This course is designed to provide information to individuals interested in Letters of Map Revisions (LOMRs) on the FEMA, state, and tribal or local community levels.

LOMRs are a type of Letter of Map Change (LOMC). LOMCs also include Letters of Map Amendment (LOMAs), Letters of Map Revision Based on Fill (LOMR-Fs), Conditional Letters of Map Amendment (CLOMAs), Conditional Letters of Map Revision (CLOMRs), and Conditional Letters of Map Revision—Based on Fill (CLOMR-Fs).

LOMRs are either a reflection of a physical change to the land or waterway that changes flood elevations or flood zone boundaries, or are an updated analysis of conditions in order to revise a map or study. This course focuses on LOMRs, including LOMR-Fs, CLOMRs, and CLOMR-Fs. A separate independent study course focuses on LOMAs.

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

• Explain the basic purpose and procedures of LOMRs.
• Describe roles and responsibilities in the LOMR process.
• Understand the floodplain management and insurance implications of LOMRs.

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 nine (9) 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.

In Lesson 1, we discussed the:

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

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

• Describe the different types of LOMRs
• Analyze scenarios to determine the LOMR type

A LOMR reflects an official change to an effective Flood Insurance Rate Map (FIRM).

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

• LOMRs may be initiated by the community or by FEMA. Communities may submit LOMR applications on behalf of property owners with the owner’s representatives providing all of the analyses, and the property owners paying all fees
• Communities may initiate LOMRs through the Cooperating Technical Partner (CTP) process, in which communities develop data to update FIRMs and Flood Insurance Studies in cooperation with FEMA
• FEMA may initiate a LOMR to provide updates for a portion of a community’s FIRM without issuing new FIRMs
• A Physical Map Revision (PMR) is a large-scale LOMR which typically affects two or more map panels

There are four types of LOMRs:

Letter of Map Revision (LOMR)– LOMR is a revision to the currently effective FIRM which changes flood zones, delineations, and elevations by letter. This allows the Federal Emergency Management Agency (FEMA) to revise flood hazard information on a FIRM without physically revising and reprinting the entire map panel.

Conditional Letter of Map Revision (CLOMR)–A CLOMR is FEMA's comment on a proposed project within the SFHA. A CLOMR is a document that comments on whether the proposed project that would alter the SFHA on the effective FIRM meets the minimum floodplain management criteria of the NFIP and whether the analysis meets FEMA’s technical mapping standards, and, if so, what revisions will be made to the community's FIRM if the project is completed as proposed.

Letter of Map Revision—Based on Fill (LOMR-F)–A LOMR-F is a revision to the currently effective FIRM which establishes that a property is not located in an SFHA due to the placement of fill that does not increase the Base Flood Elevation (BFE) and which will not be inundated by the base flood.

Conditional Letter of Map Revision—Based on Fill (CLOMR-F)–A CLOMR-F is FEMA's comment on a proposed project in the SFHA involving the placement of fill. A CLOMR-F is a document that comments on whether the proposed project meets the minimum floodplain management criteria of the NFIP and, whether a LOMR-F could be issued if the project is built as proposed.

For more information on flood hazard mapping refer to https://www.fema.gov/flood-hazard-mapping-frequently-asked-questions.

The most common reasons why LOMRs are submitted are to:

• Update information on flood risk or topography
• Reflect changes due to flood protection projects
• Update flood elevations based on bridge or culvert work
• Provide evidence that the effect of the proposed development, when combined with all other existing and anticipated development, will not result in a "cumulative rise" in the BFE of more than one foot at any point within the community
• Adjust flood insurance rate information

Other reasons why LOMRs are submitted are to:

• Support a floodplain development permit application for filled land
• Understand the effects of proposed development in the floodplain
• Reflect the effects of recent development in the floodplain

LOMR-Fs

• After reviewing a LOMR-F application, FEMA will issue a Determination Document, either approving or denying the map change
• If FEMA approves a LOMR-F application, the property owner may no longer be required to pay flood insurance. The property owner may send the Determination Document to their lender and request that the federal flood insurance requirement for the structure and/or property be removed. It is the lender’s prerogative and they may opt to still require flood insurance
• If the LOMR-F application is denied, 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
• LOMR-Fs are added to the Map Service Center (MSC) and are included in the list of LOMCs for the community

LOMRs

• After reviewing a LOMR application, FEMA will either issue a Determination Document (including any updated flood maps and Flood Insurance Study tables) or request additional information
• If more data is requested, the applicant has 90 days to submit the additional data or the case will be suspended with no further action
• All LOMRs are added to the MSC and are reviewed and, if valid, will be incorporated into any new effective FIRM or reissued after the effective date

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

• MT-1: Use the MT-1 when requesting a LOMR-F or CLOMR-F. The MT-1 application is available at: https://www.fema.gov/media-library/assets/documents/31858
• MT-2: Use the MT-2 when requesting LOMRs and CLOMRs. The MT-2 application is available at: https://www.fema.gov/mt-2-application-forms-and-instructions

Depending on what forms you need to submit, there are two ways to submit a LOMR.

