Vol. 21, No. 3 April 30, 2013


Fairfax County Process for FEMA LOMC

 

On March 22, 2013, Fairfax County issued a new Technical Bulletin to clarify that coordination with the county is required for any Federal Emergency Management Agency (FEMA) Letters of Map Change (LOMC) submittal.

In Fairfax County, any proposed use or development to occur within or adjacent to a FEMA Special Flood Hazard Area (SFHA) must demonstrate the effect of the project on the 100-year floodplain and its base flood elevations (BFE's). If a map revision is required, a request must be made to FEMA in the form of a LOMC to revise the SFHA and/or BFE's. Additionally, all LOMC requests to FEMA must be coordinated with the Fairfax County Stormwater Planning Division (SWPD), which includes providing all LOMC documentation to SWPD.

The Federal Government makes flood insurance available to those communities, such as Fairfax County, that participate in the National Flood Insurance Program (NFIP). To participate in the NFIP, communities must meet minimum federal floodplain management standards and coordinate with FEMA to develop a communitywide Flood Insurance Study (FIS) and associated Flood Insurance Rate Maps (FIRMs). The community must also regulate development within or adjacent to floodplains to ensure that all buildings are reasonably safe from flooding.

To do this, the community requires the developer to demonstrate that the project will result in either no rise in flood elevations (defined as no greater than a 0.1' increase) off the subject site or, when increases do occur, that there will be no adverse impact on off-site properties. When increases are allowed, floodplain mapping must be revised to reflect the new changes. The LOMC process is used to provide FEMA with the necessary data to update the community's floodplain maps to reflect such changes. In addition, the LOMC process may also be used to update the floodplain maps when corrections are needed or when more detailed data is available. In the Northern Virginia area, floodplain data is often outdated or does not accurately reflect current topographic conditions of individual properties and so the LOMC process is a necessary and important tool used to revise flood zones and elevations affecting a property.

LOMC is a general term that refers to any of the four types of letters issued by FEMA that reflects their official revision or amendment to the FIRM and FIS profile. These four types of LOMCs are:

1. Letter of Map Amendment (LOMA) – typically issued to make corrections in floodplain delineations when the scale of the original study was too large to reflect small areas of natural high ground that are above the BFE and inadvertently included in a SFHA
2. Letter of Map Revision based on Fill (LOMR-F) - similar to a LOMA, but used when fill is placed on a site to raise a portion of the property or a building above the BFE
3. Letter of Map Revision (LOMR) – an official revision to a FIRM to reflect changes to BFEs, floodplain boundaries or floodway boundaries
4. Conditional LOMCs – for a proposed project, FEMA will review the project to ensure that the proposed development, if built as proposed, would be in compliance with NFIP regulations and would warrant a LOMC after the project is completed.

For all communities that participate in the NFIP, all LOMC applicants are required to coordinate with the floodplain administrator for the affected community by having them sign either a Community Acknowledgment Form for LOMAs and LOMR-Fs or an Overview and Concurrence Form for CLOMRs and LOMRs confirming that the proposed work is acceptable to the community. In general, all communities in the Northern Virginia area require a copy of all LOMC submittal documents for their files, prior to providing the community approval necessary to process the request through FEMA. In accordance with the Fairfax County policy, any LOMC application for a site within the county must be coordinated with SWPD before being submitted to FEMA. The Fairfax County policy is simply clarifying that in order for the community to provide an approval signature on the required FEMA form for the LOMC submittal, electronic copies of all floodplain study reports or hydrologic/hydraulic models submitted to FEMA by a LOMC applicant must also be provided to SWPD concurrently.

For a better understanding of how a FEMA floodplain may be affecting your property or for more information regarding LOMC submittals, please contact Mike Marsala, Mark Headly, Frank Graziano, or Mike Rolband.