1. Letter of Map Change Fundamentals
FEMA Region III National Flood Insurance Program Essentials and Best Practices
Jana Green, CFM, RAMPP

2. Topics of Discussion Why Apply for a Letter of Map Change (LOMC)?
Types of LOMCs
LOMC Scenario Review
Requirements for Submitting LOMCs
Community Acknowledgment and Concurrence
Understanding the LOMC Review Process
Online Tools
Resources and Wrap Up

3. Why Apply for a LOMC? Most Common Reasons:
Remove the mandatory flood insurance requirement
To adjust flood insurance rate information
To better understand the flood risk associated with a structure or property
Other Reasons:
To support a floodplain development permit application
To understand the effects of proposed development in the floodplain
To reflect the effects of recent development in the floodplain
To determine whether the floodplain ordinance requirements apply
Why would you need a LOMC? Is it optional or has it been required? What does the applicant want to achieve by requesting one? Is he/she seeking to clarify the flood hazard status of a structure or a parcel of land, or is he/she seeking to change how the flood zones and elevations are shown on the map?
These are some of the common reasons why a LOMC would be requested.
We want to emphasize that the LOMC can only remove the Federal flood insurance requirement. A lender can still require flood insurance as a condition of the loan if they choose too, even in the absence of the Federal requirement. It is the applicant’s right to shop for another lender if they do not like the terms their lender is offering.
The Federal flood insurance requirement applies to improved real property (structures) offered as collateral for a federally-regulated loan.
These reasons can be applied to both Amendments and Revisions.

4. Letters of Map Amendment (LOMAs)
LOMAs provide flood zone determinations for individual properties and structures
Usually used to show a structure is out of the SFHA
Not required by floodplain management regulations
Based on natural ground elevations
No physical change to the FIRM
LOMAs, particularly for single lots or structures, are the most common type of LOMCs that are requested. Is my house inside or outside of the SFHA? Does FEMA say that I have to pay flood insurance? LOMAs answer these questions and are usually issued when a house is inadvertently shown in the floodplain on a Flood Insurance Rate Map (FIRM), but is actually built on natural ground that is higher than the base flood elevation. This usually happens because of issues with map scale. Flood maps often show a scale of 1 inch to 500 feet or 1 inch to 1000 feet, and every rise and fall in terrain cannot be shown on a FIRM. LOMAs allow for a comparison of property-specific information to the flood hazard information to confirm whether a house or lot is in the floodplain.
A LOMA is sometimes used when a structure receives a floodplain determination that calls them in the SFHA simply because a portion of the property is within the SFHA even though the structure itself is outside of the SFHA. The applicant should submit the LOMA application but in the out as shown situation they do not need elevation data.

5. Conditional Letters of Map Revision Based on Fill (CLOMR-Fs)
CLOMR-Fs comment on whether a structure or parcel of land that will be elevated by fill will be located within the SFHA after the project is complete
CLOMR-Fs do not remove a floodplain designation
CLOMR-Fs do not waive floodplain development requirements
An as-built LOMR-F must follow a CLOMR-F for an official change
Proposed
Structure
When is it a good idea to suggest a CLOMR-F? Answer- when there is any uncertainty regarding whether the proposed structure will be built in compliance. Watch out for the Low floor below the BFE.
Conditional determinations are conditional upon the project being completed as described. They are not a waiver for a structure to be then built without consideration of the local floodplain management ordinance.
CLOMR-Fs can also help identify and prevent encroachment into the floodway.
CLOMAs provide official comments which state whether a structure, if built as proposed on natural grade, would be considered within the Special Flood Hazard Area (SFHA) upon completion.
CLOMAs are not official determinations.
CLOMAs do not amend the FIRM.
CLOMAs do not remove floodplain development requirements.
An as-built LOMA must be received before the FIRM can be amended to remove the SFHA designation from the structure.

