Letter of Map Revisions – MT-2s · 12/10/2019  · MT-2 Application Forms and Instructions. MT-2...

Letter of Map Revisions – MT-2s

Cooperating Technical Partners Information Exchange

ASFPM Flood Science Center December 10, 2019

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Additional Logistics

ASFPM Mapping and Engineering Standards Committee

Cooperating Technical Partners Subcommittee

Co-chairs: • Brooke Seymour, P.E., CFM - bseymour@udfcd.org

Mile High Flood District• Maria Lamm, CFM - coxm@dnr.sc.gov

South Carolina Department of Natural Resources

Goals:• Identify common concerns• Provide opportunities for information exchange• Identify training needs• Promote and document the value of CTPs

Agenda

• Introduction - Alan Lulloff

• Types of revisions: LOMR, CLOMR, PMR - Ben Kaiser

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits - Brooke Seymour

• Questions/Discussion

Introduction to Letter of Map Revisions – MT-2s

Alan Lulloff, P.E., CFMASFPM Flood Science Center

Ben Kaiser, P.E., CFM AECOM

Brooke Seymour, P.E., CFMMile High Flood District

Agenda

• Types of revisions: LOMR, CLOMR, PMR

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits

• Questions/Discussion

Amendments (MT-1s)

• Specific Structure/Property

• Effective BFE

• FEMA issues letter/document

Revisions (MT-2s)

• General Area of Floodplain

• New analysis to change BFE

• FEMA issues letter/document & revision to FIS/FIRM

Letter of Map Change(LOMC)

Letter of Map Change(LOMC)

MT-1s• Letter of Map Amendment – LOMA

• Letter of Map Revision Based on Fill – LOMR-F

• Conditional LOMA and Conditional LOMR-F (CLOMA/CLOMR-F)

MT-2s• Letter of Map Revision – LOMR

• Conditional Letter of Map Revision – CLOMR

Letter of Map Change(LOMC)

Conditional Letter of Map Revision (CLOMR)

• CLOMRs are for proposed projects

• FEMA’s comment on the effects that a proposed project would have on the FIRM

• Does not revise FIRM

• Must be followed by a LOMR request when project is complete

• Not a permit

Letter of Map Change(LOMC)

Conditional Letter of Map Revision (CLOMR)

What’s in a CLOMR?

• Project description

• FEMA’s comment on proposed project

• Comparison of changes

• LOMR submittal requirements

• Community information

Part II – Overview of Program Implementation

44 CFR 60.3(c)(10)

• Zone AE

• No Floodway

• BFE increase > 1.00 foot

Must consider the cumulative effect of the proposed

development, when combined with all other existing and anticipated development

Part II – Overview of Program Implementation

44 CFR 60.3(d)(3)

• Encroachment in Floodway

• BFE increase > 0.00 foot

Letter of Map Change(LOMC)

Letter of Map Revision (LOMR)What is a LOMR?

• Shows changes in BFEs, floodplains & floodways.

• Revises the FIRM/FIS report, but does not republish the effective FIRM Panel & FIS report

• Basis of LOMR request

• More detailed analysis

• Reflect constructed project

• Natural changes

• Update/Error correction

Letter of Map Change(LOMC)

Letter of Map Revision (LOMR): What’s in a LOMR?

Cover Letter

Determination Document

Annotated FIRM

Annotated FIS Tables

Annotated FIS Profiles

Letter of Map Change(LOMC)

Letter of Map Revision (LOMR)Why submit a LOMR?

