Item I51.5
t, BOARD OF COUNTY COMMISSIONERS
County of Monroe Mayor Sylvia Murphy, District 5
The Florida Keys l'U � Mayor Pro Tern Danny Kolhage, District 1
�pw° Michelle Coldiron, District 2
Heather Carruthers, District 3
David Rice, District 4
County Commission Meeting
September 18, 2019
Agenda Item Number: I.5
Agenda Item Summary #5974
BULK ITEM: No DEPARTMENT: Building
TIME APPROXIMATE: STAFF CONTACT: Karl Bursa (305) 453-8759
PM
AGENDA ITEM WORDING: Presentation of Federal Emergency Management Agency (FEMA)
August 22, 2019 Flood Hazard Data and DRAFT Flood Insurance Rate Maps (FIRMs) availability
and future timeline for PRELIMINARY FIRMs, Appeals, and FINAL FIRMs
ITEM BACKGROUND: The Federal Emergency Management Agency (FEMA) has developed
and released DRAFT Flood Insurance Rate Maps (FIRMs) for Monroe County.
These maps show FEMA's draft data on Flood Zone and Base Flood Elevation changes from the
existing 2005 maps. Included in the draft maps is a new feature, the Limits of Moderate Wave
Action (LiMWA) line. This line is located between the edge of the most landward VE Zone
boundary and the next closest AE Flood Zone boundary. The LiMWA line notes the area where
wave action from storms would be between 1.5 to 3 feet in height. Areas located inside the LiMWA
line are designated as Coastal A Zones (CAZ) by FEMA. Florida Building Code requires these
zones to be regulated to VE Zone construction standards.
Also, FEMA has changed the vertical datum used to determine elevations from NGVD29 to
NAVD88. This change has resulted in the `0' elevation line being lowered 1.3 to 1.6 feet for all
properties in the Keys, depending on which island the property is located. The conversion factor is
site specific; so, as a result, property owners in Key West would have different conversion numbers
than property owners in Marathon or Key Largo. This change will become effective with the
adoption of the new maps.
Because FEMA did not produce comparison DRAFT Maps showing the difference in the 2005 Maps
compared to the new draft maps with the datum change, county staff have requested Woods Hole
produce these maps to aid the public in understanding what the DRAFT Maps mean to them from a
"change" point of view.
Monroe County's 30-day comment period for the Draft Maps concludes September 23rd. Staff,
along with Woods Hole Group, the consultant retained to assist in reviewing the maps are putting
together comments to submit to FEMA. Staff also posted the maps online for public comments and
Packet Pg. 1584
1.5
set up a special email address. Any comments about the Draft Maps must be submitted to Monroe
County Floodplain Management on or before that date for transmittal to FEMA.
Following receipt of DRAFT map comments, FEMA will review all comments received from
Monroe County and will use this information to aid in the production of Preliminary Maps.
At this time, FEMA anticipates the release of the PRELIMINARY Maps December 9, 2019.
Monroe County Staff has requested that the release of these maps be delayed until January, 2020 to
obtain the best community input we can; but Staff has yet to hear back from FEMA regarding this
request.
Once PRELIMINARY Maps are released, FEMA will hold Community Open House Meetings.
Staff have requested Open House meetings for Key Largo, Big Pine Key, and Sugarloaf. Each City
has also requested Open House Meetings. Attached is a FEMA Region 4 Risk Map Process
document that shows the timeline.
The County has also retained Bruce Bender to assist with public outreach and will be reaching out to
Chambers of Commerce and other organizations to present the maps and changes.
After the open house meetings, FEMA will do two public notices so community members can
submit technical data to support a request to revise the FIRM through the 90 days appeals process.
Community member appeals must be submitted through the local government. The Board adopted a
$170 fee for submittal, along with a fee for technical review (if needed).
Attached are many documents that explain these processes, as well as how to appeal the flood maps.
Woods Hole will be reviewing the maps and corresponding data and analysis to determine whether
the County should appeal any of the map panels.
FEMA will send a letter of final determination after all appeals are resolved. The County will be
required to adopt the maps within 6 months of final determination. The ordinance will be processed
through a Community meeting, Impact meeting, Development Review Committee, Planning
Commission, the Board of County Commission, and the Department of Economic Opportunity.
The County is required to adopt the FINAL Maps by ordinance. Staff are working on this now.
Staff are also rewriting the current Floodplain Regulations to follow the State of Florida Model
Code, which was developed as a Florida Building Code companion.
Based on the proposed timetable (See Attachment) and the resolution of all appeals, FEMA
anticipates the Final Maps becoming effective in approximately January of 2021. As always, all
dates provided are approximate and subject to change.
PREVIOUS RELEVANT BOCC ACTION:
On August 21, 2019, the Monroe County BOCC approved a contract for Woods Hole Group, Inc. to
provide assistance to Monroe County Staff to review and comment on the FEMA Draft Flood Maps
Packet Pg. 1585
1.5
for Monroe County.
CONTRACT/AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATION: N/A.
DOCUMENTATION:
coastal_ a_ zones
BASF _2017 flood 061217 (1)
Draft_Map_Timeline
NGVD29 NAVD88 Conv
Draft _Map Press_Release
what_ is_ risk_ map
FEMA_Report_495_Jan2019_For PRINT
New Coastal Flood Risk Information - LIMWA
I5i FIMA Overview Fact Sheet 2016
Appeal_Comment Processing_Guidance_Feb _2019
Monroe County Coastal Remapping Outreach Activity Plan-V3
FEMA_Rgn_4_Risk _Map Process
CHART OF IMPACTS OF MAP CHANGES ON INSURANCE
FINANCIAL IMPACT:
Effective Date: N/A
Expiration Date: N/A
Total Dollar Value of Contract: N/A
Total Cost to County: N/A
Current Year Portion: N/A
Budgeted: N/A
Source of Funds: N/A
CPI: N/A
Indirect Costs: N/A
Estimated Ongoing Costs Not Included in above dollar amounts: N/A
Revenue Producing: N/A If yes, amount:
Grant: N/A
County Match: N/A
Insurance Required: N/A
Additional Details:
None
Packet Pg. 1586
1.5
REVIEWED BY:
Rick Griffin
Completed
Assistant County Administrator Christine
Hurley
08/29/2019
Steve Williams
Completed
Budget and Finance
Completed
Maria Slavik
Completed
Kathy Peters
Completed
Board of County Commissioners
Pending
X11611,011
08/26/2019 3:38 PM
Completed
08/29/2019 2:28 PM
08/29/2019 4:46 PM
08/30/2019 8:51 AM
09/03/2019 9:57 AM
09/18/2019 9:00 AM
Packet Pg. 1587
Purpose: To recommend design and construction practices in coastal areas where wave and flood conditions
during the base flood will be less severe than in V Zones, but still cause significant damage to typical light -
frame construction
Recent post -storm investigations have shown that
typical A Zone construction techniques (e.g., wood -
frame, light gauge steel or masonry walls on shallow
footings or slabs, etc.) are subject to damage when
exposed to less than 3-foot breaking waves, which is
the current threshold for V Zone conditions.
Coastal A zone buildings that employ typical
residential and light commercial walls to elevate
and support habitable space above the flood level
will be susceptible to flood damage (see Figure
1). Laboratory tests and recent field investigations
confirm that breaking wave heights as small as 1.5
feet will cause failure of these types of walls (see
Figures 2 and 3).
Other flood hazards associated with coastal waves
(e.g., floating debris, high velocity flow, erosion and
scour) also damage A Zone type construction in
coastal areas (see Figures 4 and 5).
NFIP flood hazard mapping is generally divided
into two categories, V Zone and A Zone. In coastal
areas, the A Zone category could be subdivided
into "Coastal A Zone" and "A Zone." Base flood
conditions in the Coastal A Zone will be similar to,
but less severe than, those in the V Zone; base flood
conditions in the A Zone will be similar to those in
riverine or lake floodplains.
• The Coastal A Zone is not shown on the FIRM at
present; therefore, communities, designers, and
owners will have to determine whether a site lies
within a Coastal A Zone.
Figure 1, Failure of wood -frame walls used to support a coastal
building, which was subjected to shallow flooding, small waves,
and floating debris (Hurricane Opal),
V Zone design and construction standards are Figure 2, Masonry walls destroyed by 3 feet of stillwater
recommended in Coastal A Zones subject to erosion, flooding and small waves (Hurricane Dennis),
high velocity flow, and/or wave heights greater than 1.5 feet.
o,,,,,,,
FloodingAreas With Potential for
Areas With Shallow
, , K , Only, Is Low
During Base Flood Breaking Waves and Erosion
Design and Construction In Coastal A Zones December 2005 1 E° 5
Packet Pg. 1588
Figure 3. Failure of wood -frame wall, brick veneer, and windows
as a result of 4 feet of stillwater flooding and small waves
(Hurricane Katrina).
k,; .
Coastal A Zone: area landward of a V Zone, or
landward of an open coast without mapped V
Zones. In a Coastal A Zone, the principal source of
flooding will be astronomical tides, storm surges,
seiches or tsunamis, not riverine flooding. During
base flood conditions, the potential for breaking
wave heights between 1.5 feet and 3.0 feet will
exist (see Figure 6).
Figure 4. Failure of Zone type foundation in coastal area, not
subject to V Zone conditions (Hurricane Fran).
Figure 5. Damage to light frame walls due to floating debris and
small waves. The damaged home was in the third row back from a
bay shoreline (Hurricane Ivan).
Coastal A Zone design and construction practices
described herein are not mandated by the NFIP but
are recommended for communities that wish to
adopt higher floodplain management standards.
Community Rating System (CRS) credits are
available for doing so. Note that some Coastal A
Zone practices may be required by the International
Building Code, through its reference to ASCE 24-98.
X Zone A Zone
�aJe
eat %,
rDA-,1 Coastal V Zone
A Zone
�2A
Shoreline
Figure 6. Plan view showing Coastal A Zone landward of V Zone
(source; ASCE 24-05).
Design and Construction In Coastal A Zones December 2005 p, 5
Packet Pg. 1589
1.5.a
Because of the presence of damaging waves, V Zone design, construction, and certification practices are
recommended for Coastal A Zones.
Coastal A Zone construction should include:
• Use of open foundations (pile or pier) designed to resist all base flood conditions (waves, high velocity flow,
erosion and scour, floodborne debris). Where high velocity flow, scour, and erosion will not be experienced
under base flood conditions, a traditional stem wall foundation may be acceptable — see Table 1.
Elevation of the bottom of the lowest horizontal
structural member supporting the lowest floor above
the base flood wave crest elevation (see Figure
7).Since waves and debris will be impacting on the
floor joists and other foundation elements during
the base flood, do not follow current NFIP minimum
requirements that allow the lowest floor's walking
surface to be set at the wave crest elevation in
Zone A.
Toward Flood Source
100-Year Bottom of
Wave Crest Lowest Horizontal
Elevation (ABFE) Structural Member
Freeboard
MM
• Use of flood -resistant materials above the level of the 100-Year
walking surface of the lowest floor (in the event that Stillwater
Elevation
future flooding exceeds the lowest floor level). Isms
Exceeding NFIP Elevation Requirements in Coastal A Zones
• Specification of connections between the foundation
and the elevated building that are capable of Figure 7. Recommended post -Katrina building standards in
withstanding simultaneous wind and flood forces. Coasta►A Zones.
Post -Katrina investigations found many foundation -to -
building connections to be deficient (see Figure 8).
• Use of space below the lowest horizontal structural
member for parking, access, or storage only. Adding
sufficient freeboard to allow parking beneath the
building will not only reduce future flood damages, but
will also lower flood insurance premiums.
• Use of screen, lattice, or breakaway walls if space
below the elevated floor is enclosed. Note: until flood
regulations are changed, breakaway walls in Coastal A
Zones must be equipped with flood openings.
