LOMRs represent the bulk of our business. However, most property owners, land developers, and even engineers don’t know what a LOMR is, much less how to go about performing one. Therefore, please see our brief tutorial below regarding the basics of LOMRs (click here for a list of Definitions of Commonly Used Terms and Acronyms in the Field of Floodplain Management).
What is a LOMR?
A LOMR (Letter Of Map Revision) is a detailed, technical application that is performed and submitted to the local Floodplain Administrator (FPA) and FEMA for review and approval. A LOMR changes one or more floodzones, Base Flood Elevations (BFEs), or Wave Crest Elevations (WCEs) on FEMA-issued Flood Insurance Rate Maps (FIRMs).
Why are LOMRs Feasible?
LOMRs change “V” floodzones to “A” or “X” floodzones, “A” floodzones to “X” floodzones, or reduce BFEs or WCEs. These changes show reduced risks for flood damage and yield corresponding reductions in flood insurance premiums. Unfortunately, many effective FIRMs in existence today that determine flood insurance rates contain floodzones that are erroneous or antiquated. Most Florida FIRMs were originally created using large-scale, county-wide data that did not incorporate fine or “site-specific” data into the modeling and mapping of the corresponding floodzones. Additionally, many Florida FIRMs are over ten years old, with some over thirty years old. The floodzones of these FIRMs are no longer accurate due to new construction and changes in land-use, shoreline location, and topography that have occurred since the FIRMs became effective. A LOMR revises the effective FIRM, changing floodzones and/or BFEs or WCEs, based on more accurate, site-specific data used in the modeling and mapping procedures. We have found that when a property is located within an inaccurate FIRM, a LOMR can be performed at least 75% of the time.
Why are you paying so much money for Flood Insurance?
Flood insurance is based chiefly on two criteria – what floodzone your property is located within, and the difference between the BFE/WCE and your structure’s lowest finished floor (in “A” floodzones) or lowest horizontal structural support beam (in “V” floodzones). Flood insurance has always been expensive for structures located within “A” and “V” floodzones, but annual rates have increased appreciably since 2008. These increases were due to an outstanding NFIP debt of several billion dollars, resulting from flood damages/claims caused by several hurricanes since 2004 – chiefly Hurricanes Katrina and Sandy. Hurricanes Harvey and Irma in 2017 added to this debt, which currently stands at just over $30 billion.
Because this debt has not been reduced over the past few years, flood insurance rates again substantially increased in 2017, and should continue to increase considerably in the near future. The Biggert-Waters Flood Insurance Reform Act of 2012 was passed into law effective July 2012. The main effects of this law include a loss of “pre-FIRM” rating status (higher “post-FIRM” rates to apply) to certain properties, a gradual phase-out of properties “grandfathered” into lower risk floodzones, and an increase in the maximum annual flood insurance rate hike from 10% to 18%. The end result will be steadily increasing flood insurance rates for most policy holders over at least the next several years.
How much money can you save with a LOMR?
Any property located in an “A” or “V” floodzone would benefit financially from a LOMR. Below are a few examples:
For Post-FIRM buildings/structures changed from within a “V” to an “A” floodzone, the corresponding annual flood insurance is typically reduced by about 10x. So, for example, if a Condominium is currently within a “V” floodzone and is paying roughly $200,000 annually for flood insurance, a LOMR that changes the floodzone to “A” would reduce the annual flood insurance premium to about $20,000 (save $175K annually).
For Post-FIRM, non-residential buildings/structures changed from within an “A” to an “X” floodzone, the corresponding annual flood insurance is reduced by about 30%. So, for example, if a Hotel/Resort is currently within an “A” floodzone and is paying roughly $50,000 annually for flood insurance, a LOMR that changes the floodzone to “X” would reduce the annual flood insurance premium to about $35,000 (save $15K) per year. However, since the Hotel would no longer be located within a Special Flood Hazard Area (SFHA), mandatory purchase of flood insurance would no longer be required. Thus, the Hotel would be free to discontinue the policy, thereby saving the full $50K per year.
