Post by Michael Newman on Aug 20, 2024 17:58:24 GMT
August 20, 2024
Deborah Jenkins
Executive Director
Oklahoma Housing Finance Agency
100 N.W. 63rd Street
Oklahoma City, OK 73116
Deborah Jenkins:
The Insurance Institute for Business & Home Safety (IBHS) is pleased to offer the following comments for your consideration in response to Oklahoma Housing Finance Agency (OHFA)’s 2025 QAP Second Draft for public comment.
We strongly encourage OHFA to require or incentivize through the scoring criteria a designation from IBHS’s FORTIFIED™ program for all projects seeking LIHTC funding in Oklahoma.
Based on decades of scientific research, IBHS’s FORTIFIED™ program is a set of voluntary, beyond-code construction upgrades that improve a building’s resistance to the effects of high winds, hurricanes and even tornadoes. The FORTIFIED program is available for single-family houses, multifamily properties, and commercial structures. The program features a technical standard and an independent verification process that ensures that buildings obtaining a FORTIFIED designation from IBHS have, in fact, reduced their risk. To date, more than 70,000 structures have been designated by the FORTIFIED program across the country.
To require FORTIFIED for all projects, we suggest the following edits be made to OHFA’s 2025 QAP Second Draft:
Threshold Criteria
11. Resilient Construction. Commit to resilient construction standards. All projects must obtain certification from the Insurance Institute for Business & Home Safety for a FORTIFIED designation with hail supplement.
To incentivize resilient construction standards, we suggest the following edits be made to OHFA’s 2025 QAP Second Draft:
Selection Criteria
8. Resilient Construction
Total Points Possible: 3
Developments built with resilient construction standards and that receive a FORTIFIED Multifamily designation from the Insurance Institute for Business and Home Safety (IBHS) will be awarded up to 3 points as described below. Resilient construction standards are optional.
To reduce damage to residential, commercial and multifamily structures and help businesses re-open more quickly following severe weather, the Insurance Institute for Business & Home Safety (IBHS) developed FORTIFIED™ Multifamily, a voluntary, resilient construction and re-roofing standard and designation/compliance program. FORTIFIED employs an incremental approach with three levels of designations available so design professionals can work with building owners to choose a desired level of protection that best suits their budgets and resilience goals.
a. FORTIFIED Roof with hail supplement – 1 point
b. FORTIFIED Silver with hail supplement – 2 points
c. FORTIFIED Gold with hail supplement – 3 points
As set forth below, IBHS’s FORTIFIED program provides a science-based, field-proven tool for OHFA to incorporate resilience standards into the 2025 QAP. Investment in resilience will create safer homes that can withstand the increasingly severe weather (like tornados and hailstorms) Oklahoma faces. In addition, it will make these properties lower risk (and therefore more attractive risks) for property insurers.
Oklahoma’s geographic location makes it the epicenter of severe convective storms each year in the United States, specifically violent tornadoes and hailstorms with large hail. Oklahoma averages more severe thunderstorm watches issued by the National Weather Service each year than any other state. Comanche County, Oklahoma leads the nation averaging 21 severe thunderstorm watches each year. Across nearly all Oklahoma counties, the probability of experiencing severe hail (1 inch or greater) in a given year is near 100%. Since tornado record keeping began in 1950, every county in Oklahoma has experienced at least 20 tornadoes. And five counties, Oklahoma, Caddo, Canadian, Osage, and Cleveland have experienced more than 100 tornadoes.
Background
IBHS is a 501(c)(3) organization enabled by the property insurance industry’s investment to fund building safety research that leads to real-world solutions for home and business owners, helping to create more resilient communities. We conduct this work from our Research Center, located in Richburg, South Carolina.
Severe weather disrupts lives, displaces families, and drives financial loss. IBHS delivers top-tier science and translates it into action so we can prevent avoidable suffering, strengthen our homes and businesses, inform the insurance industry, and support thriving communities. The perils we study at IBHS are part of the natural world in which we live, but social and economic disasters occur when these perils meet human populations that live or work in harm’s way. To break the cycle of destruction, it is essential to address all aspects of the building performance chain: where you build, how you design and construct, and how well you maintain and repair. As a building science institute, IBHS focuses on the ways that weather behaves, what makes homes and businesses vulnerable, and how our buildings can be more resilient. We exist to help ensure that the spaces where people live, learn, work, worship, and gather are safe, stable, and as strong as the best science can equip them to be.
Resilience is a Housing Issue
We encourage OHFA to treat resilience as a housing issue. OHFA’s mission is to provide housing resources with an eagerness to serve. We assert that this mission cannot be met without investments in resilient construction.