Additional guidance for design and construction in
Coastal A Zones can be found in FEMA 499, Home
Builder's Guide to Coastal Construction (http://www.
fema.gov/fima/mat/fema499.shtm). The publication is
a series of 31 fact sheets that provide recommended
design and construction practices for foundations,
connections, building envelope, etc. Fact Sheet 2
summarizes recommended practices for Coastal A
Zones, and references other fact sheets that provide
more details.
Figure S. Post -Katrina investigations showed that many
buildings were attached to foundation piers with light
gauge metal straps. These straps failed in many instances. A
stronger (preferably bolted) connection is recommended when
attaching Coastal A Zone buildings to their foundations.
Design and Construction In Coastal A Zones December 2005 1 E=e 3 of 5
Packet Pg. 1590
1.5.a
Table 1. Foundation Recommendations for Coastal A Zones (Users should read across from a foundation
type to see under what soil and base flood conditions that foundation is acceptable. A foundation must
be capable of resisting all base flood conditions likely to exist at the site, or it should not be used. For
example, a properly constructed pier on a shallow footing will generally withstand 1.5- to 3.0-foot wave
heights, but should not be used where soils are erodible, and where high velocity flow is possible, or where
large floodborne debris may be present.)
Foundation Type
Wave Heights Between
J
Velocity Flow, Erodible
1.5 and 3.0 Feet*
Soils
Large Debris
Fill
no
no
no
Slab on grade
no
no
no
Crawlspace, shallow footing
no
no
no
Foundation walls, shallow footing
no
no
no
Stemwall, shallow footing
yes
no
yes
Stemwall, deep footing**
yes
yes
yes
Pier, shallow footing
yes
no
no
Pier, deep footing**
yes
yes
no
Post, shallow embedment
no
no
no
Pile/Column, deep embedment**
yes
yes
yes
*Wave heights greater than 3.0 feet mapped
as V Zone: fill, slab, crawlspace, wall foundations not permitted.
**Deep means sufficiently deep to withstand
erosion and scour, including that induced by the presence of the
foundation itself.
Coastal A zones are not shown on present day Flood Insurance Rate Maps (FIRMs) or mentioned in a
community's Flood Insurance Study (FIS) Report. Those maps and studies show zones VE, AE, and X (or
older designations V1-30, Al-30, B, and C). Therefore, until Coastal A Zone designations or wave height
contours are incorporated into Flood Insurance Studies, the community official, designer, or owner will have to
determine whether or not a site will be subject to Coastal A Zone conditions during the base flood.
In order for a Coastal A Zone to be designated, two conditions are required:
1) a water depth sufficient to support waves between 1.5 and 3.0 feet high, and
2) the actual presence of wave heights between 1.5 and 3.0 feet.
Condition 1 requires stillwater depths (vertical distance between the 100-year stillwater elevation and the
ground elevation) of 2 to 4 feet at the site.
Condition 2 requires wave heights at the
shoreline greater than 1.5 to 3.0 feet
(under the 100-year flood conditions),
sufficient water depth between the
shoreline and the site and few, if any
obstructions (buildings, dense tree stands,
etc.) that may block or dampen the waves,
between the shoreline and the site.
Figure 9 illustrates the relationships
between the stillwater flood elevation,
ground elevations, associated 1 percent
annual chance (100-year) stillwater flood
depths, ABFEs, and associated flood
hazard zones (see Hurricane Katrina
Recovery Advisory Reconstruction
Guidance Using Hurricane Katrina Surge
Inundation and ABFE Maps).
V ZONE
Wave Height>3.0 ft
Advisory Base Flood Elevation
(SWEL + D/2) D/2
----------------------
100-year Stillwater Level D
Shoreline
COASTAL A ZONE I A ZONE
Nave Height Between I Wave Height < 1.5
3.0 and 1.5 ft
---------------------
Stillwater Depth
Between 4 and 2 ft �Iq
Figure 9. Cross-section showing 1 percent annual chance stiliwater elevation,
stiliwater depth and ABFE, and inland limits of V Zone and Coastal A Zone.
Design and Construction In Coastal A Zones December 2005 P—P 4 of 5
Packet Pg. 1591
1.5.a
Communities, designers, and owners can obtain the information necessary to make a post -Katrina Coas a
Zone determination by observing the site and its surroundings, knowing site ground elevations, and using 1
percent annual chance stillwater elevations from the Advisory Base Flood Elevation (ABFE) guidance (see Table
2). Figure 10 shows how site and surrounding conditions would influence a Coastal A Zone determination.
Table 2. Updated 1 Percent Annual Chance (100-Year) Stillwater Elevations for Use in Calculating ABFEs (see
Figure 9)
*National Geodetic Vertical Datum
Figure 10. Although the site on the left is mapped Zone AE, proximity to the Gulf of Mexico shoreline and limited obstructions to
waves indicate the site could be classified as a Coastal A Zone. The site on the right is over 4,000 feet from the Gulf shoreline and
over 1,000 feet from the bayou, mapped as Zone AE, and has a base flood stillwater level sufficient to support >1.5-foot wave heights
- but obstructions to waves (e.g., trees and other buildings between the site and the shoreline), and distance from the sources of
flooding would indicate the area is not a Coastal A Zone.
Design and Construction In Coastal A Zones December 2005 1 E=e 5 of 5
Packet Pg. 1592
1.5.b
Building J, r°
A Safer �1 tj Irr'�l
Flood Resistant Construction and the 6t"
Florida, �In Edition Florida Building Code (2017)
Hurricanes and other storms that result in flooding have
caused billions of dollars in damage across all parts of
Florida. Local jurisdictions throughout the state recognize,
plan for and manage development in flood hazard areas. To
participate in the National Flood Insurance Program
(NFIP), communities agree to regulate all development in
flood hazard areas mapped by the Federal Emergency
Management Agency (FEMA).
Once an owner or developer makes a decision to construct,
add to or substantially improve a building in a flood hazard
area, certain requirements intended to minimize future flood
damage must be satisfied. Flood provisions for buildings
are in the Florida Building Code (FBC), making it easier
for design professionals and builders to address the
requirements along with other applicable load and design
requirements.
The flood provisions of the FBC achieve two broad
objectives:
1. As with the rest of the
code, the flood
provisions help fulfill the
purpose of safeguarding
public health, safety, and
general welfare. Many
Florida communities and
property owners can
attest that designing and
constructing buildings to
account for flood loads
and conditions
Access to the FBC.
The FBC is accessi-
ble online through the
Commission's web -
page, listed under
Resources.
Download excerpts of
the 6th Edition FBC
flood provisions from
the Florida Division of
Emergency Manage-
ment webpage, listed
under Resources.
significantly reduce
damage. FEMA reports that structures built to NFIP
criteria experience 80% less damage through reduced
frequency and severity of losses. Buildings that sustain
less damage are more quickly reoccupied, facilitating
recovery.
The flood provisions fulfill some
of the requirements necessary
for communities that participate
in the NFIP. FEMA states the
flood provisions of the
International Code Series®,
which is the foundation of the
FBC, meet or exceed the NFIP
requirements for buildings and
structures. However, NFIP
communities are responsible for
June 2017
Degree of Safety
Warning. The degree
of flood protection
afforded by the flood
provisions in the FBC
is considered reason-
able for regulatory
purposes and is
based on scientific
and engineering con-
siderations. Larger
floods can and will
occur, flooding land
regulating all development, outside of mapped
including activities that are not flood hazard areas_
within the scope of the codes.
This is accomplished by the adoption of local
floodplain management regulations (see graphic).
Relying on the model ordinance developed by the
Florida Division of Emergency Management (DEM)
and approved by FEMA, nearly all Florida
communities have adopted local regulations explicitly
written to rely on the FBC to satisfy the NFIP
requirements for buildings (see last page).
Florida ACF 7
Building
Codes ASCE4
l
Hazard Resistant
Buil'idings and Development_
Florida Statute s. 553.73(5) was amended in 2010 to allow
communities to adopt local administrative amendments to
implement the flood provisions of the FBC and local
technical amendments to adopt flood provisions that are
more stringent than the FBC (also called "higher
standards"). Under most circumstances, local amendments
will not sunset when the state adopts a new edition of the
code. Model language for some higher standards is
available on the DEM webpage (see Resources).
Packet Pg. 1593
1.5.b
Flood ui t t Construction
The NFIP — and the FBC — requires communities to ensure
that new buildings and structures in flood hazard areas are
designed and constructed to resist the effects of flood
hazards and flood loads. The same requirements apply to
existing buildings if proposed work is determined to
constitute substantial improvement or repair of substantial
damage (both terms are defined in the FBC).
Chapter 16 of the FBC, Building requires designers to
develop flood loads, which involves determining flood
conditions (flood depth, velocity, scour/erosion, and
wave/debris impact). Flood loads and load combinations are
described in Chapter 5 of ASCE 7, Minimum Design Loads
for Buildings and Other Structures. Section R322 of the
FBC, Residential requires dwellings to be designed and
constructed in accordance with specific provisions.
Although hydrostatic load, a function of water depth, is the
most obvious load and the easiest to compute, other loads
may be more important in final designs. Flood conditions
necessary to compute hydrodynamic loads are more difficult
to determine (see graphic) and may require consultation with
civil or hydraulic engineers. The FBC, Residential requires a
design professional to prepare designs for homes in coastal
high -hazard areas and Coastal A Zones, but not in other
flood zones (see next section for descriptions of flood
zones). Designers and builders are cautioned to evaluate
whether any flood conditions (such as velocities or waves)
may warrant a closer look at flood loads.
Other aspects of flood -resistant construction found in the
FBC include the use of flood damage -resistant materials,
requirements for enclosures below elevated buildings, and
the location of electrical, plumbing, heating, ventilation, and
air-conditioning (HVAC) equipment, swimming pools, and
tanks.
Flood it iteas and Flood
Conditions
Flood Insurance Rate Maps (FIRMS) prepared by FEMA are
the most common flood hazard maps adopted by Florida
communities. Designers and builders should check with
individual communities to determine whether a locally -
prepared map is used for regulatory purposes. FIRMS
identify flood hazard areas associated with the base flood
(the 1%-annual-chance or" 100-year" flood). Some FIRMS
also identify areas subject to flooding by the less frequent
500-year flood.
FIRMS identify flood hazard areas based on
characteristics of flooding:
Zone A, AE, Al-30, AO, and ALI. These zones
include flood hazard areas along rivers and streams,
in isolated areas where floodwaters accumulate
without draining to a waterway and in coastal areas
inland of Zone V and along many shorelines.
Floodways are designated along some rivers and
streams.
• Zone V, VE, V1-30, and VO. These zones identify
coastal high -hazard areas found along open
coastlines where, during the base flood, waves are
expected to be 3 feet and higher.
Limit of Moderate Wave Action.
When shown, the LiMWA
identifies the inland extent of 1.5-
foot waves and the area between
the LiMWA and the Zone V
boundary or shoreline is designated
as Coastal A Zone.
Coastal A Zone.
Revised FIRMs for
coastal communities
may have a Limit of
Moderate Wave
Action (LiMWA)
delivered. The area
between the LiMWA
Zone X (shaded) identifies areas and the Zone V
boundary or the shore
subject to flooding by the 500-year is designated the
flood and Zone X (unshaded) "Coastal A Zone."
identifies land areas that are
outside of the 100- and 500-year flood hazard areas.
Some site -specific flood conditions can be determined
using FIRMs and associated Flood Insurance Studies,
while others can be estimated using the best available
information (for a general discussion, see the checklist in
Appendix C in FEMA P-936, FloodproofngNon-
Residential Buildings):
Flood depth, used to compute lateral and vertical
hydrostatic loads, is determined by subtracting the
ground elevation from the base flood elevation
(BFE) shown on the FIRM. Lateral hydrostatic loads
need not be considered for enclosures below
elevated buildings that have flood openings to allow
floodwater to flow in and out automatically. Vertical
(buoyant) hydrostatic loads are calculated for
j
Packet Pg. 1594
1.5.b
elements below the BFE and may be important when
soils are saturated.
