LAND-LOCKED FLOATING HOUSE

FEMA Overall EVALUATION:

This report was prepared in response to several inquiries from Member(s) of the United States Congress as to Federal Emergency Management Agency's (FEMA) intentions concerning the testing of Winston International's (WI) Land-Locked Floating Home System.  Congress, through the Conference Report of the National Flood Insurance Reform Act of 1994 (NIFRA) expressed a desire for FEMA to be accommodating to the testing of new flood proofing technologies that are equivalent in effect to permanently elevated structures designed and constructed in accordance with National Flood Insurance Program (NFIP) regulations, practices and policies.

 

To date, FEMA has not supported the concept of floating home flood proofing technologies because they do not meet the Congressional intent of the Conference Report of the NIFRA.   FEMA believes that the underlying concepts supporting floating home technologies raises serious technical concerns.  This report concludes that any floodproofing technology that relies on mechanical processes to provide flood protection, such as WI's floating home system, can not be equivalent in effect to permanent elevation of a structure.

 

In addition, an analysis of WI's concept demonstrates the need for increased active human intervention and maintenance for the system to operate as intended.  In fact, the WI concept requires occupancy of the structure during conditions of flooding to ensure the electrical generator continues to operate the ballast system.  FEMA can not support any floodproofing technology that would require floodplain residents to stay in harm's way during conditions of flooding.

 

FEMA has also determined that the cost data provided by WI concerning the cost of permanently elevated structure is flawed and somewhat misleading.  A comparison of the incremental cost of constructing a new floating home to the incremental cost of constructing a permanently elevated home indicates that the cost to permanently elevate a home should be substantially less than the WI floating home system.

 

Based on information provided to FEMA by over 18,000 communities that participate in the NFIP, approximately 2.3 million properly designed and constructed structures have been placed in special flood hazard areas over the last twenty years.  FEMA has estimated that this represents a reduction in flood damages of approximately 777 million dollars a year to the National Flood Insurance Fund, National Disaster Relief Fund, the US Treasury, State and local governments, and owners of these structures.

 

In summary, FEMA has determined that floating home systems are not equivalent in effect to a permanently elevated structure built in conformance with the NFIP requirements.  The basic tenants of the NFIP calls on Federal, State and local governments to ensure that when people choose to develop flood prone areas, that such development occurs in a manner that limits future damages and minimizes risks of deaths and injuries to building occupants and the public at large. This technology is not consistent with these basic tenants of floodplain management nor the requirements of the Act.

    
WINSTON INTERNATIONAL REPSONSE TO FEMA OVERALL EVALUATION:We have reviewed the referenced "evaluation" that FEMA's "Mitigation Directorate and senior level staff engineers and floodplain management specialists" have provided to you and several other Members of the United States Congress. Winston finds this review of the WLFH to be wanting in basically every statement made in this so-called "evaluation."  FEMA is attempting to side-step the directives of the Congress and the Conference Report of the National Flood Insurance Reform Act of 1994 (NFIRA).  Nowhere in the Report does the wording suggest that FEMA write a biased "EVALUATION" of this technology, it specifically directs FEMA to be "accommodating to the testing of new technology."  The Report further states that the "testing is performed using uninhabitable structures."   How can FEMA even suggest that they do not support the concept of floating house technologies "because they do not meet the Congressional intent of the Conference Report of the NFIRA?"  The Conference Report did not ask FEMA to judge the "Congressional intent of the Report", it asked them to be accommodating to the testing of such technologies.  In short, FEMA was not asked to support or reject the WLFH until evidence through actual testing of constructed prototypes could prove or disprove the WLFH is equivalent in effect to permanent elevation of a structure. Richard Krimm, Acting Associate Director of FEMA's Mitigation Directorate, states in his cover letter to the "evaluation", "FEMA had on-going discussions for several years with the firm of Winston International regarding their proprietary technology known as the Land-Locked Floating Home."  November 15, 1993, Robert Hundley, Winston's Vice President of Public Affairs, met with staff members of FEMA and presented them with a marketing document briefly describing Winston and the WLFH.  Five business days later, FEMA responded to Winston in a letter^[1] rejecting the floating house concept.  Since that date, although Mr. Hundley has spoken on several occasions with FEMA personnel, FEMA has made no attempt to ask questions directly to me, or any technical or professional member or consultant of the Winston team.  Although FEMA was delivered an outline of the Winston Test Results, which were obliquely and inaccurately referred to in the "evaluation", there have been no questions asked of our design or testing team members.  FEMA has refused to answer Winston's letters, with the exception of their first refusal letter.

