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

Reduce Number of LOMCs

Flood Studies that involve base map changes should include a budget item for detailed review of map panels, especially for populated areas. A detailed review is needed so that any perceived shifting of the properties can be identified and large scale LOMA determinations can be made (contingent upon availability of appropriate LiDAR data) at the time of revalidation of LOMCs. This will reduce the number of LOMCs that FEMA ...more »

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17 votes
18 up votes
1 down votes
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Process Administration & Letters of Map Change

Online LOMC Certification

Offer a certification for Online LOMC submittals to allow submitters to demonstrate competency. Certified requesters should have accounts to make a submission and advance the case through a shorter turnaround process. For this privilege, an annual membership fee may be considered.

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19 votes
19 up votes
0 down votes
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Process Administration & Letters of Map Change

LOMR-F Incorporation

Develop and distribute guidance allowing large scale LOMR-Fs to be processed as LOMRs, that is, physically revise the map rather than amend by letter. A minimum area would have to be established (e.g., 5 lots/50 acres as defined in 44 CFR Part 60.3) as well as an appropriate fee. While the minimum area could be considered arbitrary by some, this change would significantly offset the cost FEMA incurs in processing large ...more »

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14 votes
15 up votes
1 down votes
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Process Administration & Letters of Map Change

COST BASIS FOR LOMAs

FEMA has always based the LOMA unit cost on a per case rate. Maybe FEMA should look at the cost on a per structure or property basis. A case may have one structure/property or may have hundreds of structures/properties. In addition, FEMA has historically procured LOMA processing under a cost reimbursable contract vehicle. FEMA may get a lower cost for LOMAs by procuring LOMA processing under fixed price contract vehicle. ...more »

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16 votes
17 up votes
1 down votes
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Process Administration & Letters of Map Change

Use of LOMCs to address inaccuracies

LOMCs should not be considered as a solution for addressing all inaccuracies in FIRMs. FEMA should explore the possibility of issuing a simple document to address errors such as incorrect stream names, incorrect map panel or suffix number, and so on. LOMCs should be used only for revisions based on engineering data/analysis.

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17 votes
18 up votes
1 down votes
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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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5 votes
5 up votes
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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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5 votes
11 up votes
6 down votes
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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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3 votes
3 up votes
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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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3 votes
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Process Administration & Letters of Map Change

FEMA Does Not Need to Peform Reviews of LOMAs

FEMA has the responsibility to appropriately map the SFHA, however the existing LOMA process absorbs much of the annual funds. The agency could just no longer review LOMAs to achieve the costs savings. If you take a look at the LOMA process, it requires a registered professional to certify the property is not in the SFHA. Why should FEMA not just accept the professional seal and grant the LOMA? The Professional carries ...more »

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-12 votes
10 up votes
22 down votes
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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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1 vote
5 up votes
4 down votes
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Process Administration & Letters of Map Change

FEMA can do H&H themselves

The Letter of Map Revision (LOMR) process could be streamlined and accelerated if LOMR requesters (community officials or private parties) had the option of asking FEMA to perform the Hydrology and Hydraulics (H&H) modeling required to support their submittal and also prepare the resulting mapping. Requestors would supply supporting topography or survey data, certified “as built” plans, etc., and would pay a higher review ...more »

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-5 votes
15 up votes
20 down votes
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Process Administration & Letters of Map Change

Full acceptance of certfiied documents for LOMCs

FEMA should accept data that is certified by a licensed surveyor or engineer without question. The eLOMA tool allows surveyors to input data, with periodic audits, to get determinations relatively fast. FEMA should open this tool to users who aren't licensed professionals if they have documentation that was stamped. That way homeowners would be able to get quick LOMAs if the data is there. Why is an additional review ...more »

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-13 votes
12 up votes
25 down votes
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