1. Managing Zone A Floodplains
FEMA Region III National Flood Insurance Program Essentials and Best Practices
Jana Green, CFM
Kim Dunn, P.E., CFM
RAMPP

2. Topics of Discussion Overview of Zone A Floodplains
Permitting Development in Zone A Floodplains
Estimating Flood Elevations in Zone A
Flood Insurance Implications
Letters of Map Change – Zone A Floodplains
Resources for more information

3. What is a Zone A Floodplain?
Area of the 1% annual-chance floodplain
Boundaries have been determined using approximate methodologies
No published Base Flood Elevations (BFEs) on Flood Insurance Rate Map (FIRM) or in the Flood Insurance Study (FIS) report
Zone As are high risk areas shown on the FIRM that are subject to inundation by the 1% annual chance flood. The boundary of the Special Flood Hazard Area has been delineated on the FIRM; however, base flood elevations have not been determined, nor are floodways shown.
Zone A floodplains are often called “approximate” zones. Some are more approximate than others – we will discuss technological advances in the delineation of Zone A floodplains in recent years, making them much less approximate.
Mandatory flood insurance purchase requirements and floodplain management standards (local ordinance requirements) apply in Zone A floodplains.

4. Zone A Challenges Without defined Base Flood Elevations:
Lowest floor elevations must be determined for permitting
Flood insurance rates may be higher based on unknown risk
Benefit-cost ratios for mitigation projects may be more difficult to calculate
Water surface elevation needs to be estimated
These challenges can make it hard for you as a FPA to be able to identify and manage risk within your community. Zone A floodplains allow for a community to be aware of existing flood hazards without the associated costs of a detailed study. Historically the expense of full detailed studies was reserved for more densely populated areas, but due to development and urban sprawl, many formerly undeveloped Zone A areas now impact many insurable structures.
Although there is no BFE published, an elevation is still needed to permit development and promote flood awareness. We will discuss some of the ways this can be accomplished.
Not having a BFE available can result in increased flood insurance rates due to unknown risk. We will discuss how estimating a BFE can reduce flood insurance rates.

5. Delineating A Zones The paper FIRMs used: topographic maps
soils analysis and mapping
historical information and high water marks
studies not completed by FEMA
More recently, Zone As are supported by automated hydrologic and hydraulic analyses
Not a detailed hydrologic and hydraulic study
In the images, you can see some of the differences between how older maps will depict Zone As compared to how they look on newer maps. Older FIRMs show floodplains that have less defined boundaries than newer Zone A floodplains backed by an automated model.
In addition to topographic and soils data and historic information, there may have been studies completed to analyze flood risk that may not meet the specific criteria to have BFEs published on a FIRM; these can be mapped as Zone A areas or can provide information to evaluate when mapping Zone A areas.
For the past ten years, Zone As are backed by automated engineering models.
Ground surveys and detailed hydraulic analyses have not been completed in Zone A floodplains.

6. Zone A Regulatory Requirements
Reasonably obtain and utilize any flood elevation data when reviewing and issuing permits
If the automated hydrologic and hydraulic analysis (model- backed Zone As) are available, use that as best available data
Use studies conducted by other federal or state agencies
Check to see if elevations have been determined for nearby development
Subdivision requirements:
Base Flood Elevations must be determined through a detailed study for proposed development larger than 5 acres or 50 lots, whichever is lesser
Again, just because a BFE has not been established by FEMA on a FIRM or in a FIS, it doesn’t mean that one doesn’t exist. There are various places you can go to look for elevation information. Remember, as a Floodplain Administrator you reserve the right to require flood elevation information prior to issuing a permit and you MUST require elevation information for subdivisions of 5 acres or 50 lots, whichever is lesser.
Permits are required for all development

7. Obtaining Estimated Elevations
Automated hydrologic and hydraulic (H&H) analyses
Other sources of data
Simplified methodologies
Contour interpolation (point-on-boundary)
Data extrapolation
Remember, the floodplain administrator can always require a detailed study to establish a true Base Flood Elevation
This is the order of preference for obtaining estimated water surface elevations.
Automated H&H – sometimes referred to as “model-backed Zone As.”
You can require detailed study - something to consider if the proposed structure is high value or subject to particular vulnerability (eg. you know it will be senior living and residents may have extra needs during an emergency.)