Homes are not “quality” unless they are sufficiently resilient to withstand knowable risk from severe weather. Investing in resilience for affordable housing helps ensure that people are not only housed, but that they remain housed following natural disasters. Quality housing that withstands severe weather allows working families to return home following natural disasters, which in turn supports local economies and economic revitalization by preventing businesses from closing from low demand and want of workers, protecting the local tax base.
Housing is not “affordable” unless it provides savings to the resident not just on the day of purchase (or lease signing), but on an ongoing basis as well. Investments in resilience provide ongoing savings to residents. Generally, risk reduction results in avoided damages from severe weather and reduced insurance premiums reflecting the reduction in risk.
Starting this November, Strengthen Oklahoma Homes will provide grants to help Oklahomans retrofit or construct their homes to IBHS’s FORTIFIED standard (with the hail supplement). Priority will be given to Oklahoma’s lowest income residents and Oklahomans who live in areas prone to severe weather, like tornados. As a significant source of funding for affordable housing in Oklahoma, OHFA’s LIHTC program could become a critical tool for strengthening the resilience in the state by joining the Oklahoma Insurance Department in using FORTIFIED as a construction standard.
FORTIFIED Strengthens Resilience
FORTIFIED provides property owners with the ability to achieve three increasing levels of resilience:
FORTIFIED Roof is the foundation of FORTIFIED because an estimated 70 to 90 percent of catastrophic homeowners’ insurance claims include roof damage, and damaged roofs can lead to water intrusion that significantly amplifies damage. FORTIFIED Roof provides a system that strengthens the roof through (i) more and stronger nails, (ii) locked-down edges, and (iii) a sealed roof deck, which work in concert to keep the wind and rain out.
FORTIFIED Silver adds increased levels of resilience through requirements on windows, doors, and siding.
FORTIFIED Gold adds requirements related to a continuous load path from the roof to the foundation.
The FORTIFIED hail supplement requires impact resistant shingles rated by IBHS that show they can withstand hail up to 2 inches in diameter. These shingles perform best when tested against realistic hailstones and better protect homes.
Studies following Hurricane Sally (in Alabama) and Hurricanes Matthew, Florence, Dorian, and Isaias (in North Carolina) concluded that FORTIFIED designated homes are less likely to have an insurance claim and, for those homes with insurance claims, claims that are smaller on average.
The value of FORTIFIED has also been explored in a 2022 study from the University of Alabama’s Culverhouse College of Business, which concluded that building or retrofitting to FORTIFIED has relatively minimal costs and a strong rate of return. Findings include:
By constructing a new multifamily building to FORTIFIED Gold, property owners could realize an 8.1 to 72 percent internal rate of return on a marginal cost increase of no more than 1.5 percent of total cost of construction. For investments in retrofitting an existing multifamily building to FORTIFIED Roof, a property owner could realize an 8.3 to 35 percent internal rate of return on the investment for the property owner.
Public Investment in FORTIFIED
FORTIFIED keeps roofs on, water out, blue tarps off, families in place, and communities intact. As a result, federal and state agencies are increasingly turning to FORTIFIED when investing in resilient housing.
In addition to creating more resilient housing for Oklahoma residents, resilience requirements in housing programs like the LIHTC program have an important effect on workforce and skills development. We have observed in Alabama and Louisiana that references to the FORTIFIED program in government programs creates opportunities to educate developers, builders, and contractors about FORTIFIED. Once these essential participants in the housing market build to FORTIFIED because of program or funding requirements, they develop a comfort level with the work and costs associated with FORTIFIED. This can result in voluntary take-up on other projects unconnected to government funding sources. In this way, QAP resilience requirements can have an even broader impact on the built environment than those projects funded by grantees.
Requiring or incentivizing FORTIFIED in OHFA’s LIHTC program could significantly increase the number of Oklahomans who live and do business in resilient homes and buildings.
Thank you for the opportunity to contribute to this critical issue. If you have any questions, please do not hesitate to contact me at mnewman@ibhs.org.
Sincerely,
Michael Newman
General Counsel
Insurance Institute for Business & Home Safety
Deborah Jenkins
Executive Director
Oklahoma Housing Finance Agency
100 N.W. 63rd Street
Oklahoma City, OK 73116
Deborah Jenkins:
The Insurance Institute for Business & Home Safety (IBHS) is pleased to offer the following comments for your consideration in response to Oklahoma Housing Finance Agency (OHFA)’s 2025 QAP Second Draft for public comment.
We strongly encourage OHFA to require or incentivize through the scoring criteria a designation from IBHS’s FORTIFIED™ program for all projects seeking LIHTC funding in Oklahoma.
