This course is designed to provide information to individuals interested in Letters of Map Change (LOMC), especially Conditional Letters of Map Amendment (CLOMAs), Letters of Map Amendment (LOMAs), Conditional Letters of Map Revision–Based on Fill (CLOMR-Fs), and Letters of Map Revision–Based on Fill (LOMR-Fs) on the FEMA, State, community, and applicant level.

At the end of this course, you should be able to:

• Explain basic purpose and procedures of CLOMAs, LOMAs, CLOMR-Fs, and LOMR-Fs
• Describe roles and responsibilities in the LOMC process
• Understand the floodplain management and insurance implications of CLOMAs, LOMAs, CLOMR-Fs, and LOMR-Fs

This lesson provides an overview of the course and an introduction to various course features and functionality.

At the end of the lesson, you should be able to describe the:

• Course structure
• Course navigation
• Knowledge Check functionality
• Slideshow functionality
• Screen features and navigation tools

Take a moment to review the lesson plan for this course. The lesson plan is labeled Lesson List and is located on the right side of your screen.

This course contains eight (8) lessons. The lessons may be accessed sequentially or independently. The time to complete each lesson varies. A page tracker is displayed at the bottom middle of the screen to help you gauge your movement through the lesson. The estimated time required to complete each lesson will be stated on the lesson’s first screen.

After completing the course, take the Final Exam to:

• Gauge your knowledge of the topic
• Receive credit for taking the course

At times during a lesson, there will be a Knowledge Check activity to review one of the concepts from the lesson. Instructions will appear at the top of the screen explaining how to complete the activity.

After you select the Check button, feedback on your answer selection will appear in a dialog box. To close the dialog box window, select the close link at the bottom of the window.

Try the sample Knowledge Check question below.

• The goals and structure of the course
• How to navigate within the course using screen features and your keyboard
• How to access slideshows
• How to interact with Knowledge Checks

Remember, you must complete all lessons and pass the Final Exam to receive credit for the course.

Now that we have introduced the course goals and discussed the various navigation elements and features of the course, let’s get started. To begin the course, select the Next button or choose a lesson from the Topic drop-down list.

This lesson presents the key concepts and principles of Letters of Map Change (LOMCs).

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

• Describe the different types of LOMCs
• Analyze basic scenarios to determine the appropriate LOMC

Flood Insurance Rate Maps (FIRMs) determine where and how floodplain building and development standards must be met, as well as flood insurance purchase requirements and flood insurance costs. However FIRMs cannot account for every minor variation in topography. FIRMs also may not account for changes in flood risk due to development; flood protection works; bridges, dams, or other structures in streams; or natural changes in hydrology.

The Letters of Map Change (LOMCs) process has been established so that property owners, developers, and communities may update the information on FIRMs to more accurately determine the flood risk for a structure, a property, or an area.

This course will help applicants, licensed professionals, and community officials understand which type of LOMC may apply to each situation and important information that each group needs to know. Residents and property owners will learn which LOMC process may apply to them. Surveyors and engineers will learn what information is needed to complete an application. Community officials will learn about the local review process required for some kinds of LOMCs.

A LOMC is a letter which reflects an official change to an effective FIRM.

LOMCs are issued in response to a request for FEMA to amend or revise its effective flood map to remove a property or reflect changed flooding conditions on the effective map.

When certain technical or scientific evidence is available that proves that a property has been inadvertently mapped in a Special Flood Hazard Area (SFHA), or flood hazard data needs to be revised due to man-made changes, a request to FEMA for a LOMC may be submitted.

Base Flood: The flood having a 1% chance of being equaled or exceeded in any given year

Base Flood Elevation (BFE): Highest water surface elevation with a 1% chance of being equaled or exceeded in a given year

National Flood Insurance Program (NFIP): The National Flood Insurance Program (NFIP) aims to reduce the impact of flooding on private and public structures. It does so by providing federally-backed insurance to property owners and by encouraging communities to adopt and enforce floodplain management regulations. These efforts help mitigate the effects of flooding on new and improved structures. Participating communities agree to adopt and enforce floodplain management ordinances to reduce future flood damage

Special Flood Hazard Area (SFHA): The land area covered by the floodwaters of the base flood. The SFHA is where the NFIP's floodplain management regulations must be enforced and the area where the mandatory purchase of flood insurance applies

Flood Insurance Study (FIS): Source of technical data for adoption of floodplain regulations and development of risk information to establish flood insurance rates

Flood Insurance Rate Map (FIRM): Graphical representation of SFHAs, flood hazard risk zones, 1-percent and 0.2-percent annual chance floodplain areas, and other flood-related information

Light Detection and Ranging (LiDAR): A remote sensing method that uses light in the form of a pulsed laser to measure ranges (variable distances) to the Earth

Lowest Adjacent Grade (LAG): The elevation of the lowest ground touching the structure including attached patios, stairs, deck supports or garages.

Lowest Floor Elevation (LFE): The floor of the structure that should be compared with the Base Flood Elevation to determine the elevation difference. It can be the lowest floor of the lowest enclosed area, except for unfinished or flood-resistant enclosures used solely for parking of vehicles, building access, or storage. The floor of a basement (where “basement” means the floor is below grade on all sides) will always be the lowest floor, regardless of how the space is used

Lowest Lot Elevation (LLE): The lowest ground elevation on the legally recorded property (recorded deed or plat)

No-Rise Analysis: The engineering analysis to determine if the project will increase flood heights

Primary Frontal Dune: A continuous or nearly continuous mound or ridge of sand with relatively steep seaward and inward limit slopes immediately landward of and adjacent to the beach

The Base Flood Elevation (BFE) is the computed elevation to which floodwater is anticipated to rise during the base flood. Base Flood Elevations (BFEs) are shown on Flood Insurance Rate Maps (FIRMs) and on the flood profiles. The BFE is the regulatory requirement for the elevation or floodproofing of structures.

The relationship between the BFE and a structure's elevation determines the flood insurance premium.

FEMA review of a LOMC application can take up to 90 days once all requested information is received.

If more information is requested, the applicant has 90 days to submit the additional data or the case will be suspended with no further action.

Once all requested information is submitted to FEMA, the preliminary review process begins again.

If no further information is required, FEMA will begin its technical review, which can take up to 90 days.

When the application review is complete, FEMA will issue a Determination Document for removal or non-removal of the structure, property, or portion of a lot from the SFHA.

If FEMA grants a LOMA or LOMR-F request, the property owner may no longer be required to pay flood insurance. The property owner may send the Determination Document from FEMA to the lender and request that the federal flood insurance requirement for the structure be removed. It is the lender’s prerogative and it may opt to still require flood insurance.

If FEMA denies a LOMA or LOMR-F request, the Determination Document will state "denial," and there is no change to the flood insurance purchase requirements or development regulations for the structure or parcel. The applicant may submit a new application with updated data.

All issued LOMAs and LOMR-Fs are added to the Map Service Center (available at msc.fema.gov/portal/home)and included in the digital FIRMs.

LOMAs or LOMR-Fs can be incorporated into new effective FIRMs or be reissued after the effective date of a new Flood Insurance Study (FIS).

LOMAs or LOMR-Fs can also be superseded by a future FIS.

Approximate or Unnumbered Zone A

• For a LOMR-F request, the applicant’s engineer may have to develop a BFE if a detailed study does not already exist.
  
• For LOMA applications with no BFE, 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 with detailed LiDAR or other elevation data and/or with surveyed cross sections or Base Level Engineering studies will have better data which should lead to more accurate BFE determinations.
  

Approximate or Unnumbered Zone V

• LOMAs in an approximate Zone V can only be processed if existing data such as a preliminary study with a BFE, draft data approved by FEMA with a BFE, or submitted data with a BFE from other federal agencies such as the U.S. Army Corps of Engineers (USACE). If this data does not exist, a Zone V LOMA cannot be processed without submitting the MT-2 application (LOMR form) with the results from a coastal analysis.
  

