LOMR/CLOMR (MT-2) Submittal and Review Process Bosulu Lokulutu Compass Region 6 MT2 Lead August 11, 2017
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 2
Letter of Map Change - LOMC MT-1 = No BFE Change MT-2 = Revisions to Flood Modeling 3
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. 4
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 5
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 6
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 7
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 8
MT-2 Application Forms 9
Hydrologic Computations Digital Hydrology Models (FEMA Accepted) and All Back Up Information must be submitted FEMA Accepted Models: https://www.fema.gov/hydrologic-models-meetingminimum-requirement-national-flood-insurance-program 10
Hydraulic Computations Digital Hydraulic Models (FEMA Accepted) and All Back Up Information must be submitted FEMA Accepted Models: https://www.fema.gov/hydraulic-numerical-modelsmeeting-minimum-requirement-national-flood-insuranceprogram 11
Topographic Work Map 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. August 18, 2017 12
Annotated FIRM 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. 13
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. 14
Certified As-Built Plans 15
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. 16
Endangered Species Act (CLOMRs) 17
Endangered Species Act (CLOMRs) 18
Review Fee Payment 19
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-applicationforms-and-instructions 20
MT-2 Review Process 158 Cases Currently in Review in Region 6 285 Cases in Region 6 since 2015 0 Cases in Region 6 since 2015 33 Cases in Region 6 since 2015 21
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 22
Timeline On Average, map revision takes 6 12 months to be issued Appeal Period conducted (90 days) Becomes Effective 4.5 Months after Issuance 23
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 24
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 25
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 26
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) 27
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 MT-2 Reduced Time to Issuance since March 2015 28
Questions? Presenter Contact Information: Bosulu Lokulutu, CFM MT-2 Lead Compass PTS A&E AECOM 972-735-7093 Bosulu.lokulutu@aecom.com 29