LOMR/CLOMR (MT-2) Submittal and Review Process

August 11, 2017

Bosulu Lokulutu

Compass Region 6 MT2 Lead

Overview

• Letter of Map Changes (LOMC)

• MT-2 Submittal and Review Process

• FEMA Process

• Timeline

• Common Issues

• Tips for Smooth LOMR Approval Process

• Compass Region 6 RSC and MT-2 Team

• Questions

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Letter of Map Change - LOMC

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MT-1 = No BFE Change MT-2 = Revisions to Flood Modeling

Letter of Map Change - LOMC

• A Letter of Map Amendment (LOMA) is an official amendment, by letter, to an effective National Flood Insurance Program (NFIP) map. A LOMA establishes a property's location in relation to the Special Flood Hazard Area (SFHA). LOMAs are usually issued because a property has been inadvertently mapped as being in the floodplain, but is actually on natural high ground above the base flood elevation.

• A Letter of Map Revision (LOMR) is a document that officially revises a portion of the effective NFIP Map according to requirements and procedures outlined in Part 65 of the NFIP regulations. A LOMR allows FEMA to revise flood hazard information via a letter without physically revising and reprinting the entire FIS and map panel or panels.

• A Conditional Letter of Map Revision (CLOMR) is FEMA's comment on a proposed project that would, upon construction, affect the hydrologic and/or hydraulic characteristics of a flooding source and thus result in the modification of the existing flood hazards.

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Letter of Map Change - LOMC

• Amendments: Requires submittal of MT-1 Forms

Structures or legally defined parcels

Not for properties in alluvial fan areas

Not for properties and/or structures that have been elevated by fill placed within the regulatory floodway, channelization projects, bridge/culvert improvement projects, or other flood control improvements

Does not typically involve an engineering analysis

Does not involve changes in BFE, floodplain, and / or regulatory floodway

• Revisions: Requires submittal of MT-2 Forms

Not usually lot or structure specific

Typically involves hydrologic and hydraulic (H&H) analysis

Does involve changes in BFE, floodplain, and/or regulatory floodway

Bases on existing or as-built conditions for LOMR and proposed conditions for CLOMR

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Letter of Map Change - LOMC

• When should a LOMR be submitted?New or More Detailed Analyses

Updated hydrology

Additional hydraulic Information (more cross sections, etc.)

New topographic information

No previous detailed study (Existing Zone A)

Physical Changes Resulting in floodplain modifications

Projects (bridge/culvert, channelization, levee, etc.)

Physical changes (fill, grading, etc.)

Natural changes (erosion, subsidence, bridge/culvert removal,etc.)

Error Corrections

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Letter of Map Change - LOMC

• When should a CLOMR be submitted? Proposed projects modifying the hydrology/hydraulics of the floodplain. Evaluate increases. Increases are determined by comparing pre-project (existing

conditions) and post-project (proposed conditions) model

• If… Encroach upon the floodway and cause an increase > 0.00 foot per 44 CFR 60.3

(d)(4) Encroach upon floodplain and cause increase >1.00 foot per 44 CFR 60.3 (c)(13)

• Then… Projects that produce increase in BFE greater than the maximum allowed must

fulfill the following requirements per 44 CFR 65.12:

Alternatives analysis and feasibility Legal Notice to impacted property owner Certification that no structures impacted

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MT-2 Submittal - Required Items

Completed MT-2 Application Forms

Hydrologic Computations

Hydraulic Computations

Topographic work map

Annotated FIRM map

Certified as-built plans or survey

Endangered Species Act (CLOMRs only)

Property Owner notifications for Flood Hazard Revisions (if required)

Review Fee Payment

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MT-2 Application Forms

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Hydrologic Computations

• Digital Hydrology Models (FEMA Accepted) and All Back Up Information must be submitted

• FEMA Accepted Models:

– https://www.fema.gov/hydrologic-models-meeting-minimum-requirement-national-flood-insurance-program

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Hydraulic Computations

• Digital Hydraulic Models (FEMA Accepted) and All Back Up Information must be submitted

• FEMA Accepted Models:

– https://www.fema.gov/hydraulic-numerical-models-meeting-minimum-requirement-national-flood-insurance-program

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Topographic Work Map

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A topographic work map, certified (signed, stamped and dated) by a Professional Engineer that shows the labeled contours for the entire area to be revised along with the effective and revised floodplain and floodway delineations and the location of all cross-sections within the revised area.

