Process Administration & Letters of Map Change

FEMA processes updates and revisions to the Flood Insurance Rate Maps for the National Flood Insurance Program. FEMA’s statutory and regulatory authorities provide specific administrative requirements for map updates and revisions, but FEMA welcomes suggestions for improving the delivery of its program services and products. Please share your thoughts on how we could deliver these products more efficiently and in a more time effective manner.

The processing of Letters of Map Change is also an area where FEMA is committed to finding new ways to use technology to help the Agency reduce the time to process requests while maintaining the quality of the products. Please share your ideas on ways to make the process easier and more accessible without sacrificing quality.

Process Administration & Letters of Map Change

An Equitable LOMR Fee Schedule

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 »

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Process Administration & Letters of Map Change

Eliminate LOMR-F

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 »

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Process Administration & Letters of Map Change

Simpler Elevation Certificate Form

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.

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Process Administration & Letters of Map Change

Revise LOMA and LOMR Standards

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.

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Process Administration & Letters of Map Change

LOMC processing as a single, non A&E contract

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 »

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Process Administration & Letters of Map Change

Utilize Technology to Improve LOMC Process

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 »

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Process Administration & Letters of Map Change

Improved LOMR Efficiency - Suggestions

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 »

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Process Administration & Letters of Map Change

Improved LOMC Process through CTPs

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 »

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Process Administration & Letters of Map Change

Eliminate LOMCs

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 »

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Process Administration & Letters of Map Change

Expand Criteria for LOMA determinations by LIDAR

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 »

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Process Administration & Letters of Map Change

LOMR Submittals and the new FIRM Database Requirements

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 »

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Process Administration & Letters of Map Change

Expand eLOMA to reduce MT-1 Costs

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 »

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