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

• Analyze LOMA and LOMR-F applications to determine if they will be approved or denied
• Analyze LOMA and LOMR-F applications to identify potential violations

Once submitted, the timeline for FEMA to process applications is as follows:

• Once all requested information is received, CLOMA, LOMA, CLOMR-F, and LOMR-F applications have a 60-day review and determination period
• LOMR and CLOMR applications have a 90-day review and determination period, after the approval of all data submitted

The general LOMC review and determination process is as follows:

• FEMA reviews and evaluates applications for completeness and accuracy
• It is an iterative process and deadlines are important. For example, if the deadline is not met, the clock restarts on the application, the case is suspended (no longer being processed) and will cost an additional fee to get it started again
• Once FEMA approves or denies the map amendment, FEMA sends the letter to the applicant, the local community (or communities), and the State NFIP coordinator. The letter is also filed in the FEMA Map Service Center
• Letters can be retrieved from the FEMA Map Service Center
• Changes to flood maps are incorporated into the National Flood Hazard Layer (NFHL)
• Submittal of the application does not guarantee approval

When a LOMC application is received at FEMA, the package is first checked to ensure that all the appropriate forms, required technical supporting information, and the correct review and processing fee are included. Complete packages receive a FEMA case number.

Next, a reviewer examines the LOMC application forms and data for completeness. If more information is required to make a determination, the submitter will be contacted by telephone or letter.

If the forms and data are complete, a case reviewer will perform the technical review of the request, comparing it to effective data and noting other requests that may affect the determination of the request. During this step, the submitter will be contacted by telephone or letter if additional information is required to complete the review. In that case, the review is suspended until the required information is received. If the information is not received within 90 days, the application processing will be suspended. Late submittals are treated as original submissions and will be subject to all payment requirements.

If the LOMC request is approved, the appropriate Determination Document is reviewed and signed by the FEMA Project Engineer. The signed Determination Document is then mailed to the submitter.

• Is the application complete?
• Is the information submitted accurate?
• Is there a signed Community Acknowledgment Form for a Letter of Map Amendment (LOMA) application for a property located within a regulatory floodway?
• Do all elevations use the same datum? If not, is a conversion provided?
• Is the location accurate?
• Does the Base Flood Elevation (BFE) match those in the Flood Insurance Rate Map (FIRM) or Flood Insurance Study (FIS)?

• Has the appropriate fee been submitted?
• Are all forms completed and all required documentation is attached?
• Is an annotated FIRM included?
• Are all form fields populated, using N/A when appropriate?
• Is the lowest adjacent grade (LAG) at or above the BFE for LOMC requests for one or more structures?
• Is the lowest lot elevation (LLE) at or above the BFE for LOMC requests for one or more lots?
• Are the elevations certified by a licensed land surveyor, registered professional engineer or architect?
• Is the land and any existing or proposed structures to be removed from the Special Flood Hazard Area (SFHA) “reasonably safe from flooding”?

For more information on LAG and LLE at or above the BFE, refer to Guidance for Flood Risk Analysis and Mapping: MT-1 Technical Guidance, available at 'http://www.fema.gov/media-library/assets/documents/34953

What gets approved?

• The LOMC application to remove a structure, a lot or portion of a lot from the SFHA

How does an application get approved?

• The MT-EZ or MT-1 forms or eLOMA requests are submitted to FEMA for review. In some cases, FEMA may request more information

What does approval mean?

• A legal letter or Determination Document from FEMA states that a structure, lot, or portion thereof, is removed from the SFHA

Letter of Map Amendment (LOMA) and Letter of Map Revision--Based on Fill (LOMR-F) applications will be denied under the following site conditions:

• Natural lowest adjacent grade (LAG) of any portion of a structure, including attached garage, deck or steps, is lower than the BFE
• Finished LAG of any portion of a structure elevated on fill, including attached garage, deck or steps, is lower than the BFE
• Natural lowest lot elevation (LLE) for property, or portion of property to be excluded from the floodplain, is lower than the BFE
• Finished LLE of property, or portion of property to be excluded from the floodplain by placement of fill, is lower than the BFE
• Structure is located seaward of the inland limit of a primary frontal dune in a coastal Zone V or Zone VE
• Structural fill was used in a coastal Zone V or Zone VE
• Property and/or structures are in alluvial fan flood hazard areas

A request must be processed as a Letter of Map Revision (LOMR) request if:

• The development causes or is affected by significant SFHA changes or BFE changes
• Fill was placed in the floodway, including compensatory storage and excavation; review of a no rise certification is outside of the scope of a LOMR-F review
• The project includes channelization projects, bridge/culvert replacement projects, or other flood control improvements; review of work within a stream channel is outside of the scope of a LOMR-F review

The lot, portion of a lot, or structure will remain legally in the SFHA.

No BFEs or floodplain boundaries are changed.

National Flood Insurance Program (NFIP) development and flood insurance requirements remain.

Project may be in violation of community regulations.

The applicant may submit another application with more accurate data.

Potential violations discovered during the LOMC application review process are flagged and sent to the FEMA Region for investigation.

• Lowest floor elevation (LFE)
• A LOMC will not be granted if the lowest floor elevation (LFE), including the basement of any existing structure, is below the BFE. This is sometimes seen with post-fill basements
• Zone AO construction
• Lowest floor is below the highest adjacent grade (HAG) plus the base flood depth number. If there is no base flood depth number on the FIRM, then the lowest floor cannot be less than 2 feet above the HAG
• Zone V or VE construction
• According to 44 CFR 60.3 (6) (available at www.law.cornell.edu/cfr/text/44/60.3), the placement of structural fill (fill used to support a structure) is prohibited in Zone V areas
• Alteration of a sand dune which would increase potential flood damage. (Structures located seaward of the inland limit of the Primary Frontal Dune are not eligible for LOMAs.)
• Construction on a sand dune or mangrove stand that would increase potential flood damage. This includes demolition of a pre-FIRM structure on a dune and replacing it with a new building
• Floodway violations
• If any LOMC application includes property in the floodway, the community Floodplain Administrator (FPA) must determine if land in the floodway has been elevated by fill. If the fill has not been permitted, then it is a violation. If the fill is permitted but causes any measurable increase in the BFE, then it is a violation

• Letters of Map Amendment (LOMAs) available at https://www.fema.gov/letter-map-amendment-loma
• LOMA and LOMR-F Fact Sheet available at https://www.fema.gov/media-library/assets/documents/19871
• Letters of Map Revision--Based on Fill available at https://www.fema.gov/letter-map-revision-based-fill
• 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
• MT-EZ Form and Instructions available at http://www.fema.gov/mt-ez-form-instructions
• MT-1 Form and Instructions available at http://www.fema.gov/mt-1-application-forms-instructions
• Online LOMC—Help and Instructions available at http://hazards.fema.gov/onlinelomc/ext/Help/loadInstructions">Online LOMC—Help and Instructions
• eLOMA Frequently Asked Questions available at http://hazards.fema.gov/femaportal/resources/eLOMA_faq.html">eLOMA Frequently Asked Questions
• National Flood Insurance Program (NFIP) definitions available at http://www.fema.gov/national-flood-insurance-program/definitions
• National Flood Hazard Layer (NFHL) available at http://www.fema.gov/national-flood-hazard-layer-nfhl
• Map Service Center available at http://msc.fema.gov/portal/home

In this lesson we discussed:

• The general timelines and processes for LOMC applications
• The LOMC application review process
• The reasons why LOMA or LOMR-F applications may be approved or denied