• Better or more detailed analyses than the effective

• Updated hydrology

• Additional hydraulic information

• No previous study

• Physical Changes

• Projects

• Natural changes

• Map updates/Reissuance

Large Revisions

Revisions >3 Full FIRM Panels Monitored as Potential:

Physical Map Revision (PMR)

• FEMA review of hydrologic and hydraulic analyses and mapping completed by the community

• Republishes FIRM and FIS• Resolves protests and technical appeals• Revalidates LOMAs and LOMR-Fs as necessary

316-PMR

• Review of large revisions through the MT-2 process• Only provides comments on the revised H&H and mapping,

does not republish FIRM/FIS.• Strongly recommend coordination with FEMA Region

LOMR vs. PMR

LOMR:• Smaller Scale (<3 panels)

• Faster

• Less Expensive

• Limited Distribution (annotated regulatory products)

PMR:• Extensive Revisions (>3 panels)

• Longer Processing Time

• More Expensive (depends on Regional funding)

• Large Distribution (republishes full regulatory products)

Agenda

• Types of revisions: LOMR, CLOMR, PMR

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits

• Questions/Discussion

NFIP Regulations

• To outline steps a community needs to take to assist FEMA’s effort in providing up-to-date identification and publication of flood hazard maps

• Chapter 44 of the Code of Federal Regulations (44 CFR)• Part 60• Part 65• Part 72

• Obtaining the Regulations• Regulations can be downloaded at:

https://www.fema.gov/media-library/assets/documents

NFIP Regulations – Part 60

• Provides Floodplain Management Criteria for Flood-prone areas

• Legally-enforceable requirements applied uniformly across community

Section 60.3

Floodplain Management Criteria of Flood-prone Areas

• Applies to the Community’s level of ordinances • 60.3(a), (b), (c), (d), (e), (d&e), (f)

• These paragraphs build and relate to each other

• Applies to each designated flooding source on the Community’s FIRM/FHBM

NFIP Regulations – Part 60

Section 60.3

Floodplain Management Criteria of Flood-prone Areas

• 60.3(a) – No SFHAs defined & No FHBM/FIRM

• 60.3(b) – Approx. (A zones) areas on FHBM/FIRM

• 60.3(c) – BFEs on FIRM

• 60.3(d) – Floodways on FBFM/FIRM

• 60.3(e) – Coastal (V zones) on FIRM

• 60.3(f) – Restoration (AR zones) on FIRM

NFIP Regulations – Part 60

Roles/Responsibilities of Communities

• Permits for all proposed development

• Building sites reasonably safe from flooding

• Structures to be elevated above BFE

• Prohibit encroachment in a Zone AE that will increase BFEs more than 1.0 foot - 60.3(c)(10)

• When a floodway is not established

• Prohibit encroachment in the floodway - 60.3(d)(3)

NFIP Regulations – Part 60

Roles/Responsibilities of Communities• Reasonably Safe from Flooding

• Assured by signing MT-2 Form 1

• Technical Bulletin 10-01

• https://www.fema.gov/media-library-data/20130726-1511-20490-3169/tb1001.pdf

• Maintenance of Channels and Structures

• Communities to verify that the flood carrying capacity of any altered watercourse is maintained

• Regulation 60.3(b)(7)

NFIP Regulations – Part 60

CLOMR/LOMR State and Local RequirementsState Approval

• R5 – IL, IN, MI, MN, and WI

• R7 – IA Floodway revisions

• Check with your state

State and local regulations

• Can be more restrictive than the federal standards

• Check with your state

• Coordinate with the community on what they require

NFIP Regulations – Section 65.3

Requirement to Submit New Technical Data

• A community’s BFEs may increase or decrease from physical changes affecting flooding.

• A community must notify FEMA within 6 months of the changes.

NFIP Regulations – Section 65.4

Right to Submit New Technical Data

• A community has a right to request changes to any information on the FIRM.

• Requests for changes to effective maps, except for those initiated by FEMA, must be initiated by a community’s CEO or CEO’s designee.

NFIP Regulations – Section 65.5

Revision to SFHA Boundaries with No Change to BFE Determinations

• In SFHAs (except V Zones and floodways), it may be feasible to elevate areas with fill above the BFE with exception to areas subject to alluvial fan flooding.

