National Flood Insurance Program:

Additional Guidance on Building Requirements to Mitigate Agricultural Structures' Damage in High-Risk Areas Is Needed

GAO-14-583: Published: Jun 30, 2014. Publicly Released: Jul 29, 2014.

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Daniel Garcia-Diaz
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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with whom GAO spoke, the farmers who were adversely affected by the building requirements have had to work around outdated Federal Emergency Management Agency (FEMA) guidance that does not fully address the challenges of vast and relatively deep floodplains or reflect industry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.

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 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.

For more information, contact Daniel Garcia-Diaz at (202) 512-8678 or

Recommendation for Executive Action

  1. Status: Open

    Comments: To obtain information for updating existing guidance, FEMA engaged a contractor to study the types of flood damage agricultural buildings and contents can sustain, mitigation and insurance available to farmers, and potential changes in mitigation options and rating guidelines to reduce risk or rates for agricultural structures. FEMA also engaged the contractor to develop new policy options, guidance, and training as a result of the study findings. In November 2018, FEMA released a draft Agricultural Structures Damage policy for public comment. As of January 2019, FEMA was reviewing comments on the draft policy. We will continue to monitor the development of new guidance.

    Recommendation: As FEMA determines the scope of its efforts to revise its existing guidance, the Secretary of the Department of Homeland Security (DHS) should 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.

    Agency Affected: Department of Homeland Security


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