School of Geography and the Environment MSc Elective Essay

Millvale, PA and the Case for Universal Flood Insurance in the United States

Andrew Tabas

______

Abstract:

The National Flood Insurance Program in the United States is in billions of dollars of debt and does not provide adequate flood insurance. The case of Millvale, Pennsylvania shows gaps in the program and community efforts to fill them. The National Flood Insurance Program should be replaced with a universal flood insurance program to solve these problems.

Introduction

The U.S. National Flood Insurance Program (NFIP) is drowning. The program reached

$30.4 billion in debt in September 2017 (Lehmann 2018). The NFIP’s debt decreased after

Congress forgave $16 billion, but climbed again to $20.5 billion in July 2018 (Lehmann 2018).

The debt increases with each major catastrophe. Meanwhile, there is uncertainty about the future of the program, demonstrated by Congress’s passage of multiple short-term NFIP extensions in

2018 (FEMA 2018a).

Why is this problem occurring? Well-developed insurance programs balance risk and solidarity (Lehtonen and Liukko 2012). Risk is “the possibility of loss” (OED 2018a).

Likelihood and consequences determine risk (Perseus 2012). Solidarity is “the fact...of being perfectly united...in interests” (OED 2018b). Insurance programs bring people together as a community to share the burden of flooding. The NFIP is not financially sound because it has not struck the correct balance between risk and solidarity. Because of this imbalance, the NFIP fails to fulfill Arnell’s three “roles” of insurance: reimbursement, cost-sharing, and mitigation (Arnell

2000).

The Federal Emergency Management Agency (FEMA) argues that it is time “for

Congress to take bold steps to reduce the complexity of the program and strengthen the NFIP’s financial framework” (FEMA 2018a). I propose a radical, bold change to flood insurance in the

U.S.: universal flood insurance (UFI).

The transition to UFI would make it possible for the NFIP to match premiums to payouts.

UFI would be able to fulfill Arnell’s three requirements more effectively than the current model.

It would also imply a change in the way that the U.S. addresses solidarity. People tend to underestimate risk, which leads them to choose not to purchase flood insurance (Kousky and

Kunreuther 2009; Kousky and Michel-Kerjan 2015; Michel-Kerjan and Kunreuther 2011). UFI would guarantee that people who need insurance have it. In addition, the current system of borrowing and debt forgiveness means that taxpayers are already subsidizing the NFIP. To analyze the NFIP and the potential for UFI, I examine key features and history of the current program, the case study of Millvale, PA, and theoretical arguments. I then lay out the full proposal for UFI and end by addressing political considerations.

Methodology

To test the effectiveness of the NFIP, I use a “holistic single-case design” case study (Yin

2003). I examine the single case of Millvale, Pennsylvania (PA) to show the gaps in the NFIP’s fulfillment of Arnell’s three “roles” for flood insurance (Arnell 2000). Newspaper articles, government records and publications, and informal personal correspondence with stakeholders from government and nonprofit organizations and local businesses inform my analysis.

My approach is similar to that of Kousky and Kunreuther (2009), who use a case study of fluvial flooding in St. Louis, Missouri to identify issues in the NFIP.

Figure 1: Sign marking the entrance to Millvale (source: taken for this paper).

Key Features of the NFIP

The NFIP includes the following features (Sherman and Kousky 2018; NRC 2015;

FEMA 2018g):

• 100-year floodplain – The area with a 1% chance of flooding.

• Flood Insurance Rate Map (FIRM) - A map that shows flood risk.

• Pre-FIRM Properties – Buildings constructed before FEMA mapped the area.

• Grandfathering – Discounted rates for properties built before the implementation of the

NFIP.

• Community Rating System (CRS): A program that lowers NFIP premiums for

communities that undertake mitigation efforts.

History of the NFIP

The NFIP is a U.S. federal program that provides flood insurance to households and businesses. The U.S. created the NFIP in 1968 after Hurricane Betsy caused severe damage in

Louisiana in 1965 (Michel-Kerjan 2010). Betsy was therefore a “window of opportunity”

(Meijerink 2006). Under the NFIP, flood insurance is offered by the government with the cooperation of private companies (Horn et al. 2018). The program enables homeowners to purchase flood insurance, with the recognition that it would not be able to cover extreme catastrophes (Michel-Kerjan 2010).

