In order to participate in the  program, communities must adopt and agree to enforce floodplain  management regulations to reduce future flood damage. Elevation. Areas where flood risk is  possible but undetermined are designated as D zones. Effects of NFIP Building Requirements Varied for Farmers in Selected Communities, but Additional Guidance May Help Those Adversely Affected

Based on interviews with floodplain management officials, farmers, and  others in selected communities, the effects of NFIP’s building  requirements for agricultural structures have generally varied. To comply  with these requirements, new or substantially improved nonresidential  structures in high-risk areas must be elevated or dry flood-proofed. However, the agency  acknowledged that the methods included in the guidance do not cover all  of the different types of agricultural structures located in vast flood plains  with deep flood depths and may not reflect the changes in the size and  scale of farm operations in recent years. We  selected eight geographically diverse locations in SFHA riverine  floodplains in California, Louisiana, North Carolina, and North Dakota that  supported crops or livestock requiring onsite agricultural structures.Representatives from FEMA, USDA, and national floodplain management  and farm organizations told us that they were unaware of any farmers in  these states or others that faced negative effects on their operations from  the NFIP building requirements (e.g., elevation, dry flood-proofing, or wet  flood-proofing for certain nonresidential structures). Correspondingly, 12 farmers in the communities we selected  concurred with these views and generally told us that they had not been  adversely affected by NFIP building requirements. Local floodplain managers from the selected  communities in Louisiana, North Carolina, and North Dakota told us  farmers in their communities typically needed to raise building  foundations by just a few feet (which they were generally able to do by  adding fill dirt) to meet the BFE requirements for structures built inside  SFHAs. However, in both Sutter and Yolo Counties in California,  the flood depths were relatively deeper (up to 15 feet in some areas). According to state and local floodplain managers and farmers we spoke  with, farmers in Sutter and Yolo Counties who were subject to the NFIP  building requirements were also facing challenges flood-proofing their  new or substantially expanded agricultural structures to comply with NFIP  building requirements. Realizing the need to provide alternative methods to  meet building requirements after a catastrophic flood in the Midwest in  1993, in the same year, FEMA issued guidance that allowed certain  structures that cannot be elevated or dry flood-proofed to be wet flood- proofed, allowing water to flow through a building while minimizing  damage to the structure and its contents.may not be viable for certain agricultural structures. The absence of current guidance on alternative methods has led some  farmers to “work around” the building requirements. Options to Address Concerns about NFIP Requirements in Agricultural and Rural Areas Involve Trade- Offs and Risks

Local floodplain managers, farmers and lenders identified several options  to help farmers located in SFHAs manage NFIP requirements for building  new or substantially improved structures and lowering the cost of NFIP  insurance. However, FEMA officials, experts  from national floodplain management and city and regional planning  organizations, and academics told us that many of these options carried  risks and may run counter to the NFIP objectives. The farmers have said that they would be willing to assume all  risks and opt out of federal disaster relief if they could expand and  construct buildings without being required to follow NFIP building  requirements. Further, experts we spoke to indicated that such an exemption  could set a precedent, leading others to ask for similar exemptions. FEMA officials shared these views, adding that FEMA had no legal  authority to allow farmers or any other specific population group to opt out  of disaster relief. Exempting structures may defeat this goal  and encourage farmers to build noncompliant structures in high-risk areas  that may inadvertently cause damage to nearby communities, according  to officials. Recommendation for Executive Action

As FEMA determines the scope of its efforts to revise its existing  guidance, we recommend that the Secretary of the Department of  Homeland Security (DHS) direct the Administrator of FEMA to update  existing guidance to include additional information on and options for  mitigating the risk of flood damage to agricultural structures to reflect  recent farming developments and structural needs in vast and deep  floodplains. In its comments, DHS concurred with our  recommendation to update existing guidance to include additional  information on and options for mitigating the risk of flood damage to  agricultural structures to reflect recent farming developments and  structural needs in vast, deep floodplains.
Why GAO Did This Study

NFIP helps protect property in high-risk floodplains by, among other things, requiring communities that participate in the program to adopt floodplain management regulations, including building requirements for new or substantially improved structures such as elevating, dry flood-proofing, or wet flood-proofing structures.
GAO was asked to evaluate the possible effects of NFIP, including its building requirements, on farmers in riverine areas that have a high risk of flooding. This report examines, among other things, the effects of building requirements on farmers in high-risk areas and options that could help address any challenges farmers face. To do this work, GAO analyzed laws, regulations, and FEMA policy and claims data; interviewed 12 state and local floodplain managers, 24 farmers, and 6 lenders in 8 selected communities in California, Louisiana, North Carolina, and North Dakota (selection based on geographic diversity, presence of high-risk flood areas, and type of farming that required on-site structures); and interviewed flood management and planning experts and FEMA officials.

What GAO Found

The effects of the National Flood Insurance Program's (NFIP) building requirements for elevating or flood-proofing agricultural structures in high-risk areas varied across selected communities, according to interviews GAO conducted with floodplain managers and farmers. Specifically:
Floodplain managers and 12 farmers in selected rural communities with whom GAO spoke in Louisiana, North Carolina, and North Dakota generally were not concerned about these requirements. Most of these farmers told GAO that they had land outside the high-risk areas where they could build or expand their structures, or they could elevate their structures relatively easily.
Floodplain managers in selected California communities told GAO that farmers in their communities had been adversely affected by the building requirements. They said that most farm land was in high-risk areas and elevation of structures would be difficult and costly—due to the relatively deep flood depths, structures would be required to be elevated up to 15 feet to comply with the building requirements. They also indicated that some structures were difficult to make watertight below the projected flood level (dry flood-proofing).
According to a California floodplain manager and several farmers with whom GAO spoke, the farmers who were adversely affected by the building requirements have had to work around outdated Federal Emergency Management Agency (FEMA) guidance that does not fully address the challenges of vast and relatively deep floodplains or reflect industry changes. For example, the 1993 guidance from FEMA allowed an alternative flood-proofing technique (wet flood-proofing) that permits water to flow through certain agricultural structures in expansive high-risk areas. However, farmers in the California communities told GAO this was not a viable option because pests might enter openings and contaminate crops stored inside. FEMA typically updates guidance as needed but acknowledged the need for additional guidance that covers all of the different types of agricultural structures and reflects recent developments in the size and scale of farm operations, including supporting structures that were expensive to build and replace. Additional and more comprehensive guidance would allow FEMA to better respond to recent developments and structural needs in vast and deep floodplains.
Some local floodplain managers, farmers, and lenders from the selected communities identified options to help farmers manage the challenges of building or expanding agricultural structures in high-risk areas, but many of the options would entail certain risks and may run counter to the objectives of NFIP. For example, one commonly cited option calls for exempting agricultural structures from building requirements, with farmers assuming all of the flood risk and opting out of federal disaster relief. Both FEMA and the experts noted such an exemption could set a precedent, leading others to ask for similar exemptions. Further, FEMA officials stated that the agency had no legal authority to allow farmers or any other group to opt out of disaster relief.

What GAO Recommends

The Administrator of FEMA should update existing guidance on mitigating the risk of flood damage to agricultural structures to include additional information that reflects recent farming developments and structural needs in vast and deep floodplains. FEMA agreed with the recommendation.