Community Rating System doesn’t rate on Martha’s Vineyard

Water Street in Vineyard Haven lived up to its name during Hurricane Sandy. — File photo by Ralph Stewart

As sea levels and flood insurance premiums continue their inevitable rise, the Community Rating System (CRS) can help mitigate the costs of both. However, none of the six towns on Martha’s Vineyard is enlisted in the Community Rating System. Chilmark is not a National Flood Insurance Program (NFIP) participant, so only five towns are eligible for the program.
The Vineyard is not an anomaly. Only 13 towns in Massachusetts participate in the CRS, according to Chris Markesich, CRS coordinator for Federal Emergency Management Agency (FEMA) Region 1. “The majority of CRS participants is in the South and Mid-Atlantic, where entire counties take part in the program,” Mr. Markesich said. “In Massachusetts it has to be done by towns because of the Home Rule provision.

Congressman William Keating, representative for the 9th Massachusetts district, which includes the Cape and Islands, played a key role in the drafting and passing of the Homeowner Flood Insurance Affordability Act (HFIA), the most recent federal flood insurance legislation, signed into law in March by President Obama. In a recent interview with The Times, Mr. Keating said, “We’re urging communities to become part of the Community Rating System. This can decrease flood insurance premiums for people from 5 percent up to 45 percent. In many cases, towns are already doing what it takes to earn credits.”
The CRS is a program run by FEMA to encourage communities in flood-prone areas to take preventive measures that exceed NFIP standards. In exchange for a community’s proactive efforts, policyholders can receive reduced flood insurance premiums. The CRS also provides incentive for communities to expand public outreach efforts, so people can keep up with constantly evolving and often Byzantine flood insurance regulations. 1,296 communities now participate in the CRS, and nearly 3.8 million policyholders benefit from it, according to the FEMA web site. The CRS uses a rating system from Class 9 to Class 1. Most communities enter the program at a Class 9 or Class 8 rating, which entitle residents to a 5 percent or 10 percent discount respectively.

Rigorous application process
Part of the reason so few towns currently participate in the CRS is that the application process is very time-consuming. The CRS manual tops out at more than 600 pages. It can take many months, even years, to attain entry, and enrollment has to be renewed by FEMA every year. “I’d recommend a town form a CRS application committee,” Bob Desaulniers, flood insurance specialist for FEMA Region 1, told The Times. “If you take a committee approach there isn’t a person in town hall who’s taking a deep breath wondering how they’ll do it.”

Mr. Desaulniers, a 40-year veteran of the insurance industry, said it would behoove towns to have an insurance agent on their CRS committee. “Insurance agents are used to dealing with big manuals. They can manage this ungodly manual and then look at the point system and figure out what the town can do and what they’re already doing,” he said.

Mr. Desaulniers recommended that the committee also include a conservation agent and a building inspector, who is often the town floodplain manager.
Mr. Desaulniers is part of a speakers’ bureau that FEMA recently formed to help town officials, CRS committees, and insurance agents keep up with changes in regulations. “Things have changed so much since 2012, even professionals have difficulty keeping up,” he said. “And our speakers’ bureau is in such demand we can’t keep up. There’s so much misinformation out there.” Underscoring his point, Mr. Desaulniers said FEMA was just asked by Congress to determine if churches and municipal buildings, which are non-income-producing, can qualify for the 18 percent annual cap increase instead of the 25 percent cap that commercial properties receive.

CRS Scituate
Scituate is one of the 13 towns in Massachusetts that participates in the CRS. Today the town is at CRS Class 8, so property owners receive a 10 percent discount on their flood insurance. “It’s a great program; I don’t know how communities survive without it,” Scituate conservation agent Pat Gallivan told The Times. “It’s reviewed every year, and some communities have lost it. I think if that happened here we’d have a taxpayer revolt,” he joked. Scituate joined the CRS in 1990, the first year of the program. “All my predecessors took it pretty seriously,” he said. “We’re at level 8 now, but I think we’ve missed some points along the way. Just documenting things we already do like cleaning clamshells out of flood basins and regulating storm water will help bring that number up. The town has also bought repetitive-loss properties in the VE zone, which is the high-hazard zone. Some of those homes had collected several times.”
Mr. Gallivan said the public-awareness component of the CRS has wide-ranging benefits. “The CRS requires an annual meeting for all homeowners in flood zones,” he said. “We had 200 people come last time. The presentation gives you [CRS] points, but it also informs. There were several people who had basements that they didn’t use. They didn’t know that by filling them they could be in an entirely new flood zone.” Like Mr. Desaulniers, Mr. Gallivan also advocates the committee approach. “We have a really strong CRS committee,” he said. “We meet every two months. Our town historian, David Ball, has done research about storms that hit here in the 17th century. It’s fascinating stuff.”

Dennis CRS-less
The town of Dennis is not in the CRS. “We’ve tossed it around, but there’s an enormous amount of documentation that goes with it, and it’s very time-consuming,” Dennis town planner Dan Fortier told The Times. “Over 60 percent of real estate sales on the Cape are in cash, so when you don’t have mortgage and the flood insurance requirement, it doesn’t have as much of an impact.”

That said, Mr. Fortier said the basic tenets of the CRS are good guidelines to follow.

“We do a lot of outreach, which is really key with all these changes,” he said.  “We hold informational sessions, we publicize them in the papers and on radio and in social media. After we got our new flood maps, we reserved the senior center for an information session from 3 pm to 8 pm, and when we arrived at 2 pm to set up there was already a line. We probably had over 1,000 people come through. Between walk-ups and phone calls we were servicing over 100 people a day, and the flood maps on the web site were averaging over 200 hits a day. We update the information on the planning blog so both seasonal and year-round residents are aware of the flood zone changes.”  Mr. Fortier said a current topic on the outreach agenda is a change in the crucial primary-residence criterion. “As of June 1 the requirement that you needed to live in your house 80 percent of the year to qualify as a primary residence changed to 50 percent. The old classification really screwed a lot of people. It meant a lot of the snowbirds who spent the summer here and the winter in Florida had no primary residence, and they got hammered on both ends.”

To CRS or not to CRS
Echoing Congressman Keating, Mr. Markesich strongly recommends coastal towns in Massachusetts join the CRS. “It’s not just for better insurance rates. It can help mitigate loss of life,” he said. “Better infrastructure and better-informed people are going to do better in a major flood event.”

Mr. Markesich acknowledged the application process can be onerous, but said there are increasing FEMA resources to help. “Our office has conducted CRS workshops throughout New England this summer to try to get the word out about the CRS program. We had a workshop in May in Hyannis, but I don’t believe anyone was there from the Vineyard,” he said. “The CRS program also has recently added an Insurance Services Office that works directly with communities on applications.”
Mr. Markevich said that while FEMA is ready to help, it must get a letter of intent from an elected town official to begin the process. FEMA responds with a 13-page “Quick Check,” which determines if the town meets the minimum threshold of 500 points. “The Quick Check usually shows people they already have enough points to qualify,” Mr. Markesich said. The 500 points earns the town a 5 percent discount on NFIP insurance.
After the Quick Check, FEMA officials make a Community Assistance Visit (CAV), usually within a month, although some cases can take longer.  Helpful information is also at, which also hosts users’ groups and conference calls. The next CRS workshop to help town officials with the application process or with maintaining their existing CRS program is a four-day program being held in Rhode Island beginning Oct. 20. It’s free of charge to town representatives from FEMA Region 1. Mr. Markevich said he will answer questions personally as well. A staff member from Mr. Keating’s office, speaking on background, said they can also work as a liaison with FEMA to help with the CRS application process.