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

• Paper forms – Applicants may submit paper applications by mail using the MT-1 or MT-2 forms. MT-1 Forms and Instructions are available at https://www.fema.gov/mt-1-application-forms-instructions. MT-2 Forms and Instructions are available at https://www.fema.gov/mt-2-application-forms-and-instructions
• Online LOMC– An internet-based tool that allows applicants to easily request an amendment or revision to a flood map. More information about the Online LOMC system is available at https://www.fema.gov/media-library/assets/documents/29954

• Community Acknowledgement Form
• Applicable forms within the MT-2 application
• Hydrologic and hydraulic data and modeling of completed development
• Topographic data
• Work maps
• Annotated FIRM panel(s) and FIS tables and/or profiles showing nature and extent of revised floodplain boundaries, floodway boundaries, and/or BFEs
• Public notice
• Processing fee
• If fill in floodway, “no-rise” analysis or CLOMR

• All fields are not populated; "N/A" wasn't used when appropriate
• Vertical datum not properly identified, or conversion not provided
• Missing Overview and Concurrence Form
• Misunderstanding of fee exemptions
• Individual property owner notifications and public notice
• No annotated FIRM and Flood Insurance Study (FIS) pages
• Inconsistencies between mapping and modeling
• No line delineation and location of the primary frontal dune (for a coastal LOMR)

• Required
  • Community concurrence and adoption
  • Applicable forms within the MT-2 application (including proposed or as-built project plans)
  • Hydrologic and hydraulic data and modeling
  • Topographic data
  • Work maps
  • Annotated FIRM panel(s) and FIS tables and/or profiles showing nature and extent of revised floodplain boundaries, floodway boundaries, and BFEs
  • Public notice
  • Processing fee
  • ESA Compliance
• Submission Methods
  • MT-2

• The MT-2 Form and Instructions are available at https://www.fema.gov/mt-2-application-forms-and-instructions

One of the often noted issues with CLOMR applications are:

• Work begins on the development before the CLOMR is approved

• Required
• Recorded plat map, OR a recorded deed accompanied by tax assessor’s map
• Community Acknowledgement Form
• Processing fee
• Other data may also be required
• Submission Method
• MT-1 Forms and Instructions are available at https://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 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 assumes liability for the development by signing the Community Acknowledgement Form

• Required
  • Recorded plat map, OR a recorded deed accompanied by tax assessor’s map
  • Community Acknowledgement Form
  • Processing fee
  • Endangered Species Act (ESA) compliance
• Submission Method
• MT-1 Forms and Instructions are available at https://www.fema.gov/mt-1-application-forms-instructions

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

• An existing structure has a lowest floor below 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 four types of Letters of Map Revision (LOMRs)
• An overview of the LOMR process
• The LOMR submission methods including paper applications and Online LOMRs
• The MT-1 and MT-2 forms and when to use each

• Describe the roles and responsibilities of the community or tribal floodplain administrator
• Describe the roles and responsibilities of licensed professionals
• Describe the roles and responsibilities of FEMA in the context of LOMRs

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 Amendment (LOMA) process: the community Floodplain Administrator (FPA) role, the licensed professionals' role, and FEMA's role.

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

The tribal or local community FPA's responsibilities include:

• Ensure all permits are obtained
• Review LOMR applications to ensure projects are compliant
• Understand how regulations apply to LOMR proposals
• Explain LOMR procedures and results to property owners and developers
• Assist property owners with the LOMR application, when needed
• Coordinate LOMR proposals with other departments and programs
• Maintain and update flood data and maps to reflect LOMRs
• Maintain LOMR records

Licensed professionals fill an important floodplain management role such as engineers and surveyors. Both assist customers or property owners with filling out forms and completing Elevation Certificates (ECs). However, surveyors collect elevation data and meets and bounds descriptions whereas engineers perform engineering analyses for floodway encroachment as well as develop new flood elevations or flood zone boundaries.

The Licensed Professional's responsibilities include:

• Conduct surveys to collect elevation data and metes and bounds descriptions
• Complete an Elevation Certificate (EC) or the Elevation Form
• Perform engineering analysis for floodway encroachment
• Develop Base Flood Elevations (BFEs) for Approximate A zones
• Perform study revisions, including Conditional Letters of Map Revision (CLOMRs) and Letters of Map Revision (LOMRs)
• Assist customers or property owners with filling out the forms

FEMA establishes the minimum standards for floodplain management for communities participating in the NFIP. Communities have the option to adopt higher standards, which will lead to safer, stronger, and more resilient communities.

FEMA’s Floodplain Management Branch provides tools and resources to help communities navigate NFIP requirements and to implement higher standards of floodplain management.

FEMA’s responsibilities include:

• Review, approve or deny applications, or request additional data to support an application
• Issue determinations and revised maps via LOMRs
• Evaluate community compliance with minimum NFIP standards
• Coordinate with community to resolve violations

• Ensure all permits are obtained
• Review LOMR applications to ensure project is compliant
• Understand how regulations apply to LOMR proposals
• Explain LOMR procedures and results to property owners and developers
• Assist property owners with the LOMR application, when needed
• Coordinate LOMR proposals with other departments and programs
• Maintain and update flood data and maps to reflect LOMRs
• Maintain LOMR records

• Conduct surveys to collect elevation data and metes and bounds descriptions
• Complete an Elevation Certificate (EC) or Elevation Form
• Perform engineering analysis for floodway encroachment
• Develop Base Flood Elevations (BFEs) for Approximate A zones
• Perform study revisions, including Conditional Letters of Map Revision (CLOMRs) and Letters of Map Revision (LOMRs)
• Assist customers or property owners with filling out the forms

• Review, approve or deny applications, or request additional data to support an application
• Issue determinations and revised maps via LOMRs
• Evaluate compliance with minimum NFIP standards
• Coordinate with community to resolve violations

• Describe the process to address potential violations of local floodplain management ordinances
• Identify the purpose and implications of the Community Acknowledgement Form
• Identify the purpose and implications of Conditional LOMRs
• Recognize LOMR recordkeeping best practices

• Serving as the local floodplain management point of contact with other jurisdictions, the state, and the federal government
• 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 LOMRs

