Federal Emergency Management Agency (FEMA) Process Administration & Letters of Map Change

To determine a more equitable LOMR fee, the present flat rate needs to be adjusted to account for a LOMR’s complexity. The LOMR fee should be set based on: new hydrology, hydraulics and LOMR complexity. There should be a required 30-60 minute telephone/webinar, time for the applicant to explain their submittal. As a State LOMR reviewer I valued these meetings as a key to giving the applicant valuable initial permitting ...more »

Letters of Map Revision based on Fill (LOMR-F) should be eliminated because they promote the loss of floodplain functions and development of the floodplain fringe. Fill in the fringe impacts adjacent floodplain areas and structures built on that fill still have flood risks and erosion risks. Elimination of the LOMR-F provision would ensure that basements are prohibited in filled areas and that property owners are subject ...more »

We have nothing but problems getting surveyors to fill out elevation certificates correctly. Surveyors can be good for doing surveys, but they aren’t very good filling out paperwork. And they really don’t understand flood insurance and floodplain management issues. Consider developing a form that just has the building information, and later it can be matched up with the flood insurance information.

To get a LOMA or LOMR-F the lowest adjacent grade should be at least one foot above the Base Flood Elevation. If the lowest adjacent grade is at least 6 inches above the lowest adjacent grade (but less than 12 inches) you still have to have flood insurance, but you can pay at a lower rate. Maybe you get a 30% discount to reflect your lower risk.

The current LOMC process is inefficient, full of cost redundancy, creates operational inconsistencies and is not cost effective for the program. LOMC processing is more fundamentally aligned with proven commercial practices in GIS technology, flood zone determination and application batch processing than A&E centric DFIRM production. The majority of LOMC cases require an out of the box analysis that needs no advanced ...more »

Incorporate LOMR mapping into NFHL as part of LOMR approval process. Regularly update NFHL. Provide current model to LOMR preparers and have them incorporate changes to the model to keep the model up to date. Making requests to find available models from the FEMA map library is tedious. A searchable digital archive of hydrologic and hydraulic models (WFS, REST end point, XML, etc…) is needed. Utilize the models ...more »

Provide training for LOMC reviewers in order to increase the consistency among reviews. Encourage LOMC reviewers to communicate directly with LOMC submitter to discuss modeling issues and concerns. Require FEMA reviewers to provide comments based on published Guidelines and Specifications only. Do not enforce comments based on “that’s the way we’ve always done it”. Add a section to the FEMA forms to discuss ...more »

The current LOMC process is too slow and reinvented every time FEMA contractors change. Encourage CTP's to take over LOMC processing. Showcase Harris County Flood Control District, San Antonio River Authority, Denver Flood Control District, Maracopa County and other CTP's that have assumed the role as LOMC processors. Encourage State Water Resource agencies to become LOMC processors even if Federal funding is needed to ...more »

There are many (perhaps most) LOMCs that have no bearing on the maps and are simply used for property owners to waive mandatory purchase of flood insurance. Eliminate the LOMC process for these and rely exclusively on a LODR type action - basically put it in the hands of the insurance side of the house. Flood maps and flood risk change - the focus should be on whether these single parcel determinations are susceptible ...more »

There have been a few pilot projects to issue mass LOMA or mass revalidations at a countywide scale by applying LIDAR data instead of the traditional MT-1 process . As LIDAR data becomes more accessible, implementing a standard process in which allows determinations on a defined area (e.g. 5 acres/50 lots) will save time and money for FEMAs LOMC program. By allowing a smaller area to be removed by this process, outreach ...more »

LOMR applicants should be required to provide all engineering backup data that would be necessary for the PTS contractors to update the new 2012 FIRM Database and new format FIS. Having an NFHL that shows an incorporated LOMR SFHA but leaves major components of the FIRM database and FIS report with obsolete data from previous underlying models in unacceptable. The new FIRM database template stores the engineering data ...more »

FEMA may wish to consider expanding eLOMA to include more case types (i.e. LOMR-Fs, CLOMA’s, Zone A’s, etc.). This would reduce cost to FEMA by allowing licensed and certified professionals to submit MT-1 application requests online independently for a wider variety of cases. This would create a “fast track” option for applicants looking to receive a speedy determination. This option takes some of the burden off of FEMA ...more »