8. Automated H&H Data Automated H&H analyses were run for Zone As
Elevation information exists in the model
Not detailed enough to be included on the FIRM
Can be used to estimate a 1% chance flood elevation
Floodplain Administrators can use this as best available data for permitting in Zone A
Existing flood elevation data for Zone As is already available in many locations. So before you attempt to develop an elevation, first – check to see if it has already been developed for you! There are a variety of sources available to obtain existing data, including data available through FEMA’s Engineering Library which will soon be available through FEMA’s GeoPlatform website.
Caveats:
Not available in all areas – Riskmap3.com will have data as it becomes available.
Models do not typically reflect bridges, culverts, or dams
May underestimate water surface elevation and floodplain extent upstream of such structures
Cross sections derived from topography (LiDAR), not field surveyed cross sections
General assumptions made of land use and roughness coefficients
A qualified engineer may use the Zone A model as the starting point for a more detailed analysis.
Zone A cross sections will soon be available online!

9. Availability of Automated H&H
or FEMA Engineering Library
Floodplain Administrators can most easily access and use this information for permitting at the RiskMap3 site ( The full model, if needed, can be obtained via the FEMA Engineering library:
Many Zone A streams in Region III have had engineering hydrologic and hydraulic models developed over the last 10 years. Your first option should be to obtain the flood elevations computed in those models. In most places where good quality digital topography is available, these models have been generated. Many of these are available online and most of the rest will be online soon.

10. State Sources for Automated H&H
Currently Region III hosts the data at
Data will be transitioned to State websites:
Maryland website:
West Virginia website:
Pennsylvania:
Elevation data is also available from a variety of state sources online, including these sources listed.

11. Other Sources of Data
When automated H&H unavailable, check for other sources of elevation data:
Community Records
Development plans
Letters of Map Amendment (LOMA) for neighboring property
State or County agencies
Departments of Transportation (plans for nearby bridges)
Departments of the Environment (Stream restoration / erosion control projects)
Federal Agencies
Unpublished USACE, NRCS, or USGS studies
Preliminary FIRM data from FEMA
If applying for LOMC, the reviewer will check for adjacent LOMAs.
If a preliminary FIRM is available, this information can be used with caution: preliminary data is subject to change due to appeals until the Letter of Final Determination is issued. Therefore it is recommended that the more restrictive (i.e. safer) version of the FIRM be used but cannot be less than the effective. See FEMA Publication 1-98 for more details.
Excerpt from FEMA 1-98 regarding Zone As and the use of preliminary FIRM data:
For Zone A areas designated on the community's effective FHBM or FIRM, the BFE and floodway data from a draft or preliminary FIS constitute available data under Subparagraph 60.3(b)(4). The requirement at Subparagraph 60.3(b)(4) is an important floodplain management tool for reducing flood damages in areas where a detailed engineering study to develop BFEs and designate floodways on streams has not been conducted. Communities are required to reasonably utilize the data from a draft or preliminary FIS under the section of their ordinance that applies to this paragraph. A community is allowed discretion in using this data only to the extent that the technical or scientific validity of the data in the draft or preliminary FIS is questioned.
When all appeals have been resolved and a notice of final flood elevation determination has been provided in a LFD, communities are required to use the BFE and floodway data for regulating floodplain development in accordance with 44 CFR 60.3(b)(4) since the data represents the best data available. This includes meeting the standards at 44 CFR 60.3(c), and (d) which includes the requirement that new construction, substantial improvements, and other development have their lowest floor elevated to or above the BFE (non-residential structures can also be floodproofed to or above the BFE). Communities must regulate floodplain development using the data in the FIS under 60.3(b)(4) until such time as the community has adopted the revised FIRM and FIS.

12. Simplified Methodologies
Contour Interpolation Method
Based on an overlay of FIRM on topographic map
Estimate water surface elevation at the intersection of the contour
Confirm accuracy is acceptable
Overlay FIRM on topographic data (make sure scale and projection match!)
Confirm that the floodplain boundary generally conforms with contour lines AND the difference between the flood elevation on the left and right overbank are with ½ contour interval.
Add ½ contour interval to account for inaccuracy of technique.
It is better to survey in the field the location of the boundary and the elevation of the structure. If going to this expense, might as well survey cross section.
Simplified methods can provide a good estimation of flood elevations, but it needs to be kept in mind that these are approximate methods. For this reason they can not be used for Elevation Certificates.
Because it is approximate, freeboard is recommended
It is important to use common sense and ensure that the result is reasonable – not just what a property owner might want to see.
Simplified methods might be used as part of a tiered approach: eg. Do this first to see if a planned project is even feasible, then use a more detailed analysis for pre-construction design.