The NFIP has had many amendments and changes since its creation (Burby 2001). In

1969, the U.S. amended the NFIP to allow the use of preliminary maps while waiting for the development of detailed, expensive FIRMs. The Flood Disaster Protection Act of 1973 added new regulations to increase community participation. These regulations included restrictions on federal aid and mortgages in areas that had not joined the program. The regulations successfully increased participation by over 500%. The 1982 Coastal Barrier Resources Act established areas in which new development would not be insured by the NFIP (FEMA 2018b). The 1994

National Flood Insurance Reform Act added several programs that encouraged mitigation by states, communities, and homeowners to reduce the risk of flood damage. The 2004 Flood

Insurance Reform Act attempted to tackle the cycle of properties being damaged and repaired multiple times. The Act provided funds for states to purchase “severe repetitive loss properties”

(Govtrack 2004).

The next round of reforms, in 2012, fell victim to politics. The Biggert-Waters Flood

Insurance Reform Act, led by the bipartisan team of Illinois Republican Judy Biggert and

California Democrat Maxine Waters, would have increased rates and removed grandfathering in order to make the NFIP more financially sound (NRC 2015). Biggert-Waters was passed in July

2012 (State of Kansas). The act’s substantial rate increases, however, were politically dangerous, especially after Hurricane Sandy struck New York in October 2012. In 2013, Waters supported an amendment to prevent rate increases (Waters 2013). Then, in 2014, she supported the

Homeowners Flood Insurance Affordability Act (HFIAA), which stopped the Biggert-Waters price increases and allowed grandfathered areas to continue to exist (Waters 2014; NRC 2015).

The HFIAA was sponsored by New York Republican Michael Grimm (Congress.gov 2014).

Grimm, whose constituents on Staten Island suffered from Hurricane Sandy, was in office only a short time before he was arrested for tax issues (Goldenberg 2014; Flegenheimer 2018).

However, his brief term in office was enough time for him to lead – and gain Waters’s support for – the undoing of Biggert-Waters. One positive result of the 2012 and 2014 reforms is that pre-FIRM properties’ premiums are increasing towards the premiums of other properties

(Sherman and Kousky 2018).

Debates about the future of the NFIP continued. The program was set to expire on

September 30, 2017. Instead of agreeing to a plan to extend the program for five years, legislators used short-term extensions to finance the program. On several occasions, delayed short-term extensions caused gaps in funding for short periods of time (Govtrack 2018). Recent extensions pushed the end date to 30 November 2018, 7 December 2018, 21 December 2018, and 31 May 2019 (FEMA 2018a).

Meanwhile, NFIP premiums have been inadequate to meet its payouts, causing the program to go into debt. Congress forgave $16 billion in 2017. The NFIP therefore uses tax revenue to pay out flood claims (Lehmann 2018). In other words, the U.S. currently has a flood insurance system in which every taxpayer subsidizes flood insurance. Major problems persist with the NFIP that affect its collection of premiums. First, grandfathering allows some households to pay low rates. Second, premiums are not high enough to cover costs and do not match risk (Burby 2001; Paskal 2011). Third, not enough people purchase insurance (Burby 2001). Fourth, repeat insurance for 30,000 “severe repetitive loss properties” drains NFIP resources (NRDC 2017; Moore and Scata 2017). Fifth, premiums should be high enough to discourage building in the floodplain, but this is not the current case (Burby

2001).

Current proposals, like gradual reforms in the past, would not solve the problem. The 21st

Century Flood Reform Act would put the NFIP further into debt by being too lenient toward grandfathered properties (Govtrack 2017). Michel-Kerjan and Kunreuther’s (2011) proposal for mandatory insurance in the floodplain with higher premiums and Kousky and Kunreuther’s

(2009) proposal for mandatory long-term insurance in the floodplain would both be a large burden for homeowners in the floodplain. The former would still require government spending on vouchers. Katz’s (2017) proposal for private flood insurance would lean too heavily toward risk management and too far away from solidarity, hurting the poorest and most vulnerable.

NRDC’s (2017) proposal to increase buyouts is a step in the right direction but would not address the NFIP’s broader problems.

Flood Insurance in Millvale, PA

Millvale is a borough in Allegheny County, Pennsylvania (PA). It has a mixture of businesses that mark its history as a working-class town and newer establishments that demonstrate the beginning of its gentrification. Girty’s Run flows through the town, including under some buildings, and into the Allegheny River. Flooding occurs when heavy rains on the hillsides above Millvale sends water coursing through Girty’s Run and through the town (pers. comm. 12/2018). The town’s website provides information on flood sirens and the NFIP

(Millvale 2018a; Millvale 2018b). Millvale’s first FIRM was created in 1979 (FEMA 2018h).

Any houses built after 1979 are “Post-FIRM buildings,” which means that they have height requirements for their lowest floors (FEMA 2016b). Millvale’s current flood map became effective on September 26, 2014 (FEMA 2018h).