• Overseeing the floodplain development permit process
• Initiating and monitoring enforcement action against violators
• Ensuring all permits are obtained
• Reviewing LOMR applications to ensure project is compliant
• Understanding how regulations apply to LOMR proposals

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

• 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

• Placement of fill has created a rise in the BFE
• An increase in paved surfaces has increased flooding significantly
• A bridge or other floodplain encroachment has exacerbated flooding in areas outside of the SFHA
• Changes to bridges, culverts, dams, or stream maintenance have changed the floodway boundaries and/or BFEs
• Flood protection structures have changed the BFE, floodway boundaries and/or flood zone boundaries

• Property owners and residents
• Surveyors
• Developers
• Insurance agents
• Business and civic groups

• Understand the types of LOMRs and provide guidance on how to complete the application
• Explain which type of LOMR is suitable for a specific situation
• Explain situations when a LOMR may not be feasible

• Review forms for accuracy and completeness:
  • Are the current FIRMs being used?
  • Is the community name and number listed correctly?
  • Is the vertical datum specified?
  • Is the lowest adjacent grade (LAG) or lowest floor elevation (LFE) compared to BFE?
  • Are all signatures and seals included?
• Remember to consider public safety and emergency access to the site.

Signed Community Acknowledgement forms are required when a LOMR-F or CLOMR-F application is submitted to revise a community’s FIRM or Flood Insurance Study (FIS).

Actions resulting in LOMRs generally require local floodplain development permits.

A signed Community Acknowledgement Form indicates to FEMA that:

• All necessary permits were obtained
• Applicant is in compliance with local and NFIP regulations
• Fill does not result in a floodway encroachment
• Endangered Species Act compliance (CLOMR-F)
• The community is aware of actions that can potentially impact floodplains
• The LOMR does not undermine the authority of the community
• The development is reasonably safe from flooding

Resource: For more information on the definition of “reasonably safe from flooding,” refer to guidance in Ensuring that Structures Built on Fill In or Near Special Flood Hazard Areas are Reasonably Safe From Flooding, Technical Bulletin 10 available at https://www.fema.gov/media-library/assets/documents/3522.

Diagram of steps for completing the community acknowledgement form. From left to right:

• Letter of Map Revision (LOMR) request submitted to community floodplain administrator's office for review.
• Have (or will) all Federal, state, and local permits been (be) obtain by the requester?
• Has (or will) a floodplain development permit been (be) issued?
• Does the request comply with all of the community floodplain management requirements, including the requirement that no fill be placed in the regulatory floodway, and that all necessary Federal, state, and local permits have been or will be obtained?
• Has it been determined that the land and any existing or proposed structures to be removed from the SFHA are, or will be, reasonably safe from flooding as defined in 44 CFR 65.2(c), and that upon request by the FEMA, all analyses and documentation used to make this determination will be available?
• The community floodplain administrator signs the Community Acknowledgement form and the applicant submits the LOMR request to FEMA.

• Submitted with each request
• Requires signatures of requester and community official
• Community affirms that:
  • Project meets, or will meet, all community floodplain management requirements
  • All necessary permits were obtained
  • Community has reviewed LOMR or CLOMR request
  • Compliance with the Endangered Species Act has been documented
  • Land and any existing or proposed structures to be removed from SFHA are, or will be, reasonably safe from flooding
  • Analysis for reasonably safe from flooding determination is available

• Existing residential structures built in the SFHA have their lowest floor elevated to or above the base flood;
• 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,’ and that they have on file, available upon request by FEMA, all supporting analyses and documentation used to make that determination

1. Ensure all permits have been received
2. A qualified design professional has certified that the land or structures to be removed from SFHA are reasonably safe from flooding
3. Lowest floor is elevated, including basement
4. Grading plans are provided
5. Buffer zones from perimeter of fill pads are created
6. Loss of storage and conveyance of flood waters are considered
7. Fill meets professional standards for consolidation, settlement, and permeability
8. The entire project has been permitted and conditions have been placed on the fill permit to have the lowest floor at or above BFE

• 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 floodplain administrator can also add comments for the record documenting any disagreement
• The floodplain administrator can refuse to sign if the project does not meet requirements, including not obtaining all required permits
• The floodplain administrator may also sign the form, but state that the project is not compliant

• When is a CLOMR required?
  • To comply with 44 CFR 60.3(c)(10) and provide evidence that the cumulative effect of the proposed development will not increase the BFE by more than 1 foot at any point within the community
  • Unless a local law or ordinance requires one, a CLOMR is not required prior to a final LOMR
• Then, why request one?
  • These conditional letters from FEMA inform the builder and others (such as the bank financing the project) that when the project is completed as designed, it will qualify for a LOMR or LOMR-F
  • Communities may require a CLOMR to receive assurance that a project, constructed as designed, will meet all final LOMR requirements
• What are the limitations of CLOMRs?
  • CLOMRs do not change the community’s FIRM
  • CLOMRs do not exempt subsequent developments from permit requirements

• LOMR-Fs change flood hazard information, but do not change the flood map
• LOMRs change the flood map and may require community to formally adopt a new FIRM and/or FIS tables or profiles
• All LOMRs are mailed to the community; communities should maintain a file of LOMRs
• LOMRs are also available using the community search process or at the National Flood Hazard Layer viewer on the FEMA Map Service Center website at https://msc.fema.gov

• Understanding who are the community’s customers and how to help them understand their LOMR options
• Errors or omissions that can delay the processing of a LOMR
• How to handle floodplain management violations revealed during the LOMR application process
• The purpose and considerations of the Community Acknowledgment Form
• The purposes and limitations of Conditional LOMRs
• LOMR recordkeeping best practices

