The Volokh Conspiracy

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Climate Change

Senator Schumer Protects Wealthy Landowners from Paying Risk-Based Flood Insurance Premiums

Effective climate adaptation depends upon effective price signals. So why is the Senate Majority Leader standing in the way?


The New York Times reported last week that Senate Majority Leader Charles Schumer discouraged the Federal Emergency Management Administration from rolling out new policies that would ensure coastal landowners pay risk-related flood insurance premiums. This policy change would have been particularly worthwhile given the threat of climate change and would have helped address concerns that the federal government is subsidizing construction in harm's way. But apparently it would also have increased insurance rates for a small percentage of affected property owners with outsized political influence, so Senator Schumer swung into action.

From the NYT report:

Senator Schumer objected to the flood-insurance overhaul when it was first announced in 2019, citing its potential to raise costs for people on Long Island. The new system would mean steeper rates for some high-value homes, and the southern shore of Long Island includes the Hamptons, which have some of the most expensive real estate in the country.

Senator Schumer's office told FEMA that the new rates could have a "severe impact" on some communities in New York, according to a person familiar with the conversation. . . .

As detailed in the NYT story, the policy change would actually save money for some homeowners, but would also have a significant effect on a small percentage of "higher-cost homes" in places like the Hamptons. In other words, Senator Schumer seems to oppose those climate policies that might impose greater costs on the rich.

Under the new approach, 23 percent of households with flood insurance would see their rates fall right away, by an average of $86 a month, according to data provided by FEMA, because the updated formula shows they have been overpaying based on their risk. Another 73 percent would see either no change or an increase of no more than $20 a month.

But for some of the remaining households, costs would go up significantly, according to others briefed on the changes.

Congress prevents FEMA from increasing a household's flood insurance premiums by more than 18 percent a year. Under the new system, some households would face that maximum annual increase for 10 years or more. As a result, their rates could increase at least fivefold over that time.

Those big rate increases would mostly apply to higher-cost homes, which under the current formula tend to underpay for insurance. Many of the people that would see a decrease live in lower-cost homes.

Senatorial hypocrisy on flood insurance and climate change is nothing new. Back in 2014, most members of the Senate Climate Caucus voted to gut changes to the National Flood Insurance Program that would have reduced subsidies for coastal development.

Climate change is a serious problem, but it's hard to take politicians seriously on the issue when they behave like this.

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  1. He probably knows climate change is fake and doesn't want to fleece his buddies.

    1. I'm kind of wondering what climate change has to do with it?

      Doesn't anyone try to look at the science?

      The seas are rising, a steady 3mm a year, for at least the last century.

      But most of the east coast is sinking, and faster than 3mm a year. Nobody has repealed continental drift, and the continents are moving at 50-90mm year, and while the East coast is moving west it's also sinking.

      I hate to say it but the Jersey shore is coming to a bad end no matter how you stack it, it's either going to subside into the Atlantic, or we'll have another glacial episode to end our current interglacial that will put it under a mile of ice, or best case the ice won't get that far and it will leave the current coast miles inland and nobody will want to live on a frigid plain miles from the ocean anyway.

      I was in Sedona 2 weeks ago enjoying the red sandstone that used to be the beach in a shallow ocean, it's a nice place again even though it was capped with basaltic lava flows for a few million years. I'm sure the east coast will be prime real estate again someday.

      1. Kazinski comment - "The seas are rising, a steady 3mm a year, for at least the last century."

        As Kaz's notes the seas are rising 3mm per year or approx 12in per century based on satellite measurements, 1.8-2.2mm per year based on tide gauge measurements.

        Which means the storm surges are increasing by approximately 3mm per year or 12in per century. The climate alarmists would have us believe that the storm surges are increasing by 10-30+mm per year or 4-10 ft per century. That aint happening.

        Frequency of storms havent increased after adjusting for observational limitation is earlier centuries. Atlantic storm frequency has been highly correlated with amo, with no correlation to a warming .

        note mann's march 2021 paper cancelling the AMO

        1. So what you are telling me is that in a century the east coast will be experiencing the results of 24inches height change. What does that mean to coastal populations?

