I've read several threads in regards to LOMA projects in a Zone A with no BFE. There doesn't seem to be a consensus with some leaving the BFE blank and letting FEMA supply the elevation while others have an engineer perform calculations and determine a BFE. I have taken both approaches in the past.
My question is this. Has anyone filed a LOMA with no BFE (letting FEMA supply) had a negative determination and then refiled with their own BFE to challenge FEMA's negative determination?
Looking at it another way. Do you think FEMA is less likely to accept your calculated BFE after they have rejected a previous filing?
Hack
We have done a few and just fill the page 2 section out for A Zones with no BFE.
Or we just don't take them as we aren't going to charge enough to do a BFE determination.
Hack
We have had a three (out of ~100) come back as non-removals. In all three cases we supplied cross section and profile data of rhe flooding souce to FEMA. In all cases they have revised the BFE. In two cases that was enough for removal, in the other it was not.
That being said, I have not submitted a independently derived BFE after requesting one from FEMA.
Sent from my SM-G900P using Tapatalk
I have a client on the edge of A Zone A who would like to apply for removal. The hydrologic study to determine a BFE would be quite expensive. The cost effective way would be to apply with no BFE. If it is removed great. If not we can decide whether to spend the money for the study.
It is possible that your State has something within its internal bureaucracy akin to Division of Water Resources within the State's Department of Agriculture. Whatever the title, it will be the State entity charged with administering issues relative to both surface and ground water. Several bureaucrats will be assigned duties pertaining to flood plain issues. Find that department and you will probably find that they are recognized as the State source for vastly more specific information than what FEMA will admit to in their maps. But, FEMA will almost definitely accept their information as being reliable.
Holy Cow, post: 356087, member: 50 wrote: It is possible that your State has something within its internal bureaucracy akin to Division of Water Resources within the State's Department of Agriculture. Whatever the title, it will be the State entity charged with administering issues relative to both surface and ground water. Several bureaucrats will be assigned duties pertaining to flood plain issues. Find that department and you will probably find that they are recognized as the State source for vastly more specific information than what FEMA will admit to in their maps. But, FEMA will almost definitely accept their information as being reliable.
Hack if you are working in NH Jennifer Gilbert at DRED is the one to contact, she is the state flood plain manager. She is the one who turned me on to requesting a BFE from FEMA if she didn't have an alternate source.
We've fought the law and won a few times.
I first submitted one with enough rope to hang myself. And was told if it is up to them to determine it would be very conservative. They were right. I got the letter and they determined the BFE to be a few tenths higher than the LAG I provided. This was a property bordering a dry creek bed... It hadn't seen water in years. I traced it back to a sinkhole upstream and was able to get it overturned with photos and topography.
So we revised our approach. We'd try to get a determination without providing LAG, HAG, FFE etc etc to see if this would influence the result.
On another project, we questioned their calcs and data used to determine BFE. A downstream twin 36" CMPS appeared to be the issue. (Were used in the determination). Those CMPs had been replaced a few years prior with a standard box culvert, which of course, increased flow and reversed the outcome. We found this out by asking questions and investigation on the ground. We sized the culvert and provided pics to get the adjustment.
What we discovered as most will agree, we have eyes on the ground. It pays to take good notes, good topo and find the source and any restrictions that may influencing flooding and back flow. The individuals I spoke with divulged that they use standard calcs. and 20" pipe sizing for most areas that they don't have data on. (Zone A) This supports a conservative determination.
So feel free to ask away. You have more information at your disposal at the project than they do at their desk.