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

MT-1 Map

Inclusion of a map in MT-1 determinations would be very useful. Such a map could show the exact location of structure(s)/property (ies) that are the subject of determinations. It could also include a list of BFEs and LAGs for structure(s)/property (ies). Of course, it could add to the cost of LOMC processing and may not be feasible under the current funding guidelines.

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19 votes
21 up votes
2 down votes
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Process Administration & Letters of Map Change

Simpler LOMC forms, better guidance

LOMC forms should be simplified. The current forms are difficult to read and have many pages of instructions resulting in confusion on the part of requesters and subsequent need for more data. The addition of a simple checklist of required items for different types of requests could potentially help the requesters. Many homeowners continue to use full elevation certificates for LOMAs (which require a surveyor and ...more »

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

Electronic submittal of additional data

FEMA should allow electronic submittal of additional data for LOMRs (MT-2s) directly to a concerned MT-2 reviewer regardless of whether the original MT-2 request was electronic or manual. Unless a MT-2 reviewer requests additional data as hardcopy, an electronic submittal should be considered an adequate response. Eliminating a hard copy submittal to LOMC Clearinghouse would expedite the review process by eliminating ...more »

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

Automation and improving the quality of LOMR submittals

Basic LOMC training should be made mandatory for Professional Engineers/Land Surveyors wishing to submit online MT-2 requests. Online submittal should require completion of inventory checklists as a part of online LOMR (MT-2) request submittal; training should cover each item of such an inventory checklist, e.g., all the required elements of a certified topographic work map. FEMA could team up with communities and/or ...more »

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22 votes
23 up votes
1 down votes
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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

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

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

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

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

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

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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Process Administration & Letters of Map Change

Large Scale LOMRs

There needs to be a faster mechanism for taking large scale LOMRS to effective status. Many of these involve significant community investment and interaction to get the modeling approved. Then to move into a PMR process holding pattern often causes frustration. Suggest adding an addition fee to the fee schedule to cover the extra costs of processing large scale LOMRs and then keep them as a LOMR instead of switching them ...more »

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28 votes
30 up votes
2 down votes
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Process Administration & Letters of Map Change

Geospatial Distribution & Viewer Tool for LOMCs

The general public cannot easily determine the current condition of their LOMC. Determination companies cannot pull the required data as needed to accurately determine the floodplain status of their clients’ properties and instead rely on manual distribution of updates. Mapping partners have no simple method to view and revalidate large quantities of LOMCs and FEMA does not currently have a method to evaluate the revalidation ...more »

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20 votes
21 up votes
1 down votes
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Process Administration & Letters of Map Change

Revalidation Process

LOMCs revalidated during the Revalidation process are not readily accessible or searchable for the end user on the MSC website. The way the MSC is structured revalidated cases are tied to the new map panel number and then only accessible if the user knows the revalidation case number. All other LOMCs are searchable by case number through the MSC’s Product Catalog, Letters of Map Change section. To increase the visibility ...more »

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24 votes
25 up votes
1 down votes
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