Based on decades of scientific research, IBHS’s FORTIFIED™ program is a set of voluntary, beyond-code construction upgrades that improve a building’s resistance to the effects of high winds, hurricanes and even tornadoes. The FORTIFIED program is available for single-family houses, multifamily properties, and commercial structures. The program features a technical standard and an independent verification process that ensures that buildings obtaining a FORTIFIED designation from IBHS have, in fact, reduced their risk. To date, more than 70,000 structures have been designated by the FORTIFIED program across the country.
To require FORTIFIED for all projects, we suggest the following edits be made to OHFA’s 2025 QAP Second Draft:
Threshold Criteria
11. Resilient Construction. Commit to resilient construction standards. All projects must obtain certification from the Insurance Institute for Business & Home Safety for a FORTIFIED designation with hail supplement.
To incentivize resilient construction standards, we suggest the following edits be made to OHFA’s 2025 QAP Second Draft:
Selection Criteria
8. Resilient Construction
Total Points Possible: 3
Developments built with resilient construction standards and that receive a FORTIFIED Multifamily designation from the Insurance Institute for Business and Home Safety (IBHS) will be awarded up to 3 points as described below. Resilient construction standards are optional.
To reduce damage to residential, commercial and multifamily structures and help businesses re-open more quickly following severe weather, the Insurance Institute for Business & Home Safety (IBHS) developed FORTIFIED™ Multifamily, a voluntary, resilient construction and re-roofing standard and designation/compliance program. FORTIFIED employs an incremental approach with three levels of designations available so design professionals can work with building owners to choose a desired level of protection that best suits their budgets and resilience goals.
a. FORTIFIED Roof with hail supplement – 1 point
b. FORTIFIED Silver with hail supplement – 2 points
c. FORTIFIED Gold with hail supplement – 3 points
As set forth below, IBHS’s FORTIFIED program provides a science-based, field-proven tool for OHFA to incorporate resilience standards into the 2025 QAP. Investment in resilience will create safer homes that can withstand the increasingly severe weather (like tornados and hailstorms) Oklahoma faces. In addition, it will make these properties lower risk (and therefore more attractive risks) for property insurers.
Oklahoma’s geographic location makes it the epicenter of severe convective storms each year in the United States, specifically violent tornadoes and hailstorms with large hail. Oklahoma averages more severe thunderstorm watches issued by the National Weather Service each year than any other state. Comanche County, Oklahoma leads the nation averaging 21 severe thunderstorm watches each year. Across nearly all Oklahoma counties, the probability of experiencing severe hail (1 inch or greater) in a given year is near 100%. Since tornado record keeping began in 1950, every county in Oklahoma has experienced at least 20 tornadoes. And five counties, Oklahoma, Caddo, Canadian, Osage, and Cleveland have experienced more than 100 tornadoes.
Background
IBHS is a 501(c)(3) organization enabled by the property insurance industry’s investment to fund building safety research that leads to real-world solutions for home and business owners, helping to create more resilient communities. We conduct this work from our Research Center, located in Richburg, South Carolina.
Severe weather disrupts lives, displaces families, and drives financial loss. IBHS delivers top-tier science and translates it into action so we can prevent avoidable suffering, strengthen our homes and businesses, inform the insurance industry, and support thriving communities. The perils we study at IBHS are part of the natural world in which we live, but social and economic disasters occur when these perils meet human populations that live or work in harm’s way. To break the cycle of destruction, it is essential to address all aspects of the building performance chain: where you build, how you design and construct, and how well you maintain and repair. As a building science institute, IBHS focuses on the ways that weather behaves, what makes homes and businesses vulnerable, and how our buildings can be more resilient. We exist to help ensure that the spaces where people live, learn, work, worship, and gather are safe, stable, and as strong as the best science can equip them to be.
Resilience is a Housing Issue
We encourage OHFA to treat resilience as a housing issue. OHFA’s mission is to provide housing resources with an eagerness to serve. We assert that this mission cannot be met without investments in resilient construction.
Homes are not “quality” unless they are sufficiently resilient to withstand knowable risk from severe weather. Investing in resilience for affordable housing helps ensure that people are not only housed, but that they remain housed following natural disasters. Quality housing that withstands severe weather allows working families to return home following natural disasters, which in turn supports local economies and economic revitalization by preventing businesses from closing from low demand and want of workers, protecting the local tax base.
Housing is not “affordable” unless it provides savings to the resident not just on the day of purchase (or lease signing), but on an ongoing basis as well. Investments in resilience provide ongoing savings to residents. Generally, risk reduction results in avoided damages from severe weather and reduced insurance premiums reflecting the reduction in risk.