Figure 2: Sections of Girty’s Run from upstream (left) to downstream (right) show structures

created to contain the river (source: taken for this paper).

Millvale has experienced six floods severe enough to warrant federal disaster declarations

(FEMA 2012). Notable recent floods occurred in 2004, 2007, and 2018 (City Paper 2008;

KDKA 2018). Millvale has 43 “NFIP-recognized repetitive loss properties” but does not have any “severe repetitive loss properties” (FEMA 2012). Millvale has 113 NFIP policies (FEMA

2018c). It is not yet a part of the CRS (pers. comm. 14/12/2018; FEMA 2016a). Millvale’s small size, relatively frequent flooding, and active flood risk management operations make it an ideal case study. The case shows gaps in the NFIP’s ability to fulfill the three roles of flood insurance

(Arnell 2000) and shows the ways in which the community fills these gaps. The following map, provided by the Southwestern Pennsylvania Commission (SPC), shows flood risk zones in Millvale:

Figure 3: Flood zones in Millvale, PA (Source: SPC 2018).

Arnell’s first “role” for flood insurance is “reimbursement.” In Millvale, the NFIP provides reimbursement after a flood but decreases its payouts to account for depreciation. Its payouts do not cover the cost of rebuilding (pers. comm. 12/2018). Arnell identifies this problem as “indemnity cover.” In addition, sanitizing existing structures after a flood can cost tens of thousands of dollars (pers. comm. 12/2018).

Arnell’s second “role” is cost spreading. While some businesses are required to purchase flood insurance because of mortgages, businesses on the same street without mortgages are not required to purchase flood insurance (pers. comm. 12/2018). The result is that too few policies are in effect, leading the NFIP to increase premiums to regain its losses. One business owner, after being notified of a 25% premium increase, was concerned that the higher price would be unaffordable (pers. comm. 12/2018). Meanwhile, actions by rich communities upstream can increase flooding in poor communities downstream (City Paper 2008). It is important to begin to address this discrepancy and to spread costs.

Arnell’s third “role” is mitigation: flood insurance should “encourage actions...to reduce exposure to flood loss.” While the NFIP requires communities to complete basic mitigation efforts to join the program, it has not been the driver of recent mitigation efforts. The NFIP has not funded mitigation in Millvale (pers. comm. 18/12/2018). Instead, mitigation efforts are developed by the the community, which goes to the U.S. Army Corps of Engineers (USACE),

FEMA, the Pennsylvania Emergency Management Agency, the Department of Community and

Economic Development, or PENNVEST for funding (Benzio 2013; pers. comm. 12/2018). Local groups include the Girty’s Run Watershed Association, Millvale PIVOT, the Millvale Borough

Development Corporation, and New Sun Rising (Benzio 2013; pers. comm. 12/2018). Local mitigation efforts include the construction of rain gardens in Millvale, negotiation with upstream communities to install green infrastructure to trap storm water, actions by the local fire department to reduce damage during floods, efforts by the church to clean up after floods, and volunteer programs to count and map outfalls into Girty’s Run (pers. comm. 12/2018). Upstream negotiations are important because, by the time water reaches Millvale, it is too late to contain all of it (pers. comm. 11/12/2018). There are some upstream bioswales, small areas to catch stormwater, but there need to be more (pers. comm. 20/12/2018). Figure 4: Rain garden behind the Millvale Community Library (Source: taken for this paper).

Meanwhile, USACE has conducted many projects to reduce flooding from Girty’s Run. While past improvement plans have focused on engineered solutions, stream management in

Pennsylvania is moving toward stormwater management and green infrastructure to control streamflow (pers. comm. 11/11/2018). Additional impetus for stormwater management comes from PA Act 167, which has runoff capture requirements for new buildings (pers. comm.

21/12/2018). USACE is working on floodproofing, and in some cases moving, houses (pers. comm. 6/12/2018). USACE’s budget includes millions of dollars for flood control and work on

Mississippi River tributaries (which include Pittsburgh’s rivers) (USACE 2018).

Figure 5: Girty’s Run channel improvement project General Plan from 1975, showing a focus on

engineered solutions at that time (Source: USACE 1975).

Mitigation also includes buyouts. FEMA has only purchased two properties in Millvale, and one of them was government-owned (FEMA 2018d). These properties were easy decisions for buyouts because they were had experienced fire damage. In general, Millvale does advocate for buyouts because it loses tax revenue when people leave the area (pers. comm. 12/2018).