          1. Don't build so close to the ocean, or at least don't build anything you don't mind rebuilding every 25-50 years.

            That isn't a new phnomenom, Alexandria subsided under the waves more than a thousand years ago, long before the first SUV:

            "Alexandria is well known for its archaeological sites where thousands of artifacts are submerged underwater, most notably the ancient Citadel of Qaitbay that covers an area of ​​22,500 square meters and houses more than 3,000 artifacts dating back to the Greek and Roman civilizations. Also in the Egyptian port city lies the Pharos (Lighthouse) of Alexandria, which is one of the Seven Wonders of the World."

      2. Sea levels are rising. The east coast is not sinking.

        1. Almost the entire east coast is sinking

          evaluate all the science, while avoid cherrypicking which is a very common error through out climate science resulting in erroneous conclusions.

        2. Almost certainly untrue. It is unlikely a coast would be static with respect to geology. New Orleans, built on a river delta that is no longer refreshed periodically, continues to sink.

          All land, coast or not, would be slowly sinking or rising. The question is how fast. Also the edge tends to wear away.

        3. Harvard and Woods Hole think it's sinking:
          “The fact that the mid-Atlantic is subsiding because of long-term geologic processes means that it will continue for centuries and millennia, in addition to whatever other changes in sea level occur,” Huybers said. “The mid-Atlantic is already having to cope with routine coastal flooding, and this problem is only going to get worse with time.”

      3. The world is constantly changing. That is the nature of it all. Water levels go up and down. Temperatures and climates fluctuate throughout the years. That is how our system works, has always worked, and will work in the future. The human impact on this is very little if anything.

        "Climate change" in its current public frenzy inducing form is nothing but cover to enact the liberal agenda. Which is why every "solution" is steeped in socialism.

        1. 'The human impact on this is very little if anything.'

          Selective humility. The human impact on the natural environment has been massive.

      4. Glaciers are the problem with the East Coast and why it is sinking.

        Walk across wet sand on a beach sometime -- and notice how the sand swells up around your footprints, and then starts to subside.

        When the mile-thick glaciers were over New York State, all that weight caused the east coast to rise up similar to the sand around your footprints -- granite is somewhat elastic on that big a scale.
        And now that the weight is removed, inshore New York is going back up and the coast is going back down.

        This is a real issue in DownEast Maine and has been for over a century.

  2. "[I]t's hard to take politicians seriously on the issue when they behave like this." Someone took Chuck Schumer seriously? Really??

  3. Climate Change? This isn't about climate change. Living in existing flood plains is a major problem country-wide.

    I can remember even as a small child, watching news reports of flooding on the Mississippi, and one man saying "this is the 8th time I've flooded in 10 years". Even then, I wanted to know why he just didn't move. The reason was that the insurance paid his repairs, and he didn't pay the proper bill for the insurance.

    I'm just disappointed that you are trying to make this about climate change. You're not dumb, Mr. Adler. You know that this is about current problems. You just added climate change as a headline drop to turn more heads.

    1. Because climate change is making flooding worse.

      1. By a few millimeters?

        As the total energy increase from gw is on the order of one percent, you could expect storm power and frequency increases on that rate, which would take decades to even suss out.

        1. I dunno, is a storm surge a few millimetres?

      2. Nige
        March.26.2021 at 6:45 am
        "Because climate change is making flooding worse."

        Nige - do you have actual data for that statement - or are just repeating the statements at those anti - science websites such as skeptical science.

        1. I've read enough persuasive scientists on the subject to be convinced.

          1. citations please - you made the claim that "Because climate change is making flooding worse.”

            Back it up with citations - at least one


                  there are just as many studies predicting more droughts due to a warming world. - Which is correct more droughts, more floods, more floods and droughts , or just more hype.

      3. This what to the IPCC's own assessment is about flooding:

        'There is limited to medium evidence available to assess climate-driven observed changes in the magnitude and frequency of floods at regional scales because the available instrumental records of floods at gauge stations are limited in space and time, and because of confounding effects of changes in land use and engineering. Furthermore, there is low agreement in this evidence, and thus overall low confidence at the global scale regarding even the sign of these changes."

        So not only does the evidence not agree, but they aren't even sure if it's getting better or worse.

        The definition of "low confidence" is "neither implies or excludes".

        The IPCC (2018) also says that it has low confidence droughts are getting worse, wildfires are getting worse, or extreme weather is getting worse, however I hear it all over the news, NPR, CNN, politicians, so that's where you heard it from. I don't know if they are ignorant or purposely lying.