Zone VE

• LOMAs are available for property that has been inadvertently included in coastal VE Zone areas unless the structure or areas to be removed is seaward of the inland limit of a primary frontal dune.
  

Zone AO

• In areas of shallow/sheet flooding (Zone AO), the elevation of the lowest adjacent grade (LAG) (including deck posts) of the structure(s) must be above the surrounding grade within the SFHA by an amount equal to or greater than the base flood depth shown on the FIRM. If the base flood depth is not shown on the FIRM, the default depth is 2 feet.

A primary frontal due is a continuous or nearly continuous mound or ridge of sand with relatively steep seaward and inward limit slopes immediately landward of and adjacent to the beach.

Out-as-Shown (OAS)

• If the structure is clearly “out-as-shown” on a FIRM, the applicant may be eligible for a LOMA without the need for surveyed elevations. Providing topographical contours demonstrating that the lowest adjacent grade (LAG) of structure is located a significant vertical distance above the BFE will assist with an out-as-shown determination.
  

Floodway

• A Letter of Map Revision--Floodway (LOMR-FW) is an official determination from FEMA as to whether a property on natural grade has been inadvertently mapped in a regulatory floodway.
  

Using LiDAR

• Where detailed LiDAR is available, ground elevations derived from LiDAR may be used to determine the LAG or lowest lot elevation (LLE). The elevation used will be the elevation shown on the Digital Elevation Model (DEM), minus  ½ of the contour interval. For example, if LiDAR is used to develop 2-foot contours, it means that any location is accurate to ½ a contour interval, and the elevation used for the LAG or LLE will be the DEM elevation.

LOMA–Inadvertent inclusion in the floodway

• Sometimes, a LOMA application determines that even though the lowest adjacent grade (LAG) or lowest lot elevation (LLE) is at least equal to the BFE, a portion of the parcel is within the floodway. In such cases, the local FPA must concur on a Community Acknowledgment Form that no fill has been placed in the floodway. Because floodway boundaries are generalized between cross sections, it is not unusual for a floodway boundary to inadvertently cross higher land.
  

Intervening high ground

• Naturally-occurring high ground may provide protection from the base flood by preventing floodwater intrusion. The high ground must be natural; it cannot be based on fill material or a manmade structure. The application form may show the actual LLE or LAG, but the preparer may add comments explaining the presence of naturally occurring intervening high ground with supporting data. Drainage pipes or culverts connecting the areas through the high ground may negate this protection.
  

Amend in (reverse LOMA)

• An applicant may wish to be amended into the SFHA for financial reasons; for example, to become eligible for a mitigation grant. A community may submit a LOMA to include a property in the SFHA in order to clarify a disagreement over applicability of floodplain regulations.

Depending on the nature and extent of the change in the SFHA, different forms requiring different levels of technical information must be submitted.

Select each of the links below to obtain more information about each form:

• MT-EZ application: Use when requesting a LOMA to remove a single structure, lot, or portion of a lot from a SFHA (available at www.fema.gov/mt-ez-form-instructions)


• MT-1 application: Use when requesting CLOMA, LOMA, CLOMR-F, or LOMR-F (available at www.fema.gov/media-library/assets/documents/31858)


• MT-2 application: Use when requesting a CLOMR or LOMR (available at https://www.fema.gov/mt-2-application-forms-and-instructions)

Depending on what forms you need to submit, there may be up to three different ways to submit a LOMC application.

Select the links below to get more information on each submission method:

• Paper Forms – Applicants may submit paper copies of any LOMC application forms and any required attachments by mail. Paper applications should be mailed to the FEMA LOMC Clearinghouse (or to a designated State or county office for jurisdictions operating under Cooperating Technical Partner (CTP) agreements with FEMA)


• Online LOMC– Applicants may complete digital copies of any LOMC application form online and upload any required attachments through the Online LOMC Mapping Information Platform, a web-based tool available at https://hazards.fema.gov/femaportal/onlinelomc/signin


• Electronic Letter of Map Amendment (eLOMA) – eLOMA is a web-based tool for licensed land surveyors, professional engineers, and other FEMA-permitted certified professionals to submit most LOMA requests available at https://hazards.fema.gov/femaportal/wps/myportal/resources/eloma

LOMC Clearinghouse

3601 Eisenhower Avenue, Suite 500

Alexandria, VA 22304-6426

To expedite processing, please address your request to the attention of the following processing specialists:

Attention: LOMC Manager

(Use for Letters of Map Amendment, Conditional Letters of Map Revision--Based on Fill, Letters of Map Revision--Based on Fill)

Under Cooperating Technical Partner (CTP) agreements with FEMA, the following counties or states will review and process CLOMRs and LOMRs for the jurisdictions defined below.

• Alabama: All requests within the state
• Colorado: All requests within the jurisdiction of the Urban Drainage and Flood Control District, in the Denver, CO metropolitan area (http://udfcd.org/)
• Illinois: All requests within the state (http://www.isws.illinois.edu/)
• North Carolina: All requests within the state
• Texas:
• Harris County: All requests within Harris County
• Bexar, Wilson, Karnes, and Goliad Counties: All requests within the jurisdiction of the San Antonio River Authority River Authority (http://www.sara-tx.org/)

Review and processing fees are not required for the following types of map change requests:

• LOMAs

• Map changes based on mapping or study analysis errors

• Map changes based on the effects of natural changes within the SFHA

• Federally sponsored flood-control projects where 50 percent or more of the project's costs are federally funded

• Map changes based on detailed hydrologic and hydraulic studies conducted by Federal, State, or local agencies to replace approximate studies conducted by FEMA and shown on the effective FIRM

• Map changes based on flood hazard information meant to improve upon that shown on the flood map or within the flood study. NOTE: Improvements to flood maps or studies that partially or wholly incorporate man-made modifications within the SFHA will not be exempt from fees

A requester shall be exempt from submitting a review or processing fee for a request for a FIRM change based on a project where:

1. The primary purpose is habitat restoration; and
2. Where the project is funded in whole or in part with Federal or State funds.

This exemption includes projects for dam removal, culvert redesign or installation of a fish passage. For the purposes of this exemption, “habitat restoration” will have the same meaning as the term as it appears in the Partners for Fish and Wildlife Act, 16 USC § 3772 (5) available at https://www.law.cornell.edu/uscode/text/16/chapter-57B.

Endangered Species Act—It is necessary to submit a(n):

• Copy of Incidental Take Permit
  
• Incidental Take Statement
  
• “Not likely to affect” determination from National Marine Fisheries Service, or United States Fish and Wildlife Service (or an official letter concurring the project has “no effect” on proposed or listed species or designated critical habitats

• LOMC Types Job Aid #2
• Letter of Map Amendment (LOMA) available at https://www.fema.gov/letter-map-amendment-loma" target="_blank
• Guidance for Flood Risk Analysis and Mapping, MT-1 Technical Guidance available at https://www.fema.gov/media-library-data/1520966727494-8c05ecc18e141449aa79665641bd9fe3/MT1_Technical_Guidance_Feb_2018.pdf
• MT-EZ Form and Instructions available at https://www.fema.gov/mt-ez-form-instructions
• MT-1 Application Forms and Instructions available at https://www.fema.gov/mt-1-application-forms-instructions
• MT-2 Forms and Instructions available at http://www.fema.gov/mt-2-application-forms-and-instructions
• Online LOMC—Help and Instructions https://hazards.fema.gov/onlinelomc/ext/Help/loadInstructions
• What is eLOMA? available at http://hazards.fema.gov/femaportal/resources/whatiseloma.htm
• NFIP definitions available at https://www.fema.gov/national-flood-insurance-program/definitions

In Lesson 2, we discussed the following topics:

• The six types of Letters of Map Change (LOMCs)
• Conditional Letter of Map Amendment (CLOMA)
• Letter of Map Amendment (LOMA)
• Conditional Letter of Map Revision--Based on Fill (CLOMR-F)
• Letter of Map Revision--Based on Fill (LOMR-F)
• Conditional Letter of Map Revision (CLOMR)
• Letter of Map Revision (LOMR)
• An overview of the LOMC process
• The MT-EZ, MT-1, and MT-2 application forms, and when to use each
• The submission methods for LOMCs including paper applications, Online LOMCs, and electronic Letters of Map Amendments (eLOMAs)
• Special processes for unique situations

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

• Describe the roles and responsibilities of the applicant in relation to LOMCs
• Describe the roles and responsibilities of the community Floodplain Administrator (FPA) in relation to LOMCs
• Describe the roles and responsibilities of licensed professionals in relation to LOMCs
• Describe the roles and responsibilities of FEMA in relation to LOMCs

Floodplain management is the operation of a community program of preventive and corrective measures designed to reduce the risk of current and future flooding to create a more resilient community. These measures take a variety of forms and are carried out by multiple stakeholders with a vested interest in floodplain management.