Figure 6: FEMA buyout site, now a rain garden (Source: taken for this paper). UFI would provide a larger pot for reimbursement, more policyholders for cost-sharing, and more funding for mitigation. It would reduce the likelihood (through mitigation) and consequences (through reimbursement) of floods, therefore reducing risk. It would relieve problems in the floodplain, where premiums are increasing and payouts are too low.

UFI would also increase solidarity in Millvale and the surrounding areas. Uphill residents benefit from downhill restaurants and businesses. All are part of a community, so all would share in the burden of floods. The program could also encourage upstream communities to build more green infrastructure. In addition, UFI would support community rebuilding efforts.

At the same time, UFI would be a tough sell. Thirty dollars per year, for example, is a lot for some people (pers. comm. 20/12/2018). In addition, one business owner who had flood insurance said that it would be unfair to require people outside of the floodplain to support his business (pers. comm. 12/2018). In order to address these concerns, FEMA would need to emphasize that tax payers are currently subsidizing the NFIP, so the new system would just bring this subsidization into the open while providing coverage for everyone. FEMA would also need to provide discounted premiums for low-income households.

Universal Flood Insurance in Theory: Risk and Solidarity

Theoretical arguments show that flood insurance is best off when it is mandatory and universal. Insurance schemes balance risk and solidarity (Lehtonen and Liukko 2012) in order to achieve Arnell’s three goals.

Risk

Risk is determined by likelihood and consequences (Perseus 2012). Flood insurance programs should be designed to reduce the risk of flooding. By spreading risk over time and space, flood insurance programs reduce the financial burden of flooding (Arnell 2000). Risk- spreading is most effective when the insurance program has a high penetration rate, a natural outcome for mandatory insurance programs (Surminski 2013).

From an economic perspective, insurance is a private good with a moral hazard problem

(Keohane and Olmstead 2016; Lee 1992). It is difficult for premiums to match risk without perfect information. By updating flood maps and including all homeowners in the program, insurance programs can seek to reduce the effects of information asymmetry.

Mitigation is both an opportunity and a challenge for a universal program. On one hand, universal insurance can use price incentives to encourage more widespread mitigation efforts. On the other, because everyone will be included in the program, the new program will not be allowed to refuse insurance to people who do not take action. An additional challenge is the need to balance government spending between insurance payouts and mitigation funding (Devarajan and Jack 2007).

Solidarity

Solidarity in flood risk management is the idea that humans face floods as a community.

The makeup of an insurance program depends on the society’s understanding of solidarity.

Beliefs about obligations and communities change. Lehtonen and Liukko (2012) describe the progression of views of solidarity over time. Devarajan and Jack (2007) argue that insurance should help the poor and high-risk in society. The next phase in society’s understanding of solidarity should be one that is more inclusive, with more policyholders sharing the burden of floods.

Solidarity also ties into conceptions of justice. Johnson et al. (2007) compare different approaches to flood insurance and justice. One of their approaches, the Rawlsian “maximin rule,” supports solidarity by guaranteeing a minimum standard of protection to the poor. Rawls writes that society should pursue “equality,” and that inequalities are only acceptable if they help

“the least advantaged members of society” (Rawls 1971). UFI, in which all of society contributes to protection from floods, fits Rawls’s ideas.

From a psychological perspective, individuals do not understand risk properly (Botzen et al. 2012). Because of this misunderstanding, too few people purchase insurance. Mandatory insurance would solve this problem.

Solidarity is necessary because purely risk-based approaches to insurance can exclude both low-income and high-risk people (Priest et al. 2005). Both of these groups would be brought into a universal insurance scheme.

A mandatory scheme would also help to reduce inequalities, because under the voluntary system some socioeconomic groups purchase insurance less frequently (Baker et al. 1996).

Public insurance programs, by redistributing wealth, can help to reduce inequality (Devarajan and Jack 2007).

Another version of solidarity would have all policyholders pay the same premiums

(Bouwer et al. 2007), but this type of program would not be able to offer discounts to encourage mitigation.

The Proposal for Universal Flood Insurance

UFI would insure all households in the interest of solidarity and would collect premiums from all households to spread risk. Revenue can increase in two ways: through increased premiums and through more policyholders. Both of these are necessary for the NFIP to be effective in the long term. UFI is a radical proposition for the U.S., offered in response to

FEMA’s request for “bold steps” (FEMA 2018a).

The program would have several key features. Premiums would “reflect risk” (Michel-

Kerjan and Kunreuther 2011), but would remain affordable through a broad premium base.

Premiums would be designed to discourage people from living and building in high-risk areas and would incentivize mitigation. The program would include improved floodplain maps

(Kousky and Kunreuther 2009).

