Housing Resilience and Financial Stability for All: The Case for National Disaster Insurance

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Massive wildfires in Los Angeles. Flash floods in Texas Hill Country. Hurricanes in North Carolina. Hailstorms in Kansas. These recent disasters resulted in billions of dollars in losses, hundreds of lives lost, and the destruction of thousands of homes. Due to the climate crisis, such catastrophes will likely only increase in frequency and scale in the months and years to come,¹ rendering more and more homes across the country at least temporarily unlivable. Far from being only a coastal issue, or one of just hurricanes and wildfires, disaster risk is collective and requires a collective response.

Insurance is vital for US housing finance and disaster recovery;² lenders require it, and insured households recover faster and more fully. This financial protection is especially important for low-income households and communities, which have less access to other sources of capital for recovery. Yet growing home-insurance gaps—from high premiums,³ insurer withdrawals,⁴ reduced coverage, and insurer nickel-and-diming over claims—are increasing financial strain on all types of homeowners and renters across the US. Nonexistent or even low insurance coverage also increases reliance on ex post facto disaster-relief budgets,⁵ which exhausts state and federal public purses and diverts spending from other key public goods. This crisis also strains budgets for rental-housing developers and providers, worsening the affordable-housing crisis.⁶

The breakdown of insurance markets is not just a result of climate change, however. Private insurers, whose profits stem largely from investing premiums, are incentivized to raise rates, shift risk to policyholders through higher deductibles and reduced coverage,⁷ reduce payouts,⁸ and refuse to renew policies, all while making billions in profits.⁹ Their short-term profit focus disincentivizes investment in long-term, often community-level disaster-risk reduction,¹⁰ and they seek to narrow their policyholder pool to the lowest-risk clients. Insurers also use practices like charging higher premiums based on lower credit scores—a greater cost factor than living in a high-risk area—which disproportionately affects marginalized groups, echoing historical redlining.¹¹

The industry’s main solution—deregulation for “actuarially sound” risk-based pricing—is misguided and ineffective. People’s housing choices are constrained by factors like schools, family, jobs, discrimination, and affordability, not just risk price signals.¹² This pricing also shifts costs onto lower-income households, who are often forced into riskier areas.¹³ Furthermore, large-scale catastrophe risks are borne collectively, and cannot be sufficiently mitigated without collective action: sewer upgrades or neighborhood brush clearings aren’t measures individual households or building owners can take on their own, with or without individual incentives. Low and middle-income households, for their part, cannot afford individual retrofits, and renters have little power to act, whereas the wealthiest homeowners can afford to ignore these price signals.

Meanwhile, patchwork state regulatory approaches and badly designed safety nets do not adequately correct these market failures. Past market failures led to federal and state insurers of last resort, like the National Flood Insurance Program (NFIP) and state FAIR Plans. However, these safety nets are overstretched, often unaffordable, and poorly designed. By concentrating on only high risk and sometimes structured to protect private insurer profitability, they are financially unstable and fail to effectively drive risk reduction.¹⁴

Without an insurance system that maintains financial security for the many and helps reduce disaster risk to homes, only the wealthier and whiter few are likely to remain financially solvent, especially as climate-driven disasters increase. The answer is a federal program tasked with providing adequate, affordable, and available national-disaster insurance to homes and carrying out proactive adaptation and risk mitigation so homes are safer to begin with.

A new approach to disaster insurance for homes

Since the evidence presented here makes it overwhelmingly clear that the insurance industry is not capable of providing an adequate and affordable insurance safety net, the policy question should not be “How can we save insurance companies?” but rather “How can insurance tools help keep people safely and affordably housed as disasters increase in frequency and scale?” Approaching the question this way leads to the prioritization of risk mitigation, equitable insurance protections, housing support for the people most vulnerable to financial devastation after disasters, and financial accountability from the entities most implicated in the breakdown of our current system.

