Florida National Guardsmen evacuate flood victims in Arcadia, Fla., in the wake of Hurricane Ian on Oct. 3, 2022. (Photo: US Army/Spc. Samuel Herman)
July 7, 2024 by David Silverberg
Project 2025, a blueprint for post-election decisionmaking in a second Donald Trump administration, is recommending termination of the National Flood Insurance Program (NFIP).
All of Southwest Florida and its residents rely extensively on NFIP for affordable insurance in the face of events like hurricanes, storm surge and flooding.
“The NFIP should be wound down and replaced with private insurance starting with the least risky areas currently identified by the program,” states Project 2025.
It’s a radical proposal that could have a devastating fiscal impact on Southwest Floridians.
A quick primer on Project 2025
Project 2025 is a sweeping, 887-page tome of recommendations for presidential and legislative changes to be made under a conservative president, in this case, upon the election of Donald Trump.
The Project is actually a continuation of an effort by the conservative, Washington, DC-based Heritage Foundation think-tank that began in 1981. Then, the Foundation published a book called Mandate for Leadership with conservative policy recommendations. These were largely adopted by President Ronald Reagan, who handed out the book at his first Cabinet meeting.
Since then, a Mandate has been published every four years.
Project 2025 is a continuation of the Mandate series, only broader, more comprehensive, more radical and entirely Trumpist. It has also expanded beyond just the book and policy recommendations to include recruitment of personnel, training for those people and a 180-day Playbook for immediate implementation should there be a change of administrations.
Because of the radical nature of its current recommendations and Trump’s avowed pursuit of retaliation, revenge and retribution, Project 2025 is getting much more attention than previous Mandates.
It is sweeping in that it includes a complete reorganization of the federal branch, installment of ideological loyalists in place of non-political civil servants and reorientation of government toward unchecked presidential rule.
A quick primer on the National Flood Insurance Program
In 1968 Congress passed the National Flood Insurance Act, spurred by losses in Florida and Louisiana caused by Hurricane Betsy and its storm surge. The bill was signed by President Lyndon Johnson and led to establishment of the NFIP to protect Americans from the financial hardships of flooding.
The program, which is administered by the Federal Emergency Management Agency (FEMA), takes three forms.
One is mapping flooding risk along rivers and coasts. By 2018, the fiftieth year of the program, NFIP had mapped all of the nation’s populated areas, or 1.1 million miles. Among other things, these maps help mortgage lenders determine flood insurance requirements.
A second goal is to mitigate risk by supporting local flood prevention and management measures. The program’s managers estimated this saves the country over $1.6 billion each year in flood losses.
The third pillar—and the one closest to everyday property owners in Southwest Florida and across the country—protects insurance policyholders from financial flood losses. In 2018, 5 million people held NFIP policies in 22,000 communities across the country.
Under NFIP, homeowners who meet its requirements can get flood insurance for most buildings and dwellings of all sorts, including condominiums, mobile homes on foundations, rental units and more. Policyholders are charged lower than market rates to make it affordable. Many commercial insurers don’t offer flood insurance and NFIP is the only option.
While homeowners are not required to purchase the insurance, some federally-backed mortgages require it if the building is in a Special Flood Hazard Area—places especially prone to flooding.
Given Florida’s susceptibility to storms, its flat terrain and its extensive coastline along the Gulf of Mexico and the Atlantic Ocean, NFIP is crucial to protecting Floridians and making life affordable.
In Southwest Florida, the City of Naples and Everglades City joined NFIP in 1970. Charlotte County joined in 1971. Collier County followed in 1979. Lee County joined in 1984 when it did its first flood insurance study and created maps to establish flood zones and determine elevations. Today, there are 51,103 NFIP policyholders in Lee County (statistics are unavailable for Collier and Charlotte counties).
Participation in the program “is crucial for coastal communities such as Lee County because most standard homeowner’s insurance policies do not cover flood damage, and without access to NFIP coverage, property owners would have to bear the full financial burden of flood-related losses or pay higher premiums from private insurers,” states the Lee County website.
Project 2025 versus NFIP
Project 2025 has no use for NFIP.
