The National Flood Insurance Program: The MT-1...

The National Flood Insurance Program: The MT-1 Process

Tom Birney – FEMA Region VIII Jefferson County, CO

August 2015

Flood Map Modernization

Workshop Overview

Definitions Types of Letter of Map Change MT-1 and the MT-EZ Forms Required Data for Letter of Map Change Determinations in Zone A: How to determine the

BFE Conclusions and Questions


Definitions

NFIP - National Flood Insurance Program • Federal program created by Congress in 1968 that makes

flood insurance available in communities that enact and enforce satisfactory floodplain management regulations

SFHA - Special Flood Hazard Area: The land in the floodplain within a community subject to a one-percent or greater chance of flooding in any given year Structure - A walled or roofed building, including a gas or

liquid storage tank, that is principally above ground, and affixed to a permanent site, as well as a manufactured home on a permanent foundation


Definitions Continued

BFE – Base Flood Elevation: The elevation of the flood having a one percent chance of being equaled or exceeded in any given year LOMC - Letter of Map Change: An amendment or revision

through the MT-1 or MT-2 process LAG - Lowest Adjacent Grade: The elevation of the lowest

ground touching the structure’s foundation • ****Elevation of ground, sidewalk, patio, garage or deck

support immediately adjacent to the building****

For LOMC submittals, removal and non-removal of a structure is based on the LAG, not the finished floor



• Lowest Floor: The lowest floor of lowest enclosed area (including basement and crawl space)

• Basement: Any area of a building having its floor subgrade (below ground level) on all sides

• See Building Diagrams in the Elevation Certificate

Crawlspace: An area of a building that is subgrade on all four sides that meet the requirements outlined within FEMA Technical Bulletin 11-01



Fill: Defined as any material that is brought in, used or grading that as a result has elevated that existing conditions above the elevation of what it use to be.

• The common construction practice of removing unsuitable existing material (topsoil) and backfilling with select structural material is not considered the placement of fill if the practice does not alter the existing (natural grade) elevation.

• Fill that is placed before the date of the first NFIP map showing the area in a SFHA is considered natural grade. Check with the Community Status Book to determine when the

community entered the NFIP.


Zone Designations

A Areas of 1% annual chance flood determined by approximate methods; base flood elevations not determined

AO Areas of 1% annual chance shallow flooding where average depths are between 1 and 3 feet (usually sheet flow on sloping terrain); average whole-foot depths are shown

AH Areas of 1% annual chance shallow flooding (usually ponding) where average depths are between 1 and 3 feet; whole-foot base flood elevations are shown

A1-30 and AE

SFHAs inundated by 1% annual chance flood; base flood elevations are shown


Zone Designations

V1-30 and VE

SFHAs inundated by 1% annual chance flood; coastal floods with velocity hazards (wave action); base flood elevations are shown

B and X (shaded)

Areas of 0.2% annual chance flood; areas subject to 1% annual chance flood with average depths less than 1 foot or with contributing drainage area less than 1 square mile; and areas protected by levees from base flood

C and X (unshaded)

Areas determined to be outside the 0.2% annual chance floodplain


Other Zone Designations

A99 SFHAs inundated by 1% annual chance flood to be protected from 1% annual chance flood by a Federal flood protection system under construction; no base flood elevations are determined

V SFHAs inundated by 1% annual chance flood; coastal floods with velocity hazards (wave action); no base flood elevations are determined

D Areas in which flood hazards are undetermined


Other Zone Designations

AR/A1-30, AR/AE, AR/AH, AR/AO,

and AR/A

SFHAs that result from decertification of previously accredited flood protection system that is in process of being restored to provide 1% annual chance or greater level of flood protection. After restoration is complete, these areas will still experience residual flooding from other flooding sources.


FIRM

FIRM reflects flooding information • Base Flood Elevations (BFEs) Shown as BFE lines and cross section lines

• Base flood depths Still water elevations and sheet flow, AO Depth and AH sheet

flows • 100- and 500-year floodplain boundaries • Flood insurance risk zones • Floodway boundaries (after January 1, 1985) Shown as hatch marks on the map


FIRM


Floodway Hazard Boundary Map: FHBM

FHBM • 100- and 500-year floodplain boundaries and floodway

boundaries • Created prior to January 1, 1985

FHBM were published separate from the FIRMs • Found within the Flood Insurance Study material


FHBM


Flood Insurance Study: FIS

A Flood Insurance Study is a book that contains information regarding flooding in a community and is developed in conjunction with the FIRM and FHBM The FIS contains flood profiles, floodway data tables,

summaries of elevations as well as a narrative of the flood history of a community and discusses the engineering methods used to develop the FIRMS


Flood Insurance Study

• Identifies communities covered by study

• Notice effective data of study


Floodway Data Table

The Floodway Data Table presents the results of the floodway analyses at the cross sections shown on the FIRM or FHBM


Profile

https://www.fema.gov/online-tutorials


Profile

When determining a BFE for a property/structure, the FIRM and Profile should be utilized


Profile


1Z6Y08820390357312

Still Water Elevation


Still Water Elevation (cont.)

