• 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