In its chapter on the Department of Homeland Security (DHS), it deals with FEMA and dismisses NFIP in a single paragraph on page 153:
“FEMA is also responsible for the National Flood Insurance Program (NFIP), nearly all of which is issued by the federal government. Washington provides insurance at prices lower than the actuarially fair rate, thereby subsidizing flood insurance. Then, when flood costs exceed NFIP’s revenue, FEMA seeks taxpayer-funded bailouts. Current NFIP debt is $20.5 billion, and in 2017, Congress canceled $16 billion in debt when FEMA reached its borrowing authority limit. These subsidies and bailouts only encourage more development in flood zones, increasing the potential losses to both NFIP and the taxpayer. The NFIP should be wound down and replaced with private insurance starting with the least risky areas currently identified by the program.”
Project 2025 has numerous authors and, as Edwin Feulner, founder of the Heritage Foundation, is proud to point out in an afterword, it draws on the expertise of 360 experts and 50 organizations. The recommendation to terminate NFIP is under the byline of Ken Cuccinelli.
Cuccinelli has long been known as an ideological extremist. He ran for governor of Virginia in 2013, losing to Democrat Terry McAuliffe. He had a tempestuous tenure as Virginia’s attorney general from 2010 to 2014 where he denied climate change and fought research into it, even launching an investigation of a climate scientist whom he accused of fraud for his scientific conclusions. In this case, Cuccinelli was rebuffed by the Virginia Supreme Court.
He’s an anti-immigration hardliner who has advocated repeal of birthright citizenship. Under Trump he was appointed acting director of the US Citizenship and Immigration Services directorate of DHS. However, his appointment was disputed and resulted in suspension of all his directives. At the same time he was appointed acting deputy secretary of DHS but this too was determined to be improper by the Government Accountability Office. He was the subject of whistleblower complaints for his decisions regarding handling DHS intelligence.
After Trump’s departure from office, Cuccinelli joined the Heritage Foundation as a visiting fellow and last year in Florida he launched the Never Back Down Political Action Committee on behalf of Gov. Ron DeSantis’ presidential bid.
Analysis: A fiscal fiasco
Termination of NFIP would be as fiscally catastrophic for Southwest Florida as the worst, most destructive hurricane—in fact, much worse. It’s not enough that Florida is facing an insurance crisis anyway—this would dump yet another cascade of woe and expense on homeowners.
It would immediately impoverish existing homeowners who wouldn’t be able to afford commercial flood insurance—if companies even offered it. More than likely, most would have to leave the state for less expensive areas.
It would create two classes of Floridians: the uninsured and the ultra-rich. The uninsured would be wiped out every time there was a storm or flooding event because they would have no backstop or support. The ultra-rich, already paying high premiums for property insurance, would be the only ones able to afford what would be staggering flood premiums at commercial rates. Not even the merely wealthy would be able to keep up.
Flood insurance for Southwest Florida’s most flood-prone areas, its barrier islands like Gasparilla, Pine, Captiva and Sanibel, would be astronomical. Rates for property on larger islands like Estero and Marco would hardly be better.
This would come amidst the ravages of climate change, which is incontrovertibly causing more frequent and intense storms, greater storm surge, sea level rise, tidal inundation and more frequent flooding—and nowhere is this truer than in Florida, which is perhaps the most climatically vulnerable state in the union.
Lee County is already in a crisis because it failed to meet FEMA requirements for permitted rebuilding after Hurricane Ian and faced the loss of its discount under the Community Rating System. That’s a FEMA program providing discounts on flood insurance premiums to communities that exceed NFIP minimum requirements.
Without the discount, affected homeowners are looking at hikes of $300 to $500 in their insurance bills. Potential loss of the discount has caused distress, fear and anger among Lee County property owners and officials.
NOW IMAGINE THE COST IF THERE IS NO FEDERAL FLOOD INSURANCE AT ALL! THAT’S WHAT PROJECT 2025 IS PROPOSING.
This disaster wouldn’t just affect Southwest Florida: the end of NFIP would hit every community on every body of water that could flood: oceans, lakes, rivers, streams, even canals. Even places inland and as landlocked as South Dakota, Nebraska, Arizona and New Mexico would be affected.
In 2018 FEMA estimated that 13 million Americans lived in flood zones. However, that same year a study, “Estimates of present and future flood risk in the conterminous United States,” by seven scientists called the FEMA estimates too low. They put the number at 41 million. That has probably risen in the years since and is expected to rise even further in the years ahead.