Flood velocity, used to compute hydrodynamic load,
may be estimated in riverine areas if the Flood
Insurance Study has a floodway data table or by
using standard methods for estimating open -channel
flow velocities (see FEMA's Recommended
Procedures for Flood Velocity Data Development. In
coastal areas there is more uncertainty in estimating
flood velocity, which is speed of the mass movement
of floodwater, not breaking waves (e.g., as a storm
surge moves onshore or recedes). A number of
FEMA references include a graph showing velocity
as a function of Stillwater flood depth (see FEMA P-
55, Coastal Construction Manual).
• Debris in moving water can impart a considerable
impact load when it collides with buildings. Whether
debris is likely to be present, and the types and sizes
of debris, cannot be determined from flood maps and
studies. ASCE 7 Chapter 5 commentary provides
guidance for consideration of debris impact loads.
Wave loads, important in coastal areas, depend
largely on wave height. Wave height is a function of
Stillwater flood depth and may be approximated
using information in Flood Insurance Studies. The
magnitude of wave loads can be 10 times or more
than wind forces. ASCE 7 Chapter 5 commentary
provides guidance on determining wave loads.
• Erosion and scour may affect the stability of
foundations and the loss of supporting soils should
be considered because it affects flood loads. Refer to
FEMA P-55 for guidance on the effects of erosion
and scour.
Duration of flooding, although not a direct
contribution to flood loads, is a condition that
warrants consideration. Long -duration flooding is
more likely to delay reoccupancy and is a factor in
whether dry floodproofing measures can be used for
nonresidential buildings (not allowed in Zone V).
Also, long -duration flooding is likely to cause
nonstructural damage even if flood damage -resistant
materials are used.
If BFEs are not shown on the flood hazard map, the FBC
gives the building official the authority to require the
permit applicant to obtain and use data from another
source or to determine the design flood elevation (DFE)
using accepted engineering practices. Many communities
provide applicants with BFE or flood depth information,
and some communities may allow the use of
approximation methods, such as interpolating the special
flood hazard area boundary based on topographic
mapping.
New Flood Requirements in the 6th Ed. FBC. For easy
identification in the following descriptions, underlining
identifies the flood requirements that are new to the 6th
Edition FBC.
FBC, Building ,- Chapter
Administration
Chapter 1 establishes the applicability of the code and
describes how the code is to be applied and enforced.
This chapter includes flood provisions in a number of
sections:
• Hunting "camps" are exempt from the FBC unless
certain conditions apply, including location in the
"100-year floodplain" (Sec. 102.2).
• Site plans should show flood hazard areas,
floodways, and DFEs (Sec. 107.2.5).
BFE and DFE. The codes use the term DFE, which is
the same as the BFE unless the community adopts a
map showing a more extensive flood hazard area than
the SFHA with flood elevations higher than the BFE.
Some communities adopt additional maps to show areas
prone to flooding outside of the SFHA.
• The minimum plan review criteria include flood
hazard areas, flood zones, DFE, lowest floor
elevations, enclosures and flood damage -resistant
materials (Sec. 107.3.5).
• The authority to issue permits on the basis of
affidavits (Sec. 105.1 and Sec. 107.6.1) does not
extend to the flood load and flood resistant
requirements of the FBC to preserve the NFIP
requirement that local officials review and approve
permits.
As part of required inspections, submission of
certifications (prepared by a Florida licensed
professional surveyor) of the lowest floor elevation
are required upon placement of the lowest floor and
prior to further vertical construction. Final ("as-
builf') certifications must be submitted as part of the
final inspection (Sec. 110.3).
• Certificates of occupancy are to include a statement
that the elevation certificate has been provided and is
retained in the community's records (Sec. I11.2).
Also see flood provisions in Sec. 102.2.5 (certain
exemptions that may be adopted by enforcement
districts), Sec. 102.7 (relocation of manufactured
buildings), and Sec. 117.1 (variances in flood hazard
areas, which refers to local floodplain management
regulations).
Packet Pg. 1595
1.5.b
FBC, Building
Most, but not all, flood provisions in the FBC, Building
are found in Sec. 1612, Flood Loads (see Table 1612.1
for a listing of all flood provisions in the FBC). The
following highlight key provisions:
In Sec. 1612.3, flood
hazard areas are
established by local
floodplain management
ordinances, which adopt
flood hazard maps and
supporting data. FEMA
Flood Insurance Studies
and Flood Insurance Rate
Maps (FIRMS) are
specified. Some Florida
communities adopt locally
prepared studies and
maps.
Special Detailed
Requirements
Based on Use and
Occupancy. Special
detailed requirements
(Chapter 4) based on
use and occupancy
include flood provi-
sions in Sec. 449
(hospitals), Sec. 450
(nursing homes), Sec.
453 (educational
facilities), and Sec.
454 (pools).
Detailed specifications for flood -resistant design are
not included in the code. Rather, Sec. 1612.4 refers
to ASCE 24, Flood Resistant Design and
Construction, for specific requirements. A number of
requirements in ASCE 24 are based on the Flood
Design Class that is assigned in Sec. 1603.1.7 (see
ASCE 24 for Flood Design Classes, which are
similar to risk categories).
Notice of Local Higher Standards (Freeboard). Many
Florida communities adopt requirements for additional
elevation above the minimum in the FBC, ranging from
2 to 4 feet above the BFE. This added factor of safety is
called "freeboard." Buildings that are higher than the
BFE sustain less damage and owners pay lower
Federal flood insurance premiums (see graphic).
Elevation requirements depend on flood zone. See
the summary of elevation requirements in
Highlights of ASCE 24-14 prepared by FEMA.
Elevation requirements above the BFE start at +1
foot (Flood Design Class 2) and go up to +2 feet or
the 500-year flood elevation, whichever is higher
(Flood Design Class 4).
- Coastal A Zones, if designated, are treated as Zone
V, although backfilled stemwalls are permitted if
foundation designs account for scour.
- Specific requirements for enclosures below
elevated buildings are based on flood zone. All
enclosure walls must have flood openings,
including walls intended to breakaway under wave
loads. Enclosures are limited to uses for parking,
storage and building access.
The use of dry floodproofmg (only nonresidential
occupancies in Zone A) is limited depending on
flood velocities and adequate warning time to
implement measures that require human
intervention. A Florida amendment to ASCE 24
permits dry floodproofmg in Coastal A Zones
provided designs account for wave loads and
potential erosion and scour.
- Utility equipment and machinery that serve
buildings are required to be elevated or meet a
specific performance expectation. Similar
requirements are found in the FBC, Mechanical;
FBC, Plumbing; and FBC, Fuel Gas.
Sec. 1612.5 requires submission of elevation
certification (also see Sec. 110.3, Inspections) and, if
pertinent to specific buildings, design documentation
for dry floodproofing, engineered openings,
foundation and anchorage, and breakaway walls.
Design documentation must be prepared and sealed
by registered design professionals.
• Sec. 1804.4 includes requirements for grading and
fill. Where allowed in flood hazard areas, fill shall
be placed, compacted, and sloped to be stable under
flood conditions.
Sec. 3109 includes
requirements for buildings
seaward of the Coastal
Construction Control Line
(CCCL). Areas seaward of
the CCCL that are also
mapped as flood hazard
BASF CCCL Fact
Sheet. Visit
www.buildingasgh rflo
rida.ora to download a
fact sheet summary of
the revised CCCL
requirements.
areas are subject to the
more restrictive of the flood requirements. This
section is revised in the 01 Edition FBC to minimize
differences with Sec. 1612 and ASCE 24.
• Buildings in "high -velocity hurricane zones"
(Broward and Miami -Dade counties) are required to
comply with the specific provisions for those zones
and also the requirements of Sec. 1612, if located in
flood hazard areas (Sec. 1601.1).
FBC, Residential
Most, but not all, flood provisions in the FBC, Residential
are found in Sec. R322, Flood -Resistant Construction (see
FBC, Building Table 1612.1 for a listing of all flood
provisions in the FBC, Residential). Unlike the FBC,
Building, which refers to ASCE 24, the FBC, Residential
includes detailed requirements. Dwellings seaward of the
CCCL must be in accordance with Sec. 3109 of the FBC,
Building. The following highlight key provisions:
4
Packet Pg. 1596
1.5.b
• New in the 6" Edition, areas subject to wave heights
between 1 % and 3 feet are delineated (by Limit of
Moderate Wave Action) or otherwise designated by the
community are Coastal A Zones (CAZ). If CAZs are
designated, dwellings in CAZs must comply with the
requirements for Zone V in Sec. R322.3.
• In Table R301.2(1), communities adopt local floodplain
management ordinances to specify the date of entry into
the NFIP and the title and date of the current Flood
Insurance Study and FIRMS.
• Sec. R309.3 requires garages to be elevated or, if below
the BFE and used solely for parking, access or storage,
meet the requirements of Sec. 322 (for enclosed areas
below the BFE).
• Sec. R322.1 includes general provisions that apply to
dwellings in all flood hazard areas (including Zone A,
Zone V, and Coastal A Zones):
Dwellings proposed in identified floodways are
required to be designed and constructed according to
ASCE 24. This requirement recognizes that flooding
is deeper and usually flows faster in floodways,
which include the channel and adjacent lands that
should be reserved to convey floodwaters.
Obstructing flow in floodways can cause increases
in flood depths, which may cause increased damage
on adjacent properties.
- Sec. R322.1.1 permits use of ASCE 24 in all flood
hazard areas as an alternative to the requirements of
Sec. R322.
- In areas commonly referred to as "approximate Zone
A" where FIRMS do not specify BFEs, the building
official may require use of data available from
another source or may require the applicant to
Ton of lowest floor
determine flood elevations using accepted
engineering practices. Keeping a record of
elevations used previously is a good practice so that
future permit decisions can be based on the same
data.
- The lowest floor is defined as the floor of the lowest
enclosed area, but does not include unfinished
enclosures below elevated dwellings that comply
with the code (see graphic below).
Unfinished enclosures under elevated buildings are
permitted if used only for parking, building access
or limited storage (or crawlspace). Building officials
should ensure that plans specify enclosed areas are
only for those uses. An owner who subsequently
modifies an enclosure in any way that alters
compliance with these requirements may be subject
to higher Federal flood insurance premiums.
- Utility equipment and machinery that serve
buildings must be elevated or meet a specific
performance expectation that generally cannot be
met by typical installations.
Use of flood damage -resistant materials is required
below the elevations required in R322.2 (Zone A)
and R322.3 (Zone V and Coastal A Zone). These
materials are capable of withstanding direct and
prolonged contact with floodwaters without
sustaining significant damage. FEMA Technical
Bulletin 2, Flood Damage -Resistant Materials
Requirements, is referenced for materials and
installation methods.
- Dwellings seaward of the CCCL that are also in
mapped flood hazard areas must comply with the
more restrictive of Sec. 3109 of the FBC Building
and Sec. R322.
Bottom of the lowest horizontal structural
member of the lowest floor at or above
OIC C . 41 i+
Packet Pg. 1597
1.5.b
• Sec. R322.2 includes specific requirements that apply in
flood hazard areas commonly referred to as "Zone A."
(except in Coastal A Zones, which are subject to Sec.
R322.3). The Zone A requirements include:
Minimum elevation requirements call for the lowest
floor (see graphic left, previous page), including
basement, to be at or above the BFE plus 1 foot or
DFE, whichever is higher. The additional elevation,
called "freeboard," is required in all flood hazard
areas. (see graphic below) Basements and all areas
that are below grade on all sides are not permitted.
The area below
elevated dwellings may Enclosures and
be enclosed by Flood Insurance.
foundation walls or Federal flood insur-
ance is more expen-
framed walls. To sive if Zone V build -
minimize damage due ings have enclosures
to hydrostatic loads, below the BEE, even
flood openings are if the walls are com-
required (see FEMA pliant breakaway
Technical Bulletin 1, walls. Insurance is
even more expensive
Openings in if enclosures are
Foundation Walls and larger than 300
Walls of Enclosures). square feet.