Development, land use changes and changes in streams or along shorelines can result in flood maps that overestimate or underestimate flood risk. Failure to request map changes when flood conditions change results in some structures being underinsured for their real risk, and others paying more than necessary for flood insurance. This also affects property values and tax revenues. It is essential that flood maps reflect actual flood risk.

The National Flood Insurance Program (NFIP) establishes responsibilities for Federal, State, and local levels of government. While many people play a role in floodplain management, we will be discussing three roles specifically for the Letter of Map Revision (LOMR) process: the community Floodplain Administrator (FPA) role, the licensed professionals' role, and the role of FEMA Regional officials.

The applicant generally begins the LOMC process because of the desire to refine the flood map boundary using ground elevation in order to more accurately determine the flood zone.

The LOMC applicant’s role and responsibilities include:

• Consulting with community officials
• Obtaining the services of the appropriate licensed professional(s)
• Checking the location of the property in relation to the Special Flood Hazard Area (SFHA) 
• Using the status of the project, structure or lot to select the appropriate map change/amendment process
• Completing the appropriate LOMC application
• Obtaining flood insurance by the deadline when a lender provides notification of the mandatory purchase requirement
• Maintaining a record of the LOMC submission

The work of the community floodplain administrator (FPA) is fundamental to the effective management of floodplain resources and flood mitigation. The FPA is responsible for implementing the community’s local floodplain regulations and ensuring that the community is complying with minimum NFIP standards and enforcing any locally-imposed higher standards. Community FPAs may fill the roles of coordinator, regulator, educator, and planner.

The community FPA's responsibilities include:

• Ensuring any required permits are obtained before Letter of Map Change (LOMC) application submittal
• Reviewing LOMC applications as necessary to ensure that projects are compliant with local ordinances
• Understanding how regulations apply to LOMC proposals
• Explaining LOMC procedures and results to property owners and developers
• Assisting property owners with LOMC application, when needed
• Coordinating Conditional Letter of Map Amendment (CLOMA) and Conditional Letter of Map Revision--Based on Fill (CLOMR-F) proposals with other departments and programs
• Maintaining and updating flood data and maps to reflect Letters of Map Amendment (LOMAs) and Letters of Map Revision--Based on Fill (LOMR-Fs)
• Maintaining LOMC records

Engineers, surveyors, and other licensed professionals fill an important floodplain management role. The licensed professionals’ responsibilities include:

• Conduct surveys to collect elevation data and/or metes and bounds descriptions (or lot and block descriptions for platted subdivisions)
• Complete an Elevation Certificate (EC) or the Elevation Form in the MT-1 application. (An Elevation Certificate is highly recommended as it facilitates a more accurate insurance rating)
• Develop Base Flood Elevations (BFEs) for unnumbered (or Approximate) Zone A areas when required
• Assist customers or property owners in completing the LOMC forms
• Understand application submission requirements for mail, Online LOMC, and electronic Letter of Map Amendment (eLOMA) submissions

Through FEMA's flood hazard mapping program, FEMA identifies flood hazards and assesses flood risks and partners with states and communities to provide accurate flood hazard and risk data to guide them to mitigation actions.

Flood hazard mapping is an important part of the NFIP, as it is the basis of the NFIP regulations and flood insurance requirements. FEMA maintains and updates data through Flood Insurance Rate Maps (FIRMs) and risk assessments. FIRMs include statistical information such as data for river flow, storm tides, hydrologic/hydraulic analyses and rainfall and topographic surveys. FEMA uses the best available technical data to create the flood hazard maps that outline a community’s flood risk areas.

FEMA responsibilities include:

• Reviewing, approving or denying, or requesting additional data to support a LOMC application
• Issuing LOMA and LOMR-F determinations and comments on CLOMA and CLOMR-F proposals
• Maintain LOMC records
• Evaluating community compliance with minimum NFIP standards
• If non-compliance is identified, issue a violation memo to the community
• Coordinating with community to resolve violations
• FEMA may develop a BFE for LOMA or LOMR-F applications for structures or lots in Approximate Zone A areas that have no BFE data. This BFE will be based on the best existing Digital Elevation Model (DEM) when more accurate data is not provided by the applicant. BFEs developed by FEMA, using best existing elevation data, tend to be more conservative.

FEMA Regional offices also:

• Provide tools and resources to help communities navigate NFIP requirements and implement higher standards of floodplain management

In this lesson, we discussed the roles and responsibilities of the applicant, the community Floodplain Administrator (FPA), licensed professionals, and FEMA in the Letter of Map Change (LOMC) process:

Applicant's Roles and Responsibilities

• Consulting with community officials
• Obtaining the services of appropriate licensed professionals
• Checking the location of the property site in relation to the Special Flood Hazard Area (SFHA)
• Using the status of the structure or parcel to select the appropriate map change/amendment process
• Completing the appropriate map amendment application
• Obtaining flood insurance by the deadline when lender notifies of mandatory purchase requirement
• Maintaining a record of your LOMC submission

Community FPA’s Roles and Responsibilities

• Ensure all permits are obtained
• Review LOMC applications to ensure project is compliant with local regulations
• Understand how regulations apply to LOMC proposals
• Explain LOMC procedures and results to property owners
• Assist property owners with LOMC applications, when needed
• Coordinate CLOMA and CLOMR-F proposals with other departments and programs
• Maintain and update flood data and maps to reflect LOMAs and LOMR-Fs
• Maintain LOMC records

Licensed Professionals' Roles and Responsibilities

• Conduct surveys to collect elevation data and/or metes and bounds descriptions
• Complete an Elevation Certificate (EC) or the Elevation Form in the MT-1 application
• Develop BFEs for Approximate Zone A areas 
• Assist customers or property owners in completion of LOMC forms
• Understand mail, Online LOMC and eLOMA application submission requirements

FEMA's Roles and Responsibilities

• Review, request additional supporting information, or approve or deny LOMC applications
• Evaluate compliance with minimum NFIP floodplain management regulation
• If non-compliance is identified, issue a violation memo to the community
• Coordinate with community to resolve violations
• FEMA may develop a BFE for LOMC applications for structures or lots in Approximate Zone A areas that have no BFE data

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

• Describe the process to locate a property on an effective flood map
• Recognize the importance of the status of a structure or parcel in selecting the appropriate LOMC application to complete
• Recognize the importance of the applicant consulting with the community Floodplain Administrator (FPA) when considering applying for a Letter of Map Change (LOMC)
• Describe the role of licensed professional(s) in helping an applicant complete an MT-EZ, MT-1, or electronic Letter of Map Amendment (eLOMA) application

It is the responsibility of the applicant to consult with the community Floodplain Administrator (FPA) on all new development in the Special Flood Hazard Area (SFHA). This conversation can help the applicant avoid expensive mistakes and time-consuming application errors.