•Summary of Still Water Elevations can be found within the FIS


Alluvial Fan

An Alluvial Fan is characterized by high-velocity flows; active processes of erosion, sediment transport, and deposition, and unpredictable flowpaths


Example of Alluvial Fan


Alluvial Fans and LOMC

FEMA issues LOMC upon determining properties/structures should not be included within a SFHA The procedures that result in the issuance of LOMCs are provided in Parts 65 and 70

of the NFIP regulations

In areas subject to alluvial fan flooding, the provisions of these parts do not apply See Paragraph 65.13B of the NFIP regulations

Letters of Map Amendments can not be issued for any property, structure or portion of property that are located

within an Alluvial Fan


Letters of Map Change: LOMC

The boundaries for the SFHAs on the NFIP maps are prepared using the best topographic data available. Due to limitations of scale or topographic definition of the source map used to prepare a community’s NFIP map, a property may be shown within the SFHA, but be on ground that is actually above the BFE for the site. As a result, the LOMC process was developed to amend or revise the published community maps by letter.


Letters of Map Change: LOMC

FEMA has established several types of map changes. Changes that revise BFEs or published floodway information are Letters of Map Revision (LOMRs) and Physical Map Revisions (PMRs). Changes that do not revise BFEs include Letters of Map Amendments (LOMAs) and Letters of Map Revision Based on Fill (LOMR-Fs). In addition, FEMA provides comments on proposed projects, these conditional LOMCs do not amend or revise the effective NFIP maps.


Map Revision Types

Amendments: • Structures or legally defined parcels • Does not involve H&H analysis (Unless

Zone A) • Requires submittal of MT-1 Forms • Does not involve changes in BFE • Can not be used for properties in an

Alluvial Fan

Revisions: • More complex map changes • Not usually lot or structure specific • Typically involves H&H analysis • Requires submittal of MT-2 Forms

MT-1 LOMA LOMR-F Conditional LOMR-FW

(Floodway)

MT-2 PMR LOMR Conditional


Amendments (MT-1)

Letter of Map Amendment (LOMA) • Request for exclusion of individual structure(s) and

or legally defined parcel(s) of land that were inadvertently included in the SFHA

• Process outlined in Part 70 of NFIP Regulations Letter of Map Revision Based on Fill (LOMR-F)

• Request for exclusion of individual structure(s) and or legally defined parcel(s) of land that were elevated by earthen fill


Amendments (MT-1)

Conditional Letter of Map Amendment (CLOMA) • A letter from FEMA stating that a proposed structure that is not to be

elevated by fill (natural grade) would not be inundated by the base flood if built as proposed.

• Process outlined in Part 70 of NFIP Regulations

Conditional Letter of Map Revision Based on Fill (CLOMR-F)

• A letter from FEMA stating that a parcel of land or proposed structure that will be elevated by fill would not be inundated by the base flood if fill is placed on the parcel as proposed or the structure is built as proposed.

• Process outlined in Part 65 of NFIP Regulations


Conditional LOMA or LOMR-F

CLOMA or CLOMR-F: • Does not amend the NFIP map • NOT a building permit! • Simply a comment document stating whether a

structure/parcel of land will be safe from flooding if built as proposed

• Mostly the same data requirements as LOMA or LOMR-F request, but with proposed data

• CLOMR-F must show compliance with the Endangered Species Act


When the Amendment Process CAN NOTbe used

Request involving changes in BFEs Request involving changes in regulatory floodway

bound delineations Request for properties in alluvial fan areas Request involving property and/or structures that

have been elevated by fill placed within the regulatory floodway, channelization projects, bridge/culvert replacement project, or other flood control improvements


Would this Structure be Likely Removed from the SFHA?


LOMA Data Requirements

Completed MT-1 Property Information Form 1 (or MT-EZ) Copy of the NFIP Map indicating the subject property

location • FEMA Map Service Center – view effective FIRM

and create FIRMette Copy of recorded Deed or Plat map


Copy of tax map showing property location Completed MT-1 Elevation Form or Elevation

Certificate Metes & bounds description and map, if request is for

portion of property BFE, and supporting data, if in unnumbered Zone A

Area***

Data Requirements (cont.)