Grandfathering would be phased out, a change originally proposed by the Biggert-Waters

Flood Insurance Reform Act. Grandfathering is a major problem for the NFIP. However, it has been 50 years since the program was created in 1968. Homeowners know by now that their properties are vulnerable, even if they were not aware in the 1960s, so they should pay risk-based premiums.

The program would also use buyouts to reduce the occurrence of repeat flooding to lower long-term risk. The NFIP is losing money over the long term to repetitive loss properties.

Instead, it should create a program to purchase vulnerable homes (NRDC 2017). This buyout fund would prevent repetitive loss properties, which can collect more than their net worth over time in insurance payouts, from eating into NFIP’s budget (Moore 2018). The collection of premiums from more voters would create additional pressure to purchase at-risk properties. Universal insurance has benefits for the whole of society. On the economic side, UFI provides a plan for disasters. Otherwise, disasters that affect the uninsured but are not declared federal disasters will leave policymakers with the choice of finding last-minute funds or refusing to help flood victims. (If a flood event is not a federally declared disaster, only people with insurance receive assistance under the current system [pers. comm. 12/2018]). On the social side, there is a benefit to having everyone insured. It affects the quality of life of neighbors to see their fellow citizens left homeless after a flood.

When spread among a large community, flood payments are not that expensive. The following table shows that fees in a universal scheme would be relatively small. It calculates fees based on the number of households, not based on the whole population, adult population, or number of homeowners. Households is a better measurement than homeowners because renters are able to purchase flood insurance under the current scheme (FEMA 2018e). Based on the past ten years of NFIP payouts, the highest annual fee per household would be less than $70. While these fees would be adjusted in practice to match risk, to deter living in flood-prone areas, and to cover buyout programs, the chart illustrates that a flood scheme would not be prohibitively expensive. One important caveat is that fees could increase in the future with more frequent heavy precipitation events (IPCC 2013).

Table 1: NFIP payments by household. Note: data is not yet available for 2018 (Source:

FEMA 2018f; United States Census Bureau 2018).

In Millvale, UFI would build on community efforts to reimburse flood victims and to mitigate the effects of floods. It would help historic businesses to stay operational by slowing the increase in premiums. There is some precedent for this type of program in Pennsylvania: the city of Lancaster has implemented a “stormwater management fee” for “all property owners...whose property has impervious surfaces” (Save It! Lancaster 2019; pers. comm. 21/12/2018).

Political Considerations

2019 is an ideal time for lawmakers to revamp the NFIP. Flood insurance reform was a bipartisan issue under Biggert-Waters, indicating that it could be a source of cooperation between the Democrat-controlled House and the Republican-controlled Senate. Furthermore, with each short-term extension and funding deadline, there is a new opportunity to reform the program for long-term success. The next deadline is May 31, 2019 (FEMA 2018a). Ideally, one of these deadlines, and not a major flood event, will form a “window of opportunity” for lawmakers to implement reforms (Meijerink 2006). The NFIP needs long-term stability and premiums that match its payouts. A new program of UFI in the U.S. will achieve these goals.

Lessons from flood insurance reform in other countries can help U.S. lawmakers to carry out the transition from the current system to UFI. For example, Germany attempted to implement mandatory flood insurance but was unable to carry out the reform due to political and legal issues (Schwarze and Wagner 2007). France, Belgium, and Spain, on the other hand, were able to implement mandatory flood insurance (Surminski 2013). The three countries tie mandatory flood insurance to other forms of insurance (Surminski 2013); this could be an approach that the

U.S. takes in the future but it is not the current proposal. By studying these cases, U.S. leaders can preempt hurdles to mandatory flood insurance in the U.S.

The Affordable Care Act (the ACA, also known as Obamacare) provides another lesson on insurance reform in the U.S. Republicans attacked the program, which provided universal healthcare, because it required people to purchase insurance through the individual mandate. The

Supreme Court upheld the individual mandate (Negrin and De Vogue 2012). Since then, however, the ACA has seen challenges from the Trump administration and a court in Texas

(Goodnough and Pear 2018). If the Texas decision leads to a new Supreme Court decision against the constitutionality of the ACA, then UFI will need to seek a different funding mechanism.

Climate change is an additional challenge. It could lead to more heavy precipitation events and sea level change (IPCC 2013). In the context of climate change, natural and manmade factors both influence flooding (Surminski 2013). The insurance market will be in jeopardy if it does not adapt to the new threats posed by climate change (Lamond and Penning-Rowsell 2014). Furthermore, the U.S. needs updated flood maps to reflect changing risk (pers. comm.

11/12/2018).

There are also political considerations at the local level, in communities like Millvale.