The community FPA can help an applicant:

• Locate the property on a Flood Insurance Rate Map (FIRM) and determine the Base Flood Elevation (BFE)
• Identify floodplain development-compliant approaches for property development
• Determine if a Letter of Map Amendment (LOMA) or Letter of Map Revision--Based on Fill (LOMR-F) would be appropriate

The community FPA can help a property owner locate the property on a FIRM, determine the BFE, and explain the local floodplain development ordinances which apply to the identified flood zone.

The FPA can also advise the applicant about the appropriate Letter of Map Change (LOMC) approach. This advice can save the property owner time and money during the application process. This consultation should take place as early as possible when a property owner is considering any floodplain development or submitting a LOMC application.

When applying for a LOMC, an applicant may need to obtain the services of a licensed professional to compile the necessary data and documentation to complete the application. Based on the type of LOMA or LOMR-F needed (whether it is for a single structure or for multiple structures):

• A licensed professional must certify the accuracy of the elevation information on an Elevation Certificate (EC) or the Elevation Form in the MT-1 application, including BFE, lowest lot elevation (LLE), and lowest floor elevation (LFE)
• A licensed professional can also advise a property owner whether a metes and bounds description or information on structure’s lowest adjacent grade (LAG) best meets the owner's application needs
• Registered professional engineers can use new or updated hydrologic and hydraulic modeling to determine BFE in an Approximate Zone A area when required
• The signature and stamp of a licensed professional is required on the elevation data to complete a LOMA or LOMR-F application

When applying for a LOMC, it is the responsibility of the applicant to determine the location of the property in relation to the SFHA by checking:

• The effective FIRM
• Applicable Letters of Map Revision (LOMRs)
• Ongoing studies or preliminary data (available at www.fema.gov/view-your-communitys-preliminary-flood-hazard-data)

It is also necessary for the applicant to determine whether the property is:

• Obviously within the SFHA
• Obviously outside the SFHA boundary
• Not clearly inside or outside of the SFHA

The effective FIRM provides information on the flood risk to the community. To determine the flood risk to a property, it is necessary to locate the property on the FIRM.

To locate a property on a FIRM, you can input an address on the Map Service Center website (available at https://msc.fema.gov/portal/home) or follow this step-by-step process when using paper FIRMs.

• Use the FIRM Index to find the correct map panel
• Find the general location of the property on the map panel
• Find the specific location of the property
• Identify the flood insurance risk zone designation
• Estimate the BFE at the property

The following scenario, with a fictional property owner, Carlo, will take you through the process.

For more detailed information on FIRMs, refer to IS-0273: How to Read a Flood Insurance Rate Map (FIRM) available at https://training.fema.gov/is/courseoverview.aspx?code=IS-273.

Carlo knows that his property is on Water Street, which lies in the southeastern portion of the town, south of Interstate Highway 32. Although Water Street is not on the Index, Carlo can use the north arrow and the major roads shown on the Index to determine that Water Street is shown on Panel 0004.

Using the panel number determined from the Index, Carlo identifies that Panel 0004 shows his property. Because the individual panel shows more physical landmarks than the Index, he can find the general location by referring to features such as major roads or city limits.

Carlo’s property is located east of the main intersection of Oak Avenue and Water Street. To find the specific property location, he will need to use known property dimensions and the flood map scale. To assist him in finding the specific location of the property, he may also refer to a plat map of the property, a tax assessor's map, or the property description found on his deed.

Carlo knows his property lies on the northern side of Water Street, east of the intersection of Oak Avenue and Water Street.

First, he finds the dimensions of the property on the tax assessor's map, a plat map, or in a legal description.

Second, he determines the location of his property and structure by determining distances in feet from streets and intersections

Then, he converts these known dimensions to inches using the flood map scale and measurements on the map panel.

For example, in a map scale where 1 inch = 500 feet, he will find that 250 feet on the ground is equal to ½ inch on the flood map, and 50 feet on the ground is equal to 1/10 inch on the flood map.

Carlo’s property is partially in the SFHA. In addition, Carlo’s house is partially in the SFHA.

He can now identify the flood insurance risk zone designation for the property by finding the zone label. The SFHA near the property is labeled Zone AE. The zone designation applies to the portion of the property in the SFHA and to any building located on that portion.

Occasionally, a property or building is shown in the SFHA on the map, but the lowest ground elevation of the property or building is higher than the BFE. This is often due to the limitations of the map scale.

To be sure whether his property or building should be in the SFHA, Carlo needs to make a comparison between the lowest ground elevation of the property or building and the BFE.

If the lowest lot elevation (LLE) of the property or the lowest adjacent grade (LAG) to the building (and, in some instances, the lowest floor elevation [LFE] including the basement of the building) are below the BFE, then the property or building are in the SFHA.

If a property or building is inadvertently shown within the SFHA, Carlo can request a Letter of Map Amendment (LOMA) from FEMA which will state that the house is not within the SFHA.

To estimate the BFE at his property, Carlo can use the BFE lines (labels) shown near the property on the flood map. For example, if BFE lines 109 and 110 are near the property, and 110 is the nearer of the two, Carlo can estimate that the BFE at the property is approximately 110 feet above mean sea level (using NGVD of 1929).

The BFE numbers shown on the flood map are round numbers and are generally no more accurate than plus or minus a half foot. For an accurate BFE, Carlo, or a licensed professional he has hired, will need to refer to the Flood Profiles in the Flood Insurance Study (FIS).

Some SFHAs do not have BFEs shown on the flood maps. These SFHAs are shown as Zone A or Zone V and were determined by approximate methods.

Possible sources for obtaining a BFE in these areas may be the community’s planning, public works, engineering, environmental or transportation departments; the local district of the U.S. Army Corps of Engineers; or the State’s Environmental, Natural Resources, or Transportation Departments. Also, a registered professional engineer could conduct an engineering analysis to determine the BFE at the site.

For LOMA or LOMR-F applications with no BFE, 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 with detailed LiDAR or other elevation data and/or with Base Level Engineering studies will have better data, which should lead to more accurate BFE determinations.

Additional information regarding BFEs in these areas is available in the FEMA publication Managing Floodplain Development in Approximate Zone A Areas available at https://www.fema.gov/media-library/assets/documents/1911.

When applying for a LOMC, it is the responsibility of the applicant to determine the status of the structure or lot:

• Is there an existing structure on the lot?
• Is the existing structure located on a portion of the lot that may be higher than the BFE?
• Has fill been placed on the property?

If a LOMA or LOMR-F request has been prompted by mandatory purchase of flood insurance, only the structure will need to be included in the LOMA or LOMR-F request. This is typically the simplest and least expensive method.

If future development is planned that may include construction of a new structure on a portion of the property at or above the BFE, that portion of the property can be included using a metes and bounds description.

If the lowest lot elevation (LLE) is shown to be at or above the BFE, the entire property can be included.

• Required
  
• Recorded plat map, OR a recorded deed accompanied by tax assessor’s map. Submitted map must include a map scale and North arrow.
  
• Copy of the effective FIRM panel (or FIRMette) on which the structure and/or property location has been accurately plotted. The FIRM or FIRMette must include the title block.
  
• Elevation Certificate or Elevation Form in the MT-1 application with the lowest adjacent grade (LAG) of a structure (including attached deck, porch or steps) or lowest lot elevation (LLE) certified by a licensed professional. (Not required for LOMA Out-as-Shown.)
  
• May be Required (See Special Processes for Unique Situations Part 1, Part 2, and Part 3)
  
• Certified metes and bounds description and map
  
• Community Acknowledgement Form (for a LOMA or LOMR-F in a floodway)
  
• Geometric details of adjacent stream crossings (for an Approximate Zone A area when no BFE data is provided with application)
  
• Forms
  
• MT-EZ application (available at https://www.fema.gov/mt-ez-form-instructions)
  
• MT-1 application (available at http://www.fema.gov/mt-1-application-forms-instructions)
  
• Submission Method
  
• Mail to the FEMA LOMC Clearinghouse (or to a designated State or county office for jurisdictions operating under Cooperating Technical Partner (CTP) agreements with FEMA)
• Submit via the Online LOMC portal (available at https://hazards.fema.gov/femaportal/onlinelomc/signin)
• Submit through the eLOMA (Only for use by licensed professionals to submit applications 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.

