Lesson 6 Objectives

At the end of this lesson, you will be able to:

Determine the appropriate data necessary for the MT-1 and MT-EZ applications
Describe the advantages and limitations of the electronic Letter of Map Amendment (eLOMA) submission process

Licensed Professionals’ Role in the LOMC Application Process

Property owners require the services of licensed land surveyors, registered professional engineers, or architects to compile the necessary data and documentation to complete Letter of Map Change (LOMC) applications. Frequently, licensed professionals provide guidance to property owners on the viability of removal of their property from the Special Flood Hazard Area (SFHA).

A licensed professional must certify the accuracy of the elevation information on the Elevation Form in the MT-1 application or an Elevation Certificate (EC).

Licensed professionals can also advise whether a metes and bounds description with the lowest lot elevation (LLE) on a lot, or portion of the lot, or information on the structure’s lowest adjacent grade (LAG) would be the best way to meet their clients needs.

Licensed professionals may be requested to assure compaction standards for projects involving fill.

Licensed professionals may need to perform hydraulic and hydrologic analyses and other studies to support LOMR-F applications.

Licensed professionals may be called upon to locate existing Base Flood Elevation (BFE) data or develop initial BFE data for Approximate A Zone areas.

After registering for an account, licensed professionals can submit LOMA requests via eLOMA and, in most cases, receive removal or non-removal determinations in minutes instead of days. eLOMA is only for LOMAs in mapped areas with BFEs. The structure(s) may not be located in areas which contain special circumstances (e.g., a floodway, VE Zone, etc.) The eLOMA portal is available at https://hazards.fema.gov/femaportal/wps/myportal/resources/eloma.

Information Required for MT-EZ and MT-1 Applications

Copy of deed for property containing the recorder’s seal and recordation date with tax assessor’s or other suitable map showing surveyed location of property
OR a recorded plat map
An annotated copy of the effective FIRM panel or a FIRMette, including title block, showing the property location
Map scale and north arrow must be shown on all maps submitted
Street address
Whether fill has been placed on the property, or will be placed to raise ground that is below the BFE
Legal description of property (lot and block, parcel number, etc.)
Whether request is for removal of structure(s), a portion of the land, or the entire property
Whether request is for removal of a single structure or multiple structures, or a single lot or multiple lots
Date of construction of structure(s) on property
Type of construction of structure(s)

Information Required for MT-EZ and MT-1 Applications (cont.)

Elevation datum: National Geodetic Vertical Datum of 1929 (NGVD 29) or North American Vertical Datum of 1988 (NAVD 88)
Lowest lot elevation (LLE) or lowest adjacent grade (LAG) to the structure
Latitude and longitude of the most upstream end of a structure or property and datum used
The BFE and the source for the BFE data
Certification by a licensed land surveyor, registered professional engineer, or architect
A signed Community Acknowledgement Form for all CLOMR-F, LOMR-F and LOMA requests for property inadvertently included within the floodway

For more information, refer to Elevation Certificate and Instructions available at www.fema.gov/media-library/assets/documents/160.

Definition of National Geodetic Vertical Datum of 1929

The Sea Level Datum of 1929, renamed the National Geodetic Vertical Datum of 1929 (NGVD 29), is a vertical control datum in the U.S. by the general adjustment of 1929. The datum was defined by the observed heights of mean sea level at the 26 tide gauges and by the set of elevations of all bench marks resulting from the adjustment.

Definition of North American Vertical Datum of 1988

The North American Vertical Datum of 1988 (NAVD 88) is the vertical control datum established in 1991 by the minimum-constraint adjustment of the Canadian-Mexican-U.S. leveling observations. NAVD 88 consists of a leveling network on the North American Continent, ranging from Alaska, through Canada, across the U.S., affixed to a single origin point on the continent. In 1993 NAVD 88 was affirmed as the official vertical datum in the National Spatial Reference System (NSRS) for the Conterminous U.S. and Alaska.

Electronic Letter of Map Amendment (eLOMA) Submission Process

FEMA has designed a web-based tool for licensed professionals and certain certified professionals to submit selected LOMA requests through the eLOMA Mapping Information Platform available at https://hazards.fema.gov/femaportal/wps/myportal/resources/eloma. An eLOMA has the same standards and results as a traditional LOMA application. However because they are filed electronically and data is automatically reviewed, results can often be obtained within minutes.

