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 insight and giving the reviewer a heads up on the submittal. Even if the LOMR is a simple submittal, this interaction is needed and mutually beneficial.
New hydrologic fees should be required based on the type of hydrologic calculations provided. Regression equations are easy to review and use, while complex routing of many detention areas takes more review time. New hydraulics should be set by number of structures and length of waterway/coastline revised. Some Unsteady Model submittals should also be considered in a separate review fee schedule. LOMR complexity should be determined by the amount of detail added to the modeling. Converting a Zone AE to Zone AE may be the most expensive LOMR, Zone A to Zone A is a less expensive fee, as would be only adjusting a floodway limits. Recreating a duplicate-effective models based on obvious historically inaccurate topography should not required, and this can be sorted out at the initial requestor meeting.
Just as BW-12 has brought insurance fees more accountable, so should FEMA adjust their LOMR fees to be administered in a more equitable manner.