Some of the common issues with LOMC applications are:

• All fields not populated; “N/A” wasn’t used when appropriate
• Failure to write the legal property description and address on the application
• Failure to enter contact information and sign and date the application
• Submitting a deed or plat map that is not recorded
• Missing vertical datum on the Elevation Form, datum not identified, or conversion not provided
• Elevations not based on finished construction for an as-built determination

Some of the common issues with CLOMA and LOMA applications are:

• The structure has a lowest adjacent grade (LAG) below the BFE
• Fill is being used to elevate in the floodplain
• Inadequate documentation included with application
• Failure to sign the application form

• Required
  
• Recorded plat map, OR a recorded deed accompanied by tax assessor’s map. Submitted map must include a map scale and North arrow.
  
• Community Acknowledgement Form
  
• Processing fee (see LOMR Processing Fees for single lot/structures or for multi lot/structures)
  
• Other data may also be required (See Special Processes for Unique Situations Part 1, Part 2, and Part 3)   
  
• Submission Method
  
• MT-1 application (available at http://www.fema.gov/mt-1-application-forms-instructions)

Some of the common issues with LOMR-F applications are:

• The existing structure has a lowest floor below the BFE
• Failure to require permits for fill in the floodplain
• Failure to understand that the community indicates its approval of the development by signing the Community Acknowledgement Form
• Failure to understand that the community is concurring that the development is reasonably safe from flooding by signing the Community Acknowledgement Form

The National Flood Insurance Act of 1968 and its amendments established the NFIP which requires a flood insurance policy as a condition of a loan from any federal lender or federally-regulated lending institution if the loan is for improved real estate or a mobile home located in an area of special flood hazard.

It is the responsibility of the applicant to obtain a flood insurance policy, if it is required by the lender, by the stated deadline.

Failure to obtain required flood insurance coverage could result in more expensive forced placement of flood insurance, or even foreclosure on the loan. If any part of a structure is within the SFHA, a LOMC is the only way to legally remove the mandatory flood insurance requirement.

Flood insurance should always be maintained whether or not the structure is within the SFHA. However, the cost of flood insurance is typically significantly lower for structures determined to be outside the SFHA. Mitigation is another option for lowering flood insurance costs for structures in an SFHA. For example, the cost of a standard Zone X flood insurance policy may be higher than the cost for a Zone AE policy if the Zone AE structure has 2 or more feet of freeboard.

Even with a LOMA or LOMR-F, flood risk remains, and homeowner’s insurance does not cover damages from floods. Applicants need to be aware that:

• A lender may require flood insurance even with a LOMA or LOMR-F.
• After receiving a LOMA or LOMR-F, the property owner may be able to receive a flood insurance refund if the lender allows the property owner to drop flood coverage.
• If flood insurance is required for a mortgage, it is the applicant’s responsibility to obtain adequate flood insurance within 45 day of closing on (or refinancing) the loan. The lender may “force-place” a policy if flood insurance is not obtained. Force-placed insurance policies are almost always costlier than standard flood insurance policies obtained before the deadline.

A successful request for a LOMA or LOMR-F results in an official letter from FEMA that describes a lot or structure that is not in the SFHA. The letter is sent to the applicant, the community’s FPA, and the State’s NFIP coordinating office. The letter is also stored online at FEMA’s Map Service Center (available at https://msc.fema.gov/portal/home). The letter may be used as documentation for lenders and insurance agents that the structure(s) is no longer at risk from the base flood. Lenders may then remove the mandatory flood insurance purchase requirement at their discretion and the property owner may use the letter to obtain a lower cost flood insurance policy.

LOMAs and LOMR-Fs are transferable to future owners of the property and remain valid until a flood map is updated. When maps are updated, FEMA reviews each LOMA and LOMR-F to determine if it should be revalidated or if it has been superseded by new mapping information.

• Map Service Center available at https://msc.fema.gov/portal/home
• MT-EZ Form and Instructions available at https://www.fema.gov/mt-ez-form-instructions
• MT-1 Application Forms and Instructions available at https://www.fema.gov/mt-1-application-forms-instructions
• Online LOMC—Help and Instructions available at https://hazards.fema.gov/onlinelomc/ext/Help/loadInstructions
• What is eLOMA? available at https://hazards.fema.gov/femaportal/resources/whatiseloma.htm
• IS-0274: How to Read a Flood Insurance Study (FIS)

In this lesson we discussed the roles and responsibilities of the applicant, as related to the LOMC process:

Applicant's Responsibilities

• Consulting with community officials
• Obtaining the services of a licensed professional(s)
• Checking the location of the property in relation to the SFHA
• Using the status of the structure or lot to select the appropriate map change/amendment process
• Completing the appropriate map amendment application
• Avoiding errors or omissions that can delay the processing of a LOMC application
• Obtaining flood insurance by the deadline, if it is a mandatory purchase
• Maintaining LOMC records

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

• Recognize the community Floodplain Administrator's (FPA’s) role in the LOMC processes
• Describe the process to address potential violations of local floodplain management ordinances
• Identify the purpose and implications of the Community Acknowledgement Form
• Recognize Letter of Map Change (LOMC) recordkeeping best practices

The community FPA’s role as a coordinator includes:

• Serving as the local floodplain management point-of-contact with other jurisdictions, State agencies, and the federal government on LOMC applications
• Coordinating the floodplain management role and actions with other jurisdictions and departments
• Maintaining maps and other floodplain records
• Maintaining and updating flood data and maps to reflect changes

The community FPA’s role as a planner includes:

• Developing floodplain management plans
• Coordinating with other planning bodies to incorporate floodplain considerations into local plans
• Participating in the community or regional hazard mitigation planning process

The community FPA’s role as an educator includes:

• Explaining the importance of floodplain management to elected officials and citizens
• Advising citizens of mandatory purchase ramifications and options for purchasing flood insurance coverage
• Explaining LOMC procedures and results to property owners and developers, and assisting property owners with LOMC applications, when needed
• Communicating flood risk

The community FPA’s role as a regulator includes:

• Overseeing the floodplain development permit process
• Ensuring all permits are obtained before LOMC application submittal
• Reviewing certain LOMC applications to ensure project is compliant
• Initiating and monitoring enforcement action against violators
• Understanding how regulations apply to Conditional Letter of Map Amendment (CLOMA) and Conditional Letter of Map Revision--Based on Fill (CLOMR-F) proposals
• Reviewing and signing the Community Acknowledgement Form if a Letter of Map Amendment (LOMA) request contains inadvertent inclusion in floodway area

The community FPA’s customers can include:

• Property owners and residents
• Surveyors, engineers or architects
• Developers
• Lenders
• Insurance agents
• Real estate agents
• Business and civic groups

To assist the customer, the community FPA will need to:

• Understand LOMCs and provide guidance on how to complete the appropriate application
• Assist applicant to understand which LOMC application is suitable for a specific situation when necessary 
• Explain situations when a LOMC may not be feasible

To assist the customer, the community FPA will also need to be able to:

• Review LOMC forms for accuracy and completeness:
• Is the correct Flood Insurance Rate Map (FIRM) being used?
• Are the community name and number listed correctly?
• Is the vertical datum specified?
• Are the lowest lot elevation (LLE), lowest adjacent grade (LAG), or lowest floor elevation (LFE) compared to the Base Flood Elevation (BFE) compliant and reflect eligibility for a CLOMA, LOMA, CLOMR-F, or LOMR-F? 
• Are all the signatures and seals included?
• Are there no LOMA or LOMR-F requests for development located seaward of the inland limit of the primary frontal dune in Zone V? 
• Is the Community Acknowledgment Form signed for CLOMR-F, LOMR-F or LOMAs involving inadvertent inclusion in floodway?

Remember to consider public safety and emergency access to the site.