All FEMA-issued FIRMs and FIS reports are available to view online or for purchase through FEMA’s Flood Map Store at www.msc.fema.gov.

Portions of FIRM panels can be printed out to scale using the “FIRMette” tool through the Map Service Center site.

Other options to get FEMA Maps online include: • KMZ National Flood Hazard Layer Files – Google Earth • Mapping Information Platform – MIP • FEMA GeoPlatform

FEMA Maps Online


Map Service Center: MSC Site

Provides two search options • Product Search By field • Map Search

MSC will also list current and historic FIRMs, Flood Insurance Study, LOMCs, and more Site address: www.msc.fema.gov MSC site is currently undergoing upgrades and

changes

http://www.msc.fema.gov/


Enter address

or

Click on Search All Products


Select page size

Move highlighted box to select area to include in FIRMette

Select Scale and Title Block

Choose FIRMette format – either PDF or TIF


FIRMette image will appear; select open file

Print

Sample FIRMette

PIQ


National Flood Hazard Layer (NFHL)

Products and Services 1. NFHL GIS Data 2. FEMA MSC Site 3. Utility files for viewing the NFHL WMS with

Google Earth™ 4. MapViewer – Web and related reports


Google Earth

Google Earth • The FEMA NFHL utility allows use of Google Earth to view

custom combinations of flood hazard information. NFHL includes: flood zones, floodways, BFE lines, cross

sections, LOMC, FIRM boundaries, panel number, etc. https://hazards.fema.gov/femaportal/wps/portal/NFHLWMSkmzdo

wnload


FEMA GeoPortal

http://fema.maps.arcgis.com

http://fema.maps.arcgis.com/


Can be based on recorded deed or recorded plat

Must be from the County, not from a title company

Recorded Deed

Legal Description of a Deed


Legal Description from Deed

Lot 16, Block 3 Kingsborough Subdivision Filing No. 6, as described in the Warranty Deed recorded as Reception No. 02143120, in the Office of the Register of Clerk and Recorder, Arapahoe County, Colorado


Legal Description of a Plat


Description of portion of property above 1% annual chance flood elevation and accompanying map (one must be certified by a professional surveyor or engineer) Certified elevation for lowest point within metes and

bounds The metes and bounds description must match that of

the map

Requirements for Metes and Bounds


Metes and bounds map or description must be certified


Descriptions are incorporated into legal description with phrase:

• “… the portion is more particularly described by the following metes and bounds”

The MT-EZ and the MT-1 instructions contain examples of the standard metes and bounds description

Metes and Bounds


Map and written description do not match Topographic map submitted shows portion of metes and

bounds below BFE Metes and bounds are not certified No tie-in to Point of Beginning Starting and ending points do not come together May cause issues with lenders for insurance purposes Point of Commencing not displayed on the map

• Point of Commencing not a definable point

Common Problems of Metes and Bounds


Metes and Bounds Determination


Tax Assessor’s Tax Map


Required for most requests where property is located in floodway

Must be certified Must include scale, North arrow,

and vertical datum May be required for a submittal for

an Out-As-Shown submittal

Survey and/or Site Plan


What is the Elevation Certificate Used For?

The Elevation Certificate is an administrative tool of the National Flood Insurance Program (NFIP) and is to be used to provide elevation information necessary to:

• Ensure compliance with community floodplain management ordinances • To determine the property insurance premium rate • To support Letter of Map Change (LOMC) requests Use of this certificate does not provide a waiver of the flood insurance

purchase requirement Only a LOMC can issue a determination document that removes the

Federal mandate for a lending institution to require the purchase of flood insurance


LOMA Review by FEMA

FEMA is required to notify the applicant in writing within 60 days form the date of receipt of all data Requesters may check on status of all Letter of Map

Change requests by contacting the FEMA Map Information eXchange toll-free at 877-FEMA MAP (336-2627).


Once you get a determination, make sure you read the entire document.


Letter of Map Revision Based on Fill

Revision to the SFHA with no change to the BFE In areas with special flood hazard, it may be feasible to

elevate areas with fill above the BFE


If structure is involved: LAG and lowest floor ≥ 1 percent annual chance

flood elevation Community must sign the Community

Acknowledgement of Fill form Fill must be engineered

− Compaction − Erosion protection

Criteria for LOMR-F


What about Basements and Crawlspaces?

