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