To assist with LOMC applications, the community FPA will also need to know which regulations pertain to floodplain development proposals, including:

• Lowest floor requirements
• Floodway requirements
• Coastal V Zone requirements
• Higher local or state regulatory standards
• Other local, State or federal permits (e.g., stream protection, wetlands, endangered species)

For more information, refer to FEMA Publication 480 NFIP Floodplain Management Requirements: A Study Guide and Desk Reference for Local Officials and MT-1 Technical Guidance available at https://www.fema.gov/media-library-data/1520966727494-8c05ecc18e141449aa79665641bd9fe3/MT1_Technical_Guidance_Feb_2018.pdf" target="_blank">MT-1 Technical Guidance

Common potential floodplain management violations include:

• Non-permitted development (including additions)
• Lowest floor/basement below the BFE
• Lowest floor below highest adjacent grade (HAG) in AO Zones
• Fill in floodway*
• Fill used for structural support in coastal V Zones
• Construction in V Zone areas located seaward of the inland limit of the primary frontal dune.
• Slab on grade construction in V Zone areas

*If an applicant is proposing to place fill in the floodway, direct the applicant to use the MT-2 application form and go through the Conditional Letter of Map Revision (CLOMR) process.

Communities that participate in the National Flood Insurance Program (NFIP) are expected to remedy violations to the maximum extent possible. A community should take the following steps if notified of a potential violation:

1. Investigate to determine if there is a violation.
2. If there is a violation and a structure has received a certificate of occupancy or compliance, notify the property owner about the nature of the violation(s) and provide recommendations on ways to mitigate the violation(s).
3. Provide technical assistance on remediation methods.
4. As appropriate, issue stop work orders or fines until the violation is remediated.
5. Order removal of materials that constitute floodway violations.
6. Periodically visit the property to determine if violations have been corrected.
7. Issue revised notice of compliance when violation has been rectified.
8. If remediation requests are not met, and state and local laws allow it, rescind any certificates of compliance or occupancy that had been issued for the property.
9. If the community has taken all legal steps to achieve compliance but has failed, a Section 1316 letter to FEMA can remove the availability of flood insurance from the structure.
10. If compliance is achieved, notify FEMA so flood insurance eligibility can be restored.

A signed Community Acknowledgement form is required for CLOMR-Fs, LOMR-Fs and when a LOMA application involves an area that was inadvertently included within the floodway.

For LOMR-F and CLOMR‐F requests, only Section A needs to be completed. For LOMA requests in which the property has been inadvertently included within the regulatory floodway, only Section B needs to be completed.

A signed Community Acknowledgement Form indicates to FEMA that:

• All necessary permits were obtained
• The applicant is in compliance with local ordinances and NFIP regulations
• Fill does not result in a floodway encroachment
• The community is aware of actions that can potentially impact floodplains
• The LOMC does not undermine the authority of the community
• Development will be/is reasonably safe from flooding

As with floodplain development permits, certification that a site is reasonably safe from flooding is not a guarantee that it will never flood. Larger floods do occur and flood elevations may increase.

The community may have comments. Additional sheets for comments may be added to the application. The community FPA can also add comments for the record documenting any disagreement.

Community officials are urged not to sign if the proper permits have not been obtained or if the project cannot be shown to be reasonably safe from flooding. The community official can also refuse to sign because the community lacks the resources in order to adequately evaluate the technical portion of the application. In this instance, the community would defer evaluation to FEMA and would state its acceptance of FEMA's decision. However, the community FPA would still need to evaluate that the application meets local ordinances and permitting requirements.

The community official may also sign the form, but state that the project is not compliant.

LOMAs and LOMR-Fs update the flood hazard information depicted on the Flood Insurance Rate Map (FIRM), but do not change the Flood Insurance Study (FIS).

FEMA mails a copy of the LOMC determinations to the property owner and to the community. Communities should maintain a file of all LOMC determinations.

LOMCs are also available using the Community Search process or the National Flood Hazard Layer (NFHL) viewer on the FEMA Map Service Center website, available at https://msc.fema.gov/portal/home.

• Elevation Certificate and Instructions available at http://www.fema.gov/media-library/assets/documents/160
• Job Aid 1, MT-EZ Form
• Job Aid 2, LOMC Types
• Job Aid 3, MT-1 Forms
• Job Aid 5, eLOMA
• Job Aid 6, On-line LOMC
• Job Aid 8, Standard Flood Hazard Determination (SFHD) Form
• Job Aid 9, Best Practices
• Job Aid 11, Community Acknowledgement
• MT-1 Form with Community Acknowledgement Form available at https://www.fema.gov/mt-1-application-forms-instructions
• FEMA Publication 480 NFIP Floodplain Management Requirements: A Study Guide and Desk Reference for Local Officials available at http://www.fema.gov/media-library-data/1481032638839-48ec3cc10cf62a791ab44ecc0d49006e/FEMA_480_Complete_reduced_v7.pdf
• NFHL viewer on the FEMA Map Service Center website available at http://msc.fema.gov
• 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

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

• Understanding community FPA’s roles and responsibilities
• Understanding who are the community FPA’s customers and how to help them understand their LOMC options
• How to handle floodplain management violations revealed during the LOMC application process
• The purpose and considerations of the Community Acknowledgment Form
• LOMC recordkeeping best practices

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

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.

• 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)

• 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.

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

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).

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.

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.

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

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

• 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.

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):

• NGVD 29 
• NAVD 88

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

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.

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

• 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)

• 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

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

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

• 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

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

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

• Identify the benefits of maintaining flood insurance after receiving a LOMA or LOMR-F
• Recognize the connection between mandatory purchase of flood insurance and LOMAs and LOMR-Fs
• Recognize the different degrees of flood risk remaining after a LOMA or LOMR-F is issued

Letters of Map Amendment (LOMAs) and Letters of Map Revision--Based on Fill (LOMR-Fs) do not expire, but they can be superseded by a new Flood Insurance Rate Map (FIRM).

LOMAs and LOMR-Fs are transferable to future owners.

When FEMA prepares to revise a FIRM, the associated LOMAs and LOMR-Fs that are affected by the revision are reviewed and incorporated when appropriate.

When preparing a Preliminary Map or revised map panel, FEMA sends a Summary of Map Actions (SOMA) to the community which identifies all LOMCs issued for a community and whether:

• The LOMA or LOMR-F will be incorporated into the new FIRM and the floodplain boundary revised to show the area outside of the Special Flood Hazard Area (SFHA)
• The LOMA or LOMR-F is likely to be superseded by new information on the FIRM and will no longer be valid
• The LOMA or LOMR-F is likely to be revalidated when the new map panel is published
• More information is required to make a determination

When the effective FIRM is issued, FEMA issues a Revalidation Letter which lists the LOMCs that are still in effect for the new FIRM.

There are actions you can take that can cause a LOMA or LOMR-F to become invalid:

• Changing the landscape in a manner that increases flood risk, such as excavating land and allowing flood waters to encroach upon the area covered by the LOMA or LOMR-F
• Expanding a structure to a portion of the lot not included in a LOMA or LOMR-F
• If an updated FIRM panel supersedes a LOMA or LOMR-F, the LOMC is invalidated.

The “100-year or 1-percent annual chance flood” is an insurance standard and not a risk standard. The 1-percent annual flood risk means that a structure has a 26-percent chance of experiencing a flood at or above the BFE over the life of a 30-year mortgage.

Even with a LOMA or LOMR-F, flood risk remains and homeowner’s insurance does not cover damages from floods. Flood insurance is available for nearly all structures, regardless of the flood zone.

Some important points to remember about LOMCs and flood insurance are:

• A lender may require flood insurance even with a LOMA or LOMR-F
• After receiving a LOMA or LOMR-F, the property owner may be able to receive a flood insurance refund if the lender allows the property owner to drop his or her flood coverage
• Structures outside the SFHA represent 20 percent of all NFIP flood insurance claims and receive one-third of federal disaster assistance for flooding
• When it’s available, federal Disaster Assistance is typically a loan you must repay with interest

Property owners whose properties do not qualify for a LOMA or LOMR-F should invest in mitigation measures. Elevating a structure above the BFE (called adding “freeboard”) greatly reduces the risk of flood damage and the cost of flood insurance, and increases resiliency following a flood event.

