INSIGHTi
The Federal Flood Risk Management
Standard (FFRMS)
July 5, 2023
Flooding is the most frequent and costly natural disaster facing the nation, and floodplain policy has
particular relevance for infrastructure and the federal government’s exposure to flood losses and demand
for disaster assistance. The Federal Flood Risk Management Standard (FFRMS) is a mechanism for
federal agencies to consider and manage current and future flood risk by requiring federally funded
projects to be located out of flood risk areas or constructed to reduce the effects of current and future
flood hazards (including less-frequent larger events). Five executive orders are directly relevant to the
FFRMS.
E.O. 11988
President Carter signed E.O. 11988, Floodplain Management, in May 1977 to require federal actions to
avoid supporting development in the floodplain:
• Federal actions are to avoid, if alternatives are available, supporting development in the
1% annual-chance floodplain (also referred to as the Special Flood Hazard Area (SFHA),
the 100-year floodplain, or the Base Flood Elevation (BFE) floodplain).
• Under implementation guidance for E.O. 11988, critical actions are to avoid the 0.2%
annual-chance (500-year) floodplain if alternatives are available.
E.O. 13690
President Obama signed E.O. 13690, Establishing a Federal Flood Risk Management Standard and a
Process for Further Soliciting and Considering Stakeholder Input, in January 2015. It established for
federally funded projects an FFRMS requiring a higher level of flood resilience than E.O. 11988.
Federally funded projects are defined as actions where federal funds are used for new construction,
substantial improvement, or to address substantial damage to structures and facilities. E.O. 13690
modified the E.O. 11988 requirements, largely by redefining the floodplain used for federal floodplain
management policy.
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E.O. 13807
In August 2017, President Trump signed E.O. 13807, Establishing Discipline and Accountability in the
Environmental Review and Permitting Process for Infrastructure Projects, in an effort to streamline
federal infrastructure approval. Among other actions, E.O. 13807 revoked E.O. 13690.
E.O. 13990 and E.O. 14030
In January 2021, President Biden revoked E.O. 13807 as part of E.O. 13990, Protecting Public Health
and the Environment and Restoring Science to Tackle the Climate Crisis, which effectively reinstated
E.O. 13690, including the FFRMS. In May 2021, President Biden’s E.O. 14030, Climate-Related
Financial Risk, confirmed that guidelines for implementing E.O. 13690 remain in effect.
The FFRMS Floodplain
The FFRMS floodplain can be determined by one of three methods:
1. the freeboard value approach (FVA);
2. the 0.2% annual-chance (500-year) flood approach (see Figure 1); or
3. the climate-informed science approach (CISA), which incorporates current and future
changes in flooding based on best-available, actionable climate science and other factors
or changes affecting flood risk.
The FVA method determines the extent and elevation subject to flooding by adding an additional two feet
to the elevation of the BFE (water level from a flood with a 1% chance of equaling or exceeding that level
in any given year) for noncritical actions or an additional three feet to the BFE for critical actions. Critical
actions are defined as any activity for which even the chance of flooding would be too great. CISA tools
are under development by the Flood Resilience Interagency Working Group (FRIWG).
Figure 1. Vertical Elevation and Horizontal Extent of the Federal Flood Risk Management
Standard Floodplain Using the 0.2% Annual-Chance Approach
Source: CRS, adapted from Pew Charitable Trusts, North Carolina City Adopts Stringent Standard for Building in a Flood Plain,
Issue Brief, November 19, 2019.
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Note: The current floodplain (the Special Flood Hazard Area) is the area inundated by the 1% annual-chance flood (shown
in red). The FFRMS floodplain is the area inundated by the 0.2% annual-chance flood (shown in blue). In this il ustration,
the 0.2% annual-chance floodplain expands both the horizontal extent and the elevation of the inundated area.
Agency FFRMS Implementation
While broad federal FFRMS implementing guidelines were finalized in October 2015, various federal
agencies are currently developing or updating procedures and regulations tailored to their programs to
account for the reinstated FFRMS.
• The Federal Emergency Management Agency (FEMA) has produced policy guidance for
partial implementation of the FFRMS. It requires the use of the FFRMS FVA for
noncritical actions involving structures in the SFHA that receive funding from any FEMA
program (Individual Assistance, Public Assistance, Hazard Mitigation Assistance). This
policy does not address the horizontal expansion of the floodplain (see Figure 1), or the
application of the FFRMS to critical actions. FEMA intends to fully implement the
FFRMS by rulemaking (i.e., amending 44 C.F.R. Part 9).
• The U.S. Army Corps of Engineers uses CISA methods set out in agency guidance to
evaluate climate change impacts on coastal and inland flood hazard for its civil works
projects.
• The Department of Housing and Urban Development (HUD) has a 2023 proposed rule
that would affect projects receiving HUD assistance, financing, or insurance. It would
establish that, when possible, the CISA approach should determine the FFRMS
floodplain and would require that newly constructed and substantially improved
structures be elevated or floodproofed to the FFRMS floodplain elevation. The proposed
rule would also revise HUD’s minimum property standards under the FHA mortgage
insurance program, and require that the lowest floor be built at least two feet above the
1% annual-chance floodplain for low-rent public housing programs.
• The U.S. Environmental Protection Agency determined that the FFRMS would go into
effect starting FY2022, applying to certain projects funded by State Revolving Fund
capitalization grants.
• The General Services Administration submitted a draft floodplain management policy
that would support the FRIWG approach to implementation of the FFRMS.
Many other agencies do not have publicly available information on their implementation of the FFRMS.
Considerations for Congress
Congress may assess FFRMS’s effect on implementation of federally funded projects and disaster-related
programs. For example, buildings and infrastructure funded by the Infrastructure Investment and Jobs Act
and P.L. 117-169 (referred to as the Inflation Reduction Act) may not be built to the FFRMS, as the
standard has not been fully implemented by most agencies, leaving these assets potentially vulnerable to
flooding. Congress may consider codifying, modifying implementation, or blocking implementation of
the FFRMS. Congress may also consider how to evaluate the net benefits of the FFRMS, including its
impact on low-income and vulnerable populations.
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Author Information
Diane P. Horn
Nicole T. Carter
Specialist in Flood Insurance and Emergency
Specialist in Natural Resources Policy
Management
Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff
to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of
Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of
information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role.
CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United
States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. However,
as a CRS Report may include copyrighted images or material from a third party, you may need to obtain the
permission of the copyright holder if you wish to copy or otherwise use copyrighted material.
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