When new studies are in progress FEMA should utilize the topographic data to make definitive determinations on properties en masse in advance of the map effective date. This will decrease the number of potential LOMA applications received in response to the new FIRMs, reducing the cost of LOMC processing. This is beneficial for the public because they will have a property specific determination (regardless of scale ...more »

FEMA should consider using a non-AE contractor for regulatory and other process administration tasks to gain efficiencies and decrease costs, as these tasks don't require engineering credentials or expertise to complete (such as product distribution, meetings prep and execution, correspondence, tracking, coordination, etc).

FEMA should consider a single contractor to complete all regulatory adminstration tasks in the post-preliminary process to gain efficiencies, ensure national consistency and reduce expenses.

Inclusion of a map in MT-1 determinations would be very useful. Such a map could show the exact location of structure(s)/property (ies) that are the subject of determinations. It could also include a list of BFEs and LAGs for structure(s)/property (ies). Of course, it could add to the cost of LOMC processing and may not be feasible under the current funding guidelines.

LOMC forms should be simplified. The current forms are difficult to read and have many pages of instructions resulting in confusion on the part of requesters and subsequent need for more data. The addition of a simple checklist of required items for different types of requests could potentially help the requesters. Many homeowners continue to use full elevation certificates for LOMAs (which require a surveyor and ...more »

FEMA should allow electronic submittal of additional data for LOMRs (MT-2s) directly to a concerned MT-2 reviewer regardless of whether the original MT-2 request was electronic or manual. Unless a MT-2 reviewer requests additional data as hardcopy, an electronic submittal should be considered an adequate response. Eliminating a hard copy submittal to LOMC Clearinghouse would expedite the review process by eliminating ...more »

Basic LOMC training should be made mandatory for Professional Engineers/Land Surveyors wishing to submit online MT-2 requests. Online submittal should require completion of inventory checklists as a part of online LOMR (MT-2) request submittal; training should cover each item of such an inventory checklist, e.g., all the required elements of a certified topographic work map. FEMA could team up with communities and/or ...more »

Flood Studies that involve base map changes should include a budget item for detailed review of map panels, especially for populated areas. A detailed review is needed so that any perceived shifting of the properties can be identified and large scale LOMA determinations can be made (contingent upon availability of appropriate LiDAR data) at the time of revalidation of LOMCs. This will reduce the number of LOMCs that FEMA ...more »

LOMCs should not be considered as a solution for addressing all inaccuracies in FIRMs. FEMA should explore the possibility of issuing a simple document to address errors such as incorrect stream names, incorrect map panel or suffix number, and so on. LOMCs should be used only for revisions based on engineering data/analysis.

Offer a certification for Online LOMC submittals to allow submitters to demonstrate competency. Certified requesters should have accounts to make a submission and advance the case through a shorter turnaround process. For this privilege, an annual membership fee may be considered.

Develop and distribute guidance allowing large scale LOMR-Fs to be processed as LOMRs, that is, physically revise the map rather than amend by letter. A minimum area would have to be established (e.g., 5 lots/50 acres as defined in 44 CFR Part 60.3) as well as an appropriate fee. While the minimum area could be considered arbitrary by some, this change would significantly offset the cost FEMA incurs in processing large ...more »

The Letter of Map Revision (LOMR) process could be streamlined and accelerated if LOMR requesters (community officials or private parties) had the option of asking FEMA to perform the Hydrology and Hydraulics (H&H) modeling required to support their submittal and also prepare the resulting mapping. Requestors would supply supporting topography or survey data, certified “as built” plans, etc., and would pay a higher review ...more »

FEMA has always based the LOMA unit cost on a per case rate. Maybe FEMA should look at the cost on a per structure or property basis. A case may have one structure/property or may have hundreds of structures/properties. In addition, FEMA has historically procured LOMA processing under a cost reimbursable contract vehicle. FEMA may get a lower cost for LOMAs by procuring LOMA processing under fixed price contract vehicle. ...more »