        1. Kaz - but the narrative is more important than the actual science. Look at Mann's recent study (march 2021 ) deleting the AMO - consistent with his HS deleting the mwp & the LIA

          1. Yeah, no molesting of data going on there at all. No siree.

          2. It's why there is such a push to de-platform skeptics, most of whom, like me believe there has been modest warming, that is also modestly beneficial.

            If you point out on facebook, or twitter there is not enough evidence to form any conclusion about flooding, wildfires, droughts, or extreme weather, then they flag it as disinformation. (Notice I didn't say no evidence, because the evidence cuts both ways, and is contradictory).

        2. Hmm. Your quote isn't about disagreement, it's about limitations in studies and not having enough clear data to say for sure. I would not read that paragraph and think, oh, well, that's all right then. Nor this one:

          'However, recent coastal assessments at the national and regional scale and process-based studies have provided further evidence of the vulnerability of low-lying coastlines to rising sea levels and erosion, so that in the absence of adaptation there is high confidence that locations currently experiencing adverse impacts suchas coastal erosion andi nundation will continue to do so in the future due to increasing sea levels in the absence of changes in other contributing factors.'

        3. Yeah, the same with the whole drought and dust-storm thing - they have low confidence in their current ability to make accurate predictions because of a lack of data - if you find that reassuring, well, you probably complained that the reason there were more covid cases was because there was more testing. You're either a fool or deliberately misreading.

        4. Really not very reassuring at all

          'Post-AR4 studies indicate that there is medium confidence in a projected increase in duration and intensity of droughts in some regions of the world, including southern Europe and the Mediterranean region, central Europe, central North America, Central America and Mexico, northeast Brazil, and southernAfrica.'

          I mean, you guys do get that the major problem about climate change is that weater becomes increasingly unpredictable, right? That 'low confidence ' in projections doesn't mean it's not going to happen, it means that it's too difficult to predict what is going to happen? And. That. Is. The. Fucking. Problem.

          1. "Post-AR4 studies indicate that there is medium confidence in a projected increase in duration and intensity of droughts..."

            Those studies are models which have shown no skill in making predictions about what will happen in the future.

            It's all just a wild ass guess. That is at least the serious predictions are, then there is the whole class of catastrophic biblical plagues that are made up to scare children like yourself.

            1. The question whether human factors are destabilizing climate strikes me as largely separate from the question whether modeling can predict accurately what will happen. The former question can be investigated by looking backward for evidence of what has happened, and by measuring presently active variables thought for good reason to affect climate.

              The latter question requires forward-looking predictions about future phenomena far too complex and interactive to be reasonable candidates for accurate modeling. Your critique seems to insist that without accurate predictions from models, it remains impossible to determine whether anything is happening at all.

              I don't think your objection bears very strongly on the first question, whether human activity has destabilized climate. Success or failure of models can't be the test of what can be shown with evidence to have happened already.

      4. Nige, see:

        That was 83 years ago -- the storm surge of the 1938 Hurricane -- and the 1635 one was even worse.

        And there were a lot of automobiles around in 1635, weren't there...

        And you do know that (a) we didn't even have spy satellites before the 1960s, and those involved dropping physical film to be caught by airplanes. Our accurate data goes back maybe 30 years, if that. Irrelevant...

        1. You think the occurrence of storms in the past means we won't or can't get worse and more frequent storms in the future, what is this idiocy?

    2. Ben's point which is correct is that the pricing for flood insurance doesnt properly take into account the actual insurance risks.

      A good example of the underpricing of the fema insurance premiums. A former client of mine purchased one of the islands off the coast of SC in the early 1950's. The price of the island approximated the value of the timber on the island. 50+ years later, the land is selling at $1m+ per acre in a large part facilitated by the below market insurance premiums.

      1. Not just that -- I'm guessing that the REA is subsidizing the electric cable to the island (which likely has to be replaced with frequency), etc. But your point is quite valid -- the poor are subsidizing the rich.

  4. Why would anyone expect anything different from Schumer.
    Alex Baldwin has him by the balls

  5. Just wait until his tax increases are drafted. Any bets that the one tax that will be cut is by removing the SALT deduction cap. The SALT deduction allowed unlimited State And Local Taxes for homes to be deducted on tax returns, which essentially meant that the rest of the taxpayers were helping pay for the taxes on the Long Island compounds and mansions of Chuck Schumer’s richest constituents. The money saved by capping the deduction on those Long Island compounds and mansions helped fund the tax cuts for everyone else.