A. Comprehensive disaster-risk reduction

Comprehensive disaster-risk mitigation is crucial for transforming home insurance, as proactive risk reduction limits damage before disasters, making insurance less necessary. Estimates suggest a $13 return for every $1 invested in physical risk reduction.¹⁵

Effective risk mitigation requires collective action beyond individual homes, moving toward community- and landscape-level measures like neighborhood home hardening, regional fire breaks, sewer upgrades, and infrastructure relocation.¹⁶ Necessary collective action also includes land-use policy to site new housing and infrastructure in safer locations and help communities relocate from high-risk areas. Informed and equitable land-use policy, not insurance premiums, should determine where housing exists, though affordable insurance access remains essential.

Finally, to reduce overall disaster risk, it’s necessary to stop climate change by ending the fossil-fuel economy, shift to renewable energy, and decarbonize homes, buildings, and transportation, which will reduce the frequency and severity of future disasters.¹⁷

B. Equitable, stable, affordable insurance

As climate disasters increase, insurance must be available, affordable, and comprehensive for all households and housing providers to support post-disaster recovery and increase resilience. Coverage must address the full range of regional risks and support proactive mitigation by enabling rebuilding to the highest standards. Disaster protection should embody solidarity, safeguarding everyone regardless of socioeconomic status, race, or geography and recognizing that the most vulnerable bear the heaviest burdens. Given the inherent conflict between profit and protection in private markets, a “public good” approach to disaster insurance is the only way to close perpetual coverage gaps.

C. New housing in lower-risk places

Without the existence of sufficient affordable, dignified, and safe housing, the necessary risk-reduction measures of relocation programs and limits on where new housing can be rebuilt may further exacerbate the country’s housing crisis.¹⁸ Although some advocates for addressing the nation’s housing crisis propose eliminating permitting, zoning, and land-use rules to build more, doing so without consideration for impacts from the climate crisis risks putting millions more households at the mercy of major disasters and the ensuing financial fallout. Instead, policies to address housing availability and affordability must also consider climate risk in zoning and siting decisions, and policies to address the home-insurance crisis must actively participate in efforts to increase green, resilient affordable-housing developments in lower-risk areas.¹⁹

D. Financial accountability for those most responsible

Insurance systems define responsibility for damages, determine the legitimacy of claims, assign accountability, and provide compensation for losses in the event of natural disasters and other emergencies. Our current system, however, has almost entirely relied on individual accountability (with the exception of subrogation claims against utility companies). In order to most equitably distribute the costs and benefits of a more stable insurance system—as well as provide adequate funding for public disaster insurance and comprehensive risk mitigation—the state must broadly analyze which institutions are most responsible for today’s home-insurance crisis and which would most benefit from the system being fairer and more stable.²⁰

The identification of those funding sources should stem from an analysis of the entities most responsible for the current climate-driven insurance crisis (like the fossil-fuel industry), and those that would most benefit from stability in home insurance (like mortgage lenders).²¹ Private insurers must also be held accountable for their role in today’s broken system. Not only have they long known climate change was a risk to housing and done little to change industry practices (including investments in fossil fuels),²² but they have also made substantial profits over decades from the premiums that policyholders have dutifully paid.²³

A federal policy vision: The National Housing Resilience Authority

The US can move away from its current model of organizing insurance as a profit-seeking business with voluntary participation in a collective protection system in which we equitably share in the burdens and benefits of collective risk sharing and resilience. Countries like New Zealand and Spain have built national disaster-insurance systems that serve as models, and the US can improve upon these examples by combining public disaster-insurance provisions with comprehensive risk mitigation.

To do so, Congress could establish a National Housing Resilience Authority (NHRA) to provide home disaster insurance for all through a National Disaster Insurance Program (NDIP) and coordinate housing risk-reduction work across the country through a Resilient Communities Office (RCO). The NHRA could also collaborate with other federal and state entities to ensure coordinated policy that increases affordability, availability, and resilience of housing and related infrastructure.

