North and Central Jersey Inland Flood Risks Ignored by Christie Sandy Rebuild Rule

Christie Rule Designed to Promote Coastal Rebuilding,  Not Reduce Severe Statewide Flood Risks

Outdated Flood Maps for Portions of the Passaic, Pequannock, Ramapo, Pompton, Hackensack, Raritan and Other Rivers and Streams Are Ignored

flood maps updated in area in light blue - not inland rivers

• The majority of the Department’s flood maps were promulgated in the 1970s and 1980s. While there have been a number of minor revisions to these maps over the years, the Department has generally not undertaken large-scale remapping or new mapping of previously unmapped waters since that time. As a result, the Department’s maps in some cases underestimate the actual extent of flooding. In order to provide more accurate flood mapping to the public, the Department has been working in cooperation with FEMA to revise many State and Federal flood maps in order to reflect current flooding conditions.   ~~~ DEP Emergency Rule  (Jan. 24, 2013)

• Trenton — As New Jersey struggles to recover from the devastating effects of Hurricane Sandy, it does so without accurate gauges of future flooding risks, according to Public Employees for Environmental Responsibility (PEER). New federal maps underestimate the risks of coastal flooding while state inland flooding maps have not been updated for at least a generation. […]

             State maps for inland flooding from rivers are even less reliable, however. At a December 3, 2012 hearing, state Senator Gordon (D-Bergen) pinned Department of Environmental Protection (DEP) Commissioner Martin down concerning the failure to update inland flood maps. Sen. Gordon said he found current DEP maps were 30 years old and based on 40-year old data and exclaimed “We can’t have maps that go back to the Jimmy Carter era.” ~~~   NEW JERSEY YET TO COME TO GRIPS WITH POST-SANDY FLOOD RISKS – Coastal Maps Do Not Account for Climate Change Effects; Inland Maps Decades Old ~~~ December 19, 2012

•  The Asbury Park Press editorial agrees with our assessment: Rush to rebuild could be costly

Base flood elevation maps show how high properties should be built to avoid flood damage.The maps released by FEMA Saturday, however, were drawn prior to Sandy and without using the latest scientific data on climate change and rising sea levels. …

Communities and homeowners alike will be free to challenge FEMA’s new official maps. But they should not wholeheartedly embrace these limited incomplete advisory maps. No one in the state can ignore the evidence of what Sandy has wrought, nor the larger issue of steadily rising ocean waters. Willful ignorance is not a winning strategy for the future.  (12/20/12)

Before I write about the DEP Emergency Flood Hazard Rule on Sandy Rebuild announced on Thursday by Governor Christie,  I want to make a few important points about what the rule fails to address.

Governor Christie has chosen to create two classes of New Jersey and provide different levels of protection of public safety and economic welfare for people who comprise those two classes, based on where they live.

Important inland flooding risks are being completely ignored by the Governor’s focus on shore impacts and his priority of coastal rebuilding over risk reduction. (view FEMA Advisory Base Flood Elevation Maps Here)

Flood risks come in two distinct categories: 1) coastal flooding resulting from storm surge and wave action; and 2) inland flooding from rivers and streams resulting from storm water runoff.

DEP is responsible for mapping and regulating both types of risk across the entire State, under the NJ Flood Hazard Control Act.

But the DEP Emergency Rule, which updated antiquated flood maps and strengthened building codes, only applies to the coast and portions of the Delaware and Hudson Rivers  (see Appendix 2 of the DEP rule for exact locations of updated flood maps by county and municipality and compare them to the FEMA ABFE maps).

And very few people understand that the primary objective of the DEP rule is not even to reduce flood risks, but to promote rebuilding.

DEP admits this themselves in the rule summary:

Given the above, the Department is concurrently proposing the emergency adopted amendments in order to establish requirements and more efficient procedures for authorizing persons to construct, reconstruct, relocate and elevate buildings and other structures in flood hazard areas or to otherwise flood-proof buildings to avoid and reduce the type and severity of flood damage experienced by many State residents as most recently exemplified by the Superstorm Sandy. This rulemaking is furthermore made in recognition of the current need to timely rebuild damaged structures within New Jersey’s coastal communities on a monumental scale.

As a result of the Governor’s decision to prioritize rebuilding over reducing flood risks, critical issues were ignored, including known flood risks in inland north and central Jersey and known outdated and under protective inland flood maps and development standards.

Again, despite these known flood risks and outdated flood maps, DEP admits this narrow coastal focus in the rule summary:

Over the past several years, and in cooperation with the Department, FEMA has been undertaking a comprehensive remapping of tidal flood elevations along New Jersey’s Atlantic coastline.   FEMA’s flood elevation models for many coastal communities were developed decades ago using various methodologies that resulted in a patchwork of flood insurance rate maps with a variety of flood elevations. In response to concerns that FEMA’s existing flood insurance studiesunderestimate the extent of tidal flooding in many communities, the Department has partnered with FEMA to develop more accurate coastal flood mapping. , Using a   uniform modeling approach, and relying on data collected over the past several decades, FEMA has confirmed that its existing flood mapping along New Jersey’s coastline generally underestimates today’s actual 100-year flood elevation by approximately one to four feet and, in some circumstances, by as much as eight feet. Many people who constructed a building with its lowest floor at the 100-year flood elevation shown on FEMA’s existing flood maps discovered during Superstorm Sandy that their building lies below the actual 100-year flood elevation. These buildings may be subject to greater flood damage potential over time and likely greatly increased flood insurance costs.

The same serious problems exist along inland rivers and streams across the central and northern portions of the State.

Those risks will only increase as more overdevelopment is allowed (which generates more storm water runoff) and climate change causes more frequent and severe rainfall amounts.

Had Superstorm Sandy dumped 5 -10+ inches of rain on north jersey – as it did in some areas to our south – there would have been catastrophic inland flooding perhaps greater than the shore devastation.

Inland river floodwaters flowing into bays would have made record storm surges even HIGHER.

Why aren’t people, legislators, and the media up in arms about that?

Most likely, because they don’t know about it.

The Bergen Record  – who should be all over this given Senator Gordon’s oversight – sure didn’t tell them about that –