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

• Determine the appropriate data necessary for a LOMR

• Property owners require the services of licensed land surveyors and/or registered professional engineers when compiling the necessary data and documentation to complete LOMR applications. Frequently, licensed professionals provide guidance to property owners on the viability of their request for removal of their property from the SFHA
• A licensed land surveyor or registered professional engineer must certify the accuracy of the elevation information on an Elevation Certificate or LOMR Elevation Form. The land surveyor can also advise a property owner on whether a metes and bounds description or information on the structure’s lowest adjacent grade would best meet their application needs
• Registered professional engineers may be called upon to locate existing BFE data or develop initial BFE data for Approximate A Zone areas or perform hydraulic and hydrologic analyses and other studies to support LOMR 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 plat map
• An annotated copy of the effective FIRM panel, including title block, showing the property location
• Street address
• Legal description of property (lot and block, parcel number, etc.)
• Whether the request is for removal of a structure(s), portion of the land, the entire property, or an area larger than a single property
• Whether the request is for removal of a single structure or multiple structures, or a single lot, multiple lots or an area defined by metes and bounds
• Date of construction of any structure(s) on property

• Elevation datum (National Geodetic Vertical Datum of 1929 or North American Vertical Datum of 1988)
• Lowest lot elevation (LLE) or Lowest adjacent grade (LAG) elevation
• Latitude and longitude of the most upstream end of structure or property and datum used
• Base flood elevation and the source for the BFE data
• Professional certification of data accuracy
• A signed Community Acknowledgement Form
• FEMA’s Elevation Certificate and Instructions are available at https://www.fema.gov/media-library/assets/documents/160.

• Narrative—a written description about the purpose of the request and the scope of the proposed/as-built project and the methodology used to analyze the project effects
• Appropriate Form
  • Riverine Hydrology & Hydraulics (rivers, streams, ponds, or small lakes)
  • Riverine Structures (channelization, bridges/culverts, dams/basins, and/or levees/floodwalls)
  • Coastal Analysis
  • Coastal Structures (levees/dikes, breakwaters, bulkheads, seawalls, and/or revetments located along the coast)
  • Alluvial Fan Flooding
• Hydrologic analysis results (occasionally)
• Hydraulic analysis results
  • Effective Model
  • Duplicate Effective Model
  • Corrective Effective Model
  • Existing Conditions Model
  • Post-Project/Proposed Conditions Model

• Certified topographic work map
• Annotated FIRM
• 44 CFR 65.10 requirements documentation
• Operation and maintenance plan
• Proposed or as-built plans
• Endangered Species Act compliance documents
• 44 CRF 65.12 requirements documentation

• Existing residential structures built in the SFHA have their lowest floor elevated to or above the base flood
• 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," and that they have on file, available upon request by FEMA, all supporting analyses and documentation used to make that determination

• The metes and bounds description 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
• FEMA encourages the submission of metes and bounds descriptions in digital format on CD

• 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
• 44 CFR 65.10 requirements: For berm, levee, or flood wall projects submit:
• Documentation addressing 65.10(b)(1)(ii) if requesting exceptions to the minimum freeboard requirements
• Analysis of potential flooding from interior drainage based on the joint probability of interior and exterior flooding and the capacity for evacuating interior floodwaters
• Operational plan and criteria
• Levee maintenance plan
• 44 CFR 65.12 requirements: If the result of the proposed project would create a BFE increase greater than 0.00 foot as a result of encroachment within a floodway (or an increase of greater than 1.0 foot in either Zone A or Zone AE with no floodway) submit:
• Certification that no structures are affected by the increased BFE
• Documentation of individual legal notice to all affected property owners, explaining the impact of the proposed action on their property
• An evaluation of alternatives that would not result in an increase in BFE

• Is an application for a LOMR-F for removal of an entire lot or for just a structure from the SFHA?
• In most cases, the structure itself is the area of concern and not the lot
• 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 entire lot is at or above the BFE, then using the lowest lot elevation may be easier than the metes and bounds approach
• For a LOMR-F, if there is an existing structure with the lowest floor, including basement, lower than the BFE, then the request will be denied
• If the lowest adjacent natural grade is at or above the BFE, then a LOMA is the better approach
• If the lowest adjacent natural grade is not at or above the BFE and fill is used to raise the ground elevation, then the structure itself must be mitigated so that the lowest floor is at or above the BFE in order to obtain a LOMR-F
• A LOMR 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 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 the information on the certificate represents your best efforts to interpret the data available
• False statements may be punishable by fine or imprisonment under 18 US Code, Section 1001
• Communicate approximate FEMA response time
• LOMR-F—approximately 60 days
• LOMR—approximately 90 days

• 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 at https://hazards.fema.gov/femaportal/onlinelomc/signin
• For LOMR paper applications sent through the mail, automated status information is available at https://www.fema.gov/status-map-change-requests
• From the Online LOMC website:
  • 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

• 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 the FIRM)
    • National Geodetic Vertical Datum of 1929 (NGVD 29)
    • North American Vertical Datum of 1988 (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

• Elevations can be based on existing or proposed conditions
• Proposed conditions may be used for a CLOMR-F or CLOMR
• 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
• Lowest elevation of the lot for requests involving an entire lot (for LOMR-F, the lowest adjacent grade (LAG) to structure)
• BFE and source (FIRM, FIS flood profile, floodway data table, community determined, or other source)
• For requests involving a portion of the property, include the lowest ground elevation within the metes and bounds description

• If the property is located in a Zone A, an area of approximate flooding with no BFEs determined, a BFE will may be determined by the engineer or surveyor
• First, determine if a Federal, state, or local government agency has developed a BFE. Such agencies include the:
• U.S. Army Corps of Engineers
• 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 will estimate a BFE based on available data. Such estimates tend to be very conservative

