I prepared an elevation certificate for a client trying to get financing for a home in a Zone A flood zone, located next to a creek. The house is a diagram 7, with the next higher floor being elevated on an enclosure. The garage is located in the front of the enclosure, where the LAG was observed at the entrance. The HAG was observed in the rear of house on top of the large amount of fill that was placed against the foundation. Well this created around 4.6' of difference between the HAG and lowest floor, which has resulted in one of the higher flood insurance quotes I've heard of approaching $6,000. After some correspondence the client wrote an email that my survey has put them in a floodplain and jeopardize the purchase of the home and demanded that I revise the survey to reflect the natural grade before the fill was placed. I tried to explain to them that per FEMA the LAG and HAG has to be observed at existing grade against the foundation, be it fill, natural grade of a finished surface, but they weren't having it. I told them they need to find another surveyor and we parted ways. This morning I was reviewing the certificate and noticed that Section E for Zone A's stated that the measurements should reflect natural grade if available. I called FEMA, which usually results in more confusion, to ask about the "natural grade" statement and they stated that all measurements should reflect existing grade and would say nothing about natural grade. Did I screw my former client?
The 4.6' difference would not be the problem, the BFE to the LAG I'm thinking is the problem. Did you get a BFE from the local yocal or did you established one on your own using the FEMA Zone A methods? If a BFE was not established then the insurance person would really have no clue on what to do, but charge the max.
In my opinion your certificate is correct. As far as I know the only time you don't use the fill for HAG is in an "AO" zone.
That is the way I read it too.
A BFE was developed by approximation based on assumed elevations for the building permit back in 1999, but it was based on the old 1983 FIRM. I was under the impression that approximated BFE's could only be used for developing a site, getting a building permit, and not for EC's to rate insurance or to support a LOMA? Per FEMA's website Zone A,(No BFE), uses the depth of the lowest floor in relation to the HAG to rate the policy.
If the BFE was 2" below the garage floor, this would not be an issue. How does the BFE relatye to the grades you took.
I think you completed the EC correctly but do need, if you haven't, to include some details with your comments. As you stated for insurance rating purposes in an A Zone the rating is based on the relationship between the reference level and the HAG. If the fill was placed after the completion of the last Flood Insurance Study, technically after the creation of the first NFIP map showing the subject area to be located within a SFHA, then the fill is not natural grade.
If the fill was placed after the date noted above then an artificial grade has been created and gives the false impression that the natural grade is much higher, relative to the reference level, than it would actually be without the fill. Think of it this way, if the structure was located in Zone AE with a detailed study and you were attempting to complete a LOMA you would not be able to use the top of the fill as the elevation for the immediately adjacent grade. You would have to use the natural grade, i.e. the grade prior to placement of the fill. Otherwise you would have to complete a LOMR-F. In your case if the top of fill elevation is not natural grade it is skewing the rating. Plenty of pictures, topographic mapping showing the natural grade, and any supporting evidence available would be sufficient to allow the rating to be based on the original (natural) grade rather than the fill elevation.
As is often the case, you will probably have to go the extra mile and walk the insurance rep through the details. They're probably assuming the fill is natural grade until you tell them, and demonstrate to their satisfaction, that it isn't.
You seem to have more knowledge than any of the FEMA Map Specialists I've spoken with. The previous effective FIRM was 1983 the home was constructed in 1999 and I assume the back fill was place then. The house has since been foreclosed on and a new FIRM was issued in 2011. I alway include pictures of all 4 sides of the house and surrounding grade and attach a drawing of the elevation survey. I even put a note in the comments section that said the HAG was observed at fill against the foundation and doesn't represent the surrounding grade.
Stupid people do stupid things
Why are so many people willing to put so much dollar value in harm's way for no good reason? Idiots in my opinion. And, I've taken many of their dollars from them.
> I prepared an elevation certificate for a client trying to get financing for a home in a Zone A flood zone, located next to a creek. The house is a diagram 7, with the next higher floor being elevated on an enclosure. The garage is located in the front of the enclosure, where the LAG was observed at the entrance. The HAG was observed in the rear of house on top of the large amount of fill that was placed against the foundation. Well this created around 4.6' of difference between the HAG and lowest floor, which has resulted in one of the higher flood insurance quotes I've heard of approaching $6,000. After some correspondence the client wrote an email that my survey has put them in a floodplain and jeopardize the purchase of the home and demanded that I revise the survey to reflect the natural grade before the fill was placed. I tried to explain to them that per FEMA the LAG and HAG has to be observed at existing grade against the foundation, be it fill, natural grade of a finished surface, but they weren't having it. I told them they need to find another surveyor and we parted ways. This morning I was reviewing the certificate and noticed that Section E for Zone A's stated that the measurements should reflect natural grade if available. I called FEMA, which usually results in more confusion, to ask about the "natural grade" statement and they stated that all measurements should reflect existing grade and would say nothing about natural grade. Did I screw my former client?
