increased expenses in federal infrastructure projects. The administration argued that these regulations impeded the Trump administration's goal of streamlining federal processes and promoting efficient project delivery.

Emphasis on State and Local Autonomy

Another reason behind the revocation was an ideological emphasis on reducing federal oversight in matters traditionally managed at the state and local levels. By rescinding the FFRMS, the administration promoted the idea that state and local governments should have more autonomy in deciding appropriate flood risk management measures within their jurisdictions, based on their unique geographic and climatic circumstances. This deregulatory approach aimed to enhance state flexibility and reduce the perceived top-down imposition of federal environmental standards.

Broader Context of Climate Policy Rollbacks

The revocation fit into a broader context where several policies addressing climate change were reversed. The Trump administration significantly reduced environmental regulatory constraints, part of its broader agenda to dismantle policies linked to the Obama-era climate initiatives. This included withdrawing from the Paris Agreement, revising the Clean Power Plan, and opening up protected lands for oil and gas exploration. Together, these actions signaled a substantial policy redirection focusing away from climate resilience in favor of traditional energy sectors and economic drivers.

Winners

Real Estate and Development Sectors

The revocation substantially benefited the real estate and infrastructure development sectors, as it lifted regulatory constraints seen as obstructive to building projects. By eliminating the requirement to build structures to the higher flood standards, developers faced fewer design and construction hurdles. This resulted in reductions in construction costs and shortened timelines for new projects, attracting more investment in areas previously deemed challenging due to stringent flood management practices.

Industrial and Manufacturing Sectors

Corporations with vested interests in rapid infrastructure and industrial expansion, such as large construction firms and manufacturing enterprises, stood to gain from the revocation. By lightening the policy framework governing federal infrastructure projects, companies such as Bechtel and AECOM could pursue projects with greater ease. The policy realignment was framed as creating a more business-friendly environment, enabling these sectors to thrive with reduced federal intervention and hence potentially larger profit margins.

Communities in High-Growth Regions

The decision particularly favored high-growth regions eager for new federal infrastructure investments, where more lenient floodplain management policies could potentially expedite development. Communities situated in economically burgeoning areas, especially those with strong ties to industries reliant on federal infrastructure, could attract more projects due to the relaxed regulatory landscape. It enabled regional authorities to capitalize swiftly on federal investments, supporting local economic growth and job creation.

Losers

Coastal and Flood-Prone Communities

The revocation posed significant challenges to communities located in coastal and flood-prone areas. By removing the requirement for using climate-informed data to guide infrastructure planning, these regions faced increased exposure to flooding risks, potentially compromising the long-term safety and resilience of their built environments. The lack of stringent federal standards heightened the susceptibility of these communities to future climate-related flood hazards.

Environmental and Conservation Groups

Environmental advocacy organizations publicly criticized the rollback, as they had pushed for stronger federal policies to guard against the impacts of climate change. The revocation undermined efforts to incorporate ecological considerations into infrastructure projects, frustrating groups like the Natural Resources Defense Council and the Sierra Club. These organizations argued that the decision neglected the role of natural floodplain functions and increased the likelihood of adverse environmental impacts from unmanaged development.

Public Health and Safety Advocates

Public health experts and safety advocates expressed concerns that the removal of the flood risk management standard eroded safeguards designed to protect human health and safety in the context of natural disasters. The original order had sought to mitigate flood risks to reduce the potential for loss of life and property, an objective compromised by the rollback. Without the holistic approach to flood risk embodied in the rescinded standard, communities could face increased health risks during flood events due to inadequate preparation and resilience measures.