Flood openings may be
prescriptive (providing 1 square inch of net open
area for each square foot of enclosed area) or
engineered (requires design certification).
Measurement of net open area must account for the
presence of louvers, blades, screens, and faceplates.
- Tanks may be installed underground or on -grade (if
anchored to resist flood loads) or elevated on
platforms.
• Sec. R322.3 includes specific requirements that apply in
coastal high -hazard areas, commonly referred to as
"Zone V," and Coastal A Zones:
Minimum elevation requirements call for the bottom
of the lowest horizontal structural member of the
lowest floor(see graphic previous page, right) to be
elevated to or above the BFE plus 1 foot or DFE,
whichever is higher. The additional elevation, called
"freeboard," is required in all flood hazard areas.
(see graphic below)
- Foundations are limited to pilings or columns
because they present the least obstruction to the
passage of waves. In CAZ, backfilled stemwalls are
permitted if foundations have deep footings to
account for scour. Foundation designs are required
to be certified by a registered design professional.
The area under elevated homes must be free of
obstruction (see FEMA Technical Bulletin 5, Free -
of -Obstruction Requirements). The area may be
enclosed with insect screening or open lattice or, if
enclosed by walls, the walls must be designed to
break away under flood loads without causing
damage to the foundation or elevated building.
FEMA Technical Bulletin 9, Design and
Construction Guidance for Breakaway Walls Below
Elevated Coastal Buildings, includes prescriptive
requirements for breakaway walls. The code
specifies that utility components are not permitted to
be mounted on or penetrate breakaway walls
because post -flood investigations have determined
that walls with such components do not break away
cleanly. Flood openings are required in breakaway
walls to minimize wall failure under relatively
shallow flooding.
uuu
U.
cc
+4 ' �1
t?
Zone AE
+3
.
s�_'1
BEE +1 ft.
Zone "VE
4.
54%
+2
is minimium elevation
required by FB (611 Ed'.)
Maximum dwelling coverage
169
($250,000) and contents
+1
ar^�
($i100,000) for a one-story
Jt�G'rl"t>'f�M;Jttiriar'pIJ9r4,�ti�t�tm,�gtm�mtm��tm,��tm,���tg,,,
u
sirrgille family home (no
,.
basment, no enclOgUre, no
BRIE
obstructions). Fees incuded
$0 $2,500 $5,000
$7,500 $10,0()0 $12,5,00
$15,000 $17,500 $20,000
rtri a ll I l� ood Ilunsui rance IlfOureurt mum*
Unofficial estimates using 2014 rates;
use only for companion purposes
Savings over G-BFB premium
Packet Pg. 1598
1.5.b
- An exterior door is required in the doorwa, at the
top of stairwa, s that provide access to dwellings and
that are enclosed by breakaway
- Tanks may be installed underground (if anchored to
resist flood loads) or elevated on platforms.
• Dwellings in flood hazard areas in "high -velocity
hurricane zones" (Broward and Miami -Dade counties)
are required to comply with the specific provisions for
those zones and also the requirements of Sec. R322
(also see Sec. R301.1 and Sec. R401.1).
In Zone A, above -ground pools, on -ground pools and
in -ground pools that involve placement of fill are
allowed without any special requirements unless located
in a floodway, in which case documentation must be
provided to evaluate the effects of the encroachment on
flood elevations. Pools in Zone V are required to
conform to the requirements of ASCE 24, which
preclude obstructing flow that causes damage to other
buildings. For consistency, Chapter 41, Swimming
Pools, cross-references to Sec. R322.
• Chapters with specifications for mechanical systems,
HVAC systems, duct construction, combustion air,
boilers and water heaters, special piping and storage
systems, fuel gas, plumbing, plumbing fixtures, sanitary
drainage and vent systems all include flood provisions.
In general, the pertinent sections refer to Sec. R322.1.6.
FBC, Existing Building
A fundamental premise of the FBC, Existing Building is that
work on an existing building does not lessen the compliance
or conformance of the structure. It is important to keep this
in mind when considering projects that repair, alter, add to,
or otherwise improve buildings in flood hazard areas that
were originally built to comply with flood -resistant
requirements. For example, the open area under buildings
required to be elevated on pilings is permitted to be enclosed
by walls only if the walls comply with the flood -resistant
construction requirements and if the use of the resulting
enclosure is limited only to parking, building access or
storage.
The first step when considering work on an existing building
in a flood hazard area is to determine whether the proposed
work constitutes "substantial improvement' (SI) or repair of
"substantial damage" (SD). If a proposal is determined to be
SUSD, then the existing building is required to be brought
into compliance with the requirements for new construction
found in Sec. 1612 of the FBC, Building or R322 of the
FBC, Residential, as applicable.
The SUSD determination is made by comparing the cost of
all of the proposed work to the market value of the building
(excluding land) before the work is undertaken. If a proposal
is to repair a damaged building, the market value is the value
of the building before the damage occurred. When the cost
equals or exceeds 50% of the market value, the work is
determined to be substantial improvement or repair of
substantial damage. In 2010, FEMA published FEMA P-
758, Substantial Improvement/Substantial Damage Desk
Reference, to summarize extensive guidance, include sample
letters and an informative sample packet for applicants,
designers and builders (Appendix D). Communities should
establish procedures for consistent handling of applications
to do work on existing buildings.
Notice of Local Amendments (Cumulative SQ. Some
Florida communities enforce "cumulative" SI over a speci-
fied period of time (e.g., 1, 5 or 10 years or life of the
building). These communities keep records and evaluate
whether each subsequent proposal to improve or repair a
building will trigger the SI requirement to bring the
building into compliance with the requirements for new
construction.
The flood provisions of the FBC, Existing Building are
found in several chapters (see Table 1612.1 for a listing of
all flood provisions in the FBC, Existing Building):
Repairs. Chapter 6 has a
general requirement that
requires compliance when the
repair of a building in a flood
hazard area constitutes
substantial improvement (Sec.
601.3). Sec. 606.2.4 also
specifies that buildings that
have sustained substantial
dama e shall be brow ht into
Reconstruction is
New Construction.
Reconstruction of a
building that is demol-
ished or so signifi-
cantly damaged that it
cannot be repaired is
new construction,
even if the old founda-
tion can be reused.
g g
compliance. Compliance refers to the requirements for
new construction in Sec. 1612 of the FBC, Building or
Sec. R322 of the FBC, Residential, as applicable.
Alterations - Levels 1, 2, and 3. Chapter 7, Alterations -
Level 1, has a general requirement that requires
compliance when alterations constitute substantial
improvement (Sec. 701.3). Because the requirements for
alterations are cumulative, the requirement in Chapter 7
also applies to Level 2 alterations (Chapter 8) and Level
3 alterations (Chapter 9).
Additions. Handling additions is complicated by the fact
that some circumstances prompt compliance of the
addition as well as the base building. Sec. 1103.5
distinguishes between horizontal additions that are
structurally connected and those that are not structurally
connected. It also specifies that if vertical additions or
foundation work are determined to constitute substantial
improvement, then base buildings must be brought into
compliance. New or replacement foundations must
Packet Pg. 1599
1.5.b
comply, without requiring SUSD determinations.
DEM's guidance listed in Resources is based on FEMA
P-758.
Historic Buildings. The key to proper enforcement of
the flood provisions is whether a historic building meets
the exception in Sec. 1201.3. The FBC, Existing
Building defines "historic buildings," however, the
definition is not entirely consistent with the definition
used by the NFIP. The NFIP allows historic buildings in
flood hazard areas to be improved and repaired without
bringing them into compliance provided the buildings
are qualified. Importantly, any proposed work must not
preclude such buildings from continued listing as
historic. FEMA guidance suggests building officials
require applicants to obtain evidence of continued
designation from the appropriate authority or a qualified
historic resources professional.
Relocated or Moved Buildings. Sec. 1302.6 specifies
that buildings relocated or moved into flood hazard
areas are required to comply with the flood provisions
of Sec.1612 or R322, as applicable (no determination of
substantial improvement). This means new foundations
must meet the elevation and other requirements based
on the flood zone of the new location.
Prescriptive Compliance. The sections that articulate the
prescriptive compliance method for additions,
alterations, and repairs and each specify that if the work
constitutes SUSD, then the existing building must be
brought into compliance with the requirements for new
construction (Chapter 4). Similarly, the performance
compliance method includes the same requirement
(Chapter 14).
FBC, Mechanical, Plumbing, Fuel
Gas
Each of the mechanical, plumbing and fuel gas codes
includes similar provisions requiring equipment and systems
to be located at or above the elevation specified in Sec.
1612.4 (thus matching the elevation of the building) or to
meet a specific performance expectation that generally
cannot be met by typical installations. See Table 1612.1 for
a listing of all flood provisions in these codes. Of particular
note:
• Each code specifies that systems and equipment shall
not be mounted on or penetrate walls intended to break
away under flood loads (applies in Zone V and Coastal
A Zones).
• FBC, Mechanical requires ducts to be located above the
elevation specified in Sec. 1612.4 or designed and
constructed to prevent water from entering or
accumulating and to resist flood loads.
Local Floodplain ManageI t
Regulations
Florida communities adopt local floodplain management
regulations to regulate development activities in identified
flood hazard areas. The regulations (typically called
"ordinances"), in conjunction with the Florida Building
Code, meet or exceed the minimum requirements of the
NFIP. Development other than buildings includes
subdivision of land; filling, grading, and other site
improvements and utility installations; placement, installation,
or replacement of manufactured homes and manufactured
buildings; installation or replacement of tanks; placement of
recreational vehicles; installation of swimming pools; and any
other development. Importantly, to fulfill the NFIP
requirements, floodplain management ordinances also
regulate structures, and facilities that are exempt from the
Florida Building Code.
Local floodplain management regulations are administered
in conjunction with the Florida Building Code. Key features
include:
• Adoption of Flood Insurance Studies and FIRMS to
establish flood hazard areas (flood zones).
• Designation of the Floodplain Administrator; in many
communities, the Building Official is designated the
Floodplain Administrator, while in others the position is
assigned to a different office.
• Duties of the Floodplain Administrator, including
review of applications for development other than
buildings, inspection of permitted development and
flood hazard areas, maintenance of records.
Details of the process for making substantial damage
and substantial improvement determinations.
Specifications for determining flood elevations in areas
without BFEs on FIRMS.
Procedures, limitations, and conditions for evaluating
requests for variances, including variances from the
flood provisions of the Florida Building Code.
• Requirements for the following:
— Subdivisions, including manufactured home parks
and subdivisions
— Site improvements and utilities (sanitary sewage
facilities and water supply facilities)
— Placement of fill
— Manufactured homes, recreational vehicles
(including park trailers)
— Tanks (above -ground and underground)
Packet Pg. 1600
1.5.b
• Limitations on development in floodways, including fill,
fences, retaining walls, roads and watercourses, in
addition to buildings and structures. Applications must
be accompanied by analyses to determine proposed
activities do not increase flood levels.
• General requirements for any development not
specifically addressed, including:
— Anchoring to prevent flotation, collapse or lateral
movement resulting from flood loads
— Use of flood damage -resistant materials
— Mechanical, plumbing and electrical systems
elevated or protected
Assistance from DEM. DEM is designated by the
Governor to be the link between Florida communities and
the NFIP. Changes to floodplain management ordinances
should be reviewed by DEM prior to adoption. Contact
the State Floodplain Management Office for guidance.
DBPR Building Code Information System, 6tn Edition
Florida Building Code (2017), International Code
Council, Inc.; www.FloridaBuilding or .
DEM Local Ordinance & Building Code Resources
(excerpts of the FBC and Highlights of ASCE 24-14);
www.floridadisaster.orLMitigation/SFMP/lobe resources.
htm.
ASCE 7, Minimum Design Loads for Buildings and Other
Structures (2010).
ASCE 24, Flood Resistant Design and Construction (2014).
FEMA, Recommended Procedures for Flood Velocity Data
Development (November 2012), ,,e �nia,g;rty/l,ng,,rkll,,,,,
ra y/bi,ssrts/docrarnie nts/2�D94 .