The scientists also noted that “…It is evident that the absolute value of assets on the Floridian floodplain is also particularly high at $714 billion: Florida is thus a hotspot of flood exposure.”
Imagine over 40 million Americans stripped of access to affordable, government-backed flood insurance as Project 2025 envisions.
Project 2025 is scornful of NFIP’s “subsidies and bailouts” that “only encourage more development in flood zones, increasing the potential losses to both NFIP and the taxpayer.”
However, there’s another way of looking at this: NFIP policyholders are getting the benefit of the tax dollars that they paid to the US Treasury.
It always needs to be remembered that taxes aren’t a one-way street. The taxpayer puts money into the national treasury—but the taxpayer also gets benefits from the taxes he or she paid and those benefits take many different forms.
In this case, taxpayers living in flood zones get the benefit of their tax dollars in the form of subsidized federal flood insurance at lower than commercial rates. It isn’t a handout or a bailout; it’s a purchase made through taxes.
As for encouraging building in flood zones, as Lee County residents have discovered, FEMA is very strict and alert to building and construction in flood plains and communities participating in NFIP have to rigorously adhere to FEMA standards.
Rather than encouraging unregulated building, NFIP provides an incentive for communities and individuals to prepare for climate change, build resilience, strengthen homes and adhere to firm standards.
Commentary: The consequences of Project 2025
In the past, presidents and political parties didn’t rely out outside entities like Project 2025 for these kinds of sweeping proposals. Instead, they laid out their ideas for the entire electorate to see in the party platforms that they adopted through consensus and party input at their national political conventions.
In 2020 the Republican Party surrendered its political platform to Donald Trump, not bothering to adopt a set of proposals from Party members as it had in the past. Instead it stated that “the Republican Party has and will continue to enthusiastically support the President’s America-first agenda.” It adjourned without adopting a new platform “until the 2024 Republican National Convention.”
In the absence of a Party platform, there is Project 2025 to provide the world with a roadmap of Republican intentions.
As alarm has spread over the Project’s recommendations, Trump has disavowed any knowledge or awareness of it.
“I know nothing about Project 2025,” he posted on his Truth Social platform on July 5. “I have no idea who is behind it. I disagree with some of the things they’re saying and some of the things they’re saying are absolutely ridiculous and abysmal. Anything they do, I wish them luck, but I have nothing to do with them.”
However, as Edwin Feulner noted in his afterword to Project 2025, the Heritage Foundation Mandates have had Trump’s attention since 2016. That one “earned significant attention from the Trump Administration, as Heritage had accumulated a backlog of conservative ideas that had been blocked by President Barack Obama and his team.”
Feulner continued: “Soon after President Donald Trump was sworn in, his Administration began to implement major parts of the 2016 Mandate. After his first year in office, the Administration had implemented 64 percent of its policy recommendations.”
Since it’s safe to say that Trump lies with every breath he takes, his protestations of ignorance of Project 2025 and its origins ring hollow. Furthermore, since his word is worthless, so is any pledge he makes not to implement Project 2025.
Even if Trump has not or will not read all 887 pages (hard to imagine him reading anything longer than an X posting!), his cultists will be looking to Project 2025 for guidance if he’s elected. In keeping with the Heritage plan, they’ll seek to implement its proposals in the first 180 days of his administration, many through executive action.
This article looks at just one small slice of Project 2025 that directly affects Southwest Florida. But if implemented as a whole, Project 2025 will be a disaster for all of America. Coupled with the total presidential immunity just granted by the Supreme Court, it will result in a radical reordering of the United States and American society. It’s a roadmap aimed at enabling a total dictatorship of unchecked power enforced by advanced technologies. Or as Winston Churchill put it when speaking of the Nazis, “all that we have known and cared for, will sink into the abyss of a new Dark Age made more sinister, and perhaps more protracted, by the lights of perverted science.”
The world knows America is at an inflection point. The battle is on between democracy and dictatorship. Project 2025 makes clear what’s at stake—for every Southwest Floridian and every American citizen.
This is the first in an occasional series of articles examining the implications of Project 2025 for Southwest Florida and the nation.
Liberty lives in light
© 2024 by David Silverberg