Lone Star Club-CS 940225February 25, 1994
Mr. John Robinson
Lone Star Country Club
1849 East Belt Line Road
Coppell, Texas 75019
RE: Property at the southeast corner of Belfline and Ledbetter
Dear Mr. Robinson:
This letter is written as a follow-up to previous conversations concerning floodplain issues
associated with the referenced property. As stated, if there were any misunderstandings
between yourself and the City or FEMA during the revision of the map, it is a situation that
should be able to be corrected through a process called Letter of Map Amendment (LOMA).
The City would be happy to discuss the process of a Letter of Map Amendment with you
and/or assist you in applying for a Letter of Map Amendment from FEMA. However, the
actual process does not require City involvement but a small fee may be required for FEMA
to process the request. I have included information on the process to be followed when
requesting a LOMA. It is my understanding that FEMA can provide a rapid turnaround on the
review of any documentation submitted for a Letter of Map Amendment.
If you would like to discuss the process further or if you would like assistance in applying for
a Letter of Map Amendment from FEMA please contact me at (214) 393-1016.
Sincerely,
Kenneth M. Griffin, P.E.
City Engineer
cc: Jim Witt, City Manager
Bob Hagar, Attorney
file&griffin/robinson.Itt
FIA- 12 January 1990
SupersedesFIA- 12 September 1985
_ FEDERAL EMERGENCY MANAGEMENT AGENCY
Appeals, Revisions,
and Amendments
to Flood Insurance Maps
A GUIDE
FOR COMMUNITY OFFICIALS
January 1990
Chapter 6
The following determinations may be made for
Map Amendments structures and parcels of land under the map
amendment process:
The accuracy of the floodplain boundaries · Out of the SFHA as shown on the
shown on the NFIP maps depends, in part, on the effective FEMA map. No amendment to
scales at which the maps are prepared and by the map is necessary.
the accuracy of available topographic data. Map
users may find it difficult to determine whether · Out of the SFHA because the structure or
a specific structure or parcel of land is within the parcel of land is above the BFE
SFHA. Also, small areas of high ground may be (inadvertent inclusion). FEMA will issue
included in the SFHA because they are too small a LOMA to exclude the existing structure
to be shown to scale. When this happens, or the parcel of land from the SFHA.
structures or parcels of land may be
inadvertently included in the SFHA when the · In the SFHA because the structure or
map isprepared, parcel of land is below the BFE. If
necessary, FEMA will issue a LOMA to
Because the requirement for the purchase of include the structure in the SFHA.
flood insurance and the Federal and local
regulations governing construction in the SFHA Only the effective NFIP map may be amended by
are important to persons who own or plan to a LOMA.
build structures, FEMA has developed the map
amendment process. Under this process, HOW tO Request an Amendment
property owners may request that FEMA
determine whether specific structures or legally
described parcels of land are in the SFHA and, if Any owner or lessee of property may request
necessary, issue a Letter of Map Amendment that a determination be made concerning a
structure or parcel of land and that, if necessary,
(LOMA). FEMA issue a LOMA. Because such requests
concern structures and parcels of land that were
Background inadvertently included in the SFHA and do not
involve recent alterations of topography or
Under the map amendment process, FEMA will result in significant changes to the flooding
make determinations for single or multiple information depicted on the NFIP map, theymay
structures on one or more lots and for parcels of be submitted directly to FEMA and are not
land that can be legally described. In making subject to the review and approval of the
such determinations, FEMA will use the best community. However, if the structure or land
available data (usually the effective NFIP map) was also included in a floodway, removal of the
and information provided by the requestor structure or land from the floodway must be
concerning the locations and elevations of with community concurrence and is
structures or the locations and elevations of accomplished under the map revision process.
legally described parcels of land. (see Chapter 4.)
The map amendment process is applicable only Requests for determinations concerning
to requests for determinations based on multiple structures on multiple lots should be
topographic conditions that existed on the sent to the FEMA Headquarters office at the
effective date of the first NFIP map that showed following address:
the structure or parcel of land to be within the
SFHA. All other requests for determinations will Federal Emergency Management Agency
be processed as requests for Map Revisions. (See Federal Insurance Administration
Chapter 4.) Office of Risk Assessment
Technical Operations Division
500 C Street, SW., Room 422
Washington, D.C. 20472
35
Requests for determinations concerning single 5. A signed statement asserting the
structures on single lots and parceis of land accuracy of the information submitted
should be sent to the appropriate FI:MA
Regional Office for processing. The Regional GeneraITechnical Guidance
Offices and their addresses are listed in
Appendix D. When developing technical supporting data, the
requestor should consider the following poi nts:
Required Supporting Data
· If an entire legally described parcel of
The requestor must provide data that are land is shown to be inadvertently
sufficient to allow FEMA to verify the location of included in the SFHA, the LOMA will be
the structure or parcel of land and that the issued for the parcel.
