Using ICC - FEMA Increased Cost of Compliance
(August 12, 2013)
I should have written this section closer to the flood but I had other things that were higher priority. Like navigating through ICC and fixing our house.
This is NOT and CANNOT be considered a guide to using ICC or any sort of official, legal or otherwise my fault advice. Don't like it? Try using the FEMA information then you'll have something you really don't like.
Increased Cost of Compliance or ICC is a FEMA/Flood Insurance program designed to help people who are regularly hit with severe flooding - called Severe Repetitive Loss. The short and pretty version, IF you qualify and IF you can navigate the system you can get $30,000 to lift (elevate) or move your home. IF you want to sell your home to the govt and have it converted into open space, this is not really the way to go. That decision is usually made at a local level as several properties usually must be bought and razed in a chunk. Matching funds have to come from local or state. It's a whole complicated process unto itself. I didn't do it and don't know enough about to be even remotely useful.
The basic premise of ICC is that it is cheaper to give you money to get out of the way of future flooding then to keep paying large claims.
STEP 1. Get flooded. This may seem obvious but your building permit is what triggers the process. I don't know if you can get ICC to elevate if you are not rebuilding from a flood.
Dig out those letters from FEMA that say your property is a severe repetitive loss property. It lists how much has been paid out over the years.
ICC's guidelines are more than 50% of the value of the home has been paid in claims in the last ten years or 75% of the value of the home in a single claim. If you meet one of those you may be able to get ICC money.
You will need your current claim amount to prove that this loss pushes you over the trigger amounts for ICC.
STEP 2. Learn patience. Then re-learn it. If you're annoyed by this sentence already, you really need to get some patience. This is a long process. They (FEMA) say to expect 6 - 18 months to complete the process and rebuild. I figured I'm motivated, organized and driven - I can do it on the six month side. Nope. I was motivated, organized, driven and unfaltering and it still took ONE YEAR and ONE DAY until I slept in my own house.
STEP 3. Look at your insurance plan. Flood insurance is not as standardized as you would expect. On our policy there was an ICC option. I never knew it was there so I'm guessing it was packaged in when we first signed up seven years ago.
Don't panic if you don't see it. Call your insurance rep and see what they can find out. As a last option call flood insurance directly but chances are good they will tell you to call your agent or insurance representative. Occasionally you get lucky and someone knows and is willing to give out the closely guarded secrets of flood insurance policies.
STEP 4. Do NOT do this until you know 100% that you have ICC coverage. Once you go down this path there is no turning back and you will have to lift or move your house. If you don't have ICC coverage you WILL BE on the hook for the full cost of lifting the house. Then again they are getting really aggressive with flood insurance and you may not be able to rebuild without mitigating anyway.
Make an appointment with your local building inspector and zoning/ordinance person.
Do NOT SUBMIT a building permit yet.
At your meeting with the inspector and zoning folks, ask them about the regulations for severe repetitive loss properties. Most local areas that are part of the FEMA Flood Insurance programs will have the necessary regulations on their books because it's part of being in the program. Still - double check.
You are looking for regulations that say after a certain value of damage to the home you are required to mitigate. ICC's guidelines are more than 50% of the value of the home has been paid in claims in the last ten years or 75% of the value of the home in a single claim. Your local regs will probably echo those figures.
You also want to know any "extra" regulations. In my area I was required to elevate the house 1.5 feet higher than the flood zone. Essentially 1.5 feet more than FEMA said I had to.
The one and only really useful thing I was told at the FEMA flood response shack was - Elevate more than you have to. Better safe than under. Especially when you think that if you are under you will not get the insurance break and insurance is only going up.
Go higher but don't go nuts. We only had to go up 6 feet; we went 8 and made a garage. Go to the next logical, larger size. You never know what may come up. The forms to build the concrete walls are set sizes so we lost four inches. Go higher.
STEP 5. Tell the building inspector and zoning folks your intentions. Tell them you will submit a permit and that they should reject it in WRITING saying that you must mitigate (elevate or move) according to regulation.
STEP 6. You've had your meeting. You know all the regulations are on the local books. You know you are covered under ICC. You know this will take a long time - it's already been weeks since the flood.
Pick up a building permit application and prepare the world's simpliest building permit. Don't waste time or money doing it right or well. This one will be rejected.
STEP 7. Download and read and re-read these publications.
- You will have to leave openings in whatever you build under your house. The booklet will tell you size and location. Get used to this. You cannot put a window or anything in the hole. You can use screen if it's large enough but be aware that the screen frame counts against you. The inside of the frame has to be big enough to meet the regulations.
- There is an option for closing the holes if you can find something that has met and been approved for the application. Essentially you have to scientifically prove it will open by itself when flooding. Way complicated. I tried. I failed.
- You will not be covered for basically anything in the area under your house.
- You can use the area under your house for parking and storage but it won't be covered. You cannot use it as living space.
- All appliances such as water heaters, furnaces and fans, sockets, lights and switches must be higher than the required elevation. We put our water heater on the first floor, our heat pump on stilts and strapped our furnace fan to the floor. Since we raised it more than we had to, the furnace fan was above the required height.
STEP 8. Decide. Elevate or move the house. If you have a property with a hill and room to move the house or can buy another property to move the house onto, it will be marginally easier. Easier because you can build the foundation and get the hook ups set then just move the house from the old location to the new. Generally moving it takes 2-3 days. Lifting it and building under means they lift it one time. You do loads of work and then they come back and set it down.
STEP 9. Hire a surveyor who can do an elevation certificate. Have them find the current height of your house above sea level and determine how high you must go. If you are moving your home to another location on the same property, have them measure the height of the new location to make sure it's high enough. If you are moving to a new property altogether and that property is not in the flood zone, you may or may not have to do an elevation certificate. Contact your zoning person.
STEP 10. Wait for the elevation number. Don't design until you know what you need to. We pre-designed and wasted a lot of time.
Design your home. Click through these pages for some ideas and tips. Will you put it on stilts? Concrete block - easier but more expensive. Poured concrete?
Once designed start doing the building permit.
STEP 11. Do this at the same time as you are designing and doing the building permit.
Get bids. ICC requires you to have contracts before you can apply. Good luck if you are planning on doing this yourself. You can try working up quotes listing the cost of materials and anyone you would pay.
STEP 12. Notify your adjuster. This is the person who did the claim for the flood. They will be your gateway to ICC. Tell them you are planning to apply for ICC. Do this before all the bids are in so they are aware of what's coming.
STEP 13. Submit your building permit application. You will need an approved permit before applying for ICC. You must also submit the building permit to the surveyor so that they can do the elevation certificate. You will need two elevation certificates. One done based on the building permit. The second after the work is complete.
STEP 14. Take the best bids and ask for contracts. You must submit contracts to ICC.
STEP 15. Prepare your application.
You will need:
- Contact information for your claim adjuster
- The letter from your local government saying that you are required to mitigate.
- Your approved building permit.
- Contracts from all of the contractors.
- Your first elevation certificate based on the building permit.
STEP 16. Submit your application. You will only get the first half of the amount. ICC will give you up to $30,000 provided your costs exceed that.It was relatively fast - 2-3 weeks I think.
Tip. If you have the resources it will go smoother to pay the other half out of your money than to try to convince the contractors to wait for half of their money until you complete the project and get the other half of the ICC money.
STEP 17. Complete the work and get the building permit signed off. You will need a second elevation certificate done. This one with pictures.
You will only get the other half of the ICC money when you have a completed elevation certificate that shows your house has been mitigated.