Detailed methods for developing BFEs include:

• Topography
• Field surveys must reference same datum used to produce 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 http://www.fema.gov/hydraulic-numerical-models-meeting-minimum-requirement-national-flood-insurance-program

Resources:

• 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
• 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

LOMR analysis for stream or floodway encroachments, channelization, or other physical changes:

• Required hydraulic modeling for LOMRs and CLOMRs
• Effective Model
• Duplicate Effective Model
• Corrective Effective Model
• Existing Conditions Model
• Post-Project/Proposed Conditions Model
• Hydrological analysis may also be necessary

Resource: Guidance for Flood Risk Analysis and Mapping, MT-1 Technical Guidance is available at https://www.fema.gov/media-library-data/1484864412580-de4aa11166f23a8f06e6121925a5b543/Floodway_Analysis_and_Mapping_Nov_2016.pdf.

To develop data for riverine analysis:

• Obtain backup flood study data from FEMA. Information on obtaining technical data from FEMA is available at https://www.fema.gov/how-order-technical-administrative-support-data
• Update FEMA data based on the current conditions (pre-new development) using the corrected effective model
• Develop a new floodway and flood elevation model for post-development conditions
• Isolate the change in the base flood elevation by running the model upstream and downstream to the point where conditions match the current study

• FEMA’s National Flood Insurance Program Elevation Certificate and Instructions is available at https://www.fema.gov/media-library/assets/documents/160
• Independent Study Course EC Made Easy: Elevation Certificate Overview is available at https://training.fema.gov/is/courseoverview.aspx?code=IS-1105
• Vertical data fact sheet is available at https://www.fema.gov/media-library-data/20130726-1755-25045-0634/ngvd_navd.pdf
• Elevation Certificate Checklist available at https://crsresources.org/300-3/
• Cooperative Program for Operational Meteorology, Education and Training (COMET) is available at http://www.comet.ucar.edu/

In this lesson we discussed:

• LOMR application data requirements
• Important information to communicate with your customers
• How to find the status of a LOMR application
• How to complete the Elevation Form
• Obtaining BFEs for Approximate A Zones
• Developing BFEs for Approximate A Zones
• Studies to support CLOMR and LOMR applications

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

• Identify the basis for approval or denial of LOMR applications
• Analyze applications to determine special processes for unique situations
• Analyze applications to identify potential violations

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

• LOMR-F and CLOMR-F applications have a 60-day review and determination period
• LOMR and CLOMR applications have a 90-day review and determination period, including the approval of all data submitted

• FEMA reviews and evaluates applications for completeness and accuracy
• There are additional FEMA reviews for CLOMR-Fs, LOMR-Fs, LOMRs, and CLOMRs
• In most cases, fees are required. However projects are exempt from fees if they are based on federal, state or local studies to update an approximate A Zone to a detailed study, map changes based on mapping or study errors, map changes based on the effects of natural changes within the SFHA, changes due to federally sponsored flood control projects where 50 percent or more of the project’s costs are federally funded, and studies based on more detailed flood hazard information
• 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 grants the revision, FEMA sends the letter to the applicant, the local community(ies), and the State NFIP coordinator. The letter is also filed in the Map Service Center
• Letters can be retrieved from the Map Service Center. Changes to flood maps are incorporated into the National Flood Hazard Layer (NFHL).
• Submittal of an application does not guarantee approval

• Is the application complete?
• Is the information submitted accurate?
• Is there a signed Community Acknowledgment Form? (CLOMR-F, LOMR-F, or for a property located within a regulatory floodway) Community officials are urged not to sign the form if they proper permits have not been obtained or if the project cannot be shown to be reasonably safe from flooding. In that case, the LOMR may not be issued
• Is there a signed Overview & Concurrence Form? (LOMR or CLOMR)
• Has Endangered Species Act compliance been documented? (CLOMR, CLOMR-F)
• Do all elevations use the same datum?
• Is the location accurate?
• Does the BFE match the effective BFE in the FIRM or FIS? Preliminary BFE is not allowed to be used for the LOMR
• If there is a BFE match discrepancy, has the applicant developed a corrected effective model prior to the impacts of any man-made changes?

• Are all forms for the specific type of LOMR completed and all required documentation attached?
• Are all fields populated, using N/A when appropriate?
• Has the appropriate fee been submitted?
• Have the applicant and the community signed the Overview and Concurrence form?
• For any changes to hydrologic or hydraulic data, have all computer runs been submitted?
• Do hydrologic and hydraulic analyses use methods acceptable to FEMA?
• Have changes to flood map zone boundaries, flood elevation data, and FIS tables and/or stream profiles been submitted in accordance with FEMA guidelines?
• Has notice been given to all affected property owners, as well as adjacent communities, for any floodway, BFE, or flood zone boundary changes?
• Have all topographic work maps been certified?
• Is an annotated FIRM included?

• For one or more structures, are the lowest adjacent grade of the structure at or above the BFE?
• For one or more lots, is the lowest point on the lot and the lowest floor of any structure on the lot at or above the BFE?
• Has the LOMR-F processing fee been received by FEMA?
• Is there a signed Community Acknowledgement Form that demonstrates that the community has determined that the land and any existing or proposed structures to be removed from the SFHA are “reasonably safe from flooding”?
• Are elevations certified by a licensed land surveyor or registered professional engineer?