6. Letters of Map Revision Based on Fill (LOMR-Fs)
LOMR-Fs provide official flood hazard determinations for individual structures and properties that have been elevated by fill
Usually to show structure is elevated out of the SFHA
Conditional LOMR-F (CLOMR-F) may be required by the local floodplain ordinance
No physical change to the FIRM
Fill is defined as material from any source, including the subject property, that elevates ground to or above the Base Flood Elevation.
The intent of a LOMR-F is to remove the SFHA designation from a building that has been elevated on structural fill, NOT for fill piled around the outside of a structure post-construction.
On rare occasions multi-lot LOMR-Fs are incorporated into map updates but in most cases LOMR-Fs are unable to be mapped due to map scale limitations.

7. Conditional Letters of Map Revision (CLOMRs)
CLOMRs comment on the impact of a proposed project to floodplain boundaries, floodway boundaries, or BFEs
Must be followed by as-built LOMRs
NFIP regulations require a CLOMR when:
Floodway encroachments increase the BFE
Zone AE without floodway development will raise the BFE more than 1.0 feet
Communities can pass the responsibility to obtain a CLOMR to the developer through the local floodplain ordinance
NFIP compliance is reviewed during the CLOMR process.
It is important to mention that CLOMRs are not official revisions to the effective FIRM and must be followed by as-built LOMRs when the project has been completed.

8. Letters of Map Revision (LOMRs)
LOMRs physically update or refine the flood hazard information used to create the FIRM.
Results in adjustment to the height of the BFE or boundaries of the SFHA
 Ensures that the FIRM is the most accurate reflection of the flood risk
Requires engineering analyses and scientific data
You as a community official must require a LOMR be sought in connection with any floodplain modifications. More detail coming up.

9. When to Request a LOMC
To remove the mandatory flood insurance requirement
Inadvertent inclusions – structures built on natural high ground (LOMA)
Structures elevated on fill* (LOMR-F)
To update the map due to better topographic data, a physical change in the floodplain, or better modeling (LOMR)
* Caution: Placement of fill around an existing foundation to increase the LAG could result in non-compliance
LOMAs can show that a structure or property is horizontally or vertically shown outside of the floodplain.
LOMR-Fs are for structures elevated on structural fill- not fill piled around the outside of the foundation post construction.
Uses for a LOMC:
Faster and cheaper than a PMR or restudy
Removes the mandatory flood insurance purchase requirements for structures elevated on solid ground higher than the BFE
Inadvertent inclusions in SFHA or floodway on natural high ground that are not mappable - Map scale/topographic limitations do not allow maps to reflect every piece of high or low ground
Structures elevated on fill
Placement of fill around a structure that could result in a non-compliance (basement definition – below grade on all sides)
LOMR - Correct the map or update the map due to a physical change (LOMR)
CLOMR - To obtain a FEMA review for a floodway modification, a proposed structure, or a proposed project prior to start of construction
Again, when an adverse effect will increase flood risk or elevations, a CLOMR will be required.

10. Requirement to Submit New Data
When is a community required to initiate a revision?
Development occurring in Zones A1-30 and AE without a designated floodway for proposed increases of more than 1.0 foot
Floodway encroachment (no-rise requirement)
Alteration or relocation of a stream (including but not limited to installing culverts and bridges)
Submission of new technical or scientific data
The Coordinated Needs Management Strategy (CNMS) tracking tool is used by FEMA to track map update needs. Communities can share needs with FEMA using this tool.
It is the community’s responsibility to require anyone creating a change in the floodplain to obtain a CLOMR and LOMR. This includes PennDOT and the USACE!!
This is a recurring problem where communities assume that state & federal agencies have followed all required FEMA processes and unwittingly permit a violation (no rise requirement).
Floodway encroachment/changes – Conditional Letter of Map Revision (CLOMR) (d)(4)
Proposed increases of more than 1.0 foot – CLOMR (c)(13)
Timely updates to flood hazard information to ensure it reflects the current flood risk is a critical step in reducing future risk.
A good floodplain management program will have procedures and requirements to obtain the data necessary to manage new development in approximate A Zones and outside the mapped floodplain. One means of obtaining this necessary data is to require the developer provide detailed flood data for all development regardless of size. The NFIP only requires elevation data for developments larger than 50 lots or 5 acres. 
A conditional review is not required when developing a water surface elevation for an approximate Zone A area but is strongly recommended to avoid potential compliance issues.

