Question for FEMA gurus.

If it makes sense to surveyors, it is nonsense as viewed by government employees who may lose their title after any election cycle.

Submit a LOMA with an EC and a cover letter that states that you checked with the following (ex. Municipality, Army Corps, Environmental Agency etc and a base flood elevation has not been determined. FEMA will make the determination and notify you with the outcome 

I would consider going through the process to place fill and get a LOMR-F as one option.  Get costs for all the options you laid out.  Then consider the calendar costs for each option.

As far as a map adjustment, none of the Zone A determinations we've done ever resulted in the map being adjusted. I've been told repeatedly by the local FEMA reps that I can just get a BFE from FEMA, so far that's never happened. Usually, we partner with an engineer who takes our X-sections and topo info and determines the BFE, writes up a complicated report and we file the data with FEMA. That satisfies FEMA and the lender but the maps all stay the same. 

We did one about a decade ago, a few years after the new maps were put on the GIS. The client's house was 15' above the flood plain, it is on a flat bench under the highway which is just east of the house, the creek 150' west of the house. The engineer stated that to get as high as the house the area west of the creek would need to flood the valley floor and climb up the west valley over 1500' west (this is a small creek with a drainage area blocked by a nearby ridge). It would need to be a biblical event. Then it would need to rise another 12' to climb up and over the highway like the Zone A was showing. Even elevations on Google clearly show it that way. After the engineer's report was filed with FEMA, maps, X-sections, details on the math used, FEMA accepted that the buildings were all clear. But the map hasn't changed.

It's different when we do a Zone AE, then the map gets adjusted and the area is removed. 

But our Zone A determinations are expensive, start about 6k and shoot up from there. 

If ever there was a class action lawsuit softball sitting up to hit it's the harm unprofessional Zone A mapping has caused landowners. If the determination isn't done under the rules and regulations governing engineering practices it should be treated as unlicensed practice and whoever is responsible should be liable for each instance of harm done. They shouldn't even be entered into the GIS, regardless what the bankers, regulators and realtors want. If they want flood plains on the mapping do the work and get them determined professionally. 

Posted by: @mightymoe

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In the late 1980's we did a subdivision near a creek. FEMA had no BFE's for this location and only a Zone A was determined. An engineer was hired and he determined the flood plain which was put on the plat. That flood plain was shown with bearings and distance ties to lot lines so it could be reproduced. After many complaints Zone As were removed from county mapping and life went on. An owner wanted to build near the flood plain and it was staked out and the house was constructed uphill from the staked line. 

Then in the 2010's after much back and forth FEMA released new mapping. Today that owner wants to re-finance and can't get a loan because the new Zone A in the county mapping GIS shows the house into the flood plain. 

Now the option is to locate the flood plain from the plat, get a new 88 elevation BFE from that and do an elevation cert from the platted flood plain. Or, hire a new engineer, redo the entire process and get the new BFE that way. From our experience the first engineer who did the flood mapping  is quite good at it. Floods we have seen where he did mapping are spot on. Of course the new Zone A is a joke, much like the previous one, some of the water course isn't even covered by the Zone A very near the house. 

So my question is: will FEMA accept the original flood plain if stated as platted, or does a new study need to be completed. This is a mountain stream, not subject to accretion or avulsion, it's remained in place since the 80's since the huge rocky bed isn't going anywhere, or at least we haven't had the 1000 year flood that might move something. 

For the record, I'm not a FEMA guru. With that written, I have had some limited experience in this area:

FEMA will not accept the "platted" flood plain without reviewing the engineer's work and receiving stamped and signed documentation. They will want to see the survey data, cross sections, calculations, etc. They may have questions, so it also helps if the engineer who did the work is still alive and available to communicate. The best approach for your client is to have a new flood study done by a PE and submit to FEMA all the documentation needed for a Zone AE flood plain determination. That will cast it in stone for time immemorial, or until the next revision to the flood mapping. When the revision is done, they will review the information in their records, and either recertify or revise the Zone AE boundaries, but at least it will retain the Zone AE designation with flood elevations.

@peter-lothian 

I think you're spot on, except getting A turned into AE probably won't happen at this location.

My original engineer is still breathing, but I don't believe he can help with this one. We are going to meet with the flood guy at the county, maybe he can push FEMA to accept the existing flood plain on the plat, one thing I do know it at least covers the actual water in the creek, unlike the Zone A on the GIS. 

Common sense should be allowed.  A couple had a small home on the bluff overlooking the river by more than 100 feet of elevation.  Their deed ran  to the center of the river.  The lender refused their loan application to add onto their home because a portion of their property was in the flood plain.  A second lender just laughed and then agreed to loan them the money immediately.

Posted by: @holy-cow

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Common sense should be allowed.

Nice to see common sense.  I have not found any of that at FEMA.  A not to recent example had our LOMA-F rejected because the existing parcel description was not a metes and bounds description.  It was a 100 year old parcel with numerous parcels broken off of it, added back in, etc...  I tried to explain that to them (when i say explain, i mean in written snail mail terms.  There is no emailing or calling FEMA.  All correspondence is via snail mail and took 3 months between responses).  Finally i just caved and created a GIS based legal of only bearings and distances so FEMA could check their box and process the application.

 if No BFEs Have Been Determined?