Premiums under the new system will need to both affordable and fair. In addition, it may take time for individuals to embrace national, instead of local, solidarity in the face of floods.

Conclusion

The NFIP is in debt and is not doing enough to protect communities like Millvale, PA. As a result, community-driven flood mitigation fills in the gaps. The NFIP needs radical change to protect households from flooding. While UFI could face political challenges, the use of fair pricing and bipartisan cooperation can help to ease the transition. In the long run, UFI would balance risk and solidarity more effectively and would be more financially sustainable.

References

Arnell, N. (2000). ‘Flood Insurance’, In: Parker D J (ed.) Floods, Chapter 27, 412-424, Routledge, London.

Baker, T., & McElrath, K. (1996). Whose Safety Net? Home Insurance and Inequality. Law & Social Inquiry, 21(2), 229-264.

Benzio, D. (2013). Girty’s Run Watershed Assessment Plan. Available at: http://www.alleghenycleanways.org/sites/default/files/girtys_run_assessment.pdf [Accessed 11 Jan. 2019].

Bouwer, L.M., Huitema, D., and Aerts, J. (2007). Adaptive flood management: the role of insurance and compensation in Europe. Institute for Environmental Studies. Amsterdam, The Netherlands.

Botzen, W.J.W. and van den Bergh, J.C.J.M. (2012). Risk attitudes to low-probability climate change risks: WTP for flood insurance. Journal of Economic Behavior and Organization, 82, 151-166.

Burby, R.J. (2001). Flood Insurance and Floodplain Management: The US Experience. Environmental Hazards, 3, 111-122.

City Paper (2008). On the anniversary of the 2007 Millvale floods, what's being done to prevent recurrences in creeks like Girty's Run? [online]. Available at: https://www.pghcitypaper.com/pittsburgh/flood-of-interest/Content?oid=1340591 [Accessed 9 Jan. 2019].

Congress.gov (2014). H.R. 3370. [online] Available at: https://www.congress.gov/bill/113th- congress/house-bill/3370 [Accessed 9 Jan. 2019].

Devarajan, S. and Jack, W. (2007). Protecting the Vulnerable: The Tradeoff between Risk Reduction and Public Insurance. The World Bank Economic Review, 21(1), 73-91.

FEMA (2018a). National Flood Insurance Program: Reauthorization. Available at: https://www.fema.gov/national-flood-insurance-program/national-flood-insurance-program- reauthorization-guidance [Accessed on 2, 8, and 22 Dec. 2018].

FEMA (2018b). Coastal Barrier Resources System: Changes to Flood Insurance Rate Maps. Available at: https://www.fema.gov/media-library-data/1541517225623- d7d0926113c464cda6c556110ddb4993/FEMA_USFWS_FactSheet_CBRS_FINAL_SEPT_2018 _508_COMPLIANT.pdf [Accessed 20 Dec. 2018].

FEMA (2018c). Policy Statistics. Available at: https://bsa.nfipstat.fema.gov/reports/1011.htm#PAT [Accessed 9 Jan. 2019].

FEMA (2018d). FEMA HMGP Property Acquisitions. Available at: https://www.fema.gov/media-library/assets/documents/85455 [Accessed 9 Jan. 2019].

FEMA (2018e). Yes, Renters Can Buy Flood Insurance. Available at: https://www.fema.gov/news-release/2018/05/04/yes-renters-can-buy-flood-insurance [Accessed 9 Jan. 2019].

FEMA (2018f). Loss Dollars Paid by Calendar Year. Available at: https://www.fema.gov/loss- dollars-paid-calendar-year [Accessed 9 Jan. 2019].

FEMA (2018g). National Flood Insurance Program Community Rating System. Available at: https://www.fema.gov/national-flood-insurance-program-community-rating-system [Accessed 9 Jan. 2019].

FEMA (2018h). The National Flood Insurance Program Community Status Book. Available at: https://www.fema.gov/national-flood-insurance-program-community-status-book [Accessed 9 Jan. 2019].

FEMA (2016a). Community Rating System (CRS) Communities and their Classes. Available at: https://www.fema.gov/media-library/assets/documents/15846 [Accessed 9 Jan. 2019].

FEMA (2016b). IS-1106.A: FEMA Mapping Changes. Available at: https://training.fema.gov/is/courseoverview.aspx?code=IS-1106.a [Accessed 9 Jan. 2019].

FEMA (2012). Flood Risk Report: Allegheny County, Pennsylvania. Available at: https://www.rampp- team.com/county_maps/pennsylvania/allegheny/RiskMap/FRR_AlleghenyCoPA.pdf [Accessed 9 Jan. 2019].