 It should be clearly noted that the NFIP, and the national model codes state that the lowest floor shall be elevated to or above the base flood elevation.  Nowhere in any of these documents do the words permanent or permanently appear in context with the elevation of the floor during flooding or non-flooding in flood hazard zones.  The following wording is added in Sec. 2102.4.2,^[2] "Anchorage:  The structural systems of all buildings or structures shall be designed, constructed, and anchored to resist flotation, collapse or permanent lateral movements due to structural loads and stresses from flooding equal to the base flood elevation."  The WLFH has been designed and computer-tested to exceed this requirement. The "evaluation" continues to claim the new technologies must be shown to be equivalent in effect to permanent elevation (per the Conference Report).  How is it possible for FEMA to make an uninformed judgement whether the effect on the WLFH will be equivalent to "technologies permitted under current NFIP regulations, policies and practices?"  This statement is begging the question, because the intent of the Conference Report was to test new technologies and, if proven, revise FEMA's outdated policies and practices.  Further, they cannot reach an objective decision with the limited knowledge they have of the performance of the WLFH systems.  This must be done through independent testing procedures, set up by independent and objective agencies, not by highly-biased, uninformed bureaucrats. FEMA has continued to demand that, prior to constructing a test structure, any applicable variances from floodplain management requirements, or building permits, must be obtained from the community having jurisdiction.  This is nothing more than an obvious delaying tactic.  No federal or local agency has the authority to require building or zoning permits or variances upon a manufacturer testing an experimental product.  Required permits are issued after acceptance of new technologies.  WLFH prototypes will be constructed in either a factory or a testing environment.  ^[2] BOCA National Building Code, Article 21.  Building Officials & Code Administrators International, Inc

   FEMA RESPONSE TO DESIGN CONCEPT:Evaluation of the Winston International Land-Locked Floating Home Concept 

The concepts on which Winston International's (WI) floating home system is based seems simple when taken at face value, but when analyzed they are quite complicated.  WI has proposed a floating home system based on the buoyancy of blocks of foam.  To hold the structure in a vertical alignment, a system of telescoping piles is proposed.  To maintain horizontality, a system of ballast tanks with solenoids and pumps is proposed.  No information has been provided by WI to FEMA concerning the design and placement of utility systems servicing a building such as water, sewer, and electrical systems.  In analyzing the basic concepts of the proposed design, FEMA found basic technical problems inherent to all floating home concepts which appear insurmountable.

WINSTON RESPONSE TO FEMA DESIGN CONCEPT:The assumption by FEMA's "evaluation", under "Concept" that "WI has proposed a floating home system based on the buoyancy of blocks of foam" is completely inaccurate.  The flotation system is designed as a series of re-enforced, malleable, HDPE pontoons, with foam located between the floor joists and not in the pontoons.  This pontoon assembly has been designed and tested for extreme conditions of flotation, all types of disruption, leveling, flood forces applied in all directions, and protection from  residuary (wave making) and frictional (wetted surface) resistance forces.  FEMA's reviewing team had made no attempt to determine the WLFH technology before making their assumptions.   Also noted was the statement "FEMA found basic technical problems inherent to all floating home concepts which appear insurmountable."  Apparently the thousands of floating homes in the Puget Sound area and the rest of the world, as well as the floating bridges and docks, the oil-drilling rigs, and other mechanical concepts also have insurmountable technical problems.    
 
FEMA RESPONSE TO ENGINEERING DESIGN ANALYSIS:Engineering Analysis of the Determination of Loads 

The engineering analysis of the load computations provided by WI were based on two state-of-the-art documents.  These documents are the American Society of Civil Engineer's ASCE 7-95 Standard entitled Minimum Design Loads for Buildings and Other Structures and FEMA's publication number 259 entitled Engineering Principles and Practices for Retrofitting Flood Prone Residential Buildings.  ASCE 7 is considered to be the definitive national standard for defining loads on buildings and other structures.  FEMA 259 is based on the most current version of ASCE 7-95 which, for the first time, included flood loads and load combinations that include flood and wind loads.