Requirements

Same information as for a MT-EZ application
Licensed professional must apply for an eLOMA account with FEMA

Potential advantage for the professional:

Results are often nearly instantaneous

Limitations—Not eligible if:

Fill has been placed or will be placed to raise the ground elevation
The request is for a proposed structure, proposed portion of property, or proposed legally recorded parcel
The subject of the request is in approximate Zone A, on an alluvial fan, or in Zone V or Zone VE
There is already a standard LOMA application being processed for the subject of the request

Note

Selected applications are subject to audit; repeated incorrect determinations may have negative impact on the user’s access to eLOMA.

For more information, refer to the eLOMA tutorial (available at hazards.fema.gov/femaportal/resources/whatiseloma.htm) and the eLOMA Fact Sheet (available at http://www.fema.gov/media-library-data/1426511957633-ecfe2c0bce2556d5ab20b490ddc42582/eLOMA_Factsheet_2015.pdf).

Metes and Bounds Descriptions

If the legal description is inadequate or only a portion of a lot is being requested to be removed, a metes and bounds description will be required. Metes and bounds descriptions must:

Cover the specific area to be removed
Be tied to an identifiable starting point—at the lot or parcel corner if it is for a legally recorded lot or parcel
Not intersect or coincide with the footprint of an existing structure

An example of the preferred format is:

BEGINNING at the northeast lot corner; thence S16°42’22”E, 100.00 feet; thence S33°14’40”W, 145.92 feet; thence S89°13’29”W, 156.01 feet; thence N16°42’22”W, 223.14 feet; thence 210.49 feet along a curve to the left having a radius of 542.00 feet to the POINT OF BEGINNING.

You may also refer to the FEMA approved format for eLOMA legal property descriptions.

FEMA Approved Format for eLOMA Legal Property Descriptions

This file type is not supported

Note

FEMA encourages the submission of metes and bounds descriptions in digital format on CD.

Important Information to Communicate to Your Customer

Is the application for removal of an entire lot or for just a structure from the SFHA?

In most lender determination challenge cases, the structure itself is the area of concern and not the lot. The mandatory purchase of flood insurance requirement is normally tied to the structure only
For proposed development, requesting removal of a portion of the lot may be the better approach and using a metes and bounds description is recommended
If it is clear that the lowest lot elevation (LLE) for the entire lot is at or above the BFE, then using the LLE may be easier than creating a new metes and bounds description to remove just a portion of the lot

Is the application for removal of a single structure or multiple structures, or a single lot or multiple lots?

For a single lot or structure, use the MT-EZ application form (available at https://www.fema.gov/mt-ez-form-instructions) or the eLOMA submission process (available at https://hazards.fema.gov/femaportal/wps/myportal/resources/eloma)
For multiple lots or structures, use the MT-1 application form (available at www.fema.gov/media-library/assets/documents/31858)

For a LOMA, if there is an existing structure (including attached garage, patio, deck, porch, or stairs) with the lowest adjacent grade (LAG) below the BFE, the request will be denied.

A LOMC application, even with appropriate data, does NOT constitute a legal change in the status of the property until FEMA issues the formal letter.

Important Information to Communicate to Your Customer (cont.)

Discuss your professional liability

Advise your customer about residual risk of flooding. Recommend flood insurance even if the structure is removed from SFHA
Professionals have to meet ethical standards. Customers may not always get what they want
You will be required to sign, provide your license number, and affix your seal to certify that elevation information and other technical data represents your best efforts to interpret the data available
False statements may be punishable by fine or imprisonment under 18 U.S. Code, Section 1001

Communicate approximate FEMA response time

For LOMC applications submitted by mail or the Online LOMC portal—customers can expect to get a response approximately 60 days after all requested information has been submitted to FEMA. The Online LOMC portal is available at https://hazards.fema.gov/femaportal/onlinelomc/signin
For LOMC applications submitted via eLOMA—customers can expect a same day response, in some cases, once all requested information has been submitted to FEMA. The eLOMA Mapping Information Platform is available at https://hazards.fema.gov/femaportal/wps/myportal/resources/eloma

Note

eLOMA applications can not be used for a LOMA in approximate Zone A, Zone V, Zone VE, or alluvial fan areas.