For Pre-FIRM Condominiums changed from within a “A” to an “X” floodzone, the corresponding annual flood insurance is reduced by about 4x. So, for example, if a Pre-FIRM Condominium is currently within an “A” floodzone and is paying roughly $100,000 annually for flood insurance, a LOMR that changes the floodzone to “X” would reduce the annual flood insurance premium to about $25,000 (save $75K annually).
For Post-FIRM buildings/structures remaining within a “V” floodzone, a 1-ft decrease in the WCE would reduce the corresponding annual flood insurance by about 20%. So, for example, if a Hotel/Resort is currently within a “V” floodzone and is paying roughly $500,000 annually for flood insurance, a LOMR that reduces the WCE by just one foot would reduce the annual flood insurance premium to about $400,000 (save $100K annually).
For developers/builders of vacant parcels within “A” floodzones, a LOMR that changes the floodzone to “X” could save six figures in construction costs. For example, let’s assume that 10 acres of a particular 20-acre parcel is to be developed, with the FEMA 100-yr BFE one foot higher than the 100-yr storm zero-discharge flood elevation. If a LOMR is performed that changes the floodzone from “A” to “X”, structural fill would be needed up to the 100-yr storm zero discharge flood elevation – as the FEMA BFE would no longer exist in an “X” floodzone. This savings of one foot of fill over 10 acres would yield an approximate construction cost savings of $160K to $200K (depending on the cost of importing fill, per cubic yard).
Who Benefits Most From a LOMR?
The following is a list of the most common properties that benefit most from having a LOMR performed:
- High-Rise/Low-Rise Condominiums
- Shopping Centers/Malls
- Residential Homeowners’ Associations
- Apartment Buildings
- Office/Commercial Buildings
- Single-Family Homes
- Waterfront Structures (marinas, ports, etc.)
- Developers/Builders of vacant lots
By having a LOMR performed, the property owner could achieve the following benefits:
Significantly reduced annual flood insurance premiums for future policies
A pro-rated refund for pre-paid NFIP flood policies
No longer forced to obtain flood insurance (in “X” floodzones)
Fewer construction/building permits required; more cost-effective construction options for development in “V” and “A” floodzones
Turn an undevelopable property into one that is developable (removal/reduction of a Floodway)
A significant increase in property value and “sell-ability”
What if a LOMR is not feasible or is not cost-effective?
Sometimes LOMRs are simply not feasible or cost-effective to do. In cases where a property is located within “V” floodzones and cannot have a LOMR performed, a viable alternative is the V-Zone Risk Factor Rating Form. These Forms are often less technically intensive than LOMRs; hence, they normally cost less than LOMRs to perform. This Form is submitted to the NFIP to show that the construction standards used to develop the building met or exceeded FEMA requirements. A V-Zone Risk Factor Rating Form often yields annual flood insurance reductions of 10-40% per structure in a “V” floodzone.
In cases where properties are located within “A” floodzones and cannot have LOMRs performed, a viable alternative is a LOMA or LOMA-F (a LOMA based on Fill used to elevate the structure). Issued by FEMA, a LOMA removes a structure – not a property – from a SFHA. LOMAs are often less “technically intensive” than LOMRs; hence, they normally cost less than LOMRs to perform. LOMAs are only feasible for properties in “A” floodzones and are based on the structure’s most recent Elevation Certificate. A LOMA will reduce flood insurance premiums by 100% when the policy is discontinued; an approximate 30% reduction would occur for continuing policies.
In all cases, we always perform a cursory LOMR Feasibility Analysis, which is free of charge, in order to determine for sure if a LOMR is feasible; we will NEVER have you sign a contract with us to perform a LOMR unless we are confident we can perform the job accurately and efficiently and get the job approved!