 

The load determination provided by WI includes errors.  These include:

 * Flood Loads:  Hydrodynamic loads as delineated by WI assume a maximum velocity of 5 feet per second.  This assumes that proposed floating structures will only be located in low velocity areas.  This precludes the installation of WI floating homes in all Coastal High Hazard area (V zones), riverine floodways and all other riverine floodplains with velocity flows in excess of 5 feet per second.

 

Secondly, no water-borne debris impact loads are considered.  Both ASCE 7-95 and FEMA 259 require consideration of, at least, minimal debris impact loads.

 In addition, there is also no consideration of loads generated by wave action.  Since it is critical to maintain horizontality during flotation conditions due to potential pitching and rolling of the structure, wave action must be analyzed with an extremely high level of  precision.  This has not been done. * Wind Loads:  There is an assumption of prevailing wind direction.  This is an inappropriate approach to determining wind loads.  Winds must assume to be coming from all directions.  Both positive and negative pressures must be considered as well.

 

* Seismic Loads:  Another concern is the absence of the determination of potential seismic loads.  Failure to consider seismic loads may result in damage to the structure as well as injuries and possible deaths of building occupants in seismic-prone area.

 

Analysis of the Design

 

The engineering analysis on the proposed design was undertaken by separating the floating home concept into several distinct engineering components.  These components are the flotation

system, the telescoping pile system, the ballast system, and utility systems.

 

Flotation System

 

The proposed flotation system consists of the series of foam blocks incorporated into the wooden first floor diaphragm of the floating structure.  Calculations provided by WI indicate that the foam proposed would provide sufficient buoyancy to float the structure with sufficient freeboard.  The proposed freeboard assumes a totally placid water surface.  This is often not the case in many flooding scenarios found throughout the U.S.  Any water surface turbidity or wave action could cause flood water to splash or run up and enter the structure.  This would cause the following to occur:

 *soaking damage to the structure which would result in increased repair costs; * increasing the weight of the structure, thereby reducing its buoyancy, possibly causing the structure to sink; and

 

*possibly causing an increase in the pitch and roll of the structure, leading to overturning of the structure.

 

WI indicates that requiring permanent elevation of structures to the base flood elevation creates an unnecessary inconvenience to the building occupants.  To address this perceived  inconvenience the WI concept proposes to have the first floor of the structure located at grade.  To accomplish this objective, a cavity must be excavated below the lowest floor of the structure.  This is needed since the first floor diaphragm of the structure is several feet thick to enclose the foam floatation system.  Cavities or depressions in floodplains fill with sediment during flood events.  As the flood waters recede, the floating home will settle back into the muck, mud and debris that have collected in the cavity under the structure.  It is probable that the material collected under the house will not allow the house to settle in a level position.  In the event the structure settles out of plumb, torsional forces and bending moments not considered in the design of the structure may well occur.

 

In any event, all material deposited under the home will need to be removed before the house can be reoccupied so the house will sit properly on the ground.  To remove debris and mud from beneath the structure would require the use of a house moving contractor to safely jack the house up and then lower it back down once the mud and debris have been removed.

 

Telescoping Pile System

 

The telescoping pile system presents three potential scenarios that could lead to catastrophic failure of the structure.  The scenarios are potential failure of the system due to being in a static state, in extension and in contraction.  These three scenarios were analyzed separately:

 *Telescoping Piles in a Static State After many years of inaction, the pile friction will increase due to detrimental effects such as: stagnation of the lubrication oil inside the piles, small amounts of surface corrosion,and drying out of the flexible seal at the top of the pile.  No evidence has been provided by WI on how extended periods of inactivity will affect the performance of the telescoping pile system.  Floating homes may be called on to float as infrequently as once every 100 years, resulting in prolonged periods of inoperation.  Extended periods of inoperation support the need for periodic maintenance and operational testing by the homeowner.  The ability of homeowners, both physically and financially, to maintain floating home systems and conduct necessary testing raises serious concerns as well. 
*Telescoping Piles in Extension All mechanical processes have a probability of failure.  The highest probability of  failure occurs when a mechanical process operates the first time.  This is known a "infantile  failure".  Failure can also occur during future extension of the telescoping piles since each operation of the telescoping pile system will expose the system to water-borne contaminants that can lead to corrosion and fine particles impacting the future performance of the telescoping piles.  Torsional forces that could occur as a result of flood and wind action may bind the piles in the retracted position, further inhibiting their performance during future flooding.  In contrast, permanently elevated structures do not  rely on a mechanical process to provide flood protection and are therefore not subject to infantile failure. 
There is no way to test an installed telescoping pile system once it has been installed in a structure since it is impossible to simulate flood conditions at each site.  Since there is no way to test each floating home after it is fabricated and installed on a site, the risk of  failure will be increased further. 
*Telescoping Piles in Retraction As with telescoping piles in extension, piles in retraction also are a mechanical process that has a probability of failure that exceeds the probability of failure associated with permanently elevated structures.  Failure of the telescoping piles in retraction can occur because each flood-triggered operation of the telescoping pile system will expose the   system to water-borne contaminants that can lead to corrosion and fine particles impacting the future performance of the telescoping piles.  Torsional forces that could occur as a result of flood and wind action may bind the piles as they retract.  This could lead to floating structures getting "hung up" on the partially retracted piles.  This could well lead to a catastrophic failure of the structure.  Fine particles, known as "grit" will adhere to the extended portions telescoping pile casings.  Grit will prevent the smooth vertical movement that could affect the retraction of the pile and the performance of the pitch and roll of the structure as it moves up and down.

 

Ballast System

To maintain horizontality during flooding conditions, the WI floating home relies on a ballast system to counteract pitch and roll generated by flood and wind forces acting simultaneously on the structure.  The previous section on the determination of loads discusses the flaws in the load analysis performed for WI.  The design concept for the WI ballast system has serious technical problems as well.  Maintaining horizontality is critical to the proper operation of the floating home.  Failure to control pitch and roll will, in all likelihood, result in a catastrophic failure of the structure.  The proposed ballast system relies on three mechanical devices, each of which, has its own probability of failure as well as the probability of failure of the mechanical systems acting in concert with each other.  The loss of electricity to power the ballast system is an example of the mechanical systems failing in concert.

 

The three main ballast system components are the level control system, the solenoid(s) and submersible pumps.  All three system components require electricity to operate properly.  Besides the potential loss of electricity, each system component can fail since:

 

*each mechanical component has the potential for mechanical failure,

* each solenoid may fail due to inaction of the solenoid burning out,
* the submersible pump may fail from the motor burning out or the water intake being clogged with debris, and 
*the level control system which relies on a mercury level switch, such as those found in a home heat/air conditioning system, is unreliable and wholly inadequate for such a critical component. 

*Each ballast tank must have a solenoid, and the failure of any solenoid would lead to failure

of the ballast system.  As with the telescoping pile system, there is no way to test the ballast system once it has been manufactured and installed on a site since it is impossible to simulate flood conditions at each site.

 

Utility Systems

 

One of the areas that has been completely unaddressed by WI is how service facilities (attendant utility systems) will be protected from flood damage.  The NFIP regulations [(44 CFR Section 60.3(a)3-6)] require that all utility systems be protected from flood damage.  "Quick disconnecting" utilities is mentioned in passing in the WI literature, but no technical discussion can be found.  All utilities need to be designed in such a manner to protect those portions of the utility systems that rise with the floating structure as well as those portions of the utility systems that remain in place and are exposed to damage from flooding.

 

 

Specifically, the following is required for utility systems under NFIP regulations:

 
*All electrical, heating, ventilation plumbing and air conditioning equipment and other service facilities be designed, constructed or located so as to prevent water from entering or accumulating within the system components during conditions of flooding. 
*All public utilities and facilities such as sewer, gas, electrical, and water systems are located and constructed to minimize or eliminate flood damage. 
*All new and replacement water supply systems be designed to minimize or eliminate infiltration of flood waters into the systems. 
*All new and replacement sanitary sewer systems be designed to minimize or eliminate infiltration of flood water into the systems and discharges from the systems into flood waters and onsite waste disposal systems to be located to avoid impairment to them or contamination from them during flooding. 

The electrical requirement of the ballast system in the WI floating home system raises many serious concerns.  An extensive amount of human intervention will be needed to convert from publicly-supplied electricity to on-site provided electricity from a generator to power the ballast system and to maintain (including adding fuel) the generator in good running condition during periods of operation associated with flood events.