FEMA P-55, Coastal Construction Manual (Fourth Edition,
April 2011); jy/ yie nt.:.,g"rev/lt,iF•"::<t::°.
1i b�bo�y/rise is/doc;i.i.iiierits/ 293.
FEMA P-936, Floodproofing Non -Residential Buildings
(July 2013) ��yjy ie Lnirl....)ov/m(.,.( is
J.ib a y/bi,sse„kts/rkoc.r,a_I,n, F I;rt;s/3 427,f).
FEMA P-758, Substantial Improvement/Substantial
Damage Desk Reference (May 2010);
tn1.V "l,.D /l.n1e.:...:<d::".
J. ib n y/bi,ssekts rkoc.r%I.n ,,I;rts/.:a:...:5.62,.
NFIP Technical Bulletins: A series of guidance on a
variety of floodplain management topics;
nl.t.:.": ;v;/I;n, F.....:<t::°:1 ........<.t:: /pe;.'. r;ra....c............::°.
docrarnisprits/collr°ctiorrs/4.
.......................................................................................................................................
Answeirs to SpecificQuestions
Florida Division of Emergency Management, State
Floodplain Program Office: 1-850-487-4556 and
floodsLyem.myflorida. corn.
Florida Building Commission: 1-850-487-1824 and
www.FloridaBtiilding.org.
]Don't know where to gar for an answer to a specific
question?
Contact Building A Safer Florida, Inc. 1-850-222-2772 and
o�/o�/o��...��,r,a,i,l,rk n
Packet Pg. 1601
741
(aullawil'8 nnalnab sdew pools 1=Ib21(3) aullawil dew-;;eaa quawq:
v (auiIawil 18 MOIAab sdew pools J=IVH4) nuoO- 88(]AVN 6Z4nJN :IU8WPBPV r�
0
m
a
Q
E
C6
X
W
O
.N
N
O
U
00
00
Q
z
O
rn
N
z
1.5.e
1
Monroe County
The Florida Keys
NEWS RELEASE
For Immediate Release
Aug. 22, 2019
Kristen Livengood, Public Information Officer
305-680-8226, Lve_ngood-Kristen@monroecounty-fl.gov
MONROE COUNTY, FL - The Federal Emergency Management Agency (FEMA) multi -year study of
Monroe County's coastal flood risks has reached its next step with the release of the new DRAFT Coastal
Flood Maps to County staff yesterday. The County has made the DRAFT maps available to view
at www.monroecounty-fl.gov/floodmaps so property owners can see potential changes to their flood
zone. FEMA has stressed that these are DRAFT flood maps.
The public can email comments on draft maps to floodmaps@monroecounty-fl.gov. County staff will be
documenting these comments and providing them informally to FEMA.
The County has hired a consultant to analyze how flood risks are changing in Unincorporated Monroe
County based on the provided studies using updated information and the best available science and
technology. After draft maps are reviewed by county staff, PRELIMINARY maps will be issued, which the
public will then have an opportunity to comment on officially through Community meetings.
When preliminary maps are published, formal public comments or appeals of the preliminary maps can
then be provided to FEMA by local governments like the County, or the municipalities. Once FEMA
completes the review of all comments and appeals, they will publish the final Flood Insurance Rate
Maps (FIRMS).
Coastal Flood Maps, otherwise known as Flood Insurance Rate Maps (FIRMS) are used to determine the
minimum elevation needed for construction to reduce the chances of flooding, as well as construction
methods required in certain zones.
"While the flood maps we received are drafts, we believe that property owners should be able to see
how their risks might change," said Christine Hurley, Monroe County Assistant County Administrator.
"That way they can be more proactive in reducing their flood risk, whether that means building higher if
they are planning on making improvements to their property or buying flood insurance now to reduce
any potential insurance cost increases."
To emphasize that flood risks are changing and to make sure property owners understand this is coming,
Hurley said permit applicants will sign a form on the County's permit application indicating they know
the maps will be changing. This is intended to help homeowners understand that what they might be
proposing to build today, under the existing flood maps, could become non -conforming after the maps
are changed, thereby making their flood risk and insurance costs greater. It could help them think
Packet Pg. 1604
1.5.e
about designing their improvements to meet the proposed, draft maps to assure they are addressing
potential future risk.
The technical consultant will also be reviewing the maps and modeling conducted by FEMA
and is prepared to appeal any of the maps that do not appear to be correct.
The FINAL flood maps (FIRMS) will most likely become effective sometime in 2021-2022. When that
happens, the county will formally adopt the maps by ordinance and the maps will be used when
reviewing permits and the final maps will establish what a finished floor elevation needs to be and
determine building and site design requirements to reduce future risk of flooding. Further, new lender
requirements may go into effect, as will any changes in flood insurance rates that result from the map
changes.
The following diagram shows the tentative process timeline for the Draft Maps, Preliminary Maps, and
Final Ma
Iuiaff Flood Insurance Rate Maps (FIRMI) Issued l for local government Review
"uicllllliiuimuuuuruiw Flood Insurance Rate Map (FIRM) Issued for public review
Community Meeting and Flood Risk Open, Houses Held
Appeal Period l (Ends
For more information about the mapping process, email FloodMap SMonroeCounty-FL.gov or call 305-
453-8759. To learn more about flood insurance, talk to your insurance agent or visit FloodSmart.gov.
Packet Pg. 1605
1.5.f
What is Risk MAP?
Risk Mapping, Assessment, and Planning (Risk MAP) is the Federal Emergency
Management Agency (FEMA) Program that provides communities with flood
information and tools they can use to enhance their mitigation plans and take
action to better protect their citizens. Through more precise flood mapping
products, risk assessment tools, and planning and outreach support, Risk MAP
strengthens local ability to make informed decisions about reducing risk.
I.aslf:.13.
Through collaboration with State,
Tribal, and local entities, Risk MAP
delivers quality data that increases
public awareness and leads to action
that reduces risk to life and property.
Risk MAP focuses on products and
services beyond the traditional Flood
Insurance Rate Map (FIRM) and works
with officials to help put flood risk data
and assessment tools to use, effectively
rramfom NWkRedwe ffisk Map Risk Data
',�
Plan 4mv Risk eo.11 lr'kufum Rwkfi
GUM— mearwre
94 mr0ifiaimre rrwslif
L AVN%�, Nedurrnon A
communicating risk to citizens and
enabling communities to enhance their mitigation plans and actions.
Building on the Risk MAP Multi -Year Plan, FEMA has developed a Risk MAP
Solution to achieve the Program's vision. The Solution identifies new strategies
and products designed to achieve the goals and objectives laid out in the vision.
These strategies and products address project prioritization, elevation data
acquisition, a watershed study approach, engineering and mapping, risk
assessment, mitigation planning support, and risk communications. The
following sections provide the overall objective of each of these strategies.
Goal 1: Data Gaps
Goal 2: Awareness &
Goal 3: Mitigation
Goal 4: Digital
Goal 5: Synergize
Understanding
Planning
Platform
Programs
Address gaps in flood
Measurably increase public's
Lead effective engagement
Provide an enhanced digital
Align Risk Analysis
hazard data
awareness & understanding
in Mitigation Planning
platform
programs and develop
I.=
The Risk MAP Team
FEMA's ten Regional Offices
implement Risk MAP at the local
level through close collaboration
with community officials.
FEMA Headquarters provides
direction, policy, and guidance to
enable consistent
implementation nationwide.
State, regional, Tribal, and local
communities can use enhanced
hazard data to make more
informed decisions regarding
risk.
FEMA's Risk MAP Multi -Year Plan
and FY12 Report to Congress
On March 16, 2009, Congress
approved the Risk MAP Multi -
Year Plan for fiscal years 2010 to
2014. The document outlines
the goals, objectives, and
strategies for Risk MAP and
summarizes FEMA's strategic
planning approach and
stakeholder roles and
responsibilities. For more
information please visit
blip::/Zwww,relrttna ov/IrnaUonall-.
:.......................................:.......p Iralr>m...0 Ir>mullti...
.hood IIIYn ulra.Yn e IrQ7.„
y g!.Ir l: l ..d.::::In, x;a rd::::lid.�'.irS.:f.li.:f.ii,ca f,ii, ,Im.::::
aka lrn.
FEMA's Risk Mapping,
Assessment, and Planning (Risk
MAP) Fiscal Year 2012 Report to
Congress, dated February 23,
2012, provides an update on
FEMA's strategic approach,
program budget and measures,
and implementation for Risk
MAP. For more information
about the report please visit
!h..fp/„/www,'rerirfin:�,govllliibrairy/viie
wlRecord,do?JA : 924.
................................................................................................................................
P 0
dskIWAP
Increasing Resilience Together
octolber 2012 vvvvvv.ferna.gov/rrn main :I.. 877 l::I:..NA MAl::"
Packet Pg. 1606
1.5.f
R rt::)'j c1;
Guides FEMA's investments in engineering, mapping,
assessment; and planning support in order to achieve Risk
MAP objectives
IN Applies a quantitative approach to determine which
communities FEMA will study
rq
r ..x
va1.It'::):III. CJl1;J1 Acqu.Iayll.I0:I3
Improves engineering data dnd supports risk assessment
data development
IN Elevation data is essential to the accuracy and reliability
of flood hazard data
IN Updated digital elevation data enables better risk
assessments
IN Detailed, digital elevation data supports innovative risk
communication products
a�; Iray:ll . � � �:�al.�:: .:II::II Ire: �°:III.
Improves engineering credibility and opens the door to
understanding risks in a more holistic, comprehensive way
N Encourages work across community boundaries and a
more comprehensive understanding of flooding
IN Allows for a better understanding of flood hazards as a
result of more comprehensive assessments of stream and
tributary relationships
IN Provides a framework to evaluate flood risk, engineering
need, elevation data acquisition availability and gaps, and
availability of community contribution by watershed
11.1 la.:ll� `:Ir �.:ll� a la a ll:3 ll.� �.:ll�.
Identifies flood hazards, provides local floodplain
management data, supports the National Flood Insurance
Program (NFIP), and provides data for risk assessments and
mitigation plans for flood hazards
IN Includes the scientific collection, processing, and analysis
of flood hazard data to provide communities with
accurate flood maps and risk assessment products
IN Engineering and mapping data provide the foundation for
more effective risk communications through assessments
and also enable effective mitigation at the local level
IN Includes significant investments in the flood mapping of
areas impacted by levees and coastal flood hazard
Outcome.,
Sene "
Increase. in
precision of
products
Effective risb
assessment+
mitigation pi
Communitw
communGcat,
more effecti%
Illkislk. .ayayeayay:IC:I:..1el t
Allows communities to make informed mitigation decisions
by providing products and technologies that communicate
and visualize risks
IN Equips communities with the information and tools they
need to develop effective mitigation plans
IN Provides communities with flood risk information
through a Flood Risk Report, Flood Risk Map, and Flood
RiskDatabase
. itig t .o.n..P:II.a.11.1I.1.:III Su.:Rlpt:'):Irt
Provides technical assistance, Mcentivizes risk reduction
activities at the local level, and develops the programmatic
infrastructure to monitor community efforts
IN Enables communities to assess risks and identify actions
to reduce vulnerability to those risks
IN Enhances collaboration with and among local stakeholders
IN Provides tools to improve communities' understanding of
risk and facilitate mitigation planning and local risk
reduction efforts
IN Incentivizes local effective mitigation planning and risk
reduction activities
Motivates citizens to make informed decisions regarding their
risks and encourages communities to take the lead in
protecting their constituents
IN Enhances local capabilities to communicate effectively
with constituents about risk
IN Allows for an exchange of information about risk
between FEMA and other stakeholders
IN Provides customizable communications plans, key
messages, and materials to communities
IN Facilitates national and local collaboration through key
partnerships
P 0
dskIWAP
gncreas'ing Resilience Together
Octolbeir 21112 www.ferna.gov/rrn maim fl.. 877 1::I:..NA MAll::"
Packet Pg. 1607
C
Adoption of Flood Insurance Rate
Maps by Participating Communities
F:IIbodin g is the I-nost co ill- ii-n n and cosi]y natuur111 disaster in the United States, and it affeas
every State. i;`:IIbodin,(g can be caul ed by storlirns, dairns oil Illrevee Ilkr:r°rr n,(,,, new de^Ill llpurm:meart
dhaingiing how ateiur iIIIows zrllbove grind brdow OIhe girouind, slir owirulrlr°III , a:urrd ururrludIh ururr.oire. 11IIhe
NJ;rt:uloun;rlll Flood iunsu:uraunce i uro glinturulrl (NJi„1P) was estalllr:llhsIIhed to lireduce OIhe iiirurrainci; 111 uriisIIk. ibir
krurqkreurty o uireirs auir.d ureuirteurs 011r:urou :Ilkr iiuirsu:urauirce; iiuir r°r dllyalu:r r, COurulriurulrluuiroftirrs adqkrt i111.00dIlkrIII iil:urr.
uriil 14 111 1;ige uriill e uii t lireg a 1ki t ii o in s Ohat t Breduce Future flood d a hill i ap es. 111 i 11 llh ai.s i„ed e ir; 111
with the .Ilir e ofthe N afl n am l F.IIbod i ulrm. r.ii ra n.ce Act of] 968, ire ,(g�ilo w n to ii n d1 r.iu d e oven �°
21,000 .Ilkra urn ii � n ii Ilkr a t ii urr c o urul rl:urul ri a uir:i ( of r.s a:urr d to Ilkr urov i d e o e lir $1 t ur ii III Ill it o uir ii uir flood ii uir su :ura uir c e r. o r°:urage.
