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structures that were built before the community or county joined the National Flood Insurance Program, Usually these buildings were constructed without taking account of flooding and are therefore at higher risk than those constructed according to floodplain management regulations (post- FIRM construction), but the National Flood Insurance Fund subsidizes the pre-FIRM insurance rates to keep them relatively affordable, The original idea was that over the long run the older buildings would reach the end of their design life and gradually be replaced by flood-resistant construction. In practice, this is taking longer than anticipated, Meanwhile, the expectation has grown that people who live in high-risk areas should pay actuarial insurance rates based on their exposure to risk. The Federal Emergency Management Agency is studying this issue to determine the feasibility of ending this discount. The third type of discount is the administrative grandfathering that occurs when a building is constructed in compliance with the local standards as based on the Flood Insurance Rate Map in effect at the time of construction, If the map is subsequently updated and the building's flood zone is changed, the structure is still subject to the rate appropriate to its originally designated zone. · The Federal Insurance Administration should continue to work to ensure equity in the discounts, particularly that provided for administrative grandfathering, Repetitive Losses When insurance claims are filed again and again for flood damage to a single building, that building becomes known as a "repetitive loss structure," There are relatively few insured structures in this category, but they account for a disproportionately large share of all the flood insurance claims filed and paid, While estimates vary, it appears that 2% of the policies held under the National Flood Insurance Program since its inception have accounted for 32% of the losses and received 38% of the dollars paid out from the National Flood Insurance Fund, Geographically, many of these losses are concentrated in the Gulf Coast states, As reported in its 1998 publication, Higher Ground, the National Wildlife Federation reviewed repetitive loss data and identified 300 communities as top candidates for mitigation opportunities in light of their extraordinary flood loss histories. "These 300 communities, located in 35 states, represent only 1.6% of the 18,700 communities enrolled in the National Flood Insurance Program. Their 31,574 repetitive loss properties are less than I % of all National Flood Insurance Program insured properties. Yet, from 1978 to August 1995, the repetitive loss properties in these communities received approximately $1.3 billion in flood insurance payments-49,8% of all National Flood Insurance Program repetitive loss payments and 20% of all National Flood Insurance Program loss payments nationwide," The pre-1999 strategy for alleviating losses due to repetitively flooded buildings relied on the structure's being substantially damaged, at which time it would be reconstructed, elevated, or floodproofed to prevent future damage, Unfortunately, due both to confusion about how "substantial" damage (or substantial improvement) should be measured, and also to a natural reluctance on the part oflocal officials to impose perceived hardships on owners of flood-damaged properties, communities have not been consistently declaring structures "substantially" damaged when in fact they are. This has resulted, over time, in buildings being repeatedly flooded because they are never declared by the community to be substantially damaged and thus are not upgraded (nor do their owners qualify for Increased Cost of Compliance payments under their flood insurance policies, which would help them pay for mitigation measures). According to the Federal Emergency Management Agency, 8300 Association of State Floodplain Managers -42- National Flood Programs in Review 2000