How to Find the Status of a LOMC Application

If you submitted an application using the Online LOMC tool, you can check the status of the application by logging into your Online LOMC account

From the Online LOMC website (available at https://hazards.fema.gov/femaportal/onlinelomc/signin):

Select the appropriate state link
Enter the case number or select a community from the drop-down menu
Click the Submit button
The Flood Hazard Determination status screen displays all the LOMC applications for the community, as well as the case number(s), status, appeal period beginning and ending dates, and a link to view the Flood Hazard Determination notice

For LOMC paper applications sent through the mail, automated status information will be available once the application is received by FEMA through http://www.fema.gov/status-map-change-requests

Letter of Map Change Application Statuses


Status	Description
Under Review	Reviewing technical data and supporting documentation
Received, Checking Completeness	Ensuring all initial data and/or fees have been received
Letter Sent - Effective Date	The date on which the LOMC for community goes into effect and all legal sanctions of the NFIP apply. The letter is effective on the date sent
Dropped	Additional data and/or fee was not received within the regulatory time frame; therefore, the processing of this case was suspended
Awaiting Data/Fee	Awaiting additional data and/or fees in support of request

Accurately Completing the Elevation Form in the MT-1 Application

Include the NFIP Community Number
Enter the property name or address
Elevations can be based on existing or proposed conditions

Proposed conditions may be used for a CLOMA or CLOMR-F

Provide the following information:

The type of construction (crawlspace, slab on grade, basement/enclosure, or other)
The date of current re-leveling, if the area is subject to land subsidence or uplift
Elevation datum used: NGVD 29, NAVD 88, or other
Latitude and longitude of the most upstream edge of

Structure
Property

Address, lot number, block number
Lowest lot elevation (LLE)
Lowest adjacent grade (LAG) to structure
BFE and source

For requests involving a portion of the property, include the lowest ground elevation within the metes and bounds description.

Recording Elevation Data

Elevations can be based on existing or proposed conditions. Proposed conditions are only used for CLOMA and CLOMR-F applications.

Elevation data must be measured to the 0.1 of a foot (except in Puerto Rico where it is measured to 0.1 meter). Indicate the vertical datum standard used (use the same datum as listed on the FIRM):

If another elevation datum standard is used, provide a conversion to NGVD 29 or NAVD 88 in the Comments area.

Indicate the source of the BFE or base flood depth data:

Flood Insurance Study (FIS) Flood Profile or Summary of Stillwater Elevations
FIRM
Community determined
Other

For more information on Flood Insurance Studies, refer to IS-0274: How to Use a Flood Insurance Study (FIS) available at https://training.fema.gov/is/courseoverview.aspx?code=IS-274.

Obtaining BFEs for Approximate Zone A Areas

If the property is located in a Zone A, an area of approximate flooding with no BFEs, a BFE may be determined by a licensed professional.

First, determine if a federal, State, or local government agency has developed a BFE. Such agencies include the:

U.S. Army Corps of Engineers
FEMA Regional Office
U.S. Geological Survey
State’s Department of Natural Resources
Department of Environmental Quality
Department of Transportation
Local planning and zoning department

If the BFE has been developed, all supporting data and calculations used to develop the BFE or a letter directly from the government agency must be submitted.

If there is no BFE available, either one must be developed, or FEMA may develop the BFE based on the best existing Digital Elevation Model (DEM) when more accurate data is not provided by the applicant. BFEs developed by FEMA using existing elevation data tend to be more conservative. Applications that include base level engineering studies or cross sections(s) with accurate elevation data will allow more accurate BFE determinations.