This brochure addresses several questions about how
communities adopt a Flood Insurance Rate Map (FIRM).
As a participant in the NFIP, your community is responsible
for making sure that its floodplain management regulations
meet or exceed the minimum requirements of the NFIP.
By law, the Department of Homeland Security's Federal
Emergency Management Agency (FEMA) cannot offer flood
insurance in communities that do not adopt and enforce
those regulations, which can be found in Title 44 of the
Code of Federal Regulations (CFR), Section 60.3. You can
also find them in model ordinances developed by most
States and by FEMA's Regional Offices.
The basis of your community's floodplain management
regulations is the flood hazard data FEMA provides.
In support of the NFIP, FEMA identifies flood hazards
nationwide and publishes and periodically updates flood
hazard data. These data are provided to communities
in the form of a Flood Insurance Rate Map (FIRM) and
Flood Insurance Study (FIS) report, typically prepared in
a countywide format. While an FIS report accompanies
most FIRMS, it is not created for all flood studies.
Knowing your flood hazards serves many important
purposes, including an increased awareness of the hazard,
especially for those who live and work in floodprone
areas. The FIRM and FIS report provide States and
communities with some of the information they need
for land use planning, to reduce the risk of floodplain
development, and to protect residents' health and safety
through codes and regulations. States and communities
also use the information for emergency management.
What liis theIpir ^ for devellollpilling I flood
hazailrd dataour irevilsiling exilstilingdata?
During the flood study process, FEMA coordinates
closely with communities to develop new flood risk
data or revise existing data. This coordination may lead
to new or updated flood hazard mapping (i.e., FIRM
and FIS report), flood risk assessment projects, and/or
mitigation planning assistance. In general, the process
includes the following activities, listed on the next page:
Floodplain management regulations include zoning
ordinances, subdivision regulations, building codes, health
regulations, and special purpose ordinances (such as a
floodplain ordinance, grading ordinance or erosion control
ordinance). The term describes any combination of these
State or local regulations that provides standards for
preventing and reducing flood damage.
1% Annual Chance Flood
Flootlway —
Flootl Flootl
Fringe Fringe
Adoption of Flood Insurance Rate Maps by Participating Communities
I111:::::'111ood Studyll tiiion I 111iui Ill
C
Multi -Year Process
*The timeframe for completing these activities may vary.
Under FEMA's Risk Mapping, Assessment, and Planning
(Risk MAP) program, FEMA with communities and
other local stakeholders engages in a Discovery process
to obtain a comprehensive picture of the community's
flooding issues, flood risk, and potential for flood
mitigation activities, including the adoption of more
restrictive floodplain management criteria. Stakeholders
vary, but they typically include local officials, Tribal
Nations, citizen associations, and representatives of
levee boards, conservation districts, and economic
development organizations. Information obtained
during the Discovery meeting helps determine whether
the community needs a flood risk assessment project,
including new or updated flood hazard data and a
corresponding FIRM and FIS report.
If new or revised flood hazard data is needed, including
an update to the FIRM and FIS report, FEMA works
with the communities and other Discovery stakeholders
to determine the parameters of the project, including
which flooding sources and their extent (how much of
the stream or coastline) to be studied.
A detailed flood study typically includes determining
the Base Flood Elevations (BFEs) and floodways for the
project area. In addition, the mapping process includes
activities such as obtaining the digital base map,
developing the FIRM's flood hazard database and,
when appropriate, incorporating or revalidating
previously issued Letters of Map Change, or LOMCs.
LOMCs include Letters of Map Revision (LOMRs),
Letters of Map Revision Based on Fill, and Letters of
Map Amendment, which are used to amend or revise
the effective FIRM and FIS report without physically
revising and republishing these materials.
When the study is complete, FEMA provides copies
of a preliminary FIRM and FIS report for review and
holds a Consultation Coordination Officer (CCO)
meeting for officials from the communities involved
in the study. FEMA may also hold public meetings —
often referred to as Open Houses —to introduce and
discuss the preliminary FIRM and FIS report with
community members.
• After the CCO meeting, FEMA initiates a 90-day period
for communities to submit appeals about the new or
modified flood hazard information shown on the FIRM.
This can include new or modified BFEs, base flood
depths, Special Flood Hazard Area (SFHA) boundaries or
zone designations or regulatory floodways, SFHAs, which
include all flood zones starting with the letters A or V, are
the areas subject to inundation by the base (I -percent-
annual-chance). FEMA will also accept comments
from communities regarding the study. Comments are
objections to a base map feature modification/addition,
One of the many homes that was flooded in Denham Springs, LA after
prolonged rainfall devastated the community. August 2016
Adoption of Flood Insurance Rate Maps by Participating Communities
C
Aerial view of the flooding from Hurricane Florence Bladen County, NC, September 18, 2018
update to the Flood Insurance Study (FIS) report
materials or any other non -appealable change.
Comments usually involve changes to items such as
road locations and road names, corporate limits
updates, or other base map features.
• Before the appeal period is initiated, FEMA will publish
a notice of proposed flood hazard determinations in
the Federal Register and notify the community's Chief
Executive Officer. FEMA will then publish information
about the flood hazard determinations at least twice in a
local newspaper. The appeal period provides community
officials and people who own or lease property in the
community an opportunity to submit scientific or
technical information if they believe the flood hazard
determinations are scientifically or technically incorrect.
• Following the 90-day appeal period, FEMA resolves
all appeals and finalizes the changes to the FIRM and
FIS report.
• FEMA then sends each affected community a Letter
of Final Determination (LFD), which establishes the
final flood hazard data and the effective date of the
new FIRM and FIS report for the community. The
LFD also initiates the six-month period during which
each community must adopt or amend its floodplain
management regulations to reference the date and title
of the new FIRM and FIS report.
• The FIRM and FIS report become effective at the end
of the six-month period. At that time, flood insurance
rates will be based on the new flood data, and the
community will apply any floodplain management
ordinances related to the new mapping. Federally
insured or regulated lenders will also use the newly
effective FIRM to determine if flood insurance is
required as a condition of a loan.
Almost 300 communities, States, and regional agencies
have entered into agreements with FEMA to be
active partners in flood hazard mapping under the
Cooperating Technical Partners (CTP) program. These
agencies participate by developing and updating FIRMs
and performing related activities. (See the box on the
inside of the back cover page for a brief description of
the CTP program.)
What imust an NF11Fk,,,,,,,,Il ur°1:iii iiill tiiiin inimuniii°t
do wh in 11::::'111::::]MA pir viii ^ inew or iirevilised flood
hazailrd data?
Each time FEMA provides your community with new
or revised flood hazard data, you must either adopt
new floodplain management regulations to incorporate
the data into your ordinance or amend the existing
ones to reference the new FIRM and FIS report.
Community floodplain management regulations must
continue to meet any additional State requirements,
and should adopt them through a process that complies
with their State's requirements.
The following bullets will help you determine what
type of changes your community will need to make to
its floodplain management regulations when a new or
revised FIRM and FIS report are provided:
• If your community's floodplain management
regulations comply with the NFIP requirements when
the LFD is issued, you will only need to amend the
map reference section of your floodplain management
regulations to identify the new FIRM and FIS report.
4 Adoption of Flood Insurance Rate Maps by Participating Communities
C
FIRM
If your community has a legally valid automatic
adoption clause established in the map reference
section of the regulations, and the community's
regulations are otherwise compliant with the NFIP
requirements, you do not need to amend the floodplain
management regulations. Automatic adoption clauses
adopt all future revisions to the FIRM without further
action by the community, but they are not permitted
in many States.
If a new type of flood hazard data is added to your
FIRM, your ordinance may need to meet additional
requirements. This could apply when FEMA upgrades
a flood zone without BFEs (such as Zone A) to a flood
zone with BFEs (such as Zone AE) or adds a regulatory
floodway or a Zone VE coastal high hazard designation.
The LFD indicates the sections of the NFIP floodplain
management requirements at 44 CFR Section 60.3 that
your community must adopt, based on the type of
flood hazard data that has been provided.
You can contact the FEMA Regional Office or your State
NFIP Coordinating Agency for assistance on the specific
requirements your community will need to adopt.
(See the back cover page for contact information.)
If your community has adopted standards higher than the
minimum requirements of the NFIP and participates in
the Community Rating System (CRS), its residents may
qualify for a reduction to their flood insurance premiums.
(See page 7 for a description of the CRS.)
When imust a cornimunil-tyllpt the a ew our
iirevilised flood hazard data?
Your community must amend its existing floodplain
management regulations or adopt new regulations
before the effective date of the FIRM and FIS report,
which is identified in the LFD. The LFD initiates the
six-month adoption period.
Communities are encouraged to adopt the appropriate
floodplain management regulations as soon as possible
after the LFD is issued. The adopted regulations must be
submitted to FEMA and the State and be approved by FEMA
before the effective date of the FIRM and FIS report.
A community may request that their proposed regulations
be reviewed by the FEMA Regional Office at any time.
In return, the Regional Office may request a copy of the
adopted regulations from the community and may require
an amendment or revision if it is determined that the
community's regulations are non -compliant.
FEMA will send two letters notifying your community that
it must have approved floodplain management regulations
in place before the effective date of the FIRM. The first is sent
90 days before the FIRM's effective date, and the second is
sent 30 days before. The second letter notifies the community
that it will be suspended from the NFIP if it does not adopt
the FIRM in time. Notice of the potential suspension is also
published in the Federal Register.
If your community adopts or amends its floodplain
management regulations in time (before the effective
date of the FIRM and FIS report), and the FEMA Regional
Office approves your regulations, the suspension will not
go into effect, and the community will remain eligible to
participate in the NFIP.
What happens If a communlitydoes a of adollpt the
Il 11 iir 11 iiriii ate flood Il 111 lin irnainagerneint ir uuulll iii in
duirling the iii i m nth adollptilon Il eur
If a community does not adopt new floodplain management
regulations or amend its existing regulations and submit
the adopted regulations to FEMA before the effective
date of the FIRM and FIS report, the community will be
suspended from the NFIP. The following sanctions apply
if a community is suspended from the NFIP:
Property owners will not be able to purchase NFIP
flood insurance policies, and existing policies will
not be renewed.
Adoption of Flood Insurance Rate Maps by Participating Communities
C
One way to apply floodplain management requirements is to elevate structures in certain flood zones. The two images above show an elevated home on pile
foundation in a coastal community (left) and an elevated home on crawl space foundation in an inland community (right).
