National Flood Insurance Program Revisions and Amendments to NFIP Maps

1. National Flood Insurance ProgramRevisions and Amendments to NFIP Maps Bill Massey and Sam Crampton Dewberry South Florida Water Management District Floodplain Management Training May 2005

2. Objectives • Understand difference between Map Amendments and Map Revisions • Provide overview of letter actions - including LOMAs, LOMR-Fs, LOMRs and Conditional LOMCs • Present information on data requirements, applicable NFIP regulations, and fees

3. Map Amendments vs. Map Revisions • Amendments: • Involve Structures or Legally Defined Parcels • Typically Do Not Involve H&H Analyses • Require Submittal of MT-1 Forms • Revisions: • Involve More Complex Map Changes • Not Usually Lot or Structure Specific • Typically Involve H&H Analyses • Require Submittal of MT-2 Forms

4. Letter of Map Change (LOMC) • A LOMC is a document issued by FEMA that officially amends or revises the Flood Insurance Rate Map (FIRM) • Types: • Letter of Map Amendment (LOMA) • Letter of Map Revision-based on Fill (LOMR-F) • Letter of Map Revision (LOMR)

5. Natural Ground LOMA A LOMA is a letter from FEMA stating that an existing structure or parcel of land that has not been elevated by fill (natural grade) would not be inundated by the base flood.

6. Natural Ground LOMA The lowest adjacent grade of the structure must be at or above the 1% annual chance flood elevation to remove the structure from the SFHA.

7. LOMA • LOMAs remove the Federal mandatory flood insurance purchase requirement • LOMAs do NOT change Base Flood Elevations (BFEs) • LOMAs are processed under Part 70 of the NFIP regulations

8. LOMA Determination Document

9. LOMR-F A LOMR-F is a letter from FEMA stating that an existing structure or parcel of land that has been elevated by fill would not be inundated by the base flood.

10. LOMR-F • The lowest adjacent grade and lowest floor of the structure must be at or above the BFE • The community must certify the structure to be reasonably safe from flooding • Fill must be engineered

11. LOMR-F • LOMR-Fs remove the Federal mandatory flood insurance purchase requirement • LOMR-Fs do NOT change BFEs • LOMR-Fs are processed under Section 65.5 of the NFIP regulations

12. Right to Submit Technical Information • Any owner or lessee of property who believes his property has been inadvertently included in a designated SFHA may submit scientific or technical information to FEMA for review.

13. Data Requirements for LOMAs and LOMR-Fs • Completed MT-1 Form 1 (or MT-EZ Form) • Copy of the NFIP Map indicating the subject property location • Property description documentation (Copy of the recorded deed or plat map) • Tax map or other suitable map (certified site survey) that shows the location of the property and at least one road intersection shown on the FIRM • Completed MT-1 Form 2 (or Elevation Certificate to remove a structure)

14. Data Requirements for LOMAs and LOMR-Fs • Metes & bounds description/map, if request is to remove a portion of property • BFE data, if approximate Zone A floodplain • A complete Community Acknowledgment Form (MT-1 Form 3) for all LOMR-Fs, and any LOMA request within the regulatory floodway • Other applicable MT-1 Forms and review fee

15. State and Local Considerations • LOMAs and LOMR-Fs only remove the Federal requirement for flood insurance. • State and/or local floodplain management requirements may still apply. • Lending institutions may exercise their right to require flood insurance even after a LOMA or LOMR-F is issued to protect their interest on the loan.

16. LOMR A LOMR is a letter from FEMA officially revising the current NFIP map to show the changes to floodplains, regulatory floodway, or flood elevations. • Basis for Revisions: • More Detailed Analyses • Projects • Natural Changes • Error Corrections

17. LOMR • A LOMR is not confined to specific properties or structures • A LOMR is usually more extensive than LOMAs or LOMR-Fs • LOMRs typically require new engineering analyses • LOMRs are processed under Part 65 of the NFIP regulations

18. LOMR Determination Document Summary Information

19. LOMR Determination Document News Release Info (for BFE changes)

20. LOMR Determination Document (Annotated FDT)

21. LOMR Determination Document (Annotated Profile)

22. LOMR Determination Document (Annotated FIRM)

23. Requirement to Submit New Technical Data • When a community’s BFEs increase or decrease as a result of physical changes affecting the floodplain, the community must notify FEMA by submitting technical or scientific data as soon as practicable, but no later than 6 months after such data become available.