Developing BFEs for Approximate Zone A Areas

Detailed methods for developing BFEs include:

Topography

Field surveys must reference same datum used to produce the FIRM
Assumed datum may be used but it may not be sufficient to revise a FIRM
One or more cross sections may be required

Hydrology

Methods include discharge-drainage area relationships, regression equations, TR-55, rational formula, and other hydrograph methods
A list of hydrologic models accepted by FEMA can be found at https://www.fema.gov/hydrologic-models-meeting-minimum-requirement-national-flood-insurance-program

Hydraulics

Methods include normal depth, critical depth, step-backwater, and calculations for the impact of hydraulic structures
A list of hydraulic models accepted by FEMA can be found at https://www.fema.gov/hydraulic-numerical-models-meeting-minimum-requirement-national-flood-insuranceprogram

For more information, refer to:

Guidance for Flood Risk Analysis and Mapping, MT-1 Technical Guidance available at 'http://www.fema.gov/media-library-data/1520966727494-8c05ecc18e141449aa79665641bd9fe3/MT1_Technical_Guidance_Feb_2018.pdf
FEMA 265, Managing Floodplain Development in Approximate Zone A Areas: A Guide for Obtaining and Developing Base (100‐year) Flood Elevations available at http://www.fema.gov/library/viewRecord.do?id=2215

Developing BFEs in Coastal Zones

Locate effective coastal input data in the Flood Insurance Study (FIS), or

Identify updated coastal input data from sources with at least 33 years of buoy data records

Run an updated coastal flood analysis with updated topography and identified coastal input conditions using an approved coastal numerical model (available at https://www.fema.gov/coastal-numerical-models-meeting-minimum-requirement-national-flood-insurance-program)

Run erosion and runup analyses, as appropriate

Map the updated results along transect lines and appropriately tie-in to flood boundaries in the current study

Model results may be superseded by primary frontal dune location and analysis results (for example, meeting requirements for an overtopping zone)

Lesson 6 Resources

Elevation Certificate and Instructions available at http://www.fema.gov/media-library/assets/documents/160
Elevation Certificate checklists available at https://crsresources.org/300-3/
Independent Study course EC Made Easy: Elevation Certificate Overview available at https://training.fema.gov/is/courseoverview.aspx?code=IS-1105.a
Vertical data fact sheet available at http://www.fema.gov/media-library-data/20130726-1755-25045-0634/ngvd_navd.pdf
Guidelines and Standards for Flood Risk Analysis and Mapping available at https://www.fema.gov/guidelines-and-standards-flood-risk-analysis-and-mapping
Online LOMC available at https://hazards.fema.gov/femaportal/onlinelomc/signin
Automated LOMC application status information available at http://www.fema.gov/status-map-change-requests
Hydrologic models accepted by FEMA available at https://www.fema.gov/hydrologic-models-meeting-minimum-requirement-national-flood-insurance-program
Hydraulic models accepted by FEMA available at https://www.fema.gov/hydrologic-models-meeting-minimum-requirement-national-flood-insurance-program
Guidance for Flood Risk Analysis and Mapping, MT-1 Technical Guidance available at http://www.fema.gov/media-library-data/1520966727494-8c05ecc18e141449aa79665641bd9fe3/MT1_Technical_Guidance_Feb_2018.pdf
FEMA 265, Managing Floodplain Development in Approximate Zone A Areas: A Guide for Obtaining and Developing Base (100‐year) Flood Elevations available at http://www.fema.gov/library/viewRecord.do?id=2215
eLOMA tutorial available at http://hazards.fema.gov/femaportal/resources/whatiseloma.htm
eLOMA Fact Sheet available at http://www.fema.gov/media-library-data/1426511957633-ecfe2c0bce2556d5ab20b490ddc42582/eLOMA_Factsheet_2015.pdf
IS-0273 How to Read a Flood Insurance Rate Map (FIRM) available at https://training.fema.gov/is/courseoverview.aspx?code=IS-273
IS-0274 How to Read a Flood Insurance Study (FIS) available at https://training.fema.gov/is/courseoverview.aspx?code=IS-274

Lesson 6 Review

In this lesson we discussed the roles and responsibilities of a licensed professional in regard to LOMCs, including:

MT-EZ and MT-1 application data requirements
Advantages and limitations of eLOMA submission process
Important information to communicate with your customers
How to find the status of a LOMC application
How to complete the Elevation Form in the MT-1 application
Obtaining BFEs for Approximate A Zone areas
Developing BFEs for Approximate A Zone areas
Developing BFEs in coastal zones