• What gets approved?
• The application to remove a property or portion of a parcel or to change BFE or flood zone boundaries gets approved or denied
•  How does an application get approved?
• The MT-1 or MT-2 forms are submitted to FEMA for review. In some cases, FEMA may request more information. Community acknowledgment is required for a LOMR-F or LOMR
• What does approval mean?
• Either the FIRM and/or FIS tables and profiles are physically changed, or a legal letter from FEMA determines that a parcel, or portion thereof, is not within the SFHA

• Lowest grade adjacent (LAG) to a structure is lower than the BFE
• Lowest floor elevation (LFE) of an existing structure is lower than the BFE

• The lot, portion of lot, or structure will remain legally in the SFHA
• No BFEs or floodplain boundaries are changed
• NFIP development and flood insurance requirements remain
• The applicant may submit another application with more accurate data

• Zone V
  • LOMR requests in Zone V require an MT-2 with a revised coastal analysis
• Approximate or Unnumbered Zone A
  • For a LOMR-F or LOMR request, the applicant’s engineer may have to develop a BFE if there is not one on the FIRM or FIS
  • If the LOMR is simply to develop a BFE where there is none, the application is fee exempt
• Zone AO
  • When a property is within a Zone AO, the review of requests is case specific and must consider several characteristics of Zone AO flooding, including the extent of the flooding that would inundate the property, the direction of sheet flow, whether fill will convey AO flow to adjacent properties, and whether there is a defined velocity. It is not sufficient to simply fill the zone and submit for a LOMR-F without additional analysis

• Lowest floor elevation (LFE)
  • A LOMR-F will not be granted if the lowest floor elevation (LFE), including basement, is below the BFE. This would be a violation for a post-FIRM structure that would need to be corrected, but is merely a denial of the application for a pre-FIRM structure
• LOMR without CLOMR
  • Sometimes a LOMR is used to justify a violation after the fact. If the project was not permitted by the local FPA and it includes a floodway encroachment, then it is a violation
• Zone V construction
  • According to 44 CFR 60.3 (6), the placement of structural fill (fill used to support a structure) is prohibited in Zone V
• Floodway violations
• If a LOMR-F application includes property in the floodway, the fill must have been permitted. If the fill was not permitted, then it is a violation
• For LOMR applications, fill in a floodway that causes any measurable increase in the BFE is allowed only if all LOMR requirements have been met, which includes obtaining an approved CLOMR-F prior to applying for a LOMR

• Guidance for Flood Risk Analysis and Mapping, MT-1 Technical Guidance is available at https://www.fema.gov/media-library/assets/documents/34953
• The MT-1 Application Forms and Instructions are available at https://www.fema.gov/mt-1-application-forms-instructions
• The Online LOMC—Help and Instructions is available at https://hazards.fema.gov/onlinelomc/ext/Help/loadInstructions
• NFIP Definitions are available at https://www.fema.gov/national-flood-insurance-program/definitions
• The National Flood Hazard Layer (NFHL) database is available at https://www.fema.gov/national-flood-hazard-layer-nfhl
• FEMA Flood Map Service Center is available at https://msc.fema.gov/portal/home

In this lesson we discussed:

• The general timelines and processes for LOMR applications
• The LOMR application review process
• The community acknowledgment requirement
• Basis for approving a LOMR application
• Why an LOMR application may be denied
• Special processes for unique situations
• Violations to floodplain management regulations that may be discovered during the LOMR application process

• Identify the benefits of maintaining insurance after receiving a LOMR approval
• Recognize the connection between LOMRs and mandatory purchase of flood insurance
• Recognize the different degrees of risk remaining after an LOMR is issued

• LOMRs and LOMR-Fs do not expire, but they can be superseded by a new FIRM

LOMR-Fs

• LOMR-Fs are transferable to future owners
• When FEMA prepares to revise an effective FIRM, all the LOMRs that are affected by the revision are reviewed and incorporated as appropriate
• When preparing a Preliminary Map or revised map panel, FEMA sends a Summary of Map Actions (SOMA) to the community which identifies all the Letters of Map Change (LOMCs), including LOMRs and LOMR-Fs issued for a community, and whether:
• The LOMR will be incorporated into the new FIRM
• The LOMR or LOMR-F is likely to be superseded by new information on the FIRM and will no longer be valid
• The LOMR-F is likely to be revalidated once the new panel is published
• When the effective FIRM is issued, FEMA issues a Revalidation Letter which lists the LOMCs that have been reaffirmed for the new FIRM

• There are actions you can take that can cause a LOMR to become invalid:
• Changing the landscape in a manner that increases flood risk, such as excavating an area that was a path for floodwaters (LOMR-F)
• Removing certified protections from floodwaters (LOMR)
• Expanding a structure to a portion of the parcel not included in a LOMR
• If an updated FIRM panel supersedes a LOMR, the LOMR is invalidated. If a structure is then determined to be in the SFHA, the property owner will be required to purchase flood insurance

The “100-year Flood” is an insurance standard and not a risk standard. The 1-percent annual flood risk actually means that a structure has a 26-percent chance of being flooded over the life of a 30-year mortgage.

Even with a 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. Structures outside high-risk zones may qualify for a more inexpensive Preferred Risk Policy. More information is available on Preferred Risk Policies at https://www.fema.gov/media-library/assets/documents/17576.

Some important points to remember about LOMR-Fs and flood insurance are:

• A lender may require flood insurance even with a LOMR-F
• After receiving a 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
• For LOMR-Fs, the policy may also be converted to a lower-cost Preferred Risk Policy if there has been no more than one claim over any 10-year period

For more information, watch the FEMA Value of Flood Insurance video, available at https://www.fema.gov/media-library/assets/videos/159672.