Federal grants or loans for development will not be
conventional loans for insurable buildings in flood
available in identified flood hazard areas. This applies
hazard areas of non -participating communities.
to funds from programs administered by Federal
However, the lender must notify applicants that the
agencies such as the Department of Housing and
property is in a flood hazard area and that the property
Urban Development, the Environmental Protection
is not eligible for Federal disaster assistance. Some
Agency, and the Small Business Administration.
lenders may voluntarily choose not to make these loans.
Federal disaster assistance will not be provided to
permanently repair insurable buildings in identified
flood hazard areas for damage caused by a flood.
Federal mortgage insurance or loan guarantees, such
as those written by the Federal Housing Administration
and the Department of Veteran Affairs, will not be
provided in identified flood hazard areas.
• Federally insured or regulated lending institutions,
such as banks and credit unions, are allowed to make
e
In accordance with the Flood Insurance Reform Act of 2004,
all of FEMA's flood mapping products are now prepared
digitally. Users have several different digital options for
viewing the flood hazard information shown on their
community's FIRM. All the digital flood hazard resources
referenced below can be accessed through FEMA's Map
Service Center (MSC) at I�_tta;.��rrc=_frr_ay.
Once the FIRM is effective, FEMA will provide your
community digital copies of the FIRM panels. These will
also be available through the MSC. Letters of Map Change
are also available through the MSC (in .pdf format).
FIRMettes show a section of a FIRM panel specified by a
user, plus the map scale, and other legend information
from the FIRM. FIRMettes can be created online through
the MSC and printed or saved in .pdf format at no cost.
The FIRM database is designed for use with Geographic
Information System (GIS) software. GIS users can integrate
their own local datasets with FEMA's flood hazard data in
the FIRM database to assist with floodplain management or
If your community is suspended from participation in
the NFIP, it may regain its eligibility by enacting the
floodplain management measures established in the NFIP
regulations (44 CFR 60.3). If development takes place in
your community during the period of suspension that
does not meet the minimum NFIP requirements, your
community will be asked to take actions to reduce the
increased flood hazard prior to its reinstatement.
mitigation planning. The FIRM database is provided to your
community once the FIRM becomes effective and can also
be downloaded through the MSC.
The National Flood Hazard Layer (NFHL) contains all
effective digital flood hazard information from FIRM
databases and LOMRs produced by FEMA, in one integrated
nationwide dataset. It also contains the point locations of
Letters of Map Revision Based on Fill and Letters of Map
Amendment. The NFHL is available for viewing through
FEMA's online map viewer. It can also be viewed as a layer
in Google Earth or accessed via Web Map Service (WMS),
a web -based method of viewing map information using
commercial GIS software. Additional information on these
services is available through the MSC.
Note for communities that do not yet have digitally produced
FIRMs: scanned digital versions of the paper FIRM panels are
available through the MSC. However, since the FIRMs were
not produced digitally, there is no FIRM database, and that
flood hazard information is not included in the NFHL.
Adoption of Flood Insurance Rate Maps by Participating Communities
C
One of the major objectives of the CTP program is to recognize
the States, regional agencies, and communities with proactive
floodplain management programs that include identifying
flood risk and getting the information incorporated into official
FEMA flood hazard data. The CTP program maintains national
standards consistent with the NFIP
Some of the benefits of being a CTP include:
CTPs can develop more detailed maps by making local
geospatial data a part of the FIRM.
CTPs receive support, such as access to existing data,
access to custom-made FEMA tools, technical assistance,
and national recognition.
CTPs receive mentoring support, online examples of
"best practices," and free training.
Communities that participate in the Community Rating
System and also become CTPs (or those in an area
covered by a regional or State CTP) may be eligible to
receive CRS credit for CTP activities.
Another major objective and benefit of the CTP program is
to share and leverage available funding and local data, to
make the most of limited resources. Communities, States,
and regional agencies can take advantage of these benefits
by entering into an agreement with FEMA that formalizes the
types of mapping activities and support the CTP will provide.
Almost 300 communities, States, and regional agencies
participate in the CTP program.
To learn more about becoming a CTP, visit ht W-S;f/or contact your
FEMA regional office (see back page for contact information).
rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrnr The NFIP Community
Rating System
recognizes community
floodplain management
practices that
exceed the minimum
requirements of the
NFIP The CRS
recognizes these efforts
by reducing the cost of
flood insurance premiums from 5 percent to 45 percent for
flood insurance policies in participating communities.
Many communities may already be involved in activities that
would earn credit under the CRS and reduce flood insurance
premiums for their residents. Here are a few examples:
Adopting and enforcing more protective building standards
that result in safer new construction
Informing the public about flood hazards and flood
insurance and about how to reduce flood damage
Preserving open space in the floodplain
To receive CRS credit, your community must submit a CRS
application that identifies the floodplain management practices
you are applying. (FEMA can help with the application.) After
FEMA reviews and verifies your application, the flood insurance
premium discounts will go into effect. The amount of the
discount depends on the number of CRS-credited activities
your community performs.
Community participation in the CRS has many benefits:
Discounts for flood insurance premiums from 5 percent
to 45 percent
Enhanced public safety
Reduced flood damage
Increased environmental protection
Informed community residents supporting improved flood
protection measures that will make their neighborhoods
safer from flood risks.
To learn more about CRS, visit ht W-S;f/vrvrvr.' uxu ,gspvl rpuauuauuT g y- u g y _ uxu.
Adoption of Flood Insurance Rate Maps by Participating Communities
FOR ASSISTANCE
If your community needs assistance to join the NFIP, you can contact the FEMA Regional Office
(see below for address and telephone number). You can also contact your
State Coordinating Agency for the NFIP You can go to https://www.fema.gov/fema-regional-contacts
for a listing of the FEMA Regional Offices or
http://www.floods.org/index.asp?menuI D=274&firstleveImenuI D=185&siteI D=1
for the NFIP State Coordinating Agencies.
REGION I
CT, ME, MA, NH, RI, VT
99 High Street
Boston, MA 02110
(877) 336-2734
REGION II
NJ, NY, PR, VI
26 Federal Plaza, Suite 1307
New York, NY 10278
(800) 611-6122
REGION III
DE, DC, MD, PA, VA, WV
615 Chestnut Street
One Independence Mall, 6' Floor
Philadelphia, PA 19106
(215) 931-5500
REGION IV
AL, FL, GA, KY, MS, NC, SC, TN
3003 Chamblee Tucker Road
Atlanta, GA 30341
(770) 220-5200
REGION V
IL, IN, MI, MN, OH, WI
536 South Clark Street, 6' Floor
Chicago, IL 60605
(312) 408-5500
REGION VI
AR, LA, NM, OK, TX
FRC 800 North Loop 288
Denton, TX 76209
(940) 898-5399
REGION VII
IA, KS, MO, NE
9221 Ward Parkway
Kansas City, MO 64114
(816) 283-7061
REGION VIII
CO, MT, ND, SD, UT, WY
Denver Federal Center
Building 710, Box 25267
Denver, CO 80225
(303) 235-4800
REGION IX
AZ, CA, HI, NV, American Samoa,
Guam, Marshall Islands,
and Northern Mariana Islands
1111 Broadway, Suite 1200
Oakland, CA 94607
(800) 611-6122
REGION X
AK, ID, OR, WA
Federal Regional Center
130 — 228' Street, Southwest
Bothell, WA 98021
(425) 487-4600
The Federal Emergency Management Agency (FEMA) has
undertaken a multi -year effort to better identify and communicate
the flood hazards and risks in coastal communities through coastal
engineering, analysis, and mapping.
New and updated coastal Flood Insurance Rate Maps (FIRMs)
communicate two elements of regulatory flood mapping: the area of
land at risk of inundation by the base (1-percent-annual-chance)
flood, and the associated flood elevation(s) in these areas, which are
called Base Flood Elevations. In addition to identifying these two
regulatory mapping elements, FEMA provides an informational line
called the Limit of Moderate Wave Action (LiMWA). This fact
sheet explains what the LiMWA is and why it should be of interest
to homeowners and local officials
Background on Coastal Zones
FIRMs in coastal areas identify two different flood zones:
Zone VE is mapped in areas that are subject to coastal
flooding with wave heights of 3 feet or higher. These areas
are referred to as Coastal High Hazard Areas (CHHAs).
• Zone AE is mapped in areas subject to coastal flooding with
wave heights of less than 3 feet.
For More Information
A FEMA fact sheet titled "Using the
Limit of Moderate Wave Action
(LiMWA) to Build Safer and Stronger
Coastal Communities" is available for
communities that want to learn more
about how they can use the LiMWA to
implement higher construction
standards.
Anyone interested in obtaining a copy
of that fact sheet should contact a
FEMA Map Specialist through the
FEMA Map Information eXchange
(FMIX). The FMIX can be reached by
telephone, toll free, at 1-877-FEMA
MAP (1-877-336-2627), choose
"Option 1"; by email at
femamapspecialist@riskmapcds.com;
or by live chat through
https://www.floodmaps.fema.gov/fbm/
The primary reason for having two different coastal flood zones is fmx_main.html.
that the risk of structural damage is higher within Zone VE, due to
the significant wave energy that can occur in these areas. As a result,
flood insurance rates are higher and building codes are stricter for
structures in Zone VE.
However, over the past decade, post -storm damage surveys have
confirmed that even wave heights as low as 1.5 feet can cause
significant structural damage to buildings that were not built to
withstand forces such as the wave hazards in VE zones.
October 2017
Packet Pg. 1616
On its recently updated FIRMs, FEMA notifies communities of the potential for significant wave damage by
using both the regulatory Zone VE designation (coastal flooding, plus waves of 3 feet or higher) and an
informational line depicting the extent of 1.5-foot wave heights. This line is called the LiMWA.
LiMWA and Coastal A Zone Mapping
Using the LiMWA shown on a FIRM, homeowners and communities can better understand which portions of
the areas identified as Zone AE are at risk for high wave energy. Those higher risk portions of Zone AE, the
areas between the LiMWA and the Zone VE boundary, are referred to as the Coastal A Zone. Figure 1 shows
how these hazards and zones are defined.
Once the coastal flood hazard analyses are complete, FEMA provides preliminary versions of the updated
FIRMs and Flood Insurance Study (FIS) reports to local officials and residents for their review and use. On the
updated FIRMs, the LiMWA is shown as a line with triangular arrows that point toward the area of higher
hazard —that is, toward Zone VE.
Wave height ! 3 ft 3 ft > Wave height > 1.5 ft Wave height < 1.5 ft BFE < 1 ft
Properly elevated (post -FIRM) building in CHHA
BFE including
gave effects
,,
w,.
1-percent-annual-
chance SWEL
N
Normal grater level»,
u�uu uuu uuu�
w.
Im7prope%
Shoreline
Beach
face
BFE = Ease Floods Elevation
cHHA= Coastal High Hazard Area
LiMWA = Limit of Moderate Wave Action
SWEL = Stilllwater Hood Elevation,
Best practice - Elevated
building in Coastal A Zone
Figure 1. Coastal Flood Zones. Not all coastal communities' FIRMS include LiMWA lines.
October 2017
Packet Pg. 1617
Figure 2 shows what the
LiMWA looks like on an
updated FIRM. Some flood
maps may include different
symbols to mark the LiMWA;
consult the map's legend for
details specific to your
community's flood map. Flood
maps may also be accessed
through FEMA's National
Flood Hazard (NFHL) digital
map webviewer. (NFHL users
should be aware that the
appearance of the LiMWA line
on the NFHL differs from that
on most FIRM panels.)
LiMWAs, Flood
Insurance, and Higher
Construction Standards
Figure 2. Sample updated FIRM showing Zone AE, the LiMWA, and Zone VE. Base
Flood Elevations for each zone are noted in parentheses below the Zone AE/VE text.
