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Council questions 'adding levels' rule as flood changes may affect housing affordability
Summary
Councilors pressed staff on how the revised 'substantial improvement' rule — which can trigger elevation when a homeowner adds a level — could block smaller homeowners from adding space. Staff said FEMA policy and insurance implications justify the threshold.
Councilor Susan (speaker 5) raised affordability concerns during the Dec. 2 hearing on PA 24‑01, asking whether the amendment’s test for substantial improvement would prevent homeowners who cannot afford full elevation from adding a second story. “They can't afford they don't wanna build out because they know it's gonna trigger having to elevate the home to base flood elevation,” she said.
Planning staff responded that FEMA’s rules push communities to avoid increasing insurable value without corresponding flood protection and noted that, in some cases, elevating a house could be less expensive than adding an entire new level. Staff emphasized the amendment is intended to close a loophole where rising construction costs might allow an owner to add value without meeting the 50% threshold that would otherwise require bringing the structure into compliance.