    Why are the Democrats trying to raise taxes as we start heading into the expected recession? One big reason is that they need the revenue from the tax increases to essentially finance uncapping the SALT deductions for their richest supporters. Sound crazy? Maybe, but we have been hearing indirectly from Democrat leaders that this was driving their push for tax increases since the Trump tax cuts were enacted.

    1. The loss/limitation at $10k of the salt deduction was trivial. Due to the changes in AMT or the increase in the standard deduction, the $10k Salt limitation, had a very negligible impact on the tax liability. State and local taxes were never deductible for amt. Prior to the 2017 tax act, individuals were effectively not getting a tax deduction for SALT because of AMT. The 2017 tax act, greatly increased the AMT exemption.

    2. I live in the People's Republic of NJ, and frankly it would be outright crazy to repeal the SALT deduction cap. And even crazier to subsidize the uber-wealthy who own shore homes and don't want to pay the true market price to insure them.

      Why do these politicians insist on stealing from the poor to give to the rich?

      1. They only thing the poor have to offer is votes, they get money from the rich.

    3. Bruce, the GOP is the party of the working class...

  6. Would someone send Bernie Sanders down the hall to kick Shumer's ass please.

    1. Bernie who has at least three mansions -- memory is four...

      Bernie probably is benefiting from this on his Lake Champlain beach mansion...

  7. The point of this is to take shots at Schumer, right? If not it makes no sense considering flood plains are everywhere and millions of non-Hamptons people live in them.

    1. "Certainly means testing it so the kind-hearted Hamptons dwellers, who don't need it, wouldn't get it, as they need to pay their fair share."

    2. " If not it makes no sense considering flood plains are everywhere and millions of non-Hamptons people live in them."

      There is a difference between elevation and beachfront -- it's the difference between water in your cellar and only having a cellar hole left. Both will be an insurance claim -- which do you think will be more?

  8. So much for the idea that the Democrats are socialists who are going to fleece the rich.

    1. My thought precisely. They are bought and paid for. And like the political prostitutes they are, they are delivering the goods.

    2. The parties are shifting...

      Democrats are becoming the party of the rich professional class. The bankers, the tech titans, the hedge fund managers, the trial lawyers, the "institutional" class.

      The GOP is becoming the party of the working class.

      When Rubio supports unionization at Amazon factories in Alabama and Schumer is protecting wealthy landowners in the Hamptons.... well...

      1. What does Rubio have against Amazon hourly workers? He may be supporting the unions to retaliate against Amazon, but that isn't going to do much for the workers, which is why only 6% of the private workforce is unionized.

        1. I wish that those who hate unions could go back in time 100 years and be made to work in pre-union factories for a month or so -- low wages, no workplace safety, no overtime, no weekends, 60 hour weeks. A veritable libertarian paradise.

          Now that workers have better conditions, it's easy to forget who got them. That was the unions.

          1. Krycheck,

            The problem is one of balance. It's possible for Private Industry to be too powerful, and abuse its workers. It's also possible for unions to be too powerful, and to abuse their power and position to the detriment of the rest of society.

            100 years ago, private industry was too powerful. And unions played a major role in workers rights. But eventually, unions became too powerful, and and that excessive power usage was part of their own downfall in the private sector. They made so many demands, that in many places, the very industry just wasn't competitive anymore. And in many places, the union ultimately was not even serving all its members, but a certain subsect of union leadership at the cost of its poorer workers.

            And in fact, you see abuse of power with the teachers unions today. They are frankly...too powerful. The fact that when everyone else is back at work in person, teachers can demand vaccines before our elderly...and then STILL demand they won't go back to work in person. Despite the damage being done to today's children.

            So balance here is key.

            1. I don't actually disagree with your larger point. I think there need to be checks and balances. I don't want either workers or management to be all powerful.

              But that's not most of the anti-union rhetoric that I hear.

              1. The way to really understand this is to understand the power struggles that go on, and how they can affect things.

                In the early days (ie, 1900), one of the advantages large companies often had is that they were effective monopolies in their local area. If you wanted to work, you worked for the local company. This could lead to abusive practices, because workers "couldn't leave". And that in turn led to unions.