11. LOMC Request – Scenario One
Property owner receives letter from bank requiring flood insurance for a home. Property owner must either provide proof of adequate flood insurance coverage or provide proof that the house is not in the high risk flood zone within 45 days. No fill has been placed on the property.

12. Scenario One – Option and Considerations
Options
Request a LOMA if the house is on natural ground
Considerations
How many structures are on the property?
Are the structures in the SFHA or is only part of the property in the SFHA?
Is future development planned?
If the structure has been elevated on a fill pad, the property owner should request a LOMR-F.
There are some considerations that may be helpful to share with property owners; some of the issues that can be anticipated.
Will the determination be for structure(s), the entire property, or a portion of the property? This affects what information FEMA will need to review.
How many structures are on the property? Is flood insurance required for all of them? BG-14 legislative change removes the Federal requirement for uninhabited structures.
If future development is planned, consider recommending a metes and bounds description and map submission to remove the portion of the parcel above the BFE. If a LOMA is for a structure, any additions will modify the building footprint and will make the LOMA invalid. If other, separate structures are built on the property, a LOMA may be needed again. A metes and bounds submission might be the solution.
Requesting a LOMC does not guarantee a favorable outcome for the applicant. There are both removals and non-removals from the SFHA, and flood insurance will be required for structures that are subject to the Federal requirement.

13. LOMC Request – Scenario Two
Property owner would like to build a house on a vacant parcel of land that is shown in an SFHA on the effective FIRM. Ground elevations at the project site are higher than the BFE because fill has been placed.

14. Scenario Two – Options and Considerations
Request a LOMR-F for the portion(s) of land above the BFE
Request a CLOMR-F for the proposed structure
Consideration
If a CLOMR-F is requested for a structure, its proposed lowest floor should be above the BFE; Federal development requirements apply until the structure has been removed from the SFHA.
Portion of property requests require a licensed professional to certify a metes and bounds map and a metes and bounds description of the portion of property in question.
If the entire property is above the BFE, an applicant may request the determination for the entire property.
Discuss pros/cons of each – processing fee for CLOMR-Fs and requirement for as-built submission; additional survey costs for M&B map/description; for conditional letters, as built determination required after project has been completed.
As you can see, a conversation with the property owner to discuss these options allows him/her to make the decision that will be best for his/her specific situation.

15. LOMC Request – Scenario Three
A developer would like to improve a large area of vacant land by building a subdivision within the SFHA. There are areas above and below the BFE on the site. The developer would like to ensure that the future residents will not be required to carry flood insurance and that if they chose to they could get a low risk premium.

16. Scenario Three – Options and Considerations
Submit a multiple structure CLOMA request for proposed structures with natural ground above the BFE; submit a multiple structure CLOMR-F request for proposed structures in lower lying areas.
Obtain grading permit; add fill to lower lying areas and request a LOMR-F for all areas above the BFE, defined by metes and bounds.
The developer and the Floodplain Administrator should discuss ways to design the subdivision so that the structures will be located on naturally high ground.
It’s a good idea to use a cluster development technique to keep structures outside of the SFHA.

17. LOMC Request – Scenario Four
A community has permitted a major urban drainage project that has enlarged culverts, installed detention ponds, and has buried a section of a stream underground. The improvements have reduced obstructions to flows and the effective FIRM no longer reflects the actual flood risk.

18. Scenario Four – Options and Considerations
The community should request a LOMR to incorporate the changes into the effective FIRM.
Consideration
If improvements are made and a LOMR is not issued to update the flood hazard information, flood insurance rates and flood insurance requirements will continue to be determined based on the outdated, effective information. Further, LOMAs and LOMR- Fs can only be issued against the effective flood hazard information.
One of your responsibilities as an FPA is to ensure the maps are kept up to date. Ensure as-built projects are sent to FEMA as a LOMR request. The ultimate responsibility is on the community, but a community may establish in their ordinance that the applicant/developer fulfill this requirement as a condition of their permit.
An entire subdivision can be built in between FIRM updates. If a stream is relocated, a FIRM can show a stream running through several houses. There can be significant decreases to BFEs if a culvert is enlarged to reduce a backup in flows. Only a LOMR can incorporate these improvements before the next FIRM update.