• LOMR-Fs are processed under provisions of Section 65.5

NFIP Regulations – Section 65.6

Revision to BFE Determinations

(a) Data required for a request to revise BFEs

• Items 1-15 required for CLOMR/LOMR submittals

(b) Correcting BFEs

(c) Changed physical conditions

• Affecting both hydrologic (c)(1) and hydraulic (c)(2) conditions

(d) Incorporating improved data

(e) Incorporating improved methods

NFIP Regulations – Section 65.7

Revision of Floodways

• Copy of public notice distributed by the community stating intent to revise the floodway must be submitted, or

• Statement by the state/community that it has notified all affected property owners and affected adjacent jurisdictions

NFIP Regulations – Section 65.8

Review of Proposed Projects Conditional LOMR (CLOMR)

• Data requirements same as LOMR

• As-built information not applicable, since project is proposed

• Some of the applicable regulations

• 65.5, 65.6, 65.7, 65.8, 65.12

NFIP Regulations – Section 65.10

Mapping of Areas Impacted by Levee System

• Design criteria (freeboard, closures, embankment protection, foundation stability, interior drainage, etc.)

• Operation plans and criteria

• Maintenance plans and criteria

• Certification requirements

NFIP Regulations – Section 65.11

Evaluation of sand dunes in mapping coastal flood hazard areas

• Considers storm-induced dune erosion potential for primary frontal dues

• Does not apply to artificially designed/constructed dunes that are not well established

• Establishes criteria for primary frontal dunes as effective barriers to base flood storm surges and associated wave action

NFIP Regulations – Section 65.12

Revisions Involving Encroachments to Floodways or Base Floodplains

• An evaluation of alternatives that would not have caused the BFE increase

• Individual legal notice to all impacted property owners

• Certification that no structures are impacted by the BFE increase

NFIP Regulations – Section 65.12: What is an increase in BFE?

Example:

• Effective BFE = 102

• Duplicate Effective BFE = 102

• Corrected Effective BFE = 101

• Pre-project BFE = 100

• Post-project BFE = 101

Does project cause an increase?

Poll Question

Any method, in addition to guidance, that helps to

meet or exceed Risk MAP standards.

Agenda

• Types of revisions: LOMR, CLOMR, PMR

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits

• Questions/Discussion

MT-2 Application Forms and Instructions

MT-2 Submittal Requirements

Project Narrative• Describe the project area & what work was done

• Describe the objective of this LOMC (ex: establish BFEs in a previous Zone A)

• Explain engineering judgement, including model input variables, model progression (effective » pre-project » post-project), unique/complex aspects of analysis, etc.

• Provide explanation for any fee exemption or special response requested on MT-2 Forms

Failure to identify basic components of the revision will require clarification to your reviewer, and may delay the overall processing time

MT-2 Submittal Requirements

Hydrology and Hydraulics Revision

Hydraulics:

• https://www.fema.gov/hydraulic-numerical-models-meeting-minimum-requirement-national-flood-insurance-program

Hydrology:

• https://www.fema.gov/hydrologic-models-meeting-minimum-requirement-national-flood-insurance-program

Before you start, ensure you are using a model on the list of FEMA approved models

MT-2 Submittal Requirements

Hydrologic/Hydraulic Models:• Provide digital (executable) version of the model

• Document input variables in the report (ex: manning’s-n, vertical datum conversions, soil types, rainfall depths, etc.)

• Submit appropriate as-built or proposed plans to verify structures in model (certified & datum listed)

• Recommended to list vertical datum and details in the description box

MT-2 Submittal Requirements

Hydraulic Model Progression1. Duplicate Effective Model: A reproduction of the Effective

model covering the area of revision. (Contact FEMA engineering library or community)

2. Corrected Effective Model: Used to correct errors in the Duplicate Effective model. Must not reflect any man-made physical changes since the date of the Effective model.

3. Existing/Pre-Project Conditions Model: Reflects current conditions/terrain. Used to evaluate actual impacts of the project.

4. Revised/Proposed/Post-Project Conditions Model: Incorporates the physical changes to the model.

Good to describe changes between modelsin Project Narrative

MT-2 Submittal Requirements

Hydraulic Model Requirements• CFR 44 § 65.6(a)(2): When BFEs established, a revised analysis

must tie-in vertically within 0.5-ft at upstream and downstream ends.