                However, typically in an area with many different employers, unions aren't strictly needed. A bad employer will see employees jump ship to a better company. You'll still see unions, sometimes, in select areas, but they aren't as strictly needed. But when you do see larger unions (IE large teachers unions, large agricultural unions) you have a reversal of the early power situation. One big union, many employers. This is really a situation set up abuse by unions, which is what we see the most of today. The big, powerful, super-unions you see on the state and national scale, which flex their power and make employers and politicians tremble.

                Now, the Amazon situation in Alabama is somewhat unique. Amazon is playing the role of "big company employer" there, and there aren't a lot of good options elsewhere for employment in that local area. Which is why it goes back to the original situation.

                The power imbalances are what's important.

            2. Unions killed the railroad industry -- management helped, but it was the unions. For example, in the 19th century, there was a guy whose job was to shovel coal into the locomotive. In the 20th century, automatic stokers arrived, but you still needed someone to tend the fire and watch the water level in the boiler, adding to it so it didn't explode. OK.

              Then the Diesels arrive and the unions insist on having a "fireman" to shovel coal into the Diesel engine -- I am not making this up. Likewise while trains were once stopped by "brakemen" manually screwing down brake wheels on each car, by the 1930s it was all automatic air brakes, yet the union insisted on crews of 5 or 6 men, sometimes more.

              Look at Amtrak, which charges $2.75 for a can of Diet Pepsi that *I* can buy in the supermarket for 34 cents in the supermarket (12/$4) and still loses money in the deal.

              The arrogance of the teachers unions well may wake up the citizens to the mess that K-12 has become. I'm hoping...

          2. low wages, no workplace safety, no overtime, no weekends, 60 hour weeks.

            Thing is, every single one of those issues has since been addressed by a (some would say choking) web of regulation. To the extent unions were filling that gap 100 years ago, there's no longer any gap to fill.

            If the actual bottom line is "unions can always achieve better conditions than regulation and the free market afford, whatever those may be," that's somewhat tautological and perhaps not quite as poignant.

          3. I do appreciate what unions did 100 years ago, just as I appreciate the marvelous increase in mobility and farm production 150 years ago.

            But we are talking about now not then.

            The laws in this country make it possible to unionize when the workers wish too, but mostly now, workers choose not to. Hence unions have become coercive.

            I fully approve of voluntarily unionization, I abhor coercive unionization.

        2. "What does Rubio have against Amazon hourly workers?"

          I would think supporting their unionization would be supporting Amazon hourly workers.

  9. Sounds like the same reaction we had in Massachusetts. The new flood maps several years ago sparked intense pressure from politicians to declare the coast south of Boston not to be a flood zone. Most of those politicians will claim to be worried about climate change/crisis/emergency until a consequence lands in their back yard. Then they turn into King Canute and decree the waters to retreat.

    1. Yep. Follow the science, unless it inconveniences your constituents, and loses you votes.

    2. The new flood maps several years ago sparked intense pressure from politicians to declare the coast south of Boston not to be a flood zone.

      The problem with those maps is that they failed to distinguish between the Gulf of Mexico and New England, between New Orleans and Augusta, ME.

      First, we don't have long-term fresh-water flooding like they have along the Mississippi and in Houston. Look at the worst flood in Maine history -- the April 1, 1988 flood when several feet of snow melted in several inches of warm rain and several large cities were literally underwater. 12 hours later they weren't -- we have much better drainage and rivers that can handle far more water at flood stage.

      Second, most of our flooding is salt water flooding at high tide and that's only for about one hour out of every twelve because we have a ~10 foot drop in the sea level (even with storm surge) at low tide. The Gulf of Mexico has 2-3 foot tides.

      If New Orleans were Boston, it would only have flooded at high tide -- and have drained at low tide. What that means is that the flood isn't going to extend as far inland on ground of the same elevation -- because the water keeps running back out. Distance from the water source becomes relevant because the water doesn't have time to get to you if you are some distance away -- even though it could were there not tides and drainage.

      The new maps didn't take this into account, and it is a legitimate grievance.

  10. Please correct me if I'm wrong, but isn't there also no incentive to build a home that can take the brunt of a flood.