 

Compliance with National Model Building Codes

 

Informal discussions with the engineering staff of the three national model code organizations indicate that they are in agreement with the NFIP interpretation the "lowest floor" of a structure located in a Special Flood Hazard Area must be elevated to, or above, the base flood elevation during both flood and non-flood conditions on a permanent foundation.  The International Conference of Building Officials, The Building Officials and Code Administrators, and Southern Building Code Congress International were all consulted in this matter.

 

Need for Active Human Intervention and Maintenance

 

All the mechanical processes involved in the floating home system will require active human intervention and maintenance far in excess of those associated with a permanently elevated structure.  Since a permanently elevated structure is elevated to the base flood elevation prior to flood events, no human intervention is required for successful operation.  Maintenance of an elevated structure is minimal and may be limited to such minor items as painting to protect against weathering.

 

The WI floating home system requires extensive human intervention and maintenance.  To operate properly, human intervention is required to ensure the on-site generator continues to operate properly during conditions of flooding.  This places people at an unacceptable risk (see the discussion on emergency management the follows).  A considerable amount of human maintenance is required in an attempt to have to the mechanical systems associated with the floating home system operate properly during flooding conditions.  Much of this maintenance is expensive and beyond the technical capabilities of the vast majority of homeowners.  There is also no mechanism in place to ensure that maintenance has, in fact, been performed.  The following is a sample of the critical maintenance activities that will need to be carried out:

 

*The telescoping piles will need:

 to have their lubrication oil changed to be inspected for corrosion due to moisture found in wall cavities to be inspected for corrosion and grit infiltration after each flood event to be inspected to ensure proper working status 

*The electrical generator and accompanying engine required to operate the ballast system will need be tested and serviced regularly.

 

*The ballast system will need to have the following tested and maintained regularly:

 the level sensor system the solenoids the submersible pump(s) 

WI has stated in its literature that they will provide lifetime maintenance.  However, there is no guarantee of the long term existence of the company.  FEMA can not support; a flood protection system such as the WI floating home system, that requires more human intervention during flooding conditions and/or maintenance than permanently elevated structures.

 

Emergency Management

 

The emergency management considerations that would result from the WI floating concept are a cause for great concern to FEMA.  This concern is generated from the following issues:

 

*Since the WI literature indicates that the floating home is intended to remain safe during flood conditions, many people will choose to continue to occupy their floating home during flood conditions, even after a mandatory evacuation order has been given by local authorities.  In fact, for the floating home system to operate properly, it requires human   occupancy of the structure during flood conditions to maintain and operate the electrical generator to power the ballast system.  FEMA will not support a flood protection concept that require's people to stay in harm's way during flood conditions.  Any failures of the system will require emergency response personal to rescue occupants of threatened structures and could result in injuries or loss of life to occupants of the structures and  rescue personnel.

 

* There is no way to "exercise" (operationally test) the floating home system.  Once a home is fabricated and installed, there is no feasible way of testing the system after initial installation nor periodically to test for deterioration over time.

 

*Since there is no way to test the system on site, there is no way to predetermine which structures will fail to perform as designed.  With several different mechanical processes required for each floating home to operate properly, the probability of failure of any one process or processes is great enough that emergency management officials will need to prepare to deal with large number of floating home system failures.

 

The sum total of these concerns may well require emergency response resources to be kept in reserve in the event the WI floating homes failed to perform properly.  FEMA finds that this potential additional burden of federal, state, and local emergency response capabilities is not acceptable.