19. LOMC Request – Scenario Five
A developer would like to build a shopping center in the regulatory floodway. The Floodplain Administrator believes the project will cause an increase in the BFE. The developer has stated that measures will be taken to avoid an increase in the BFE.

20. Scenario Five – Options and Considerations
Because there is a floodway present, the Floodplain Administrator must ask the developer to provide a “no-rise” certification from an engineer to prove that the development will not cause an increase in the BFE. or
The Floodplain Administrator must request that the developer secure a CLOMR, as a condition of permitting the development.
Consideration
An as-built LOMR must be requested before the community’s FIRM will reflect the post-project conditions.
The point of a CLOMR is to review the impact of a proposed project and to show that it will be compliant with NFIP regulations.
CLOMRs may be requested for many different types of projects: levees, bridge enhancements/replacements, subdivisions, retaining walls, etc.
Your ordinance probably has language like, “No use shall be permitted in the floodway that would result in any increase in the 1% annual chance flood level. Consideration of the effects of any development on flood levels shall be based upon the assumption that an equal degree of development would be allowed for similarly situated lands.”
The objective of this requirement and the floodplain management ordinance is to ensure that the floodway is reserved to do its natural job: carrying floodwater. The preferred approach is to avoid all development there.
To ensure that the encroachment review is done right, you may want to require the developer to provide an encroachment certification. This is often called a “no-rise” certification because it certifies that the construction or development project will not affect flood heights. Another option is to require a CLOMR request be submitted to FEMA.

21. LOMC Application Forms
MT-EZ
Single-lot or single- structure residential LOMA requests
MT-1
Multiple-lot or multiple- structure LOMA requests
LOMA request for commercial properties
CLOMAs and CLOMR-Fs
LOMR-Fs
MT-2
LOMRs and CLOMRs
The applications contain detailed guidance to ensure a complete, accurate submission and in some cases require you (community officials) to sign off on certain types of projects.

22. Elevation Form Elevation Form – MT-EZ /MT-1 Application
Only includes information required to make a LOMC determination
Key Takeaways – only for LOMAs; not for insurance or community compliance.
Form 2 of MT-1 Application:
Only includes information required to make a LOMC determination
Accommodates multiple structure/lot requests
Part B of MT-EZ Application:
Elevation Form only includes information required to make a LOMC determination
A certified Elevation Certificate may be submitted in lieu of this form

23. Elevation Certificate
Three main purposes
Rate an insurance policy
Demonstrate NFIP compliance
Request a FIRM amendment
May be submitted instead of the Elevation Form
To learn more about Elevation Certificates, you can view the webinar Reviewing and Interpreting Elevation Certificates available at
The Elevation Certificate is comprised of the following sections:
Section A – Property Information
Section B – Map Information
Section C – Building Elevations (w/survey)
Section D – Certification and Comments
Section E – Building Elevations (w/out survey)
Section F – Property Owner Certification
Section G – Community Compliance

24. Documentation for a LOMA
Required
Recorded plat map or
A recorded deed accompanied by tax assessor’s map
Usually Required
Elevation Form with the certified Lowest Adjacent Grade (LAG) or Lowest Lot elevation(s)
May be Required
Certified metes and bounds description and map
Other elevation data
At a minimum, documents are needed to both locate the property or structure on the FIRM and to legally describe the property on the final determination document. The recorded plat map would serve both purposes; otherwise, a recorded deed and a tax map can be submitted.
Sometimes a property boundary map can be submitted instead of a tax assessors map if it includes an intersection that can be plotted on the effective FIRM.
A structure location map may be needed if the request is for a structure that cannot be located using data available to the individual reviewing the request. For requests requiring multiple structures, a structure location map must be provided that gives each structure a unique identifier that is consistently used to identify each structure throughout the documentation submitted to support the request.
If the request is for a portion of property, a certified metes and bounds description and map must be provided which describes the portion of property in question by calling out each distance and bearing from and to the point of beginning.
Elevation data is required if the subject of the request is shown on the FIRM within the SFHA.
In some cases, certified property-specific topographic maps or certified spot elevation maps may be accepted to provide elevation data; this kind of data would need to be reviewed before it can be confirmed that it will be accepted.
Depending on the nature of the flood hazard affecting the property, other forms of certified elevation data may be required.
All elevation data must be certified by a licensed professional.
If the subject of the determination is located within a regulatory floodway, community acknowledgment must be provided by the Floodplain Administrator.
All information required for a LOMA are also required for a LOMR-F.
In addition, a fee is required since fill is the basis of the request and it is considered a revision. Only amendments are fee-exempt. The fee is currently $425 for individual structures or lots and a flat fee of $800 for multiple structures or lots.
For some LOMR-F requests, a certified grading plan may be required to show the extent of fill placement.

