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 model complexity. The LOMC reviewers could assess the complexity of the submittal and assign the case to a reviewer with the appropriate experience for the case.
Many LOMC models are prepared on digital terrain; however these data are frequently in a wide variety of digital file standards (GeoTIFF, ESRI FLT, DEM, LandXML). FEMA should encourage the submittal and future dissemination of these surface models by recommending non-proprietary standard. As to not discourage the submittal of these data, FEMA may have to provide a blanket disclaimer protecting the submitter of terrain data from future claims regarding its accuracy.
Large scale LOMRs/PMRs should become effective at approval. Sufficient funding needs to be available to process the PMRs. Significant issues can result from shelving the best available data.