Flegenheimer, M. (2018). Out of Prison, Back to Congress? Michael Grimm Is Trying on Staten Island. The New York Times, [online]. Avialable at: https://www.nytimes.com/2018/05/20/us/politics/michael-grimm-staten-island.html [Accessed 9 Jan. 2019].

Goldenberg, S. (2014). Grimm Attacks Sandy Efforts. Politico, [online]. Available at: https://www.politico.com/states/new-york/city-hall/story/2014/04/grimm-attacks-sandy-efforts- 012348 [Accessed 9 Jan. 2019].

Goodnough, A. and Pear, R. (2018). Texas Judge Strikes Down Obama’s Affordable Care Act as Unconstitutional. The New York Times, [online]. Available at: https://www.nytimes.com/2018/12/14/health/obamacare-unconstitutional-texas-judge.html [Accessed 9 Jan. 2019].

Govtrack (2018). National Flood Insurance Program Extension Act of 2018: Summary. Available at: https://www.govtrack.us/congress/bills/115/s1182/summary [Accessed 9 Jan. 2019].

Govtrack (2017). 21st Century Flood Reform Act: Summary. Available at: https://www.govtrack.us/congress/bills/115/hr2874/summary [Accessed 9 Jan. 2019].

Govtrack (2004). Bunning-Bereuter-Blumenaur Flood Insurance Reform Act of 2004: Text. Available at: https://www.govtrack.us/congress/bills/108/s2238/text/enr [Accessed 9 Jan. 2019].

Horn, D.P. and Webel, B. (2018). Private Flood Insurance and the National Flood Insurance Program. Congressional Research Service.

IPCC (2013). Summary for Policymakers. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

Johnson, C., Penning-Rowsell, E., and Parker, D. (2007). Natural and Imposed Injustices: The Challenges in Implementing ‘Fair’ Flood Risk Management Policy in England. The Geographic Journal, 173 (4), 374-390.

Katz, D. (2017). The National Flood Insurance Program: Drowning in Debt and Due for Phase- out. The Heritage Foundation.

KDKA (2018). Flooding Causes Significant Damage In Millvale, Residents Left Frustrated. Available at: https://pittsburgh.cbslocal.com/2018/07/05/millvale-flooding-residents-frustrated/ [Accessed 9 Jan. 2019].

Keohane, N.O. and Olmstead, S. (2016). Markets and the Environment, 2nd ed. Island Press.

Kousky, C. and Kunreuther, H. (2009). Improving Flood Insurance and Flood Risk Management: Insights from St. Louis, Missouri. Resources for the Future.

Kousky, C. and Michel-Kerjan, E. (2015). Examining Flood Insurance Claims in the United States: Six Key Findings. The Journal of Risk and Insurance.

Lamond, J. and Penning-Rowsell, E. (2014). The Robustness of Flood Insurance Regimes Given Changing Risk Resulting from Climate Change. Climate Risk Management.

Lee, K. (1992). Moral Hazard, Insurance and Public Loss Prevention. The Journal of Risk and Insurance, 59(2), 275-283.

Lehmann, R. (2018). Congress Let NFIP Off Hook for $16B Debt, Despite Less Than $10B in Claims. Insurance Journal. Available at: https://www.insurancejournal.com/blogs/right- street/2018/07/09/494466.htm [Accessed 9 Jan. 2019].

Lehtonen, T. and Liukko, J. (2012). The Forms and Limits of Insurance Solidarity. The Journal of Business Ethics, 103, 33-44.

Meijerink, S. (2006). Understanding Policy Stability and Change: The Interplay of Advocacy Coalitions and Epistemic Communities, Windows of Opportunity, and Dutch Coastal Flooding Policy 1945–2003. Journal of European Public Policy, 12(6), 1060-1077.

Michel-Kerjan, E. (2010). Catastrophe Economics: The National Flood Insurance Program. The Journal of Economic Perspectives, 24 (4), 165-186.

Michel-Kerjan, E. and H. Kunreuther (2011). Redesigning Flood Insurance. Science, 333 (6041), 408-409.

Millvale (2018a). Floods. [online] Available at: https://www.millvalepa.com/emergency- management/pages/floods [Accessed 20 Dec. 2018].

Millvale (2018b). Flood Insurance. [online] Available at: https://www.millvalepa.com/emergency-management/pages/flood-insurance [Accessed 20 Dec. 2018].

Moore, R. (2018). New Legislation Would Require Review of FEMA Buyout Efforts. NRDC, [online]. Available at: https://www.nrdc.org/experts/rob-moore/new-legislation-requires- assessment-fema-buyout-efforts [Accessed 9 Jan. 2019].