25. Common Application Issues – LOMAs
Failure to write the legal property description and address on the application
Failure to enter contact information and sign/date the application
Submitting a deed or plat map that is not recorded
Missing vertical datum on the Elevation Form
Elevations not based on finished construction for an as-built determination
The address and legal description may exist in other places within the application package; however, it must also be entered on the form.
A name must be provided; a company cannot be the applicant. Failing to sign/date the application can result in processing delays until the corrected form has been received.
A notarized deed may or may not be recorded. Recordation data MUST be shown on a deed or plat.
Elevations must be referenced to the same vertical datum before they can be compared to each other. Property elevations should be in the same datum as the elevation on the FIRM.

26. Documentation for a CLOMR-F
Required
Recorded plat map or
A recorded deed accompanied by a tax assessor’s map
Community acknowledgment
Processing fee
Endangered Species Act (ESA) compliance
CLOMR-F requests require documentation similar to a LOMR-F; however a map must be provided which shows the location of the proposed structure(s).
For some CLOMR-F requests, a proposed certified grading plan may be required to show the extent of fill placement.
The processing fee for CLOMR-Fs is $500 for single structures or lots and a flat fee of $800 for multiple structures or lots.
For CLOMR-F requests, documentation is also required which demonstrates compliance with the Endangered Species Act. Documentation may come from the Fish and Wildlife Service, National Marine Fisheries Service, or certain state agencies. In some cases, a project impact assessment may be required for review.
“No Effect” Statement for ESA Compliance

27. Documentation for a LOMR-F
Required
Recorded plat map or
A recorded deed accompanied by tax assessor’s map
Community acknowledgment
Processing fee
Similar to CLOMR-F requests, other data may also be required.
At a minimum, documents are needed to both locate the property or structure on the FIRM and to legally describe the property on the final determination document. The recorded plat map would serve both purposes; otherwise, a recorded deed and a tax map can be submitted.
Sometimes a property boundary map can be submitted instead of a tax assessors map if it includes an intersection that can be plotted on the effective FIRM.
A structure location map may be needed if the request is for a structure that cannot be located using data available to the individual reviewing the request. For requests requiring multiple structures, a structure location map must be provided that gives each structure a unique identifier that is consistently used to identify each structure throughout the documentation submitted to support the request.
If the request is for a portion of property, a certified metes and bounds description and map must be provided which describes the portion of property in question by calling out each distance and bearing from and to the point of beginning.
Elevation data is required if the subject of the request is shown on the FIRM within the SFHA.
In some cases, certified property-specific topographic maps or certified spot elevation maps may be accepted to provide elevation data; this kind of data would need to be reviewed before it can be confirmed that it will be accepted.
Depending on the nature of the flood hazard affecting the property, other forms of certified elevation data may be required.
All elevation data must be certified by a licensed professional.
If the subject of the determination is located within a regulatory floodway, community acknowledgment must be provided by the Floodplain Administrator.
All information required for a LOMA is also required for a LOMR-F.
In addition, a fee is required since fill is the basis of the request and it is considered a revision. Only amendments are fee-exempt. The fee is currently $425 for individual structures or lots and a flat fee of $800 for multiple structures or lots.
For some LOMR-F requests, a certified grading plan may be required to show the extent of fill placement.