    1. Pretty hard to do that. You ever try to waterproof a celler where the water table goes higher than floor level?

      Boats float, that's why you are better off with a sump pump.

      But they do have houses where it floods regularly, bottom floor is concrete and tile, move all the furniture to the top floor when it floods, still a mess to clean up, doesn't help much if the foundations erode or 4' of silt gets laid down around and in the bottom floor.

      1. Pretty hard to do that. You ever try to waterproof a celler where the water table goes higher than floor level?

        No it isn't. For some reason, there are parts of Florida where you can't get flood insurance -- Rush Limbaugh spoke of it once and mentioned how one has to "self insure" via construction -- deeper footings. Then what is often done is having an open first floor, used as a carport, with just vertical structural walls -- open front and back toward the ocean so the waves can wash right through.

        Boats float, that’s why you are better off with a sump pump.

        Cellars float too -- anything that displaces water does -- and if you keep pumping the cellar dry while the ground water level rises around the house, you will either crack the foundation or pop the entire cellar out of the ground like a pimple. The latter will usually destroy the house, and even a cracked/shifted foundation can be rather expensive to fix.

        still a mess to clean up, doesn’t help much if the foundations erode or 4′ of silt gets laid down around and in the bottom floor.

        Which is why you intentionally flood it with clean water first. Then you have both eliminated the flotation issue and most of the dirty water coming in.

  11. There is a good reason private insurance companies won't right policies for people who build on flood plains. Sure the real estate gives your domicile a nice view, but it is a horrible idea to build a wooden structure on something that IS GOING TO FLOOD (if isn't a question of IF but WHEN) on a regular basis.

    I would have a little sympathy for someone who built on something that later shifted to a flood plain due to regular cyclical weather patterns or government damming water ways, but to knowingly do so, you shouldn't get "insurance" protection on the government dime. You should get to enjoy your view and then enjoy the bill to fix up the house when it floods.

    1. Jimmy, while it is badly abused today, initially the issue was the solvency of the insurance company. Insurance is sharing risk and -- forgetting profit and expenses -- they can't pay out more in claims than they take in from premiums.

      Floods cover large areas and hence produce large numbers of claims at the same time and it is more the latter that they are afraid of. If *all* their customers submit a claim at the same time, there is no way they could pay them all.

      This is different from, say, fires where it would be the same number of houses burning down each year and hence they could base a premium structure on paying out that much each year. But a flood only comes once every 10-20-50 years and hence the only way they could have the ability to pay all the claims at the same time would be to charge such exorbitant rates that no one would ever want to pay them.

      If they *knew* that the flood wouldn't come for 20 years, *and* that all of the people with claims then would have been purchasing flood insurance from them for said 20 years, then they could bankroll today's premiums for the 2041 claims. But the flood could come tomorrow...

      Now this wasn't a problem until mortgages arrived and then became bundled and resold. (Title insurance wasn't needed either.) And hence the Federal Government stepped in as the only entity with the financial resources to pay all the claims tomorrow should the flood arrive then.

      BUT what this did was enable people to build in places where they had no business building -- where they never would have built were their own money at risk. The ability to get mortgages because of the Federal insurance enabled the development of land that never should have been built on.

      In a way it is like the subprime mortgage issue.

      1. The other thing people forget is just how highly leveraged a lot of people are. That wasn't true 50 years ago...

      2. Some of this is true, some is nonsense. Given the nature of the risks it may well be that only the government is capable of bearing it.

        But there is no reason a government-run flood insurance program can't charge actuarially correct premiums. If it did so it would definitely discourage building in flood plains. It's the subsidized nature of the program, not the fact that it is government-run, that is the problem.

    2. All flood insurance is underwritten by private insurance companies. A percentage of the premium (and a percentage of the payout, I guess) is then paid by FEMA. And as someone who live on Hatteras Island NC about 100 yds from the ocean, I can tell you that a lot of insurance companies are willing to write flood policies. I'm a whopping 10 ft above sea level, so my lot is relatively dry.

      Now homeowner's insurance and wind insurance - that's another story. That's the real insurance expense when it comes to building and living out here.

  12. No doubt flood insurance premiums should be rationalized, but why not doing so makes one a hypocrite on climate change is unclear.

    Will the higher premiums reduce GHG emissions?

    Adler is just doing his usual - professing his concern about climate change while criticizing Democrats at every opportunity.

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