Map Appeals and Amendments
Letters of Map Amendments
A Letter of Map Amendment (LOMA) is a letter from FEMA confirming that a portion of the map is incorrect. For an individual lot (or multiple lots) where a structure is shown in the flood hazard area on FEMA's floodplain maps and the flowing are valid:
- Better elevation information shows the structure is higher than the Base Flood Elevation (BFE), or 1% annual chance flood elevation, or
- A better aerial photo or other information shows the structure is not actually "in" the flood hazard area. This is also referred to as a Letter of Map Amendment - Out as Shown (LOMA-OAS)
- No fill has been placed to elevate the building or adjacent to the building (after the date of the first FEMA floodplain map showing the structure in a flood hazard area)
When to pursue a LOMA?
Eligible for LOMA. The Lowest Adjacent Grade is higher than the Base Flood Elevation.
Eligible for LOMA, even if the structure has a basement, if the Lowest Adjacent Grade (LAG) is higher than the Base Flood Elevation (BFE). Only eligible if no fill has been placed after the first FEMA floodplain map showing that site in a floodplain.
Not eligible for LOMA. The Lowest Adjacent Grade would be at the lowest support for the deck or stairway. Since the Lowest Adjacent Grade is below the Base Flood Elevation the structure is not eligible. It would be eligible if the deck is removed or detached from the house.
Types of Letters of Map Amendments
Traditionally, the application for most LOMAs include a field survey to verify the Lowest Adjacent Grade (LAG) is above the Base Flood Elevation (BFE). However, there are a couple of abbreviated methods which can be utilized depending on the scenario
- Letter of Map Amendment - Out as Shown (LOMA-OAS) would be used when a GIS-based floodplain map overlaid on top of an aerial photo plainly shows that a structure is completely out of the floodplain. This method would require some form of elevation data for the structure.
- Letter of Map Amendments using LiDAR utilizes a streamlined method for elevation data in Minnesota (except in Pine and Stearns Counties).
- eLOMAs are available to licensed surveyors and PEs, and offers an opportunity to get a LOMA from FEMA in less than a day. This option is available for detailed study areas and A Zones where more accurate Base Flood Elevations have been determined.
- Conditional Letter of Map Amendments (CLOMA) would be used to show that a 100-year flood if built as proposed.
There is no fee for FEMA to review a LOMA. However, there will likely be costs associated with obtaining the data needed, or for assistance completing the application. If any part of the structure or lot requested to be removed from the FEMA mapped floodplain is in the floodway, a community official will be required to sign a Community Acknowledgement Form.
Letter of Map Revision Based on Fill
A Letter of Map Revision Based on Fill (LOMR-F) is for individual or multiple lots when there has been fill placed to elevate the building or adjacent to the building (after the date of the first FEMA floodplain map showing the structure in a floodplain).
To be eligible for a LOMR-F:
- the lowest natural ground touching the building (including decks and stairway supports) is above the base flood elevation (BFE) and
- the lowest floor (including basement or crawl space) is above the base flood elevation (BFE).
There is a $425 fee for FEMA to review the LOMR-F application. This is in addition to any costs associated with obtaining the data needed, or for assistance completing the application packet.
Conditional Letter of Map Revision based on Fill
A Conditional Letter of Map Revision based on Fill (CLOMR-F) is used to show that a proposed structure that is to be elevated on fill would not be inundated by the 100-year flood if fill is placed on the parcel as proposed or the structure is built as proposed.
Apply for a LOMA or LOMR-F
- MT-EZ Form - For Single Lot Letters of Map Amendment, no fill involved
- MT-1 Forms - For Multi-Lot Letters of Map Amendment and Letters of Map Revision Based on Fill
- MT-2 Forms - For changes to FIRMs based on updated data or changes to the Base Flood Elevation or floodway.
- Online Letter of Map Change (LOMC) application - For LOMAs, LOMR-Fs and LOMRs:
- Can be used by anyone, including landowners. Alternative to filling out and mailing the paper MT-EZ, MT-1 or MT-2 forms and attachments and is processed faster.
- eLOMA - For LOMAs
- Available to licensed surveyors and professional engineers only. Can only be used for LOMAs (not LOMR-Fs or LOMRs) where there is detailed Base Flood Elevation data. Can be processed in a matter of minutes.