 
 WINSTON REPONSE TO FEMA ENGINEERING DESIGN ANALYSISUnder Engineering, Analysis of the Determination of Loads, Flood Loads, states:  "Hydrodynamic loads as delineated by WI assume a maximum velocity of 5 feet per second."  This assumption was quoted to our marine engineer by Mr. Ken Corbin of the U.S. Army Corps of Engineers in St. Louis, Mo., who verified that "his experience was that 4-5 feet per second was fast for currents around flood banks of larger rivers."  He further stated that larger currents might be found in mountain stream areas (rapids, etc.), but not in major river areas.  WI used a design force of 5 feet per second, but proved in the computer-test, the WLFH could withstand much greater currents.  Winston has developed software that can predetermine all design forces for any model in any flood hazard zone. A design force for 2,000# impact loads was set per the hydrodynamic pressure formulation provided in "Design Manual for Retrofitting Flood-Prone Residential Structures", a FEMA publication.  The WLFH was found by computer-testing to have a safety-factor in excess of this.  This identifies the complete inaccuracy of the "evaluation" stating "no water-borne debris impact loads are considered." The statements about "no consideration of loads generated by wave action" and "an inappropriate approach to determining wind loads" (not coming from all directions with both positive and negative pressures) is also a complete misstatement.  All lateral and vertical loads were successfully tested in combination.  Seismic loads were thoroughly analyzed and documented by independent consulting structural engineers.  Again, FEMA was found to be making assumptions without knowledge. Titled under Analysis of the Design, Flotation System, Telescoping Pile System, Ballast System, and Utility Systems include totally false statements of the true conditions of each system.  No design at any time was undertaken assuming a "totally placid surface," and the problems of soaking damage, increased weights due to soaking, and increase in the pitch and roll of the structure which would lead to overturning, were researched, designed, and tested in depth and proved to be properly designed for extreme conditions.  Winston has also considered and designed methods for diverting, draining, and/or removing "muck, mud and debris" from under the structure as floods recede.  Safety factors are included to allow the house to settle smoothly, and in a level position, even with large foreign obstacles deposited under the house.  Any and all torsional forces and bending moments have been considered in the design of the structure.  "House-moving contractors  required to jack up the house and lower it back down" will never be required.  Any such rare need will be done by full warranty. 

Guidelines for setting heights of many of the 2.2 million homes FEMA reported as elevated in the flood hazard zones were set over twenty years ago, and, in many of  these zones, these limits have already been exceeded.  What will be the savings to the homeowners, the NFIF, and the DRF, when these already elevated houses are damaged by floods rising above their already elevated floors?  What will be the costs for damaged homes, furnishings, and expensive automobiles?  It is completely unjustified to make a statement such as the following found in the Emergency Management section of the "evaluation".  "There is no way to 'exercise' (optionally test) the floating home system.  Once a home is fabricated and installed, there is no feasible way of testing the system after initial installation nor periodically to test for deterioration over time."  Obviously, FEMA has not done its homework.  Winston International has!   As previously noted, WI has developed a highly feasible and simple way of testing the system after initial installation and periodically test for deterioration at any time, which we will proudly demonstrate with construction of prototypes.  FEMA can expect far fewer failures from flood events with the WLFH floodproofing system than any method currently allowed by the NFIP.  

FEMA RESPONSE TO ECONOMIC ISSUES:

Economic

 

Two areas of economic concerns were identified.  The potential costs to government entities related to failure of the floating home system to operate properly and the costs associated with the construction of the floating home compared to permanently elevated structures were both analyzed.

 

There are potential financial costs to the Federal government if floating homes were permitted..  Considering the possibility of failure of the floating home system, the Federal government is placed at financial risk through the National Flood Insurance Fund (which is backed by the US Treasury) and the National Disaster Relief Fund (which is funded through the general revenue of the US Treasury).  Of concern to FEMA, as well, is the potential cost to States since they cost share in disaster relief expenses.

 

With the increased probabilities of failure inherent in all floating home concepts, there will be a corresponding increase in outlays from the National Flood Insurance Fund as well as federal and state disaster relief expenses if FEMA was to allow floating homes under the NFIP.  FEMA finds that the resulting potential increase in federal disaster relief expenditures is unacceptable.  In addition, the additional costs would not be limited to the federal government.  State and local expenditures would also be increased.

 

WI has presented cost estimates of the incremental additional costs associated with elevating structures for both the floating home system and permanently elevated structures.  The analysis presented by WI comparing the incremental costs associated with elevating a new floating home with the incremental costs of permanently elevating an existing structure (known as retrofitting) is misleading and incorrect.

 

When comparing the increased incremental costs of elevating a new floating home to a new permanently elevated home, one finds that permanent elevation can be accomplished at the same or lower cost than the floating home system.  Using the Means Cost Guide publications we have found that the incremental additional cost to elevate a new home that would have been built on a crawl space, with solid perimeter walls, to a height eight feet above grade is comparable to the cost of a floating home.  This is also true for a home that would have been built on short piers, but would be elevated on a column foundation system, to a height eight feet above grade.

