When removing a portion of a property do you use the BFE at the upstream location of the portion or the parcel when filling in the Lowest Lot Elevation box. FEMA instructions are vague on this I think. There is no structure on the subject property and the actual lowest lot elevation is in the Colorado River.
Thanks.
I believe they want the lowest elevation of the portion to be removed. Poorly worded, but that is FEMA.
Thanks Paul. We have 2 CFMs in house and they recall that during their training FEMA discouraged the LOMR-F for a portion of a lot. FEMA stated it was better to just apply for the structure. In this case we have no structure yet.
I would use the BFE at the upstream edge of the portion to be removed and the lowest elevation would be the lowest elevation on the portion to be removed.
The last one of these that I worked on was a portion of a lot in a commercial subdivision. I initially submitted a copy of the subdivision plat and the FIRM with the portion to be removed highlighted and a metes and bounds description of the portion of the lot to be removed from the SFHA. The reviewer was unable/unwilling to comprehend how the M&B fit with the plat despite the fact that the two were identical with the exception of the 15' strip along one side that I omitted because it was below the 500 year flood elevation. I ended up having to produce an exhibit showing the entire lot with the portion to be removed from the SFHA hatched so she could follow the calls from the M&B description without having to think about what she was reading. I placed a note on the exhibit stating that the hatched portion of the lot was above the 0.2% Annual Chance Flood Elevation as determined at station x+xx on creek y on FIS xxxx dated xxxxx.
Thank you Stephen. That is pretty much what I was planning and expecting. It is nice to know that it worked form someone.
I have previous experience with a CLOMR-F for a portion of a property. That took about 3 months to get approved. I do not recommend that process!
I would use what your local floodplain administrator recommends...
The BFE's shown on the panals are generally rounded to the nearest foot and are OK to use for certificates. For any type of LOMR you need to use the elevation shown on the flood profile map which shows the BFE's rounded to the nearest tenth.
Whoever reviews the LOMR-F request will be comparing your fill elevations vs. the profile map and if too low it will be denied.
If you are audited on an ELOMA you will find that the FIS should be used in all instances. That is just one of the inconsistances within FEMA as some instructinos state you should use the published BFEs. Thanks for your comment.
Check out Online LOMC
From the FIS profile, I determine the BFE 'gradient' from the upstream limits of the property to the downstream limits. I place this on my 'certified' topographic survey of the land (or fill) and write a metes-bounds description of that portion of land above this line. Then, at FEMA's demand, I remove the bounds calls and submit only a metes description.:pissed:
Oh...and hope the FEMA reviewer knows about FIGURE 6-20 or FEMA's BFE determination will not match yours.
DDSM:beer:
I would never use the BFE shown on the panel in this area. At times they are feet different than the FIS. It would be very easy to cost a homeowner thousands a year in excess premiums or put an insurer in the spot of collecting preferred premiums for an extreme risk. Either way you can be on the hook for some big bucks...
