Vantage Point: Elevations, Forms, Advice, and Frustration

When trying to keep dry, elevation means everything. When trying to show a site is likely to remain dry during a 1% annual chance flood, elevation still means everything. When trying to reduce flood insurance premiums, elevation remains paramount. When the lowest adjacent grade to a structure and any extensions to it are above the Base Flood Elevation (BFE) and no fill is involved, the site can be removed from the area where mandatory flood insurance coverage applies with a Letter of Map Amendment.

How we report those elevations in making applications to amend Flood Insurance Rate Maps (FIRMs) is a fairly uniform process, but the means of submitting that information may not be. Aside from mailing everything in, there are two web-based means for submitting applications for Letters of Map Amendments (LOMAs) to remove “inadvertent inclusions” from regulated floodplains. If the ground has been elevated by fill since being mapped, the appropriate process is a Letter of Map Revision Based on Fill, with different qualifications for a successful application.

The two online submittal platforms are meant for different purposes and different users.

eLOMA is only usable by licensed professionals, generally surveyors but possibly engineers and/or architects if permitted by their licensing boards to perform certain topographic work. Once that hurdle is passed and an account established, the professional can submit the most basic kinds of applications for quick production of a formal LOMA. These are not for sites with any fill, not for sites in coastal high hazard areas (V-type zones), and not for areas without identified BFE, whether from the FIRM, accompanying study report, or other reliable source of 1% annual chance floodplain study. For areas with detailed studies, the eLOMA process is instantaneous.

For more complicated LOMAs, and for all other kinds of map change applications, the online LOMC platform is available for anyone, licensed or not, to submit data for review by FEMA’s contractors. Aside from being the general catch-all alternative to mailing in documents, there are some specific situations requiring application through online LOMC rather than eLOMA.

  • If working in an approximate A zone without a BFE, use the online LOMC process to submit cross-sections for FEMA’s contractors to determine the BFE for you.
  • If your client wants to drive home a point, more than just “Removal” printed in the header of a LOMA for a site outside of the mapped Special Flood Hazard Area, use the online LOMC. The plotting you submit can result in “Out As Shown” in the LOMA header. That language implies something different to non-technical people.
  • If you find a discrepancy between data supplied by the maps, profiles, and/or floodway data tables (yes, that does happen!), eLOMA is not for you. Report the most conservative BFE (the one least favorable to your client) in Box B-9 of the Elevation Certificate and explain its source in Section D, along with identification and copies of the conflicting data. The reviewers will not resolve the data discrepancy, but will confirm the proper use of the higher BFE in issuing the LOMA.

On a related note, the new Elevation Certificate is identical to the one that expired in November 2018. It followed a curious route to suddenly bursting upon the floodplain management scene. The usual, and legal, approach is to publish a notice in the Federal Register prior to expiration asking for public comments about the form, FEMA’s evaluation of and response to those comments, and the announcement of when a new form will be coming out, well in advance of its mandated use. If a form expires before this process is completed, then official extensions allowing use of the old form keep that form legal. This is what happened before the now overly expired 2016-2018 form came into being; the form expiring July 31, 2015 was extended several times so that insurance agents and local floodplain managers knew they could accept and rely on forms despite being past their “best used by” date. When a new form is issued, notices in the Federal Register and on FEMA’s website announce a six-month grace period to transition into using the new version.

Things went a bit awry with the 2016-2018 form. The Federal Register request for comments went out just after the work group providing input to update and revise the form was inexplicably and suddenly told to cease work and disband. The Elevation Certificate expired without any advance notice of extension. No subsequent notices came out, either, and FEMA’s website provided no guidance as to when a new form could be expected. Then without warning, a new Elevation Certificate debuted on Friday February 21, 2020, with a statement on FEMA’s website that it was to be used immediately, sans grace period to transition from the old form we had been using illegally for 15 months. The sole difference was the date printed in the upper right corner. Perhaps this is a stop gap measure and perhaps some of the suggested improvements will be incorporated at some point (the 2016-2018 form suffered several issuances with upgrades). For now, we can only hope FEMA gets the funding and support it needs for mapping and floodplain management effectively and responsively for the nation’s protection.

About the Author

Wendy Lathrop, PS, CFM

Wendy Lathrop is licensed as a Professional Land Surveyor in NJ, PA, DE, and MD, and has been involved since 1974 in surveying projects ranging from construction to boundary to environmental land use disputes. She is a Professional Planner in NJ, and a Certified Floodplain Manager through ASFPM.