• Even though a LOMR revises the effective SFHA which affects the mandatory purchase requirement, it is still considered a good mitigation measure to have flood insurance. Where it rains, it can flood
• Preferred Risk Policies (PRP) are available to structures with LOMAs and LOMR-Fs, are located in Zones B, C, X, AR or A99 on the effective date of the policy, and meet certain loss requirements
• Preferred Risk Policies cover building and contents, or contents alone
• Preferred Risk Policies are available to structures with LOMAs and LOMR-Fs which are located in Zones B, C, X, AR, or A99 on the effective date of the policy and meet certain loss requirements.

There are different degrees of risk. Consider risk and the likelihood of an event times the consequence of that event. You can have a high probability/low consequence event, such as a shallow flood that is slightly higher 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, that deep or high-velocity flooding within the SFHA is a high probability/high consequence event.

A LOMR-F may remove a parcel or a structure from the SFHA, meaning that it would not be inundated by the base flood (1-percent annual chance flood). But that does not mean that there is no risk. More than 25 percent of all NFIP claims are from structures outside of the high-risk flood zones.

A LOMR changes the area subject to the base flood, but does not eliminate risk. As such, it should not be used as merely a means to “get out of” paying for flood insurance. FEMA recognizes that by offering low-cost Preferred Risk policies for structures outside of high-risk flood zones. It pays to use this low-cost flood insurance option to protect against the residual risks of flood damages.

• Even after a LOMR is obtained, flood risk remains
• Lower-cost flood insurance is available outside of the high-risk flood zone, as long as claims history conditions are met
• Mitigating structures in flood zones and building new structures to higher standards significantly lowers flood risk and related flood insurance costs

• Information on Preferred Risk Policies is available at https://www.fema.gov/media-library/assets/documents/17576
• Flood Insurance Information is available at https://www.floodsmart.gov/
• FEMA Know Your Risk brochure is available at https://www.fema.gov/media-library/assets/documents/18542
• FEMA RiskMAP information is available at https://www.fema.gov/risk-mapping-assessment-and-planning-risk-map
• FEMA Map Service Center is available at https://msc.fema.gov/portal/home
• NFIP Flood Insurance Advocate is available at https://www.fema.gov/flood-insurance-advocate

• LOMRs and LOMR-Fs do not expire, but they can be superseded by a new FIRM
• LOMR-Fs remain with the property or structure until they superseded by new flood maps or by changes to the property
• LOMR-Fs are transferrable to new owners
• When FEMA updates a FIRM, all the LOMRs that are affected by the revision are reviewed and incorporated as appropriate
• Ways a property owner can invalidate a LOMR
• If an updated FIRM panel supersedes a LOMR, the LOMR is invalidated. If a structure in then determined to be in the SFHA, the property owner will be required to purchase flood insurance
• Different degrees of flood risks remain after a LOMR-F is obtained
• Flood insurance is always advisable and lower rates are available outside of high-risk flood zones

• Explain the basic purpose and procedures of LOMRs
• Describe roles and responsibilities in the LOMR process
• Understand the floodplain management and insurance implications of LOMRs

• The four types of LOMRs and their purposes and limitations:
  • A Letter of Map Revision (LOMR) is an official revision to the Flood Insurance Rate Map (FIRM) that is used to change flood zones, floodplain and floodway delineations, and flood elevations
  • 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 FIRM upon completion of the project
  • A Letter of Map Revision—Based on Fill (LOMR-F) is used to remove a structure or parcel of land from the Special Flood Hazard Area (SFHA) because it has been elevated on fill above the base flood elevation (BFE)
  • 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
• An overview of the LOMR process
  • After reviewing a LOMR-F application, FEMA will either approve or deny the map change, or request additional data to support the application. If the request is approved or denied, FEMA issues a Determination Document
  • After reviewing a LOMR application, FEMA can approve or deny the map change, or request more information.  If the applicant does not provide the requested information, or it the information does not meet with FEMA's satisfaction, FEMA will drop the case and inform the applicant by letter. If the LOMR is approved or denied, FEMA will issue a Determination Document
  • If FEMA grants the revision request, the property owner may no longer be required to pay flood insurance. The property owner may send the Determination Document to his or her lender and request that the federal flood insurance requirement for the structure be removed. Lenders must require flood insurance in an A Zone or V Zone. However, it is the lender’s prerogative to require flood insurance in an X Zone
  • If FEMA denies the request, 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 or clarified data
  • When a FIRM is revised, LOMRs are incorporated into the new effective map and added to the Map Service Center. LOMR-Fs may be included in the updated FIRM panel, reissued 1 day after the updated FIRM is effective, or will no longer be valid because they have been superseded by new information on the FIRM
• The MT-1 and MT-2 forms and when to use each
  • Use the MT-1 when requesting a LOMR-F or CLOMR-F
  • Use the MT-2 when requesting LOMRs and CLOMRs
• The LOMR submission methods including paper applications and Online LOMRs
  • Paper form: Applicants may submit paper applications by mail using the MT-1 or MT-2
  • Online LOMR: An internet-based tool that allows applicants to easily request an amendment or revision to a flood map

In Lesson 2, we discussed the roles and responsibilities of the tribal or local community floodplain administrator, licensed professionals, and FEMA, as related to the LOMR process:

Tribal or Local Community FPA's Role

• Ensure all permits are obtained
• Review LOMR applications to ensure project is compliant
• Understand how regulations apply to LOMR proposals
• Explain LOMR procedures and results to property owners and developers
• Assist property owners with the LOMR application. when needed
• Coordinate LOMR proposals with other departments and programs
• Maintain and update flood data and maps to reflect LOMRs
• Maintain LOMR records