LOMA and LOMR-F may remove a lot or a structure from the SFHA, meaning that it would not be inundated by the base or 1-percent annual chance flood. But that does not mean that there is no risk.

There are different degrees of risk. Consider risk and the likelihood of an event multiplied by the consequence of that event. You can have a high probability/low consequence event, such as a flood that is lower than the base flood. You can have a low probability/high consequence event, such as a failure of a dam or a flood control structure. We have seen with recent hurricanes and with the increase in high-intensity rainfall events that deep or high-velocity flooding within the SFHA is a high probability/high consequence event.

A LOMA or LOMR-F does not eliminate risk. As such, it should not be used as merely a means to “get out of” paying for flood insurance. As we have learned, more than 20 percent of all NFIP flood insurance claims and fully one-third of all federal Disaster Assistance requests are for structures located outside of the SFHA.

Flood risk remains even after obtaining a LOMA or LOMR-F and it is still considered a good resilience measure to have flood insurance. Where it rains, it can flood.

Mitigating structures in flood zones and building new structures to higher standards can save property owners money on flood insurance and post-disaster recovery costs.

• Flood Insurance Information available at http://www.floodsmart.gov/
• FEMA Know Your Risk available at http://www.fema.gov/media-library/assets/documents/18542
• FEMA RiskMAP available at http://www.fema.gov/risk-mapping-assessment-and-planning-risk-map
• FEMA Map Service Center available at http://msc.fema.gov/portal/home
• NFIP Flood Insurance Advocate available at http://www.fema.gov/national-flood-insurance-program-flood-insurance-advocate

In this lesson we discussed:

• LOMAs and LOMR-Fs remain with the property or structure until they are superseded by new flood maps or by changes to the property
• LOMAs and LOMR-Fs are transferrable to new owners
• When FEMA updates a FIRM, multi-lot LOMAs and LOMR-Fs may be incorporated into an updated FIRM panel
• Residual flood risks remain after a LOMA or a LOMR-F is obtained
• Flood insurance is always advisable
• Mitigating structures in flood zones and building new structures to higher standards can save property owners money on flood insurance and post-disaster recovery costs

At the end of this course, you should be able to:

• Explain basic purpose and procedures for Conditional Letters of Map Amendment (CLOMAs), Letters of Map Amendment (LOMAs), Conditional Letters of Map Revision—Based on Fill (CLOMR-Fs), and Letters of Map Revision—Based on Fill (LOMR-Fs)
• Describe roles and responsibilities in the Letter of Map Change (LOMC) process
• Understand the floodplain management and insurance implications of CLOMAs, LOMAs, CLOMR-Fs, and LOMR-Fs

In Lesson 2, we discussed the following topics:

The six types of Letters of Map Change (LOMCs), their purposes, and limitations

• A Conditional Letter of Map Amendment (CLOMA) is FEMA’s official review comments for a proposed project that involves only the elevation of structures on natural high ground
• A Letter of Map Amendment (LOMA) is an amendment to the FIRM which establishes that a property is not located in a Special Flood Hazard Area (SFHA) due to natural high ground
• A Conditional Letter of Map Revision—Based on Fill (CLOMR-F) is FEMA’s official review comments for a proposed project in the SFHA that involves the placement of fill
• A Letter of Map Revision—Based on Fill (LOMR-F) is used to remove a structure or lot of land from the SFHA because it has been elevated on fill above the Base Flood Elevation (BFE)
• A Conditional Letter of Map Revision (CLOMR) is FEMA’s official review comments for whether a proposed project complies with the minimum National Flood Insurance Program (NFIP) floodplain management criteria and any eventual revisions that will be made to the Flood Insurance Rate Map (FIRM) upon completion of the project
• A Letter of Map Revision (LOMR) is an official revision to the FIRM that is used to change flood zones, floodplain and floodway delineations, and flood elevations

Why are LOMAs and LOMR-Fs requested

• CLOMA--To receive FEMA’s comment on whether a project, if built as proposed, would or would not be removed from the SFHA by FEMA if later submitted as a request for a LOMA
• LOMA--To receive FEMA’s determination on a property's location in relation to the SFHA. To obtain an official amendment, by letter, to an effective NFIP map
• CLOMR-F--To obtain FEMA's comment on whether a project involving the placement of fill, if built as proposed, would or would not be removed from the SFHA by FEMA if later submitted as a request for a LOMR-F. To assure all required federal, State and local permits have been obtained and Endangered Species Act (ESA) requirements have been met
• LOMR-F--To obtain FEMA's determination concerning whether a structure or parcel has been elevated on fill to or above the BFE so that it would be excluded from the SFHA. To obtain an official revision, to an effective NFIP map

An overview of the LOMC process

• FEMA review of a LOMC application can take up to 90 days once all requested information is received
• If more information is requested, the applicant has 90 days to submit the additional data or the case will be suspended with no further action
• Once all requested information is submitted to FEMA, the preliminary review process begins again
• If no further information is required, FEMA will begin its technical review, which can take up to 90 days
• When the application review is complete, FEMA will issue a Determination Document
• If FEMA grants a LOMA or LOMR-F request, the property owner may no longer be required to pay flood insurance. The property owner may send the Determination Document from FEMA to the lender and request that the federal flood insurance requirement for the structure be removed. It is the lender’s prerogative and it may opt to still require flood insurance
• If FEMA denies a LOMA or LOMR-F request, the Determination Document will state "denial" and there will be no change to the flood insurance purchase requirements or development regulations for the structure or parcel. The applicant may submit a new application with updated data
• All issued LOMAs and LOMR-Fs are added to the Map Service Center and included in the digital FIRMs

Special processes for unique situations

• LOMAs are not available within Zone V unless the property is located seaward of the inland limit of a primary frontal dune
• For applications with no BFE, FEMA may be able to develop BFEs based on existing data
• In areas of shallow/sheet flooding (Zone AO), the elevation of the lowest adjacent grade (LAG) (including deck posts) of the structure(s) must be above the surrounding grade within the SFHA by an amount equal to or greater than the base flood depth shown on the FIRM
• If the structure is clearly “out-as-shown” on a FIRM, the applicant may be eligible for a LOMA or LOMR-F without the need for surveyed elevations
• Where detailed LiDAR is available, ground elevations derived from LiDAR may be used to determine the lowest adjacent grade (LAG) or lowest lot elevation (LLE). The elevation used will be the elevation shown on the Digital Elevation Model (DEM), minus ½ of the contour interval
• Sometimes, a LOMA application determines that, even though the LAG or LLE is at least equal to the BFE, a portion of the structure or lot is within the floodway. In such cases, the community FPA must concur on a Community Acknowledgment Form that no fill has been placed in the floodway to elevate the structure or portion of the lot
• Naturally-occurring high ground may provide protection from the base flood by preventing floodwater encroachment on the property. This protection cannot be based on fill material or a manmade structure. The application form may show the actual LLE or LAG, but the preparer may add comments explaining the presence of naturally occurring intervening ground that is higher than the expected base flood with support data
• An applicant may wish to be amended into the SFHA for financial reasons; for example, to become eligible for a mitigation grant

The MT-1 and MT-EZ forms, and when to use each

• Use the MT-EZ when requesting single lot or single structure residential LOMA requests
• Use the MT-1 when requesting a commercial or a multi-lot or multi-structure CLOMA, LOMA, CLOMR-F, or LOMR-F
• Use the MT-2 when requesting a CLOMR or LOMR

The LOMA submission methods including paper applications, Online LOMCs, and eLOMA applications