28. Documentation for a CLOMR
Community concurrence
Applicable forms within the MT-2 application
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
Property owner notification
Processing fee
ESA Compliance
In addition to documentation required for LOMRs, ESA compliance is also required for CLOMR requests.

29. Documentation for a LOMR
Community concurrence
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
Property owner notification
Processing fee
If fill in floodway, “no-rise” analysis or CLOMR
Because a LOMR physically revises the legally adopted FIRM, community concurrence is required before a LOMR can be reviewed. The community may need to adopt the LOMR before it becomes effective.
Depending on what is causing the change in the floodplain, certain application forms are required, such as the Riverine Hydrology and Hydraulics Form, Riverine Structures Form, Coastal Analysis Form, Coastal Structures Form, and the Alluvial Fan Flooding Form.

30. Required Modeling for LOMRs and CLOMRs
Effective Model
Duplicate Effective Model
Corrective Effective Model
Existing Conditions Model
Post-Project/Proposed Conditions Model
One must begin with the hydraulic model from the effective FIS.
The Duplicate Effective model is a run of the effective model with the applicant’s software to ensure that it is compatible.
The Corrected Effective Model corrects any errors in the duplicate effective and may add any changes that are not manmade that have not been already incorporated into the model.
The Existing Conditions Model is a modified version of the Duplicate or Corrected Effective model. If there haven’t been any modifications since the effective, the Duplicate Effective or Corrected Effective becomes the Existing Conditions.
The Post-Project/Proposed Conditions Model includes modifications to reflect the proposed project.

31. Common Application Issues – LOMRs
Vertical and horizontal tie-ins
Missing Overview and Concurrence Form
Misunderstanding of fee exemptions
Individual Property Owner Notifications and Public Notice
No Annotated FIRM and FIS pages
Inconsistencies between mapping and modeling
To avoid waterfalls, BFEs must tie in to the effective mapping within maximum of 0.5 foot, 0.0 foot if at all possible.
The floodway and SFHA width must tie in within 5% of FIRM scale.

32. Role of the Community - Amendment
Community Acknowledgement Form
Understand your role - you do not have to sign!
Assist applicant with proposed development considerations
Tracking and storing information
LOMC determinations
Elevation Data
Permit and Inspection Data
FPA should be familiar enough with the LOMC processes to assist constituents with questions regarding the best process for addressing a map revision or amendment. This usually comes up during a permit review but general questions will be received regarding the removal of the mandatory flood insurance requirement.
Stress the importance of the ordinance supporting the requirement for a conditional when NOT required by the NFIP.
A questionable BFE should be an exception and not require a conditional request for most permit applications.

33. Role of the Community – Revisions
Review CLOMR and LOMR applications
Ensure revision is appropriate and in line with ordinance
Make use of local resources, such as an engineer or legal counsel
Require developers to request revisions through the local floodplain ordinance
Make use of conditional process to ensure compliance before a project is complete
Clearly communicate to developers their responsibility in the revision process
Follow-up - ensure a LOMR is completed for final projects before C.O.
Review, sign, and submit LOMR/CLOMR applications
A LOMR will eventually become the official flood map for the area it has revised and the FPA will need to enforce the local floodplain ordinance based on the information it shows. Communities must provide concurrence for LOMR requests and should thoroughly understand the project and how it will affect local flood hazards before providing concurrence.
You may update the ordinance to require a developer/applicant to cover the fees for a LOMR/CLOMR submission and the costs for the community to review.
Remember these requirements apply to state agencies who might be doing work in your SFHAs as well, including your state department of transportation, etc.

34. LOMCs: Basis of Determination
For structures, the LAG must equal or exceed the regulatory flood elevation, to the nearest tenth of a foot.
For parcels or portions of parcels of land, the Lowest Lot Elevation of the parcel or within the portion of parcel must equal or exceed the regulatory flood elevation, to the nearest tenth of a foot.
Specific consideration is given to properties located in coastal areas, areas of sheet flow, or areas with other unique flood hazards.

