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Fill or Backfill?
Would you, or better yet FEMA, consider the below addition to be built on fill when applying for a LOMA? The original house is built on a basement (natural grade) and then later an addition was added on to the back, built on a crawl space, as seen below. I typically don’t look at backfill against the foundation as fill, but this example seems to stretch normal backfill.
I can call FEMA, but I usually have to call 2 or 3 times to take an average on the responses from the agents and end up even more confussed.
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