The National Disaster Insurance Program

The best way to equitably spread the risk of non-preventable disasters and ensure access to equitable post-disaster recovery finance that increases resilience—all without prioritizing rent-seeking—is through a public disaster-insurance program. To that end, the NDIP would serve in this capacity to provide cover for multiple catastrophic perils for all housing types: single-family homes, mobile homes, multifamily housing, rentals, and so on.

Private insurers would still serve the basic home-insurance market for standard coverage of theft, burst pipes, and more. The NDIP, meanwhile, would cover a defined set of catastrophic hazards. Similar to Spain’s Extraordinary Risks Cover program, which handles floods, earthquakes, tsunamis, and winds exceeding 120 kph, perils would be defined in statute based on the qualitative definition of the covered disasters, not the amount of damage, geographical extent, or a presidential declaration.²⁴ Given current catastrophe-risk levels across the US, this would likely include flooding (the NDIP would subsume the NFIP), earthquakes, wildfires, severe convective storms, and windstorms. The program design should allow for adjustment in types or levels of peril as climate change further shifts conditions. For example, landslides or subsidence (the sudden or gradual sinking of the earth’s surface) might require coverage as drought and rising sea levels worsen, though this will also need to be balanced with relocation and other risk-reduction measures (more on this below).

Broad coverage requirements would ensure both sufficient diversity in the NHRA’s risk pool and adequate disaster-recovery finance for households across the country. After all, individuals are not good at gauging their own risk,²⁵ and even when they are, only those at the highest risk tend to be willing to purchase insurance if not required to do so.²⁶

NDIP coverage would be mandatory for all loans issued by federally insured financial institutions (as is the case with standard insurance policies today), private insurance policyholders, and housing that receives federal financial assistance (e.g., LIHTC).

The NDIP would not provide unlimited coverage, however. It would establish regional coverage limits based on regional rebuilding cost estimates up to a cap that would adequately cover what working- and middle-class households would need to rebuild to the highest building-code standards in the case of a total loss. For example, the coverage limit in the San Francisco Bay Area might be $750,000, whereas in the Iowa City area $350,000 might suffice—though these limits would have to be adjusted periodically for inflation. A public rebuild cost calculator, akin to the Association of British Insurers’ publicly available rebuild cost calculator,²⁷ could inform these calculations.

In the case of multifamily building coverage, a similar framework would apply: The NDIP would determine regional coverage limits by building type to adequately cover all but the excess for luxury buildings. A premium percentage rate would then determine the building’s premium. It is important to note that while this would do a great deal to alleviate the crippling cost of insurance for affordable-housing operators, the high cost of liability coverage would not be solved by the NDIP.²⁸

Since the full rebuild cost of luxury homes would not be covered by the NDIP, the affluent could, if so desired, purchase further protection, known as “surplus” coverage, from private insurers, as long as it complied with the risk-reduction-oriented land-use policies established by the RCO. (See below.) Similarly, policyholders of all types could purchase surplus coverage for contents above the standard contents coverage amount offered by the NDIP. (Note: The NDIP renters-insurance policy would only cover contents.) And a higher premium percentage would apply to second homes and vacation units.

The standard consumer-facing interaction between NDIP coverage and private insurance would be one integrated policy. This would significantly improve the consumer experience—they’d need only one policy—and simplify consumer education about what their disaster policy covers.²⁹ Each private residential property insurance policy would have an NDIP coverage rider attached to it that the private insurer would pass on to the NDIP. The private insurer would serve as the policyholder’s point of contact in case of an NDIP-covered claim. If a property owner did not have a private policy, they could purchase directly from the NDIP. This is similar to how New Zealand’s Natural Hazards Cover functions.

A standardized, stable pricing system for NDIP coverage would ensure affordability for lower- and middle-class households and affordable-housing providers. It would also turn traditional price signaling on its head by incentivizing the NHRA to reduce the program’s total costs through population-level risk reduction. The NDIP would define a nationwide yearly premium rate based on a percentage of the property’s rebuild cost, up to the defined coverage limit. For example, if the premium percentage is 3 percent, a house with a rebuild cost of $450,000 in a region with a $500,000 coverage limit would pay $1,350. A house with a rebuild cost of $600,000 in that same region would pay $1,500 (based on the $500,000 coverage limit) but would likely want to purchase surplus coverage for the additional $100,000 in rebuild costs not covered by the NDIP. A higher premium percentage would apply to second homes and vacation units.