• Paper form: Applicants may submit paper applications by mail using the MT-1 or MT-EZ forms
• Online LOMC: A web-based tool that allows applicants to easily request an amendment or revision to a flood map
• eLOMA: A web-based tool for licensed land surveyors, professional engineers, and other FEMA-permitted certified professionals to submit most LOMA requests

In Lesson 3 we discussed an overview of the roles and responsibilities of the applicant, the community Floodplain Administrator (FPA), licensed professionals, and FEMA, as related to the Letter of Map Change (LOMC) process:

Applicant’s Responsibilities

• Consult with community officials
• Obtain the services of appropriate licensed professional
• Check the location of the property in relation to the SFHA
• Use the status of the structure or lot to select the appropriate map change/amendment process
• Complete the appropriate map amendment application
• Obtain flood insurance by the deadline when lender notifies of mandatory purchase requirement
• Maintain LOMC records

Community FPA’s Role

• Ensure all permits are obtained
• Review LOMC applications to ensure project is compliant with local regulations
• Understand how regulations apply to CLOMA and CLOMR-F proposals
• Explain LOMC procedures and results to property owners
• Assist property owners with LOMC application, when needed
• Coordinate CLOMA and CLOMR-F proposals with other departments and programs
• Maintain and update flood data and maps to reflect LOMAs and LOMR-Fs
• Maintain LOMC records

Licensed Professionals’ Responsibilities

• Conduct surveys to collect elevation data and/or metes and bounds descriptions
• Complete an Elevation Certificate (EC) or the Elevation Form in the MT-1 application (An EC is highly recommended as it facilitates a more accurate insurance rating)
• Develop BFEs for unnumbered Approximate Zone A areas
• Assist customers or property owners in completing the LOMC forms
• Understand requirements for mail, Online LOMC, and eLOMA application submissions

FEMA Responsibilities

• Review, request additional supporting information, or approve or deny LOMC applications
• Evaluate compliance with minimum NFIP floodplain management regulations
• If not compliant, issue a violation memo to the community
• Coordinate with community to resolve violations
• Possibly develop a BFE for LOMA or LOMR-F applications for structures or lots in Approximate Zone A areas that have no BFE data

In Lesson 4, we discussed the applicant’s roles and responsibilities in regard to LOMCs, including:

• Consulting with community officials
• Obtaining the services of appropriate licensed professional(s)
• Checking the location of the property in relation to the SFHA by checking:
• The effective FIRM
• Applicable Letters of Map Revision (LOMRs)
• Ongoing studies or preliminary data
• Determining whether the property is:
• Obviously within the SFHA
• Obviously outside the SFHA boundary
• Not clearly inside or outside of the SFHA
• Using the status of the structure or lot to select the appropriate map change/amendment process:
• Is there an existing structure on the lot?
• Is the existing structure located on a portion of the lot that may be higher than the BFE?
• Has fill been placed on the property?
• If a LOMA or LOMR-F request has been prompted by mandatory purchase of flood insurance, only the structure will need to be included in the request. This is typically the simplest and least expensive method
• If future development is planned that may include construction of a new structure on a portion of the property at or above the BFE, that portion of the property can be included using a metes and bounds description
• If the LLE is shown to be at or above the BFE, the entire property can be included
• Completing the appropriate map change application based on the location of the property to the SFHA and the status of the property. The community FPA can provide guidance on the appropriate LOMC application
• Obtaining flood insurance by the deadline when lender notifies of mandatory purchase requirement
• Maintaining LOMC records

In Lesson 5, we discussed the roles and responsibilities of a community FPA, in regard to LOMCs including:

The process to address potential violations of local floodplain management ordinances

• Investigate the site to determine if there is a violation
• Provide notice to property owner of the nature of violation(s)
• Provide technical assistance on remediation methods
• Issue stop work orders or fines
• Rescind certificate of occupancy or certificate of compliance
• Send notice to FEMA that the structure(s) is not in compliance in spite of the community's taking all legal means to achieve compliance. This may be done via a Section 1316 letter which informs FEMA that it can remove the availability of flood insurance from the structure

The purpose and limitations of the Community Acknowledgment Form

• To determine whether the community has evidence that the site is reasonably safe from flooding
• Implies that all permits have been received

LOMC recordkeeping best practices

• LOMAs and LOMR-Fs change flood hazard information, but do not change the physical flood map panel
• LOMCs are mailed to the community; communities should maintain a file of LOMCs

In Lesson 6, we discussed the licensed professional’s role and responsibilities, in regard to LOMCs including:

Information Required for LOMC 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 fill 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)
• 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 structure or property and datum used
• BFE and the source for the BFE data
• Certification by licensed land surveyor, registered professional engineer, or architect
• A signed Community Acknowledgement Form for LOMA requests for property inadvertently included within the floodway

Also in Lesson 6, we discussed:

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
• Base flood elevation (BFE)
• For requests involving a portion of the property, include the lowest ground elevation within the metes and bounds description.
• 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 source of the BFE or base flood depth data
• For requests involving a portion of the property, include the LAG within the metes and bounds description

Advantages and Limitations of eLOMA Applications

• Same information as for a paper-based LOMA
• Licensed professional must apply for an eLOMA account with FEMA
• Results are often 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 on an alluvial fan or Zone V area
• There is already a LOMA application being processed for the subject of the request

In Lesson 7, we discussed FEMA’s roles and responsibilities, in regard to LOMCs including:

Basis for approval of a LOMC application

• For one or more structures, the lowest adjacent grade (LAG) must be at or above the BFE
• For one or more lots, the lowest lot elevation (LLE), must be at or above the BFE
• Elevations must be certified by a licensed land surveyor, registered professional engineer or architect
• All forms for the LOMC are completed and all required documentation is attached
• An annotated FIRM is included
• The participating community has determined that the land and any existing or proposed structures to be removed from the SFHA are “reasonably safe from flooding”

Why a LOMA or LOMR-F application may be denied

• If the LAG to a structure is lower than the BFE
• If the LLE, or lowest portion of property to be excluded, is lower than the BFE

Violations to floodplain management regulations that may be discovered during the LOMC application process

• A LOMA or LOMR-F may not be granted if the LFE, including basement, is below the BFE. This may be a violation for a post-FIRM structure that would need to be corrected
• In Zone AO construction, the lowest floor is below the highest adjacent grade (HAG) and plus the base flood depth number
• Placement of structural fill (fill used to support a structure) is prohibited in Zone V areas
• Construction seaward of the inland limit of the primary frontal dune in Zone V areas
• If a LOMA application includes property in the floodway, the community 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, it is a violation

In Lesson 8, we discussed the:

Benefits of maintaining insurance after receiving a LOMA or LOMR-F approval

• Flood risk remains even after obtaining a LOMA or LOMR-F
• Homeowner’s insurance does not cover damages from floods
• Twenty percent of flood insurance claims and one-third of Disaster Assistance requests are for structures outside of the SFHA
• Flood insurance is available for nearly all structures, regardless of the flood zone
• Flood insurance is always advisable

Connection between LOMCs and mandatory purchase of flood insurance

• A lender may require flood insurance even with a LOMA or LOMR-F

Different degrees of risk remaining after a LOMA is issued

• High probability but low consequence of shallow flooding due to ponding after heavy rains
• Low probability and high consequence of flash flooding due to sudden release of water (from a beaver dam rupture/ice jam release) outside of the SFHA or due to a flood structure (levee or dam) failure
• High probability and high consequence of flash flooding deep or high velocity flooding within the SFHA due to a hurricane or high-intensity rainfall event
• Mitigating structures in flood zones and building new structures to higher standards can save property owners money on flood insurance and post-disaster recovery costs

Congratulations! You have finished the final lesson in the IS-1119: LOMAs and LOMR-Fs course!

To receive credit for this course, you must:

• Take the final exam online at the EMI Independent Study Programs Secure exam site. Copies of the exam answer sheet will not be accepted
• Answer at least 75 percent of the questions correctly

Additional instructions on completing the exam are provided on this secure site.