 

FEMA questions the cost estimate provided by WI for their floating home system since several design issues have not been addressed.  As an example, the design and associated cost of providing utilities to the floating home structure has not been determined.  This could easily add several thousand dollars to the cost of the WI floating home.

 

Based on information provided to FEMA by over 18,500 communities that participate in the NFIP, approximately 2.3 million properly designed and constructed structures have been placed in special flood hazard areas over the last twenty years.  FEMA has estimated that this represents a reduction in flood damages of approximately 777 million dollars a year to the National Flood Insurance Fund, the National Disaster Relief Fund, the US Treasury, State and local governments, and owners of these structures.  This date demonstrates the cost-effectiveness of currently approved flood protection technologies under the NFIP.  It is FEMA's belief that, based on our review of the floating home technology, such gains in damage reduction would be put in jeopardy by allowing floating homes under the NFIP.

  
 WINSTON RESPONSE TO ECONOMIC ISSUES:The area of Economic concerns are also highly incorrect.  The potential financial costs to the Federal and local governments if the WLFH is permitted, will be demonstrably reduced.  If  FEMA's current policies of retrofitting damaged elevated and non-elevated houses and relocating millions of homes to higher elevations are adhered to, the federal debt will increase by billions, possibly trillions. The  lack of research in FEMA's statement concerning the comparison of incremental costs of a new floating house to a permanently elevated home is dramatically overstated.  Accepting their statement that the "cost to elevate a new home that would have been built on a crawl space, with solid perimeter walls, to a height eight feet above grade is comparable to the cost of a floating home", has not taken into consideration the tremendous increase in cost of repairing the elevated house if floods rose higher than eight feet (or higher than any other pre-set elevation) nor the cost of replacing one or more auto-mobiles that were not protected.  The use of the WLFH in hazard zones where annual floods occur, will save major National Flood Insurance Fund and Disaster Relief Fund monies over the annual replacement costs of elevated homes, not considering the thousands of damaged, unprotected homes that will also require replacement.  All paid-in WI policy funds will be used for underwriting flood casualties, and not for other uses as is allowed under NFIP and FEMA policies. FEMA claims to have extensive knowledge of the performance of floodproofing technologies.  This may be true, but they have demonstrated in their inaccurate and unfair "evaluation" of the WI technology, that they know little about this technology, nor have they made any effort to ask for information from Winston principals. Winston's original approach to FEMA, November 15, 1993. was done out of courtesy to an agency we assumed would be anxious to review  the "smarter housing" they claimed to be seeking.  We did not anticipate that this agency would review the marketing information in less than a week, and blatantly refuse to acknowledge any possibility of success for this well-researched technology.  Since this date, WI has only received obstacles from FEMA to our efforts. The Conference Report represents the intent of Congress, which encouraged FEMA's  approval to construct a prototype, it was not the intent of Congress for FEMA to prepare a highly biased, pre-conceived, and completely unenlightened "evaluation" of a well-researched new technology.

We are appalled by  a Federal bureaucracy that thinks it has the power to stop technological progress with so little knowledge.  No private enterprise would dare make an arrogant presumption of the type FEMA has made with an "evaluation" of this magnitude!

 

 

 

FEMA CONCLUSIONS:

Conclusions

 

In light of the Agency's review of the WI floating home technology, FEMA can not support testing or research into the viability of the WI Land-Locked Floating Home System.  This is based on the determination that the concepts on which floating structure systems are based raise several serious engineering, floodplain management, financial, and emergency management concerns.

 

The Agency's concerns about floating home technologies are not unique to the WI floating home proposal.  FEMA has extensive knowledge of the performance floodproofing technologies. This, combined with the limited data provided by WI, permitted FEMA to complete this comprehensive review of the floating home technologies, which includes WI's proposal.  Therefore, any additional submission of supporting data would not alter the findings of conclusions of our report.

 

The Congressional intent in this matter is for FEMA to be receptive to testing new technologies that in no way place an increased financial burden on the Federal government, including the National Flood Insurance Fund, as well as State and local governments; result in increased damage to structures located in floodprone areas; or place residents of floodprone areas at greater risk of financial loss, injury, or death.  FEMA believes all the above could occur as a result of allowing floating homes under the NFIP.