To further deepen affordability and resilience, the NDIP could establish a system by which communities that carry out adequate risk reduction and decarbonization work (as defined by the RCO, see below) could receive a resilience certification, resulting in a discount on the applied premium rate. The certification would require periodic updating, since we cannot assume community risk profiles will stay constant as the climate changes. This is reminiscent of the NFIP’s structure, but instead of only offering coverage if risk reduction has already occurred,³⁰ the NDIP, in recognition of the fundamental role of home insurance to the public interest, would provide coverage broadly and then reward community-level risk reduction. (See more on risk reduction below.)

Similarly, the NDIP’s claims payment process should be standardized, equitable, and timely. Measures to achieve this could include an automatic partial payment to policyholders to help with immediate costs in the event of a qualifying disaster. The aforementioned rebuild cost calculator would help standardize price-setting for rebuilding work.

The NDIP could also help account for the prohibitively high upfront costs of repairs for low- and moderate-income homeowners and affordable-housing providers by setting up a system to directly pay approved contractors to provide repair and rebuilding services to low-income policyholders in the case of a widespread catastrophe. Standards for vetted contractors would need to include training on best materials, construction techniques, and design for climate resilience in the operating region; family-sustaining wages and benefits; and labor-peace neutrality agreements.

The NHRA could also establish a framework for public disaster repair entities, which could ensure proper worker protections, adequate rebuilding standards, and all insurance program funds going to repairs rather than to shareholders. This could take the form of the (currently suspended) Civilian Climate Corps assuming building retrofitting projects, or other green jobs programs. The NHRA’s implementing legislation should also establish anti-price-gouging and anti-speculation rules for post-disaster periods.

While much of what’s proposed for the NDIP likely does not require federal regulation of private insurance markets, such power could ensure greater consumer protections as they relate to the interaction between the NDIP and private insurance. To that end, Congress may want to include repeal of McCarran-Ferguson provisions as they apply to residential property insurance (and could also consider a broader repeal, though that is outside the scope of this paper) in the NHRA’s implementing legislation. While states would still maintain regulatory power, the restored federal regulatory power could serve as a regulatory floor for the aforementioned NDIP/private-interaction question as well as for broader consumer-protection and financial-stability questions (including as they related to financial risk to insurance markets from climate change).³¹

The Resilient Communities Office

Comprehensive reduction of the risks that disasters pose to housing is essential to housing resilience and safety, as well as to a financially stable NDIP. The NHRA’s Resilient Communities Office (RCO) would be tasked with designing, carrying out, and supporting adaptation and mitigation work across the country. Vital to this work would be accounting for, and taking reparatory steps to address, the ways that housing policy in the US has been shaped by and contributed to discrimination and disparate impact, including the forcing of communities of color into some of the highest-risk geographies.³²

One element of disaster-risk reduction for housing is ensuring that when rebuilding happens, the resulting building is safer. Similarly, new housing should not be sited in the riskiest areas. To address this, the RCO could develop and implement nationwide resilience standards for rebuilds and new housing, as well as to expand existing building codes to include all forms of residential housing, including manufactured homes and multifamily buildings. Along those lines, the RCO could develop and implement zoning and other land-use rules that limit new buildings in the riskiest areas, like easements or setbacks along coastal and other flood-prone areas.³³ Japan’s national zoning and building-code framework³⁴ and Malaysia’s national disaster-prevention building-code system provide models to adapt for the US. The Tenth Amendment may limit federal power in zoning and building-code rules, though creative solutions to this could include conditioning of adaptation funds on the federal standards.