24. Data Requirements for Map Revisions • 65.6(b) Correcting Map Errors (1) Data identifying mathematical errors (2) Data identifying measurement errors and providing correct measurements

25. Data Requirements for Map Revisions • 65.6(c) Changed Physical Conditions (1) Changes affecting hydrologic conditions (i) Description of the changes (ii) Construction plans for as-built conditions (iii) New hydrologic analysis accounting for effectsof changes (with appropriate back-up data) (iv) New hydraulic analysis and profiles using the new discharges (with appropriate review files, i.e. CHECK-RAS or CHECK-2) (v) Revised delineation of floodplain and floodway on certified topographic map & annotated FIRM

26. Data Requirements for Map Revisions • 65.6(c) Changed Physical Conditions (2) Changes affecting hydraulic conditions (i) Description of the changes (ii) Construction plans for as-built conditions (iii) New hydraulic analysis and flood elevation profiles, using FIS published discharges (with appropriate review files, i.e. CHECK-RAS or CHECK-2) (iv) Revised delineation of floodplain and floodway on certified topographic map & annotated FIRM

27. Data Requirements for Map Revisions • 65.6(c) Changed Physical Conditions (3) Changes involving topographic conditions (i) Description of the changes (ii) New, certified topographic information (iii) Revised delineation of floodplain and floodway on topographic map and annotated FIRM

28. Data Requirements for Map Revisions • 65.6(d) Incorporating Improved Data (1) Data believed to be better than those used in original analysis (2) Documentation of the source of the data (3) Why the new data will improve the results of the original analysis (4) Revised hydrologic analysis (with appropriate back-up data) (5) Revised hydraulic analysis (with appropriate review files, i.e. CHECK-RAS or CHECK-2) (6) Revised delineation of the floodplain and floodway on certified topographic map & annotated FIRM

29. Data Requirements for Map Revisions • 65.6(e) Incorporating Improved Methods (1) New hydrologic analysis when an alternative method is being proposed (with appropriate back-up data) (2) New hydraulic analysis when an alternative method is being proposed (3) Why the alternative methodologies are superior to original methodologies (4) Revised delineation of the floodplain and floodway on certified topographic map & annotated FIRM

30. Additional LOMR Requirements • Revised and unrevised BFEs must match within ½ foot at transitions • All models used to perform H&H analyses must be accepted by FEMA for NFIP usage: http://www.fema.gov/fhm/en_modl.shtm • All analyses must reference the same vertical datum as the effective study • If increase in SFHA and/or BFEs: • Property Owner Notification and/or acceptance • If revision to floodway: • Copy of public notice stating intent to revise floodway • Applicable MT-2 Forms and fees

31. Review of Proposed Projects • A community, or individual through community, may request FEMA’s comments on whether a proposed project will justify map amendment or revision, if built as proposed.

32. Conditional LOMCs • Issued for proposed projects • Do not amend or revise the FIRM • Offer FEMA’s formal comment on: • Eventual revision to FIRM • Compliance with regulatory requirements • Types: • Conditional LOMA (proposed structure on natural grade) • Conditional LOMR-F (parcel of land or proposed structure to be elevated by fill) • Conditional LOMR (comment on whether a proposed project would justify a map revision)

33. Conditional LOMR • Required if a community proposes to permit encroachments which will cause BFE increases in excess of those permitted under Subparagraphs 60.3(d)(3) or 60.3(c)(10) • Increase = (Post-project WSEL) - (Pre-project WSEL) Allowable Increase: a. without Floodway = 1.0’ [60.3(c)(10)] b. with Floodway = 0.0’ [60.3(d)(3)] • If project results in an increase, then as per Section 65.12, the CLOMR request should include: • An evaluation of alternatives • Certification that no structures are impacted by increased BFEs • Individual legal notice to all impacted property owners

34. What Forms Are Required for Processing a LOMC?

35. Fees for Processing Map Changes • To provide administrative andcost-recovery procedures for engineering review and administrative processing associated with FEMA’s response to requests for CLOMAs, CLOMRs, CLOMR-Fs, LOMR-Fs, and LOMRs. • http://www.fema.gov/fhm/frm_fees.shtm

36. Fee Exemptions The following requests are fee exempt: • LOMAs • Map changes based on mapping or study analysis errors • Map changes based on the effects of natural changes within SFHAs • Map changes based on federally sponsored flood-control projects • Map changes based on detailed H&H analyses meant to replace approximate studies • Map changes based on flood hazard information meant to improve upon that shown on the current map (not including man-made modifications)

37. How Are LOMCs Distributed? • Community’s Chief ExecutiveOfficer (CEO) and Floodplain Administrator • Requestor and/or property owner • Community Map Repository • LOMC Subscription Service • LOMC Compendium (http://www.fema.gov/fhm/dl_comp.shtm)

38. How Do I Get More Information?

39. National Flood Insurance ProgramRevisions and Amendments to NFIP Maps QUESTIONS ? ? ? ? ? ? ?