Annotated FIRM

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An annotated FIRM map where the FIRM map has been annotated to show the area to be revised and the revised floodplain and floodway delineations along with how the revised delineation of the floodplain will tie-in to the effective delineation at the boundaries of the revised area.

Certified As-Built Plans

• Certified as-built plans or survey for all hydraulic structures that are new or modified since the effective model, or are being modeled using different geometry than the effective model.

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Certified As-Built Plans

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Endangered Species Act (CLOMRs)

• Visit U.S. Fish & Wildlife Service Environmental Conservation Online System (ECOS) website at http://ecos.fws.gov/ecp/

• Identify project location and receive an official species list (pursuant to 50 CFR 402.12) of threatened and endangered species that should be considered when evaluating the potential impacts of a project.

• Obtain no effect or no take statement from the service that proposed project will not have an impact on any endangered species.

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Endangered Species Act (CLOMRs)

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Endangered Species Act (CLOMRs)

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Review Fee Payment

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MT-2 Submittal Process

• Mail application to the follow address:

LOMC Clearinghouse

3601 Eisenhower Avenue, Suite 500

Alexandria, VA 22304

• Or online submittal by visiting FEMA website at www.fema.gov/online-lomc

• MT-2 Application Forms and Instructions can be accessed by visiting FEMA website at www.fema.gov/mt-2-application-forms-and-instructions

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MT-2 Review Process

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0 Cases in Region 6 since 2015

33 Cases in Region 6 since 2015

285 Cases in Region 6 since 2015

158 Cases Currently in Review in Region 6

MT-2 Review Process

Common items checked during initial review:

Fees

MT-2 Forms (including required signature)

Models and backup

Maps

Notifications

Common items checked during detailed review:

Technical review of Hydrologic and Hydraulic Analyses (H&H)

H&H compliance with guidelines and specifications

Map and Model agreement

Potential floodplain management violations

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Timeline

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• On Average, map revision takes 6 – 12 months to be issued

• Appeal Period conducted (90 days)

• Becomes Effective 4.5 Months after Issuance

Common Issues

• Community Acknowledgement

- Multiple community LOMRs

- Corporate Limit changes (Annexation)

• Missing Notifications

- Increase in SFHA and/ or BFE

- Floodway public notice

- Regulation 65.12 (CLOMR Requirements)

• Incorrect fees

• No backup data provided

• No As-Built provided

• Incorrect Effective information (Current Effective, Effective LOMR)

• Unaccepted models/methodology

• Work map not legible or missing crucial required information listed on the MT-2 Application Form 2, Section C

• Revised floodplain does not tie-in to effective floodplain and/ or profile

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Common Issues

• Project built in Special Flood Hazard Areas without CLOMR and/or LOMR approval may jeopardize a community standing with the National Flood Insurance Program (NFIP). – Coordination with FEMA Headquarters and Regional Office

– Coordinate with Floodplain Administrator on submitting no rise analysis.

– A deficient no rise analysis may result in violation.

– Violation resolution: Mitigate increase, return to previous condition, probation/suspension of community from NFIP

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Tips for Smooth LOMR Approval Process

• Encourage the requesters prior to submit applications to:– Closely review the MT-2 application instructions

– Provide project narrative and back-up data

– Conduct Internal Agreement Checks

• Encourage communication between MT-2 analysts and requesters via phone or e-mail to address issues that can be resolved without sending a formal letter to request additional information

• MT-2 analysts have to complete their review within 90 days from the date the case is assigned to them. Within those 90 days, they will either have to provide comments by sending a formal letter requesting additional data to the requester or issue the determination document to complete the case. The requester in turn has 90 days to respond to our comments.

• We limit our formal request for additional data to two letters

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Tips for Smooth LOMR Approval Process

• We are currently working on setting up a LOMR Collaborative Commitment Processing (LCCP) pilot to expedite the review of cases that are not complex and will meet the following criteria:

- Zone A

- Follow-up to CLOMR

- Single flooding source with partial panel(s)

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Facts about Compass MT-2 Team • Compass started receiving MT-2 cases on March 1, 2015

• Dallas production center has 4 engineers who are fully dedicated to processing Region 6 MT-2 cases and providing support to RSC as needed.

• Compass MT-2 team closely shares workload across all production centers to ensure timely processing and consistent methods and high quality

• Summary of cases worked on by Compass between March 1, 2015 and June 30, 2017

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MT-2 Reduced Time to Issuance since March 2015

Questions?

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Presenter Contact Information:

Bosulu Lokulutu, CFM

MT-2 Lead Compass PTS A&E

AECOM

972-735-7093

Bosulu.lokulutu@aecom.com