Marengo's Neighbors Get a Flood Insurance Discount. Marengo Never Joined the Program.

If you own a home in Marengo's floodplain and carry flood insurance, you pay the full federal rate. A homeowner in the same situation in Crystal Lake pays 20 percent less. In Lake in the Hills, 25 percent less. In unincorporated McHenry County, 20 percent less.

The difference is not the flood risk. It is a federal program called the Community Rating System, which discounts the National Flood Insurance Program policies in a town that does extra floodplain work beyond the federal minimum. Marengo has participated in the flood insurance program since 1979 and has never entered the Community Rating System, according to FEMA's community status book, which lists no entry date and no class for the city. That means a discount of zero.

Marengo is not unusual in that. Only four of the 23 McHenry County communities in FEMA's records carry a class. But the program has come up at City Hall more than once, and the paper trail of what happened is thin enough that the city itself cannot say.

What the Program Does

The Community Rating System, or CRS, grades towns on a scale from Class 10 to Class 1. Class 10 is where every community starts and carries no discount. Each class up is worth another 5 percent off, so a Class 9 town gets 5 percent, a Class 6 town gets 20 percent, a Class 5 town gets 25 percent, and the scale runs to 45 percent at Class 1. Under FEMA's current pricing the same percentage applies to every policy in the town, whether or not the property sits in the mapped floodplain.

Towns earn their way up by doing things FEMA gives credit for: keeping elevation certificates on file, sending flood information to residents, adopting stricter building rules than the federal minimum, protecting open space in the floodplain. A town has to be in good standing with the flood insurance program, name a staff member as its CRS coordinator, recertify every year and host a verification visit every three to five years. A town found out of compliance with the flood insurance program's building standards drops to Class 10 until the problem is fixed.

FEMA's own guide for small communities says that a town's existing open space and floodplain rules "often provide enough credit to enter the CRS as a Class 9 community." Marengo may have a head start there. Its code adopts the McHenry County stormwater ordinance by reference, and that ordinance requires more than the federal minimum. The program gives credit for stricter rules whether or not the town wrote them itself.

What It Would Be Worth Here

FEMA's policy-level data shows 76 flood insurance policy terms in Marengo with effective dates in 2025, 74 of them inside the mapped floodplain. Together they carried about $56,000 in premium, and the median policy cost $671 a year. FEMA's dataset runs a few months behind, so the 2026 picture is incomplete.

On those numbers, a Class 9 rating would return roughly $2,800 a year to Marengo policyholders as a group, about $34 on a typical policy. A Class 6 rating, the level Crystal Lake and the county hold, would return roughly $11,000 a year, about $134 on a typical policy. Those are not life-changing sums for any one household. They are the difference between paying the federal rate and paying what the neighbors pay, every year, for as long as the town keeps its class.

There is a second number worth putting next to that one. Since 1995, FEMA has ruled on 42 requests from Marengo property owners to have a house or a lot taken out of the mapped floodplain, two of them already this year. At least 39 were granted in some form and two were denied, and in most of the successful cases only the building came off the map while the land around it stayed in. Nearly half of those cases are in Jackson's Addition and Syndicate Addition, the blocks around the numbered avenues and North Taylor Street, and about a quarter are in the Deerpass subdivisions. Most are individual owners paying for a survey or an elevation certificate to get one house or one lot off the map, which ends the federal requirement to carry flood insurance on a mortgage, though a lender can still insist on it. Residents have been buying their way out one property at a time for more than thirty years. The program that would discount the policies in town all at once is one the city has never entered.

What the City Record Shows

The city's record touches the program at several points, and the thread runs through the same dozen houses.

