UPDATE: City Notice: Community Rating System Open House and Community Discussion – September 8, 2021.
Bellaire residents were informed recently that as of October 1, 2021, they will not receive a 15% discount on flood insurance premiums.
Thanks to an open records request some of the FEMA documents sent to representatives of the City of Bellaire have been made available, and they reveal a troubling timeline. You can read the FEMA letters by clicking on the image at left.
The letter of January 22, 2021, addressed to Mayor Andrew Friedberg, clearly states “In a CAC letter dated January 16, 2020, we requested copies of Bellaire’s floodplain development repair permits and other documents related to substantial damage determinations for 86 addresses. We had expected that a simple clerical operation to gather and forward the documents would have sufficed, and the CAC would have closed in a matter of weeks; unfortunately, we did not find comprehensive enforcement of substantial damage requirements.
However this ‘simple clerical operation’ must not have occurred, and in a letter dated June 14, 2021, Interim City Manager Brant Gary was informed of FEMA’s decision to lower the City’s 7 Rating to 10, which resulted in the loss to Bellaire residents of any discount on flood insurance as of October 1, 2021.
A second letter from FEMA to Mayor Friedberg, dated July 12, 2021, is also on file. That letter reiterates the need to verify compliance on 54 sites for substantial damage documentation. By then the City’s 7 rating and the 15% discount had been lost.
The explanation on the City’s website for this loss reads: “We are working diligently to rectify the situation and regain our status in the Community Rating System to pass along potential flood insurance discounts to eligible residents. We will provide updates to the community along the process. ” But no explanation is provided for how this loss occurred.
At a recent City Council meeting the Assistant Director of Development Services stated that the discount was lost due to noted deficiencies by FEMA associated with maintenance and production of records and deficiencies in the processes within the Development Services Department.
Meanwhile our Director of Development Services, ChaVonne Sampson, who also served as Community Rating System Coordinator (CRS), resigned at the end of July, 2021.
Tthere were earlier warning signs in letters in January, 2020, referencing an earlier letter from October 25, 2017, and another on June 10, 2020. This is a portion of the June 10, 2020, letter:
“The NFIP paid 452 claims with a 2017 date-of-loss in Bellaire which appeared to have been substantial damage. Historically, NFIP claims data reports 668 apparent substantial damage claims in your community, yet only 72 claims for Increased Cost of Compliance (ICC) have been paid. We fear that policyholders have not been able to access the full value of their NFIP policies, namely ICC claim payments, due to a lack of substantial damage determinations.“
Recent correspondence from the City of Bellaire informs us that the National Flood Insurance Community Ratings System will be changing, and rates and discounts will also change. Stay tuned.
FEMA letters 2021
FEMA letter January 16, 2020
FEMA letter June 10, 2020
Report from Wood Environment & Infrastructure Solutions, Inc. regarding a Verification Visit on 8/13/2020
Letter from INSURANCE SERVICES OFFICE, INC. regarding a change in the Community Rating System as of January1, 2021
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