structure or parcel of land is not subject to
inundation during the base flood. For · If the request is for more than one lot or
determinations for structures, the following structure, the requestor must provide an
data must be submitted: effective FIRM or FHBM, or a
photographic copy of it, on which the
· A copy of the recorded deed with the legal metes and bounds of the property,
legal description of the property and the including each lot, have been drawn as
deed book volume and page number, accurately as possible. The map
bearing the seal of the Recorder of submitted must bear the seal of a
Deeds registered professional engineer or
licensed land surveyor to certify that the
· A copy of the recorded plat showing property is correctly located on the NFIP
both the location of the property and map based on the legal description of
the plat book volume and page number, the property.
bearing the seal of the Recorder of
Deeds. If the property is not recorded on If a floodplain boundary runs through a
a plat map, the requestor must provide lot or tract of property, the location(s) of
copies of a tax map or other suitable the structure(s) on the lot or tract should
maps to help FEMA accurately locate the be accurately drawn. A photocopy of
property, the NFIP map is unacceptable because
the size of the map may be distorted.
· A topographic map, certified as-built by
a registered professional engineer or · In some instances, FEMA may need
licensed land surveyor, showing additional data to make a
structure locations (if applicable), determination. These data may consist
ground elevations, and the elevations of of, but are not limited to, certifications
the lowest finished grades adjacent to by a registered professional engineer or
the structures (if applicable). If the licensed land surveyor as to the type of
request concerns an undeveloped parcel structure and whether it is elevated on
of land, the submitted data must include posts, piers, pilings, or frontal sand
the elevation of the lowest ground point dunes, or a hydraulic analysis of the
within the parcel, flooding conditions.
· Data to substantiate the BFE. These data · To support a request involving fill that
may be taken from an authoritative was placed before the effective date of
source, such as the COE, USGS, SCS, any the first NFIP map showing the structure
other Federal agency; State and local or parcel of land to be within the SFHA, a
water resource or planning requestor may be required to submit a
departments, a FEMA FIS, or information
prepared by a registered professional
engineer.
36
certification to that effect. Th~s ® Structures that have been elevated
certification may be made by a above the BFE on posts, piers, or pilings
community official, registered cannot be excluded from the SFHA if any
professional engineer, or licensed land portion of the structure (~ncluding the
surveyor, posts, piers, or pilings) is still in the SFHA
· When the effective NFIP map is an · If a structure and/or parcel of !and has
FHBM, BFEs will not be shown. The been inadvertently ;ncluded in both the
requestor may either determine an SFHA and the regulatory floodway, it
approximate BFE using standard will be excluded from the SFHA and
engineering techniques or request that floodway by a LOMR under the map
FEMA determine an approximate BFE. revision process rather than by a LOMA.
FEMA will either check the BFE (See Chapter 4.)
determined by the requestor or, if
necessary, determine an approximate · Neither structures nor parcels of land
BFE using the supporting data for the will be removed from an alluvial fan
FHBM or the best available data. SFHA -- usually designated Zone AO,
with a depth and a velocity shown --
When a Preliminary or Revised regardless of the elevations of the
Preliminary FIRM has been issued and lowest floor, lowest adjacent grade, or
the BFEs shown on the FIRM have been lowest grade point. No determinations
made final by FEMA, those BFEs must be can be made for such structures or
used as best available data. parcels of land unless it is demonstrated
through the map revision process
· When the effective NFIPmapisa FIRM, (Chapter 4) or the appeal process
FEMA will base the determination (Chapter 3), as appropriate, that alluvial
concerning the structure or parcel of fan flood hazards do not exist at the site
land on the BFEs shown on the FIRM. in question.
Determinations cannot be made using
other flood elevations, unless FEMA first · Neither structures nor parcels of land
revises the effective FIRM to incorporate will be removed from an SFHA subject to
the new elevations. (See Chapter4.) velocity hazards, designated Zone V1 -
V30, VE, or V, regardless of the
· When the effective FIRM shows an elevations of the lowest floor, lowest
average depth of flooding rather than a adjacent grade, or lowest grade point.