In September 2009, an alderman asked Public Works Director Jayson Shull about the trouble the city was having with the county's hazard mitigation planning. The minutes record the answer this way: 12 properties had been built in the mid to late 1990s lower than the flood insurance program allows, the codes in force at the time had been overlooked, and those properties were keeping the city out of a program the minutes do not name. Whatever program the clerk meant, the Community Rating System's own rules say a community found out of compliance with the flood insurance program's building standards cannot hold a class. Two months later the council voted to take part in the county's hazard mitigation planning committee.

The number came back on June 25, 2012, when the council agenda carried an item titled "Authorization to Execute Agreement with HR Green for Community Rating System, Floodplain Mitigation." The minutes summarize Public Works Director Jayson Shull's briefing this way: 12 properties could possibly benefit from the change, and far more in the floodplain could benefit as well. The motion the council actually passed was narrower than the agenda title: a professional services agreement with HR Green for a Deerpass Subdivision flooding analysis, not to exceed $21,272.

What came of that work is not clear from public records. FEMA's map records show a determination completed in December 2013 for two houses on Woodland Lane in Deerpass, which took the buildings out of the mapped floodplain but left the lots around them in it. Whether that was the product of the HR Green study, or a separate effort by those owners, the records available to us do not say.

The council has also adopted the county's hazard mitigation plan three times, in January 2011, in November 2017 and most recently on December 11, 2023, when it unanimously adopted Resolution 23-12-A putting the city behind the county's 2023 plan. The 2023 packet is the one that mentions the program. The county's own FAQ, attached to it, notes the plan "is also eligible for credit under the FEMA National Flood Insurance Program's Community Rating System." The staff memo recommending adoption noted that the police chief had been attending the county committee's meetings on the city's behalf and described adoption only as a way to be eligible for FEMA mitigation grants. The plan's action item on the subject, "Consider Community Rating System Participation," is assigned in Marengo's resolution to the county's planning department, and nothing on the plan's list is assigned to the city. That may simply be how these resolutions get written. Either way, nothing in the resolution makes the item anyone's job at City Hall.

What the City Says Now

Marengo Weekly put five written questions to City Administrator Derik Morefield in late August, and the answers came back the next day. The short version is that the institutional memory is gone.

Asked whether the city had ever applied to the program or requested the free preliminary assessment FEMA's contractor provides, the answer was, "Not that we are aware of." Asked whether the 2012 HR Green work was still in city files, Morefield wrote, "Looking through our files but don't hold your breath that we will find anything." The same reply noted separately that the city no longer works with HR Green. Asked whether joining the program was discussed when the council adopted the county plan in 2023, the answer was again, "Not that we are aware of. Participating staff no longer employed by the City." Asked whether there was a current city position on the program, the answer was, "No. Staff would need to revisit."

Morefield also wrote that Finance Director Megan Lopez has the most history on the subject of anyone at the city and "zero knowledge about any of these questions." None of this is a finding that the city decided against the program. It is a finding that nobody now working at City Hall knows whether it ever did.

What Joining Would Take

The entry point is deliberately low. To reach Class 9, a community must be in good standing with the flood insurance program, keep elevation certificates for new construction and substantial improvements in the floodplain, and identify any repetitive-loss properties and notify those owners each year. Beyond that it needs a named coordinator on staff and the paperwork of annual recertification.

The cost of the first step is nothing. FEMA's contractor will produce a "What If" statement for any community that asks, showing the discount policyholders would receive at each of the ten classes alongside the town's current policy count. That is the whole business case on one page, and as far as anyone now at City Hall knows, the city has never asked for one.

Whether the staff time is worth roughly $34 to $134 a year per policy is a fair question for the council, and reasonable people can answer it either way. In 2012 the public works director told the council that 12 properties, and far more in the floodplain, stood to benefit, and the council authorized a study. Seventeen years after the council first heard about a dozen houses built too low, the question is still open, and nothing in the record makes it anyone's job to close it.

The Marengo Weekly contributor who reported this piece owns a home in Marengo's mapped floodplain and carries a flood insurance policy that a Community Rating System discount would apply to, which is how the question came up.