13. Simplified Methodologies
Data Extrapolation Method
Extend water surface profile at the same slope
Transfer that elevation to the map view
Relevant within 500 feet of detailed study
No hydraulic structures (e.g. bridges, culverts) between end of detailed study and site
If the subject location is only a short distance upstream of the end of a detailed study, you might be able to extrapolate the profile for a water surface elevation if:
No structures (bridge or culverts) in between.
No confluences in between.
The general conditions of the stream are fairly consistent.
Use common sense!
This is taught in more detail in FEMA Course LP73.

14. Using Elevation Data
Once the BFE is established, development is required to comply with Section 60.3(c) of the NFIP regulations.
Residential: elevate lowest floor to the BFE
Non-residential: elevate or dry floodproof to BFE
Manufactured homes: elevate and anchor to BFE
Enclosures below BFE, must have adequate flood openings and be used only for parking, access, or storage.
Openings
Elevation of utilities and mechanicals
Lowest Floor above BFE
Yardley Borough, Bucks County, PA (from PEMA)
Once the BFE is established, development is required to comply with Section 60.3(c) of the NFIP regulations.
Residential: elevating the lowest floor of residential structures to or above the BFE.
Non-residential: elevate or dry floodproof commercial structures
Manufactured homes: anchor and elevate manufactured home so that the lowest floor is at or above the BFE.
If there are enclosures below the BFE, they must have adequate flood openings and be used only for parking, access, or storage.

15. Flood Insurance Implications
Mandatory flood insurance purchase requirements:
applies for all structures in or touching the floodplain that carry a federally-backed mortgage

16. Elevation Certificate
An Elevation Certificate is an administrative tool to provide elevation information necessary to:
record building elevations
demonstrate compliance with the NFIP
support a Letter of Map Change (LOMC)
determine proper flood insurance premiums
The point of this slide is to introduce the main uses of the Elevation Certificate. It may be used as an extremely useful administrative tool to document compliance with NFIP regulations and to support LOMC requests, but for this presentation, we will focus on its use when rating a flood insurance policy.
To learn more about Elevation Certificates, you can access the Reviewing and Interpreting Elevation Certificates recorded webinar available through

17. Elevation Certificate – Section E
Property owners can provide measurements that insurance agents can use to rate a flood insurance policy in Zone A
These measurements are not informative of risk or water surface elevations – should not be used for permitting purposes
Section E can be found on the second page of the Elevation Certificate.
Usually, a surveyor or engineer completing an Elevation Certificate will need to tie into a local benchmark to provide building measurements that are absolute and referenced to a vertical datum.
Section E can be completed by the property owner, who is required to find the highest and lowest points where the outside of the building touches the ground, and then measure the distance between those points and the building’s floor elevations.
Property owners will need also to fill out Sections A, B, and F; you as the floodplain administrator may be asked for guidance with the map panel information and with understanding the various building diagrams.

18. Post-FIRM Zone A Rating
No Base Flood Elevation Provided
Post-FIRM rating considers the elevations of the structure to determine rates
Top of Bottom Floor - Highest Adjacent Grade = Elevation Difference
For rating purposes, the more information the better. Having an EC filled out with the following information is better than not providing anything: Top of Bottom Floor, Highest Adjacent Grade, Lowest Adjacent Grade.
Additionally, providing an estimated BFE is better than no estimated BFE.
Borough of Olyphant, PA - Post-FIRM structure (FEMA Region III)

19. Post-FIRM Zone A Rating
Base Flood Elevation Information Available
If a Base Flood Elevation is available from another source, Lowest Floor Elevation – Flood Elevation = Elevation Difference
Lowest Floor elevation is not an entry on the Elevation Certificate
It is determined by an insurance agent using information provided on the Elevation Certificate
The lowest floor for insurance rating purposes may or may not be the top of bottom floor, depending on certain criteria.
The lowest floor is something that a qualified insurance agent will determine because many considerations go into where exactly this elevation is. It isn’t simply just the floor that has carpet, or the floor where the bedrooms are located.
Determining a base flood elevation or requiring one for new construction can have positive implications on insurance and eases the burden on the FPA.

20. Letters of Map Change in a Zone A
If flood elevation data is provided, FEMA will verify its reasonableness
If elevation data cannot be provided, FEMA will compute a flood elevation
This elevation determination may not be included on the determination letter
For Zone A areas, a flood elevation must be determined to compare against the property information for a property-specific LOMC determination. Sources include:
Local communities and counties
Local and State natural resource and environmental protection or conservation agencies
U.S. Army Corps of Engineers or State transportation departments
Local engineers
Preliminary FIRM and FIS data

21. Reviewing Zone A LOMCs
If more detailed data is needed, the applicant may be asked to provide data such as:
Culvert/bridge dimensions
One or two cross sections
If supporting data is provided and is reasonable, it is incorporated into the hydrologic and hydraulic evaluation
If additional data is not provided, the determination may be based on more conservative methodology
If a community submits a 1% annual chance flood elevation, it will be reviewed to make sure it has been calculated reasonably. If determined to be reasonable, future submissions will not need to reviewed. Community-determined 1% annual chance flood elevations should be submitted on community
letterhead; initial submissions should include relevant data and calculations for review.