35. Zone A LOMCs: Basis of Determination
For Zone A areas which do not show BFEs on the FIRM/FIS, a 1% annual chance Water Surface Elevation (WSEL) must be determined to compare against the property information for a determination.
For requests for which a flood elevation cannot be provided, one will be established by the LOMC reviewer using the best data available.
In some cases, supporting data may be required before an elevation can be established by the reviewer.
Sources of WSEL may 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
For more information about managing Zone A floodplains, view the recorded webinar on this topic available through
If a Zone A 1% WSEL is calculated in house, it will only be displayed on the final letter for conditional or non-removal determinations. Removals will not include the 1% WSEL on the final letter. If a 1% WSEL is needed on a removal determination, please contact the FMIX and ask to be transferred to the LOMA Analyst.

36. LOMA/LOMR-F Outcomes Removal
The subject of the determination has been removed the SFHA
Non-Removal
The subject of the determination remains in the SFHA
Out as Shown
The subject of the determination is not shown in the SFHA
Other Response
A determination cannot be made
The Federal flood insurance requirement does not apply to removed structures.
For removal determinations, portions of the property outside of the subject of the determination may remain in the SFHA.
Other responses may be issued if a LOMC has already been issued or if a community does not have effective flood hazard data to review and make a determination.

37. LOMA Outcome
This is an example of a completed LOMA. The case number will be at the top, along with the determination date. You’ll see the community and map panel information on the left side. This is helpful to make sure the determination is still effective, as there may have been another map released since the determination was made. On the right, you’ll see the legal property description. Even if a 911 street address changes, a LOMA would still be considered valid and anyone reviewing the LOMA can refer to the legal property description as the official description.
The outcome of the determination will be found in near the middle of the first page. This will show the Lot/Block/Subdivision information, if applicable, and also the property address. The outcome box will show what the determination was for a residential structure, a garage, a warehouse, and then you’ll see the flood zone. In most cases, the flood and property elevations will also be shown.
The additional considerations are very important and should be reviewed. If a determination is made for a structure, there may be portions of the property still in the SFHA and this is something that will be reflected here. It would be up to the FPA to ensure that any other development that may be located in the SFHA will follow the local ordinance. Another note that may be present is “Study Underway”. This note can be confusing to some because it does not necessarily mean that the flood hazard information for the structure in question has changed, but that there is an ongoing flood study somewhere in the county. Sometimes this can be misconstrued to mean that a non-removal will be reversed or vice versa, but it is primarily for informational purposes.

38. CLOMA Outcome
Conditional letters are comment documents rather than determination documents simply because they provide comments on proposed development instead of determinations based on as-built development.

39. LOMR Outcomes Official Determination Document
Accompanied by annotated FIRM panel(s) and Flood Insurance Study (FIS) tables and/or profiles
The determination document describes the nature / extent of change and its effect on floodplain / floodway boundaries, and/or BFEs.
Floodplain improvements are incorporated into the effective flood hazard information, such as changes that lower the BFE such as dam removals
Lenders may use the new data to determine whether flood insurance is required.
Insurance agents may rate policies based on the updated information.
Floodplain administrators may use the new data to issue permits. A major issue can occur when a community permits development based on its own study that hasn’t been incorporated into the official map. This can result in compliance problems or high flood insurance premiums for any affected structures.

40. Fee Schedule ***eLOMAs and LOMAs are fee exempt*** LOMC Type Fee
LOMR-F
$425-$800
CLOMA
$500-$700
CLOMR-F
$500-$800
LOMR-F following CLOMR-F
$325-$700
CLOMR (New Hydrology, Bridge, Culvert, Channel, or Combination Thereof)
$4400
CLOMR (Levee, Berm, or Other Structural Measures)
$6050
LOMR (New Hydrology, Bridge, Culvert, Channel, or Combination Thereof)
$5300
LOMR (Levee, Berm, or Other Structural Measures)
$7150
LOMR following CLOMR
$5000
LOMR (Alluvial Fans)
$5600 initial fee
Periodically reviewed and revised. Fees listed are current as of April 2014.
The applicant is invoiced for additional fees for alluvial fan LOMR review.
Fee Exemptions
LOMRs based solely on submission of more detailed data (fee applies if there are structures that need to be evaluated)
Map changes based on mapping or study analysis errors
Map changes based on the effects of natural changes within the SFHA
Federally sponsored flood-control projects where 50% or more of the project's costs are federally funded
Map changes based on detailed hydrologic and hydraulic studies conducted by Federal, State, or local agencies to replace approximate studies on the FIRM
Map changes based on flood hazard information meant to improve upon that shown on the flood map or within the flood study
Improvements to flood maps or studies that partially or wholly incorporate manmade modifications within the SFHA will not be exempt from fees.
***eLOMAs and LOMAs are fee exempt***
Access the FEMA website for the most updated fee schedule:

41. LOMC Processing Timeframes
LOMAs, LOMR-Fs, CLOMAs, and CLOMR-Fs are completed within 60 days of receiving all required data
If additional data or a fee has been requested, the applicant has 90 days to submit the required data before the case is suspended
Extensions may be granted
LOMRs and CLOMRs are completed within 90 days of receiving all required data
Issued LOMRs require a 4-6 month adoption period before becoming effective for legal use
Additional data:
If data is provided after the 90-day timeframe, a new request will be opened and all previously submitted fees will be forfeited; previously submitted data usually does not need to be resubmitted.
An extension may be requested by the applicant if the required data/fee cannot be provided within 90 days; a written request is required before an extension can be granted.

42. Revalidation Letters
LOMCs are only valid as long as the FIRM on which it was determined is still effective
When a new FIRM is issued, all previously issued LOMCs are reviewed to determine whether the outcome has changed based on the new flood hazard area
LOMRs are either superseded or incorporated into the new FIRM
LOMAs and LOMR-Fs may be superseded, but those that are still valid are listed on a Revalidation Letter
The Revalidation Letter is effective the day after the FIRM is effective
Automatically initiated by FEMA as a map action
Revalidation letters are sent to the community and not to individual applicants.
Letters are also uploaded to the FEMA Map Service Center.

43. Online LOMC
Allows a FIRM amendment or revision to be requested through an online platform instead of mailing in an application
Supporting documentation can be uploaded online and case-related correspondence is ed to the applicant

44. eLOMA Online determination tool for simple LOMA requests
Audits ensure accuracy
Registration form available at:
Registration form can be:
ed to
Faxed to (800)
Mailed to:
RAMPP eLOMA Coordinator Jonathon Foster, CFM Arlington Boulevard Fairfax, VA
eLOMA is an interactive online determination tool for simple LOMA requests.
It is free to use and register for eLOMA, but use is restricted to Licensed and Certified Professionals.
eLOMA is not available for multiple lot/structure requests, requests for which the subject of the determination is located in the regulatory floodway, conditional requests or requests involving fill, and for requests for which the subject of the determination is located in an area without a regulatory flood elevation shown on the FIRM.
FEMA review to ensure accuracy of processed eLOMAs
First submission is always audited
Random audits also occur
Processed in up to 5 business days
The LOMA Determination Document may be printed after the audit is approved
eLOMAs are processed within 5 business days; if an audit is required, it is completed within 5 business days of receiving the required supporting documentation.
Final eLOMA determinations can be printed out by the Licensed or Certified professional directly from the online platform after they are finalized.

45. eLOMA Eligibility Eligible for eLOMA Not Eligible for eLOMA
Structure/lot on natural ground
Structure/lot elevated by fill
Single structure/lot
Multiple structures/lots; condominiums
Existing structure
Proposed construction
Zones A1-30 (except in floodway),
AE (except in floodway), and AH
Zones A, V, VE, V1-V30, AO, D, B, C, X
New LOMA requests
Re-issuances or LOMAs in progress
Subject area on FIRM panel has not been revised by a LOMR
Subject area on FIRM panel revised by LOMR
Structure/lot located on land that has not been annexed
Structure/lot located on annexed land

46. Resources FEMA Map Information eXchange (FMIX)
Toll free by phone at
By at
FEMA Map Service Center
National Flood Hazard Layer – FEMA GeoPortal
eLOMA (Mapping Information Platform)
Online LOMC
Code of Federal Regulations
LOMC Fee Information
FEMA Forms
NFIP Technical Bulletins
USGS Vertical Datum Conversion Information

47. 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