However, although much policy discourse on risk reduction to housing focuses on zoning, the fact remains that all currently housed US residents live in existing housing. That means a significant focus of the RCO should be risk reduction and resilience for those existing homes. This could take the form of programs that directly conduct risk-mitigation work, perhaps building off the model of Pennsylvania’s Whole-Home Repairs Program. The RCO could also negotiate with contractors for reduced prices for, say, roof replacements across a whole neighborhood. In addition to or instead of the RCO directly leading programs, it could provide funding for more local risk-mitigation efforts. In either case, the community should be involved in envisioning and planning the necessary interventions, as modeled in the Community-Driven Climate Resilience Planning Framework.³⁵

To ensure that the RCO’s work properly reaches lower-income households and communities, risk-reduction grants should be given to nonprofit affordable-housing providers, as well as to low-income homeowners—including those typically shut out of existing rebate systems, like mobile-home dwellers. Tax credits are an option, too, but only for households and entities with sufficient disposable income to pay up front for such expensive upgrades. And as with any public money given to private actors, support for multifamily housing providers should be conditioned on a strong set of tenant protections and antidiscrimination rules.

The RCO could also consider a carrot-and-stick approach with resilience funding for states: The states implementing strong land-use planning, for example, could receive additional risk-mitigation and adaptation funding. And post-disaster recovery funding rules could be upgraded to require alignment with national climate-resilience strategies.³⁶

In some cases, catastrophe risk and vulnerability analyses may indicate that certain areas are too dangerous to sustain housing in the long- to even medium- and short-term. This kind of scientific and equity analysis by a public agency should guide buyout prioritization decisions, not the cost or availability of insurance.

To adequately and justly address such cases, the RCO would need to institute comprehensive, science-based, equitable, and democratic mechanisms to support preventive relocation into safer, more affordable housing. FEMA’s NFIP-linked buyout program provides a cautionary tale: Although it is designed to help homeowners in high-risk areas, its methodology of compensating people based on the current value of their declining real estate has limited efficacy. Not only can such an approach result in inadequate compensation, but it also discourages participation and can lead to situations in which people rebuild in unsafe areas.³⁷ To avoid negative outcomes, the RCO’s preventive-relocation work should include the transformation of evacuated areas into public spaces, measures to address the socioeconomic and mental-health outcomes of relocation, and sufficient financial support for low- and moderate-income households.³⁸ Particularly when an entire community needs to be relocated, participatory decision-making processes, like the use of community needs assessments when planning the relocation and community advisory boards as key inputs, will foster greater buy-in and help ensure that these efforts do not re-entrench systemic racism or create new forms of uprooting and displacing BIPOC communities. This approach is distinct from the open processes used in municipal zoning and land-use decision-making, both in its purpose (moving a community out of existing but unsafe housing) and in its structure (which includes specific roles for community representatives who are compensated for their time).

Of course, the insufficient supply of affordable, dignified, and safe housing in the US makes preventive relocation even more difficult. While not in the purview of the NHRA, programs like the Green Social Housing Development Authority proposed by the Climate and Community Institute will be key to the success of relocation initiatives, and the RCO can work with various federal government entities to identify the lowest-risk areas for developing green social housing.³⁹

In order to ensure adequate technical analysis and equity-oriented prioritization of the RCO’s work, a Climate Risk Council could be formed to conduct risk analysis and lead the prioritization of risk-mitigation efforts, building-code-standard upgrades, land-management priorities, and other initiatives. The Council could develop and oversee public catastrophe-risk modeling to bring together the best of climate- and catastrophe-modeling research in a transparent and democratically run platform for risk assessment that also provides disaster history and risk mapping to the public.⁴⁰

Importantly, prioritization of this work should be guided not just by catastrophe-risk levels but also by a reparative approach that seeks to counter the undue burden of climate-change-fueled disasters on communities of color (particularly Black, Latine, American Indian, and Alaska Native) and low-income communities. These communities should be involved in participatory decision-making about mitigation measures.⁴¹

Governance structure

In replacing the NFIP, a logical place for the NHRA to sit would be FEMA. However, as proposed in the FEMA Act of 2025, FEMA should be its own stand-alone Cabinet-level agency separate from DHS, and separate from any law-enforcement activity, in order to properly meet its mission of “helping people before, during and after disasters.” Furthermore, this new FEMA should incorporate much greater national policymaking on climate adaptation and disaster resilience, and put ex ante mitigation efforts in much closer contact with ex poste disaster-response policy.