22. Providing Cross Sections
For one lot, one cross section is usually sufficient
For a large lot or multiple lots, a cross section should be surveyed at each end of the parcel
Perpendicular to flow path
If property is upstream of a bridge, at least 2 cross sections are required
Should capture changes in channel characteristics: slope, roughness, etc.
Should reference vertical datum
For a large lot or multiple lots, at a minimum a cross section should be surveyed at each end of the parcel - more if distance is greater than 500’ or water surface difference is more than 1.0’ between cross sections.
If in doubt of requirements for a specific site, contact FMIX and speak with the case analyst for clarification prior to paying for survey.
Make sure the surveyed section goes through the house or proposed house location.
A qualified engineer will be familiar with the appropriate methods and software to compute a WSEL:
StreamStats hydrology:
HEC-RAS - available directly from the US Army Corps of Engineers Hydrologic Engineering Center at:
Or Normal Depth - Quick-2 Program ; Quick-2: only applicable in areas not affected by downstream obstructions or flow changes

23. Zone A LOMA
Page 1
Page 2
Every LOMC completed in Zone A will include this paragraph to explain the additional considerations that apply to Zone A.

24. LOMC Determination Documents
Considerations When Elevations are Displayed
The flood elevation used to complete a LOMC determination may or may not be displayed on the final letter.
Flood elevations are shown for:
Conditional Letters of Map Change
Non-removal determinations
Flood elevations are not shown for:
Removal determinations
Out As Shown determinations
The flood elevation is shown on conditional determinations because it is needed to ensure the development will be compliant.
It is shown on non-removals to provide the detail about the flood risk since it remains in the SFHA.
It should be stressed that the point of a LOMC is not to “get a BFE from FEMA.” The point of a LOMC is to determine whether a property or structure is located within the Special Flood Hazard Area.

25. Zone A Permitting – Example One
A resident enters the permitting office with the intention to build a house on a riverfront plot of land. The land is natural grade, and gently slopes down a hill from the main road to the stream channel. The stream has a history of flooding and its floodplain is mapped as Zone A.
Suggestions
Recommend moving building site outside of the mapped Zone A floodplain
If possible, establish a flood elevation
Automated H&H if available, other sources of data, simplified methodologies, detailed study
Document how reasonably safe from flooding was established
Use high water elevations, add freeboard, use flood resistant materials, etc.
When you do not have a BFE, you use what you have. It is usually better to make a more conservative decision than a less conservative decision when it comes to protecting against realized flooding risks. If possible, however, it is always best to determine the flood elevation.

26. Zone A Permitting – Example Two
You are permitting development for a 60 lot subdivision.
15 of the lots are located in a Zone A floodplain.
As you are aware, not every permit request is for a single structure or parcel. Sometimes you’ll see an application for a larger area and will need to consider the flood hazard risk when permitting development for those larger areas. This slide looks at an example of a request to put in a subdivision with many lots, some of which are located in Zone A.

27. Zone A Permitting – Example Two
Suggestions:
Recommend altering plans so houses will not be in the SFHA
Remember: If the development in the SFHA exceeds either 50 lots or 5 acres, flood elevation data is required
If a flood elevation has been developed, permit the development under 60.3(c). A Letter of Map Revision may be requested so the FIRM can be updated with the new information.
Good place for a higher standard, fewer lots and/or fewer acres.

28. Resources Visit the FEMA Library for:
FEMA 1-98 – Use of FIS Data as Best Available Data
The Zone A Manual: Managing Floodplain Development in Approximate Zone A Areas
FEMA Engineering Library for Models
HEC-RAS:
USGS Stream Stats:
FEMA GeoPlatform:
FEMA Map Information eXchange (FMIX)
(877) FEMA-MAP

29. Contacts Phetmano Phannavong, P.E., CFM
FEMA Region III Floodplain Management and Insurance Branch:
Washington, D.C.
Phetmano Phannavong, P.E., CFM
Delaware
Michael Powell, CFM
Maryland
David Guignet, P.E., CFM
Pennsylvania
Daniel Fitzpatrick, CFM
Virginia
Charley Banks, CFM
West Virginia
Kevin Sneed, CFM