For a Zone A, I believe that "natural grade" means just that (i.e. before fill was placed). If that was a Zone A when they built that house, they should have been instructed to build the lowest floor to be at least 2 feet above the highest adjacent grade (pre-fill) to meet minimum NFIP requirement. An elevation certificate done today should reflect that as well otherwise it would show the building not being built in compliance with NFIP regulations hence a sky high insurance rate.
The Bow Tie Surveyor
I can't tell from the photo, but does it have enough flood vents?
I suppose that could be determined by interpolating around the perimeter of the fill. Is this what should have been done?
No vents
> I suppose that could be determined by interpolating around the perimeter of the fill. Is this what should have been done?
I believe so. I did one in a unnumbered Zone A, but with no enclosure for a metal building construction. When I did the final elevation certificate, I used the highest grade from the original topo survey before they put the fill pad on. This basically documented to the County that they did elevate the lowest floor to at least 2 feet above the highest ground to meet the NFIP requirements.
Do you think that with interpolation it would put your c2a about 2 foot above your interpolated HAG? If you do it that way, I would make sure you explain that in the comments section. Also, I looked at the Flood Insurance Manual, and it instructs the insurance agent to "submit for rate" on any Post-FIRM buildings with basement, enclosure, crawlspace, or subgrade crawlspace (like diagram 7) in an unnumbered Zone A. Usually "submit for rate" is not what homeowner wants to hear concerning flood insurance. I imagine it is still going to be pretty high.
The Bow Tie Surveyor.
Well, isn't that the real problem? No vents in a Zone A or AE = extremely high insurance rate, every time.
The client was in a hurry because of the financing they were trying to get to purchase the home. After the insurance quotes came back high they sent me an email about jeopardizing their purchase which was followed by a heated phone call that ended with me telling to find another surveyor. So at this point I'm just trying to further educate myself. I made multiple phone calls to FEMA and talked with their map specialists and was instructed that the grades needed to be measured from the top of the fill. I never feel very confident after talking with them as they always sound confused and have to put me on hold to ask someone else.
To answer your question I'm not sure if it would make the 2 feet, but it would be close. They did say that the certificate was submitted to FEMA for the quote. I believe that I included enough photos and notes that they would of commented if the certificate was wrong or need more information, at least I hope.
In lieu of evidence to the contrary the insurance company will assume that the fill is natural grade and therefore that the figures in the EC should be based on measurements from the top of the fill if that is the HAG. Nevertheless, it appears that in this case the fill is not natural grade and that the rating should actually be based on the HAG using the natural grade prior to placement of fill.
In a perfect world the needed topographic information would have been gathered prior to construction and placement of fill. On several occasions I've done as you mentioned and interpolated the "before fill" natural grade using the surrounding area. I still had to provide verification and was lucky to have some topographic mapping with a contour interval that proved useful in delineating the natural grade and documenting my interpolation. If this situation repeats in the future you'll be more successful if you're able to talk directly with the insurance agent actually doing the rating. On rare occasions you get lucky and deal with one that actually understands the NFIP and proves an invaluable asset in providing guidance regarding the information needed to provide an accurate rating.
Typically, and unfortunately, it appears the land surveyor was consulted after the fact and too late to provide sound advice. It's always easier to shoot the messenger than admit any responsibilty for having been hoisted oneself by one's own petard.
> The client was in a hurry because of the financing they were trying to get to purchase the home. After the insurance quotes came back high they sent me an email about jeopardizing their purchase which was followed by a heated phone call that ended with me telling to find another surveyor. So at this point I'm just trying to further educate myself. I made multiple phone calls to FEMA and talked with their map specialists and was instructed that the grades needed to be measured from the top of the fill. I never feel very confident after talking with them as they always sound confused and have to put me on hold to ask someone else.
It is a bit confusing, because in section C the LAG and HAG are to be measured to the "finished" grade (i.e. on fill if there is any). But in section E they want the LAG and HAG to the "Natural Grade, if available". To me they don't differentiate this well enough and if you get some FEMA rep who is not to familiar with the nuances of elevation certificates, you could easily get a wrong answer.
The Bow Tie Surveyor