Even within FEMA, the NHRA should have its own governing board that embodies an inclusive, democratic approach with roles for federal department heads, impacted community representatives, insurance experts, and consumer-protection advocates.

This governing board should also include a mechanism to ensure that the voices of those most burdened by disasters are heard and integrated into decision-making processes, as with a community advisory board. Such a mechanism should have representatives from communities affected by disasters, among them residents from different geographic regions, socioeconomic backgrounds, and vulnerable groups (e.g., elderly, disabled, low-income households). Members should be selected based on their exposure to and experience with disaster-related impacts, similar to the Environmental Justice Advisory Committee for the California Air Resources Board.

Stakeholder financial contributions to the NHRA

While the federal government’s monetary power means it doesn’t need to identify direct “pay-fors” for a program like this, dedicated funding sources alongside premium income would reduce the expectations that the NHRA insurance program make use of risky and/or expensive hedging products like catastrophe bonds. Plus, the sourcing of funds from outside entities could more equitably spread the costs and benefits of a more stable insurance system.

The identification of those additional funding sources should stem from an analysis of the entities most responsible for the current climate-driven insurance crisis, and of those that would most benefit from stability in home insurance. When it comes to assigning responsibility, top of the list are taxes or fees on fossil-fuel companies causing climate change.

Private insurers must also compensate for their role in today’s broken system. Not only have they long known climate change was a risk to housing and done little to change industry practices (including investments in fossil fuels),⁴² but they have also made substantial profits over decades from the premiums that policyholders have dutifully paid. For that reason, the NHRA should establish a metric for requiring contributions to the NDIP’s initial capitalization. This can be understood as a fee to relieve the insurers of the services they don’t have to continue providing and to keep them from assuming future disaster risk. For example, all insurers providing residential property insurance in the US on the date of the bill passage would have to contribute an amount proportional to their market share. The California Earthquake Authority took a similar approach at its inception.⁴³

Property market lenders are among the entities that would benefit from stability in home insurance and therefore should contribute to a better system. Insurance is a critical lubricant for the housing market. The existence of insurable properties means they can lend against them as collateral, while decreasing climate-related risks reduces the likelihood of defaults. Stable mortgage markets also allow lenders to profit from the packaging and selling of mortgages on investment markets. Other sectors that fall into this category include mortgage brokers and real estate brokers and agents.

Once capitalized, the NHRA could invest some of its funds in capital markets, as insurers do today, but rather than use investment returns primarily for profit, it would churn returns back into the program. The NHRA would need to establish climate-justice investment criteria to make its investments align with climate-mitigation goals. New York’s Insure Our Communities Act provides examples of such criteria.⁴⁴

Policymakers could also consider creating a financial vehicle by which public pension funds in the state could co-invest with the NHRA instead of in risky financial market products like insurance-linked securities. (Public pension funds had nearly $1.3 trillion invested in insurance-linked securities as of 2024.⁴⁵)

Conclusion

No individual household or housing provider can mitigate the planet’s growing disaster risk alone. Nor should they be expected to; after all, risk sharing is the primary purpose of insurance. Only a holistic, collective response to this crisis, designed to ensure safe, affordable housing for all rather than prioritize insurance-company profits, can fully address the interconnected risks communities face.