Any area of the building having its floor subgrade (below ground level) on all sides is considered a basement, unless it meets the definition of a crawlspace. The construction of a residential building in an identified SFHA

with the lowest floor below the BFE is a violation of the floodplain management requirements set forth in CFR 60.3(c)(2) Basements below the BFE are only allowed in communities

that have obtained a basement exception from FEMA. Floodproofed non-residential basements are allowed.


What about Basements and Crawlspaces?

Technical Bulletin 11-01


Diagram 9 and Technical Bulletin 11-01

•Per Technical Bulletin 11-01, some distinguishing features are:

• The interior grade of the crawlspace cannot be more than 2 feet below the LAG

•Shown as item D in the diagram on the left

•The difference between the crawlspace elevation and that of bottom of floor joist cannot exceed 4 feet

•Shown as item L on above diagram •This limitation will prevent crawlspaces from being converted into habitable spaces •The height limitation was determined using engineering analyses and building code requirements for flood hazard areas (page 7 of Technical Bulletin 11-01)

•Further restrictions apply and should be referenced to Technical Bulletin 11-01 •This pertains more to community compliance and documentation


BFE

LOMR-F


LOMR-F Data Requirements

In addition to LOMA Data requirements, need: • Completed MT-1 Form 4 (Community

Acknowledgement Form) • Appropriate Fee • If applying for a CLOMR-F, need ESA

documentation


ESA Compliance

ESA compliance must be documented to FEMA prior to the issuance of all CLOMR-Fs (required for all requests received on or after October 1, 2010). FEMA must receive confirmation of ESA compliance from the U.S.

Fish & Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS), collectively referred to as “the Services”.

Once the required ESA documentation is received, the data will be sent to the FEMA Area E PAM for concurrence. Once concurrence is received from FEMA, processing of the case can resume.

Acceptable documents demonstrating ESA compliance include the following:

• Incidental Take Permit • Incidental Take Statement • “Not likely to adversely affect” determination from the Services, or • Documentation that the project has “No Effect” on listed species or critical habitat


Zone AO

For a property located in Zone AO, the characteristics of the Zone AO area shown on the NFIP map will determine the appropriate methodology to be used to develop the BFE for the property.

If the flooding is conveyed by the street, provide the highest top of curb or crown of street elevation along the property line and add the depth of flooding to determine the BFE

If the entire property is inundated by the SFHA and the flow is not conveyed by the street, add the depth of flooding to the average lot elevation

If the property is partially inundated by the SFHA and the street does not convey the flow, add the depth of flooding to the lowest lot elevation

Along with the information required above, sufficient certified topographic information, including flow paths, to show that the structure is located on high ground relative to the depth of flooding is required


Additional Data

In certain instances, additional data that are not referenced on the MT-1 or MT-EZ forms may be required

• Grading plans, building permits, cross sections, etc.


Online LOMC

Can be used to request Amendments or Revisions. Online LOMC replaces the use of the MT-1, MT-

EZ or MT-2 paper forms. Although it speeds the time to submit an

application, it does shorten the actual processing time. Unlike the eLOMA, anyone can utilize the online

LOMC when submitting an application.


Why use the Online LOMC?

Submit, pay and upload all data through one online platform. Save information online and finish applying at

your convenience. Manage multiple LOMC requests with one login. Check their application status in real-time. Efficiently communicate with LOMC processing

staff.


eLOMA vs. Online LOMC


Data Requirements by LOMC Type

LOMA LOMR-F CLOMA CLOMR-F

Property Information Form X X X X

Deed or Plat X X

Tax Map X X X X

FIRM X X X X

Elevation Information X X X X

Processing Fee X X X

Community Acknowledgment Form

X X

ESA Documentation X


LOMC Required Fees

Requests for Single-Lot, Single-Structure Map Change

Paper Form Fee Online LOMC Fee

Single-Lot or Single-Structure LOMA Free Free

Single-Lot/Single-Structure CLOMA and CLOMR-F

$600 $500

Single-Lot/Single-Structure LOMR-F $525 $425

Single-Lot/Single-Structure LOMR-F Based on As-Built Information (CLOMR-F previously issued by FEMA)

$425 $325


LOMC Required Fees (cont.)

Requests for Multiple-Lot/Multiple-Structure Map Changes

Paper Form Fee Online LOMC Fee

Multiple-Lot/Multiple-Structure LOMA Free Free

Multiple-Lot/Multiple-Structure CLOMA $800 $700

Multiple-Lot/Multiple-Structure CLOMR-F and LOMR-F

$900 $800

Multiple-Lot/Multiple-Structure LOMR-F Based on As-Built Information (CLOMR-F previously issued by FEMA)

$800 $700


Concerns

The National Flood Insurance Program: The MT-1...

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