• Conduct surveys to collect elevation data and metes and bounds descriptions
• Complete an Elevation Certificate (EC) or Elevation Form
• Perform engineering analysis for floodway encroachment
• Develop base flood elevations (BFEs) for Approximate Zone A
• Perform study revisions for CLOMR and LOMR requests
• Assist customers or property owners with filling out the forms

• Review, approve or deny applications, or request additional data to support an application
• Issue determinations and revised maps via LOMRs
• Evaluate compliance with minimum NFIP standards
• Coordinate with community to resolve violations

• The process to address potential violations of local floodplain management ordinances:
  1. Investigate the site to determine if there is a violation
  2. Provide notice to property owner of the nature of violation(s)
  3. Provide technical assistance on remediation methods
  4. Issue stop work orders or fines
  5. Rescind certificate of occupancy or certificate of compliance
  6. 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 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
• The purpose and limitations of a CLOMR:
  • A CLOMR is not required prior to a final LOMR, unless the project is going to result in a BFE rise in the floodway
  • The conditional letters from FEMA inform the builder and others (such as the bank financing the project) that when the project is completed, it will qualify for a LOMR or LOMR-F
  • Communities may require a CLOMR to receive assurance that a project, constructed as designed, will be eligible for a final LOMR.
  • CLOMRs do not change the FIRM and do not exempt subsequent developments from permit requirements
• LOMR recordkeeping best practices:
  • LOMR-Fs change flood hazard information, but do not change the flood map
  • LOMRs change the flood map and may require community to formally adopt a new FIRM and/or FIS tables, profiles, or higher floodplain regulations
  • LOMRs are mailed to the community; communities should maintain a file of LOMRs

In Lesson 4, we discussed:

The licensed professional’s role and responsibilities in regard to LOMCs including:

• Information Required for LOMR-F 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 plat map
• An annotated copy of the effective FIRM panel, including title block, showing the property location, street address
• Legal description of property (lot and block, parcel number, etc.)
• Whether the request is for removal of a structure(s), portion of the land, the entire property, or an area larger than a single property
• Whether the request is for removal of a single structure or multiple structures, or a single lot, multiple lots or an area defined by metes and bounds
• Date of construction of any structure(s) on property
• Elevation datum (National Geodetic Vertical Datum of 1929 or North American Vertical Datum of 1988)
• Lowest lot elevation (LLE) or lowest adjacent grade (LAG) elevation
• Latitude and longitude of the most upstream end of structure or property and datum used
• Base Flood Elevation and the source for the BFE data
• Professional certification of data accuracy
• A signed Community Acknowledgement Form
• Information Required for CLOMR and LOMR Applications
• Narrative—a written description about the purpose of the request and the scope of the proposed/as-built project and the methodology used to analyze the project effects
• Appropriate Form
  • Riverine Hydrology & Hydraulics (rivers, streams, ponds, or small lakes)
  • Riverine Structures (channelization, bridges/culverts, dams/basins, and/or levees/floodwalls)
  • Coastal Analysis
  • Coastal Structures (levees/dikes, breakwaters, bulkheads, seawalls, and/or revetments located along the coast)
  • Alluvial Fan Flooding
• Hydrologic analysis results  (occasionally)
• Hydraulic analysis results
• Effective Model
• Duplicate Effective Model
• Corrective Effective Model
• Existing Conditions Model
• Post-Project/Proposed Conditions Model
• Certified topographic work map
• Annotated FIRM
• 44 CFR 65.10 requirements documentation
• Operation and maintenance plan
• Proposed or as-built plans
• Endangered Species Act compliance documents
• 44 CRF 65.12 requirements documentation

• Why a LOMR-F application may be denied
  • If the lowest grade adjacent (LAG) to a structure is lower than the BFE
  • If the lowest floor elevation (LFE) of an existing structure is lower than the BFE
• Special processes for unique situations
  • LOMRs for Zone V require an MT-2 with a revised coastal analysis. This includes the location of the primary frontal dune
  • In areas of shallow/sheet flooding (Zone AO), the elevation of the lowest adjacent grade (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
  • An applicant may wish to be amended into the SFHA for financial reasons; for example, to become eligible for a mitigation grant
• Violations to floodplain management regulations that may be discovered during the LOMR application process
  • A LOMR-F will not be granted if the LFE, including basement, is below the BFE. This would be a violation for a post-FIRM structure that would need to be corrected, but is merely a denial of the application for a pre-FIRM structure
  • Sometimes a LOMR is used to justify a violation after the fact. If the project was not permitted by the local FPA and it includes a floodway encroachment, then it is a violation
  • According to 44 CFR 60.3 (6), the placement of structural fill (fill used to support a structure) is prohibited in Zone V
  • For LOMR applications, fill in a floodway that causes any measurable increase in the BFE is allowed only if all LOMR requirements have been met, which includes obtaining an approved CLOMR-F prior to applying

• Benefits of maintaining insurance after receiving a LOMR approval
  • Even with a LOMR-F, flood risk remains
  • Homeowner’s insurance does not cover damages from floods
  • A lender may require flood insurance even with a LOMR-F
  • After receiving a LOMR-F, the property owner may be able to convert to a lower-cost Preferred Risk policy if there has been no more than one claim over any 10-year period
• Connection between LOMR-Fs and mandatory purchase of flood insurance
  • A lender may require flood insurance even with a LOMR-F
  • After receiving a LOMR-F, the property owner may be able to convert to a lower-cost Preferred Risk policy if there has been no more than one claim over any 10-year period
• Different degrees of risk remaining after an LOMR-F 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 (beaver dam rupture/ice jam release) outside of the Special Flood Hazard Area (SFHA) or due to a flood structure failure (levee or dam). due to food structure
  • High probability and high consequence of flash flooding deep or high velocity flooding within the SFHA