1. “How Climate Change Is Fueling Extreme Weather,” Earthjustice, July 28, 2025.
2. Caroline Ratcliffe et al., “Insult to Injury: Natural Disasters and Residents’ Financial Health,” Urban Institute, April 11, 2019; Anna Rhodes and Max Besbris, Soaking the Middle Class: Suburban Inequality and Recovery From Disaster (Russell Sage Foundation, 2022), 97.
3. Michael Copley et al., “It’s Harder to Get Home Insurance. That’s Changing Communities Across the US,” NPR, November 12, 2025; Martin Shannon, “Average Homeowners Insurance Cost in March 2026,” Bankrate, accessed March 19, 2026.
4. “Climate Change and Trump Are Fueling a Nationwide Insurance Crisis,” Climate Power, December 8, 2025.
5. Moira Birss and Rebecca Elliott, “How Do We Fix Public Insurance Programs?”, Climate and Community Institute, August 21, 2024.
6. Alex Casey et al., “The Insurance Crisis in the Multifamily Affordable Housing Sector,” Climate and Community Institute, 2026; David W. Chen, “‘Not Sustainable’: High Insurance Costs Threaten Affordable Housing,” New York Times, June 7, 2024; Samuel K. Hughes and Raven Molloy, “Rising Property Insurance Costs and Pass-Through to Rents for Apartment Buildings,” FEDS Notes, Board of Governors of the Federal Reserve System, September 19, 2025.
7. Ronen Avraham and Ariel Porat, “The Dark Side of Insurance,” Review of Law & Economics Vol. 19, no. 1 (November 2023): 13–45.
8. Sharyn Alfonsi et al., “Florida Family Was Shocked by Their Hurricane Insurance Payout. Then They Learned the Damage Report Was Altered,” 60 Minutes Overtime, CBS News, September 29, 2024.
9. “Annual Report on the Insurance Industry,” Federal Insurance Office, US Department of the Treasury, September 2025, 2; “Florida Home Insurance Crisis Bleeding Into Louisiana,” Weiss Ratings, accessed May 13, 2025; “Climate Change and Trump Are Fueling a Nationwide Insurance Crisis”
10. Daniel Schwarcz, “Collective Coverage: How Group Homeowners Insurance Could Promote Climate Adaptation and Resilience,” SSRN Scholarly Paper no. 6142046, Washington University Law Review (forthcoming 2027).
11. Moira Birss et al., “Penalized: The Hidden Cost of Credit Score in Homeowners Insurance Premiums,” Consumer Federation of America/Climate and Community Institute, August 2025.
12. Rhodes and Besbris, Soaking the Middle Class: Suburban Inequality and Recovery From Disaster; Jade A. Craig, “Struggle Against the Water: Connecting Fair Housing Law and Climate Justice,” Nevada Law Journal Vol. 24, no. 3 (Spring 2024): 737–92; Zac J. Taylor and Manuel B. Aalbers, “Climate Gentrification: Risk, Rent, and Restructuring in Greater Miami,” Annals of the American Association of Geographers Vol. 112, no. 6 (2022): 1685–701.
13. Judson Boomhower and Meredith Fowlie, “The Efficiency and Equity Impacts of Risk Classification in Catastrophe Insurance,” Environmental and Energy Policy and the Economy Vol. 7, University of Chicago Press (2025).
14. For more on the history and structure of these state insurer-of-last-resort programs, see: Isabel Peñaranda Currie, Moira Birss, Ruthy Gourevitch, and Tanaya Srini, “Insurers of Last Resort: Why Today’s FAIR Plans Need a Redesign to Address the Home Insurance Crisis,” Climate and Community Institute, October 2025.
15. “Mitigation Saves: Mitigation Saves Up to $13 Per $1 Invested,” National Institute of Building Sciences, 2019.
16. Birss et al., “Shared Fates: A Housing Resilience Policy Vision for the Home Insurance Crisis,” Climate and Community Institute, September 2024, pp. 82–86.
17. Johanna Bozuwa et al., “Just Disaster Response,” Climate and Community Institute, October 2022.
18. Julia Wagner et al., “Transforming the Housing Sector with Green Industrial Policy,” Climate and Community Institute, July 2025.