• CFR 44 § 65.6(a)(8): A revision must study the same recurrence intervals as studied in the effective FIS (0.2%, 1%, 2%, 10%).

• Unless basis of request is new methodology or it can be shown that effective methods are inappropriate, revision should be made in the same model type as the effective.

• For requests where an executable effective model is available, the revision should be incorporated into that model and not truncated to the revision area.

MT-2 Submittal Requirements

Hydrologic Analyses• All backup calculations (Tc, CN, regression eqns.,

etc.)

• Supporting data (soil types, land use, gage data)

• Certified topographic drainage area map

• Ensure change in hydrology is significant (>5%)

• Appropriate level of detail:• Gage analysis (best)• Rainfall Runoff• Regression (lowest detail)

Revised hydrology should be as good or better than the effective analysis

MT-2 Submittal Requirements

Topographic Work Map• Certified (signed, sealed,

dated)

• Effective floodplain delineations

• Revised floodplain delineations

• Graphical tie-in

• Topography: Use best available. Must be as detailed or better than effective.

• Vertical Datum, Scale, North

LOMRs - submit digital mapping files associated to work map (GIS or CAD)

MT-2 Submittal Requirements

Annotated FIRM• Obtain effective

FIRM

• Overlay revised delineations

• Show floodplain tie-in

• Maintain scale and title block of FIRM

As-built Plans

Levees

Accreditation Requirements - Listed in 44 CFR 65.10• 65.10(a) – General Requirements

• 65.10(b) – Design Requirements

• 65.10(c) – Operations Plans

• 65.10(d) – Maintenance Plans

• 65.10(e) – Certification Requirements

Operation and Maintenance (O&M) Plans

• Dams / Detention Ponds

• Accredited Levees

• Coastal Structures

MT-2 Submittal Requirements

Property Owner Notification• Notification may take the form of individual notifications,

or newspaper notifications.

Floodway:

For floodway revisions, individual notifications must either be sent on community letterhead, or a statement provided by community official that everyone affected by floodway revisions has been notified.

*Newspaper notification still acceptable.

CLOMR:

If 65.12 is required, individual notifications are mandatory.

Property owner notification templates available in MT-2

Instruction package

65.12 Requirements

• CLOMR Only

• When proposed projects are not in compliance with 60.3(c)(10) or 60.3(d)(3)

• An evaluation of alternatives that would not have caused the BFE increase

• Individual legal notice to all impacted property owners

• Certification that no structures are impacted by the BFE increase

• Items required in Zone A when increase > 1.0’

Endangered Species Act (ESA)

• CLOMRs Only• If Federal Action Agency:

• “No Effect” made or concurred by the fed. agency

• “Not Likely to Adversely Affect” determination with concurrence of the Services

• Biological opinion with “no jeopardy” determination

• A copy of the federally issued permit

• If no Federal Action Agency:

• No potential for “Take” exists. The requester will be responsible for the potential for take determination.

• If a “Take” will or has a potential to occur, they can consider contacting the Services to discuss potential project revisions to eliminate the “Take.”

• Incidental Take Permit

MT-2 Fees*

* Subject to change

Agenda

• Types of revisions: LOMR, CLOMR, PMR

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits

• Questions/Discussion

Common Issues - General

• MT-2 Forms missing or not completed properly

• Community/Stateconcurrence not obtained

• Multiple communities

• No report narrative

• Fee not submitted

• No as-builts or proposed plans

• Vertical datum not referenced

• Incorrect effective data

• Inadequate notifications

Common Issues

Mapping

• Doesn’t match model results

• Insufficient topo

• No tie-in

• Missing key item(s)

Hydrology

• Model/method not FEMA approved

• Drainage area map missing or inadequate

• Backup data/calcs not submitted

Hydraulics

• Boundary conditions

• Structures not matching plans

• Floodway issues (encroachments, surcharges)

• BFE tie-ins

Poll Question

Which of these is not typically required to support a LOMR request?