BFE, the determination will be made by No determinations can be made for such
comparing the elevation of the lowest structures or parcels of land unless the
grade adjacent to the structure to the zone designation is changed. Changes
elevation of the surrounding terrain to zone designations shown on effective
where sheetflow would be conveyed. If maps are made under the map revision
the difference in these elevations is process(Chapter4).
equal to or greater than the flood depth
shown on the effective FIRM, such that When a new or revised NFIP map becomes
floodwaters cannot be conveyed to the effective for a community, that map supersedes
structure, the structure can be excluded all LOMAs previously issued for properties i_n
from theSFHA, that community. Once a LOMA has been
superseded, it is no longer effective. Therefore,
· When the SFHA on an effective FIRM is a requestor who wishes a previously issued
designated Zone A, no BFEs are shown. LOMA tO remain in effect must request that it be
In this situation, a BFE may be re-issued. FEMA will base its determination
determined by the same method as that concerning such requests on the latest effective
used when the effective NFIP map is an NFIP map. If that map presents new flood
FHBM. hazard information for the area where the
property in question is situated, the
37
determination stated in the previously issued data w~ll be sent to the requestor. Th~s !attar w,!!
LOMAcould be modified, allow the requestor 30 more days to prowde the
necessary data. If the data are r~ot provided
When FEMA is preparing and intends to publish with.n the allotted t. me, FEMA w. II generally
a new or revised NFIP mao for a community, with suspend the process, ng of the request. If the
flood risk data developed by a map revision requested data are provicled, FEMA will
requestor or by FEMA as part of an FIS or RFIS, complete its review and issue the appropriate
FEMA may receive a request for a LOMA based LOMA.
on a portion of those data. FEMA can issue a
LOMA on the basis of such data but only as Generally, single-lot and single-structure LOMAs
described below, will be issued within 4 weeks of the date that all
the required supporting data are received.
· If the LOMA request involves property Multiple-lot and multiple-structure LOMAs will
shown in an SFHA designated Zone A or generally be issued within 8weeksof that date.
Zone V on the effective NFIP map, the
LOMR can be issued as soon as FEMA has When FEMA determines, from the legal
determined that the new flood risk data description or recorded plat, that the structure
are the best available for the area in or parcel of land is outside the SFHA shown on
question, the effective NFIP map, a LOMA will be issued
stating that the structure or parcel is "out as
· If the LOMA request involves property in shown."
an SFHA designated Zone Al-A30, AE,
AH, AO, Vl-V30, or VE on the effective When the elevation of the lowest grade
NFIP map, the LOMA will not be issued adjacent to the structure or the elevation of the
until the new or revised map has been lowest portion of a parcel of land is determined
issued in preliminary form, an appeal to be at or above the effective BFE, FEMA will
period has been held, all appeals have issue a LOMA stating that the effective map has
been resolved, and a final BFE been amended and that the structure or parcel
determination hasbeenmade, of land has been excluded from the SFHA.
Otherwise, the LOMA will state that the
In either case, however, the restrictions structure or parcel of land is below theBFEand,
described previously in this chapter for therefore, intheSFHA.
properties in Zones Vl-V30, YE, or V and
properties in alluvial fan SFHAs would still apply. A prevalent determination for both a LOMA and
(See the section entitled "General Technical a LOMR-Based on Fill is the "Partially Inundated
Guidance.") Structure Exempt" determination. This
determination means the structure has been
Map Amendment Procedures found to be above, and therefore out of, the
SFHA. However, the rest of the parcel of land is
still subject to flooding and is still in the SFHA.
After a request has been received, FEMA will
Therefore, any future improvements to that
acknowledge receipt of the request by letter to
the requestor. The acknowledgment letter will parcel would require an additional map change
request.
be accompanied by a checklist that identifies any
basic data the requestor may have neglected to
submit. If sufficient data have been provided When an effective NFIP map is amended by a
LOMA, the amendment is effective as of the
with the request, FEMA will review the request date of the LOMA. Copies of LOMAs that amend
and the supporting data. If any questions or
an effective map are sent to the CEO of the
problems arise during this review, FEMA will
work withtherequestortoresolvethem, affected community, the State coordinating
agency, and the Regional Office.
If the missing data identified on the checklist are
not provided within 30 days of the date of the
acknowledgment letter, a letter requesting the
38