Moore, R. and Scata, J. (2017). Broken insurance should insurance should help people move, not rebuild. The Hill, [online]. Available at: https://thehill.com/opinion/energy-environment/354697- broken-flood-insurance-program-should-help-people-move-not-rebuild [Accessed 5 Nov. 2018].

Negrin, M. and De Vogue, A. (2012). Supreme Court Ruling: The Mandate Can Stay. ABC News, [online]. Available at: https://abcnews.go.com/Politics/OTUS/supreme-court-announces- decision-obamas-health-care-law/story?id=16663839 [Accessed 9 Jan. 2019].

NRC (2015). Affordability of National Flood Insurance Program Premiums: Report 1. [online] Washington, D.C.: The National Academies Press. Available at: https://www.nap.edu/catalog/21709/affordability-of-national-flood-insurance-program- premiums-report-1 [Accessed 9 Jan. 2019].

NRDC (2017). Seeking Higher Ground: How to Break the Cycle of Repeated Flooding with Climate-Smart Flood Insurance Reforms, [online]. Available at: https://www.nrdc.org/sites/default/files/climate-smart-flood-insurance-ib.pdf [Accessed 9 Jan. 2019].

OED (2018a). Risk. In: OED. Available at: http://www.oed.com/view/Entry/166306?rskey=qukRTs&result=1#eid [Accessed 31 Dec. 2019].

OED (2018b). Solidarity. In: OED. Available at: http://www.oed.com/view/Entry/184237?redirectedFrom=solidarity#eid [Accessed 31 Dec. 2019].

Paskal, C. (2011). Rebuilding Sandcastles. The World Today, 67 (7), 7-9.

Perseus (2012). AMP Toolbox. [online] Available at: http://www.perseus- net.eu/site/content.php?artid=2204 [Accessed 9 Jan. 2019].

Priest, S.J., Clark, M.J., and Treby, E.J. (2005). Flood Insurance: The Challenge of the Uninsured. Area, 37(3), 295-302.

Rawls, J. (1971). A Theory of Justice. Cambridge, Massachusetts: The Belknap Press of Harvard University Press.

Save It! Lancaster (2019). Stormwater Fee & Credits. Available at: http://www.saveitlancaster.com/resources/stormwaterfee/ [Accessed 11 Jan. 2019].

Schwarze, R. and Wagner, G.G. (2007). The Political Economy of Natural Disaster Insurance: Lessons from the Failure of a Proposed Compulsory Insurance Scheme in Germany. European Environment, 17, 403-415.

Sherman, J. and Kousky, C. (2018). Local Solutions to Flood Insurance Affordability: Portland’s Flood Insurance Savings Program. Wharton Risk Center.

SPC (2018). Borough of Millvale FEMA Flood Zones. Personal communication, 19 Dec. 2018; reprinted with permission.

State of Kansas (2013). Biggert-Waters Flood Insurance Reform Act of 2012: Summary. Available at: https://agriculture.ks.gov/docs/default-source/dwr-floodplains/summary-of-the- biggert-waters-act.pdf?sfvrsn=ce3ffec1_0 [Accessed 9 Jan. 2018].

Surminski, S. (2013). The Role of Insurance in Reducing Direct Risk - The Case of Flood Insurance. International Review of Environmental and Resource Economics, 7, 241-278.

United States Census Bureau (2018). Historical Households Tables. Available at: https://www.census.gov/data/tables/time-series/demo/families/households.html [Accessed 20 Dec. 2018].

USACE (2018). President’s Fiscal 2019 Budget for U.S. Army Corps of Engineers Civil Works Program Released. Available at: https://www.usace.army.mil/Media/News-Releases/News- Release-Article-View/Article/1438488/presidents-fiscal-2019-budget-for-us-army-corps-of- engineers-civil-works-progra/ [Accessed 9 Jan. 2019].

USACE (1975). General Plan. Personal communication, 11 Dec. 2018; reprinted with permission.

Waters, M. (2013). Waters Applauds Passage of Bipartisan Amendment to Delay Flood Insurance Rate Increases. [online] Available at: https://waters.house.gov/media-center/press- releases/waters-applauds-passage-bipartisan-amendment-delay-flood-insurance-rate [Accessed 20 Dec. 2018].

Waters, M. (2014). Comprehensive Flood Insurance Legislation Passes House. [online] Available at: https://waters.house.gov/media-center/press-releases/comprehensive-flood- insurance-legislation-passes-house [Accessed 20 Dec. 2018].

Yin, R. (2003). Case Study Research: Design and Methods. Thousand Oaks, California: SAGE Publications.