19. Gianpaolo Baiocchi et al., “Green Social Housing at Scale: How a Federal Green Social Housing Development Authority Can Build, Repair, and Finance Homes for All,” Climate and Community Institute, June 2024.
20. Rebecca Elliott, Underwater: Loss, Flood Insurance, and the Moral Economy of Climate Change in the United States (New York: Columbia University Press, 2021).
21. See more suggested contributors in Moira Birss, “Protection or Profit? Transformative Solutions to the Home Insurance Crisis,” Climate and Community Institute, October 2025.
22. Peter Bosshard, “Fifty Years of Climate Failure: 2023 Scorecard on Insurance, Fossil Fuels and the Climate Emergency,” Insure our Future, November 2023.
23. “Florida Home Insurance Crisis Bleeding Into Louisiana”; “Annual Report on the Insurance Industry”; “Climate Change and Trump Are Fueling a Nationwide Insurance Crisis.”
24. “The Spanish Extraordinary Risk Coverage System,” nos. 720-16-206–5, Consorio de Compensación de Seguros, 2016.
25. Rhodes and Besbris, Soaking the Middle Class: Suburban Inequality and Recovery From Disaster.
26. Ilan Noy and Tomáš Uher, “The Transition from Private to Public Insurance for Natural Hazards: A Review of International Experiences,” Te Herenga Waka—Victoria University of Wellington, October 2024.
27. “BCIS Rebuilding Cost Guidance,” Association of British Insurers, accessed August 23, 2024.
28. For more on insurance costs for affordable housing, see: Casey et al., “The Insurance Crisis in the Multifamily Affordable Housing Sector.”
29. Schwarcz, “Collective Coverage: How Group Homeowners Insurance Could Promote Climate Adaptation and Resilience.”
30. Jared T. Brown, “Introduction to FEMA’s National Flood Insurance Program (NFIP),” Congressional Research Service, August 16, 2016.
31. Graham Steele, “Confronting the ‘Climate Lehman Moment’: The Case for Macroprudential Climate Regulation,” Cornell Journal of Law and Public Policy Vol. 30, no. 109 (2020): 109–57; Dennis Kelleher, “Special Report: The Unseen Banking Crisis Concealed Behind the Climate Crisis,” Better Markets, August 23, 2023.
32. Craig, “Struggle Against the Water: Connecting Fair Housing Law and Climate Justice.”
33. For areas the federal government does not have direct jurisdiction over, updates to the Coastal Zones Management Act could provide a vehicle by which greater federal influence on setbacks is implemented.
34. “Converting Disaster Experience Into a Safer Built Environment: The Case of Japan,” Building Regulation for Resilience, World Bank, 2018.
35. Rosa Gonzalez, “Community-Driven Climate Resilience Planning: A Framework,” National Association of Climate Resilience Planners, October 2017.
36. Nevitt, “Destroy, Rebuild, Retreat,” 555.
37. Elliott, Underwater.
38. For more, see: Birss et al., “Shared Fates.”
39. See: Baiocchi et al., “Green Social Housing at Scale.”
40. The Biden administration proposed such an approach. See: Council of Economic Advisers et al., “Memorandum: Tools to Support the Management of Near-Term Macroeconomic and Financial Climate Risks,” December 22, 2023; see also: Mark Nevitt, “Destroy, Rebuild, Retreat: How to Break the Climate Disaster Cycle,” Vanderbilt Law Review Vol 78, no. 2 (2025).
41. “Policy Basics: Advancing Racial, Economic, and Health Justice Through Climate Action,” Center on Budget and Policy Priorities, December 12, 2024; Amanda D. Stoltz et al., “No Coastal Justice Without Environmental Justice: A Systematic Literature Review of Climate and Coasts,” Climatic Change Vol. 178, no. 11 (2025): 206.
42. Bosshard, “Fifty Years of Climate Failure.”
43. California Insurance Code § 10089.15.
44. New York State Senate, Assembly Bill A3842A (2025).
45. Birss et al., “Shared Fates,” 70.