I'm a little confused about what properly is considered to be the lowest adjacent grade. I'm working on a site, where the interpolated base flood elevation is 835.3'. The horizontal limits of the flood zone clearly encompass the entire lot as well as the structure which is built on it. Based upon adjacent recovered reference mark, I determined that the top of the bottom floor (basement) is 836.0'. Just outside the basement (through the sliding glass doors) the elevation drops to a stone patio, above which is an attached deck. The elevation of the stone patio is 835.3' (equal to BFE). Then, moving down towards the river, I reach the structural posts which hold up the deck, which sit on square concrete pilings, the bottom elevation of which is 833.8'.
Looking at the Elevation Certificate, it appears as if FEMA distinguishes between the the lowest adjacent grade next to building (in C2.f.) and the lowest adjacent grade at lowest elevation of deck or stairs including structural support (in C2.h.). In this case, I have considered the "building" in C2.f. to be the main part of the house (excluding decks) - i.e. that part of the house which has a full concrete foundation, and the LAG near it seems to be the elevation of the patio = 835.3'. Whereas C2.h. seems to be 833.8'
Now the owner is considering whether to apply for an exemption from the requirement to obtain flood insurance on the structure, and I am reviewing the MT-EZ application, in order to be able to advise him in that respect. The MT-EZ application, in contrast to the Elevation Certificate, appears not to make a distinction between the LAG near the building and the LAG near the deck posts, but rather asks for the LAG "to the structure (elevation of the lowest ground touching the structure including attached patios, stairs, deck supports, or garages)". Which in this case would appear to be equal to 833.8', which is below the base flood elevation.
The purpose of my post is to ask whether I've got it right, and to ask whether FEMA will allow a LOMA for the structure as a result of this application even though a portion of the deck structure lies below the BFE.
I'm open to any suggestions. Thanks.
In your photos, show both, describe which you used as LAG in the "Comments" section.
Considering how close the base flood elevation is to the lowest floor elevation and further contemplating the accuracy of the flood elevation I would be very cautious in making a recommendation against flood insurance
If you look at the MT-EZ instructions, "General Instructions - Section B", the Elevation Cert can be submitted in lieu of Section B of the MT-EZ form. Therefore, the EC trumps Section B of the MT-EZ.
Letter of Map Amendments Determination Documents (Removal) that I have received from FEMA listed the deck support elevation as the LAG. Therefore, it would appear to me they do consider deck support elevations.
I, too, would be very careful. How solid are your benchmarkS (emphasis on plural)? You're splitting hairs.
You have been provided wise advise above. Now, recommend to the client that he buy flood insurance whether someone else requires it or not. I have some horror stories to tell about silly people thinking they don't need coverage.
> You have been provided wise advise above. Now, recommend to the client that he buy flood insurance whether someone else requires it or not. I have some horror stories to tell about silly people thinking they don't need coverage.
I know what you mean - working with it today. Flood insurance is cheap if you're
not in the flood plain! You might still flood and your insurance company will
be real quick to say it was flood damage. Even for a water leak or a blown out
window.
We just had major floods - I am high and dry - peace of mind is good.
Just my 2 cents..
Thanks very much for the feedback. I agree that caution is good advise, and I have urged the client to consider the value of flood insurance in this case.