MT-2 Forms

Hydraulic Analysis

Topographic Workmap

As-built plans

Property Owner Concurrence

Agenda

• Types of revisions: LOMR, CLOMR, PMR

• Applicable regulations and policies

• Submittal requirements

• Common issues/mistakes

• Mile High Flood District LOMR review process and benefits

• Questions/Discussion

Letter of Map Revision (LOMR) Review Partners Program

Alan Lulloff, P.E., CFMASFPM Flood Science Center

Ben Kaiser, P.E., CFM AECOM

Brooke Seymour, P.E., CFMMile High Flood District

Mile High Flood District

• 1,608 square miles

• 3,500 stream miles

• 3 million people

• 7 Counties

• 35 Municipalities

What is a Cooperating Technical Partner (CTP)?

• Communities, regional agencies, state agencies, tribes and universities that partner with FEMA to help ensure that the flood maps are accurate, current, and reflect local conditions.

• Requires a formal partnership agreement with FEMA.

• Key goals of the program:

1. Leverage partnerships

2. Reduce the impacts of flood hazards

3. Empower communities

LOMR Review Partners Program

MT-2 Letters of Map Change

Conditional Letters of Map

Revision (CLOMRs)

Letters of Map Revision (LOMRs)

LOMR Review Partners Program

Originally Letter of Map Change (LOMC)

Delegation Pilot Program

20011 CTP

Regional

2006Add 1

State & 1 Local-level

Partner

2009Add 4 more CTPs

2018Program

expansion approved

LOMR Review Partners Program

On behalf of Federal Emergency Management Agency (FEMA)

Objective and Consistent

Maximum Revisions for Funding

Local Resource for Assistance

LOMR Review Partner Support

Training

Guidance & Standards

FEMA Headquarters

FEMA Region

PTS Contractor

Colorado Water Conservation

Board

Other CTPs

Compensation

• Processing costsDirect Costs

• Staff• ResourcesIn Kind Service

• Local knowledge• Customer Service and Accessibility• Enhanced process

Intangible Benefits

Local Knowledge

• Often already familiar with projects due to the local permitting process

• CLOMR may alert us to a new project that has not gone through the local review process

• Help communities coordinate between multiple active LOMCs, floodplain studies and PMRs

• Knowledge of nearby developments and District capital and maintenance projects

Accessibility and Customer Service

• Established local relationships

• Local information resource for communities

• Effective models available locally

• Accessibility for meetings with requestors and communities, which results in more complete submittals and fewer additional data requests

Enhanced Process

• Developed LOMC guidelines

• Standardization

• Quality control checks for common items

• Informal exchange of data

• Additional data request timeline reminders

• CLOMR follow-up letter summarizing steps for subsequent LOMR submittal to become effective

• Efficiency for LOMRs based on CLOMRs we’ve previously processed

LOMR Review Partners

Public service with intangible benefits for the CTP, FEMA, requestors and local governments

FEMA

CTP

Enhanced Map

Revision Process

Questions&

DiscussionAlan Lulloff, P.E., CFMalan@floods.org

Ben Kaiser, P.E., CFMbenjamin.kaiser@aecom.com

Brooke Seymour, P.E., CFMbseymour@udfcd.org

ASFPM Flood Science Center

Cooperating Technical Partners

Information Exchange

Poll Question

Please rate this webinar.

• Certified Floodplain Managers are eligible for 1 CEC for participating in this webinar.

• You must have registered individually and indicated you are a CFM at time of registration.

• Eligibility for CEC is dependent on your participation in poll questions and time spent viewing the webinar, as determined by the webinar software.

Attending this webinar in a group setting or only viewing the recording is NOT eligible for CEC.

Continuing Education Credits

• To suggest future CTP webinar topics, please contact Alan Lulloff at alan@floods.org or type a suggested topic into the Questions panel today.

ASFPM CFM CECs will be automatically applied.

Certificates of Attendance will be emailed, please contact cfm@floods.org with any certificate issues.

• Follow-up email with link to slides and recording will be sent next week.

Thank You for Joining Us!

Closing Comments