Starting this November, Strengthen Oklahoma Homes will provide grants to help Oklahomans retrofit or construct their homes to IBHS’s FORTIFIED standard (with the hail supplement). Priority will be given to Oklahoma’s lowest income residents and Oklahomans who live in areas prone to severe weather, like tornados. As a significant source of funding for affordable housing in Oklahoma, OHFA’s LIHTC program could become a critical tool for strengthening the resilience in the state by joining the Oklahoma Insurance Department in using FORTIFIED as a construction standard.
FORTIFIED Strengthens Resilience
FORTIFIED provides property owners with the ability to achieve three increasing levels of resilience:
FORTIFIED Roof is the foundation of FORTIFIED because an estimated 70 to 90 percent of catastrophic homeowners’ insurance claims include roof damage, and damaged roofs can lead to water intrusion that significantly amplifies damage. FORTIFIED Roof provides a system that strengthens the roof through (i) more and stronger nails, (ii) locked-down edges, and (iii) a sealed roof deck, which work in concert to keep the wind and rain out.
FORTIFIED Silver adds increased levels of resilience through requirements on windows, doors, and siding.
FORTIFIED Gold adds requirements related to a continuous load path from the roof to the foundation.
The FORTIFIED hail supplement requires impact resistant shingles rated by IBHS that show they can withstand hail up to 2 inches in diameter. These shingles perform best when tested against realistic hailstones and better protect homes.
Studies following Hurricane Sally (in Alabama) and Hurricanes Matthew, Florence, Dorian, and Isaias (in North Carolina) concluded that FORTIFIED designated homes are less likely to have an insurance claim and, for those homes with insurance claims, claims that are smaller on average.
The value of FORTIFIED has also been explored in a 2022 study from the University of Alabama’s Culverhouse College of Business, which concluded that building or retrofitting to FORTIFIED has relatively minimal costs and a strong rate of return. Findings include:
By constructing a new multifamily building to FORTIFIED Gold, property owners could realize an 8.1 to 72 percent internal rate of return on a marginal cost increase of no more than 1.5 percent of total cost of construction. For investments in retrofitting an existing multifamily building to FORTIFIED Roof, a property owner could realize an 8.3 to 35 percent internal rate of return on the investment for the property owner.
Public Investment in FORTIFIED
FORTIFIED keeps roofs on, water out, blue tarps off, families in place, and communities intact. As a result, federal and state agencies are increasingly turning to FORTIFIED when investing in resilient housing.
- The Louisiana Housing Corporation requires a FORTIFIED Roof as a minimum construction standard in its 2024 QAP and provides additional scoring consideration for projects that build to FORTIFIED Silver and Gold.
- The Louisiana Housing Corporation requires FORTIFIED Gold as a minimum construction standard for projects funded by HUD CDBG-DR grants.
- The Mississippi Home Corporation incentivizes FORTIFIED Multifamily in its 2024 QAP scoring criteria.
- Alabama, Louisiana, and South Carolina help pay for FORTIFIED retrofits through grant programs managed by the state insurance departments. These states will soon be joined by grant programs in Kentucky, Minnesota, and Oklahoma, all of which have been enacted into law since 2023 although not yet operational. In addition, North Carolina provides homeowners with grants through the state wind pool, the North Carolina Insurance Underwriting Association.
- The Federal Home Loan Bank of Dallas invests in FORTIFIED through two mechanisms: as part of the scoring criteria for its Affordable Housing Program and through a new FORTIFIED Fund grant program.
- The U.S. Department of Housing and Urban Development’s new Green and Resilient Retrofit Program (GRRP) includes FORTIFIED as a covered expense for eligible property owners.
In addition to creating more resilient housing for Oklahoma residents, resilience requirements in housing programs like the LIHTC program have an important effect on workforce and skills development. We have observed in Alabama and Louisiana that references to the FORTIFIED program in government programs creates opportunities to educate developers, builders, and contractors about FORTIFIED. Once these essential participants in the housing market build to FORTIFIED because of program or funding requirements, they develop a comfort level with the work and costs associated with FORTIFIED. This can result in voluntary take-up on other projects unconnected to government funding sources. In this way, QAP resilience requirements can have an even broader impact on the built environment than those projects funded by grantees.
Requiring or incentivizing FORTIFIED in OHFA’s LIHTC program could significantly increase the number of Oklahomans who live and do business in resilient homes and buildings.
* * *
Weather events become natural disasters by devastating communities, damaging property, disrupting local economies, and dislocating families. This need not be the case. Solutions exist to strengthen the resilience of our homes—investments by OHFA can turn these solutions into a reality for Oklahoma residents.Thank you for the opportunity to contribute to this critical issue. If you have any questions, please do not hesitate to contact me at mnewman@ibhs.org.
Sincerely,
Michael Newman
General Counsel
Insurance Institute for Business & Home Safety