 Sometimes, BFEs for a certain SFHA have not yet been determined. FEMA will try to calculate the BFE when a 

LOMA application is submitted for properties of less than 50 lots or 5 acres.

https://www.fema.gov/sites/default/files/documents/fema_request-loma-lomrf.pdf

My thought is that the GIS in the county is the problem. Once the county signed off on a flood zone determination, which they did, then it's incumbent on them to honor that decision. Sooo, they should input the line from the plat that the county signed off on into the GIS for those lots and remove the line of the FEMA Zone A which doesn't even cover the creek near the lot in question. I'm going to petition them to adjust at least that line for the five lots it's shown on. Once that is done the house will be clear and they should have the result needed without any survey, elevation certificate, or report from an engineer.

It's an impressive effort by FEMA, there is a 200' long portion of the creek out of the Zone A as plotted in the GIS. That portion is across the creek and downstream from the house in question, some of the creek entirely exits the Zone. And that creek is where we surveyed it back in the late 1980's and stays in that position as you follow photos through the years. The new FEMA maps are 2010.

They are probably too tied in with FEMA to do it, but this isn't the only area where flood determinations needed to be done for development prior to the new mapping being released. As long as it's a Zone AE we have no problem with the FEMA maps, they work very well, some small exceptions but those can be taken care of with an elevation cert and possibly a map adjustment. These Zone A plots make an engineering study mandatory, but that was already done, it shouldn't be needed again. 

The flooding in 2007 peaked two feet higher than the BFE in many places.  At the same time, two rivers in the next county to the west had six feet and eight feet peaks higher than their BFEs.  We were in the later steps of finally getting new flood maps from FEMA.  They chose to ignore this new data as they decided they were too far along on the final blessing of the new maps.  So, 19 years later, we are still using BFEs that we expect to find substantially raised in another couple of years.  These rivers  flow eventually to the Arkansas River in Oklahoma.  Starting about six miles to the east of my house is the ridge separating the Arkansas River and Missouri River basins.  That water hits the Missouri River a short distance before the Missouri River joins the Mississippi River.  The Mississippi River should be called the Missouri River as the Missouri River is both longer and has more flow at the junction than the Mississippi River.

Posted by: @holy-cow

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The flooding in 2007 peaked two feet higher than the BFE in many places.  At the same time, two rivers in the next county to the west had six feet and eight feet peaks higher than their BFEs.  We were in the later steps of finally getting new flood maps from FEMA.  They chose to ignore this new data as they decided they were too far along on the final blessing of the new maps.  So, 19 years later, we are still using BFEs that we expect to find substantially raised in another couple of years.  These rivers  flow eventually to the Arkansas River in Oklahoma.  Starting about six miles to the east of my house is the ridge separating the Arkansas River and Missouri River basins.  That water hits the Missouri River a short distance before the Missouri River joins the Mississippi River.  The Mississippi River should be called the Missouri River as the Missouri River is both longer and has more flow at the junction than the Mississippi River.

Perhaps they did not ignore the new data. They might have determined that these floods resulted from a longer-period storm than the 100-year storm that the BFE is based on.

@peter-lothian 

The question came up many times during Town Hall type meetings held by FEMA when announcing the new flood maps.  The answer was always "No.".  They said FEMA would take that data into consideration for some future update.  Enough years have passed that the next round of new maps are almost here.  The "potential" new maps can be found online.  I own some lots in the nearby city that showed no flood plain in the current mapping.  The "potential" maps show a depth of roughly 18" across the lots.  That is no surprise to me as I have seen those lots completely flooded.  A few blocks away I own lots that a prior owner had raised to one foot above the BFE but never built anything.  They now (future) have about six inches of flood plain depth on them.  The 2007 flood was the only time when floodwaters overtopped a stretch of US Highway constructed about 1960.   The highway is effectively a dam for several miles before reaching the river bridge A large part of that city filled up like a bath tub in areas where flood insurance had never been a requirement.

Posted by: @holy-cow

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@peter-lothian 

The question came up many times during Town Hall type meetings held by FEMA when announcing the new flood maps.  The answer was always "No.".  They said FEMA would take that data into consideration for some future update.  Enough years have passed that the next round of new maps are almost here.  The "potential" new maps can be found online.  I own some lots in the nearby city that showed no flood plain in the current mapping.  The "potential" maps show a depth of roughly 18" across the lots.  That is no surprise to me as I have seen those lots completely flooded.  A few blocks away I own lots that a prior owner had raised to one foot above the BFE but never built anything.  They now (future) have about six inches of flood plain depth on them.  The 2007 flood was the only time when floodwaters overtopped a stretch of US Highway constructed about 1960.   The highway is effectively a dam for several miles before reaching the river bridge A large part of that city filled up like a bath tub in areas where flood insurance had never been a requirement.

That is astounding. It makes me wonder how they could have blown the flood modelling so badly. I know the models are not perfect, but I would expect them to be better than a foot-and-a-half off.

@peter-lothian 

This county has many miles of river levees designed to protect farm land.  This city has the highway mentioned that effectively works as a levee protecting the west half of the city (land sloping to west and southwest).  The east half of the city slopes to the east and southeast.  The east side is heavily dependent on local tributaries to set the maximum floods. Normally, what happens in time of major floods is that one or more blowouts occur somewhere in the ag levees.  In 2007, the railroad grade blew out as it crossed the flood plain south of the city allowing relief on the eastern side of the city, but, the highway had already overtopped and filled the bath tub on the west side of the city.  Within minutes, a convenience store, a grocery store, a church, a few small businesses and about 20 houses had about four feet of water inside.  That stretch of highway had never overtopped but the stretch south of the river bridge had overtopped in 1980 for the first time, spilling into ag land.  The only other time was in 2007.