Property owners are encouraged
to build structures with a higher first floor and to purchase flood insurance. While the LiMWA is not a
regulatory element of the FIRM and has no effect on a structure's National Flood Insurance Program (NFIP)
flood zone status or on the rates for federal flood insurance premiums, some communities require Zone VE
building code standards in the Coastal A Zone. These communities use the LiMWA to determine where higher
construction standards are required.
Through the �. ��am�u,ut,,,,,;;1[tu„t�am�:':IE�S FEMA encourages sound floodplain management practices by
offering reduced insurance rates within communities that proactively adopt flood mitigation actions. In coastal
areas, CRS credits are offered to communities that use the LiMWA data to identify where structures should be
improved to withstand the higher wave energy expected within the Coastal A Zone. Communities that require
foundations designed and built to withstand Zone VE conditions in the Coastal A Zone can earn up to 225 CRS
points. Communities that regulate structures in all flood hazard zones to follow Zone VE standards can earn up
to 650 CRS points.
1 9 WNI,#-„ , I I I,
October 2017
Packet Pg. 1618
Peters -Katherine
FIMA — Overview—Fact—Sheet-201 6r
09/04/19 04:23 PM
I Packet Pg. 1619 1
Guidancefor !!1 Risk
Analysis and Mapping
Appeal 1 Comment ProcessinO
1.5.j
E
Packet Pg. 1622
1.5.j
Requirements for the Federal Emergency Management Agency (FEMA) Risk Mapping,
Assessment, and Planning (Risk MAP) Program are specified separately by statute, regulation,
or FEMA policy (primarily the Standards for Flood Risk Analysis and Mapping). This document
provides guidance to support the requirements and recommends approaches for effective and
efficient implementation. Alternate approaches that comply with all requirements are acceptable.
For more information, please visit the FEMA Guidelines and Standards for Flood Risk Analysis and
Mapping web a e yyyrLV. :ir m �r� u.�li� :llliir� :s ir�� s . ir�� ire s II � irlisllc ire ill slis ir�� it m liir� .
Copies of the Standards for Flood Risk Analysis and Mapping policy, related guidance, technical
references, and other information about the guidelines and standards development process are
all available here. You can also search directly by document title at wW fENrn ( oy/lliilk
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page i
Packet Pg. 1623
1.5.j
The following summary of changes details revisions to this document subsequent to its most
recent version in February 2018.
Affected Section or
Subsection
Date
Description
February
Revised Section 4.0 to provide separate subsections for Flood
Section 4.0
2019
Risk Projects and PMRs (4.1), LOMRs (4.2), and Property
Owner Education (4.3).
Section 8.0
February
Updated to indicate documents are accessible through the
2019
FEMA Guidelines and Standards for Flood Risk Analysis and
Mapping webpage.
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page ii
Packet Pg. 1624
1.5.j
HF-MYTTWOMMMPA
1.0
Introduction...........................................................................................................................1
2.0
Post -Preliminary Processing Timeline..................................................................................1
3.0
Determining if an Appeal Period is Required........................................................................
3
4.0
Appeal Period Initiation.........................................................................................................3
4.1 Appeal Period Initiation for Flood Risk Projects and PMRs...............................................3
4.2 Appeal Period Initiation for LOMRs...................................................................................4
5.0
Appeal and Comment Classification.....................................................................................4
6.0
Tracking and Archiving of Incoming Appeals and Comments...............................................6
6.1 Tracking and Archiving......................................................................................................
6
7.0
Evaluation of Data Submitted................................................................................................7
7.1 Mathematical or Measurement Error or Changed Physical Condition...............................8
7.2 Technically Incorrect..........................................................................................................8
7.3 Scientifically Incorrect......................................................................................................10
7.4 Flooding Sources Studied by Approximate Methods.......................................................10
7.5 Topographic Data............................................................................................................11
8.0
Appeal and Comment Resolution Process.........................................................................11
8.1 Determine if a Second Appeal Period is Required..........................................................15
9.0
Scientific Resolution Panel (SRP).......................................................................................16
9.1 SRP Process...................................................................................................................16
9.2 Supporting an SRP Evaluation........................................................................................19
9.3 SRP Outcomes and Recommendations..........................................................................19
Figure 1. Post -Preliminary Processing Timeline..............................................................................2
Figure 2. Appeal and Comment Resolution Overview...................................................................12
Figure3. SRP Process Chart.........................................................................................................17
Figure4. SRP Timeline..................................................................................................................18
Table 1: Appeal vs. Comment..........................................................................................................5
Table 2: Appeal and Comment Resolution Procedures.................................................................13
Appeal and Comment Processing
Guidance Document 26
E
February 2019
Page iii
Packet Pg. 1625
1.5.j
1.0 Introduction
This document provides the standard procedures that staff from the Department of Homeland
Security's Federal Emergency Management Agency (FEMA), FEMA contractors, and other
organizations that partner with FEMA are to follow for processing new and revised Flood
Insurance Study (FIS) reports and a Flood Insurance Rate Map (FIRM). Specifically, this
document provides guidance on appeal and comment processing procedures that occur during
the Post -Preliminary Processing (PPP) phase of a Flood Risk Project or Physical Map Revision
(PMR), or following a Letter of Map Revision (LOMR) issuance, as related to Title 44, Chapter 1,
Code of Federal Regulations (CFR) Part 67 and 42 U.S. Code § 4104(a)-(g) for flood hazard
determinations.
For those seeking to submit an appeal to FEMA, additional detail on the criteria for appealing
proposed changes in flood hazard information on FIRMs may be found in FEMA's Criteria for
Appeals of Flood Insurance Rate Maps.
2.0 Post -Preliminary Processing Timeline
Figure 1 depicts the overall PPP timeline of Flood Risk Projects or PMRs to demonstrate where
appeal and comment processing occurs. For LOMRs, appeal and comment processing occurs
following the LOMR issuance and prior to the LOMR effective date.
Detailed guidance on Key Decision Points (KDPs) and Quality Reviews (QRs) may be found in
Key Decision Point (KDP) Process Guidance and Quality Management for Flood Risk Projects
Guidance documents, respectively, at yr rw,fE.irna:,_ ��y�igj :. i Illilk ir2[y�c , , :�. /��oc� ,AirTm :ir�ts/w'. ,����w'3.
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 1
Packet Pg. 1626
Ui
ili�pl
i tounalli ,7� m
CN
co
M N 4)
C) 0)
cq co IL
L� CL
co
LL
0)
0
2
co
CN
E
E E
0 =
C) 0
0
Co C-)
co a
cu
0
1.5.j
3.0 Determining if an Appeal Period is Required
The National Flood Insurance Act of 1968, as amended, authorizes FEMA to conduct Flood
Risk Projects, PMRs, and LOMRs and prepare FIS Reports, FIRMs and FIRM databases to
identify and update flood risk zones and estimate the risk premium rates. Under the enabling
legislation, FEMA must provide communities with a 90-day appeal period when FEMA proposes
new or modified flood hazard information, i.e., Base Flood Elevations (BFEs), base flood
depths, Special Flood Hazard Areas (SFHAs), SFHA zone designations, and regulatory
floodways for a community.
When these changes occur, the designated Mapping Partner must determine if communities
affected by a Flood Risk Project, PMR, or LOMR should be afforded a statutory 90-day appeal
period. An appeal period is provided for all new or modified flood hazard information shown on a
FIRM, including when:
• New BFEs or base flood depths are proposed or currently effective BFEs or base flood
depths are modified;
• New SFHAs are proposed or the boundaries of currently effective SFHAs are modified;
• New SFHA zone designations are proposed or currently effective SFHA zone
designations are modified;
• New regulatory floodways are proposed or the boundaries of currently effective
regulatory floodways are modified.
Scenarios outlining when an appeal period is required can be found in FEMA's Post -Preliminary
Due Process Guidance. Prior to the 90-day appeal period, Mapping Partners responsible for
Due Process, should identify if the data or information shown on the Preliminary FIRM should
be revised based on data submitted during the initial 30-day comment period after Preliminary
Issuance. If changes to the Preliminary FIRM are warranted, the Regional Office may request
that the Mapping Partner prepare and issue a Revised Preliminary FIRM or FIS Report. The
updated preliminary information should be provided to all the communities impacted by the
revised information. Additional information on Revised Preliminary Issuance can be found in
FEMA's Preliminary Distribution and Revised Preliminary Guidance. Both guidance documents
can be found on IFIEMA_j qy, under FEMA Guidelines and Standards for Flood Risk Analysis.
4.0 Appeal Period Initiation U
4.1 Appeal Period Initiation for Flood Risk Projects and PMRs
Once the 30-day comment period has closed after Preliminary Issuance, any changes as a
result have been made and Revised Preliminary FIRM(s) and FIS Report are issued, this begins
the initiation of the 90-day appeal period. A statutory 90-day appeal period will be provided to
communities based on the criteria identified in Section 3.0. If it is determined that a community
is not eligible for the 90-day appeal period, the Regional Project Officer may provide
communities a 90- day comment period
If it is determined that a community requires a 90-day appeal or comment period, a series of
steps must be taken before it can be initiated. The steps to initiate Due Process can be found in
Appeal and Comment Processing February 2019
Guidance Document 26 Page 3
Packet Pg. 1628
1.5.j
FEMA's Post -Preliminary Due Process Guidance. In some situations, a second appeal period
may be required. This is discussed further in Subsection 8.1 of this document as part of the
appeal and comment resolution process. Education of Property Owners
In addition, in response to a requirement established by the U.S. Congress, Flood Risk Project
team members may need to work with the FEMA Regional Office of External Affairs, other
FEMA Regional Office staff, community officials, and local radio and television outlets to further
educate property owners about flood map revisions and the appeals process. Detailed
information on how Project Teams may help fulfill this requirement, including tools and
templates developed by FEMA Headquarters (HQ), is provided in two FEMA guidance
documents: Guidance for Stakeholder Engagement: Preliminary National Flood Insurance
Program Map Release Phase and Guidance for Stakeholder Engagement: Due Process Phase.
Both documents are accessible from the FEMA Guidelines and Standards for Flood Risk
Analysis and Mapping webpage.
4.2 Appeal Period Initiation for LOMRs
Upon completing a LOMR, the designated Mapping Partner will issue the LOMR and enclosures
to the community Chief Executive Officer (CEO), or designee, with copies to the community
floodplain administrator (FPA), other community officials and the revision requester for review
and comment. For LOMRs not requiring a statutory 90-day appeal period, the community may
receive a 30-day review period. A statutory 90-day appeal period is provided to the communities
for LOMRs based on the criteria identified in Section 3.0. The LOMR issuance and the proposed
flood hazard determination letter sent to start the appeal period are sent at the same time. Any
LOMR in a community already compliant with the necessary requirements outlined in 44 CFR
Section 60.3 that requires an appeal period will become effective 120 days from the second
newspaper publication date. LOMRs in communities that are not compliant with the necessary
requirements outlined in 44 CFR Section 60.3, or in communities that require adoption of the
LOMR, will become effective following a 6-month compliance period.
For additional information on initiating an appeal period for a LOMR, users should refer to Flood
Map Revision Processes content on I µllw lr (ov.
5.0 Appeal and Comment Classification
The data and information provided by communities during a Flood Risk Project, PMR, or LOMR
are classified as either a comment or an appeal and resolved by following the procedures
discussed in this guidance. While FEMA considers all information and data submitted by a
community throughout the Flood Risk Project, PMR, or LOMR lifecycle, the criteria for data
submittals that classify as an appeal are outlined in Title 44, Chapter 1, CFR, Section 67.6(b)
(44 CFR Section 67.6(b)) and in this document.
The sole basis of appeal is the possession of knowledge or information indicating that the flood
hazard determinations proposed by FEMA are scientifically or technically incorrect. Scientific
and technical correctness is often a matter of degree rather than absolute (except where
mathematical or measurement error or changed physical conditions can be demonstrated). Due
to this, appellants are required to demonstrate that alternative methods or applications result in
more correct estimates of flood hazard determinations, thus, demonstrating that FEMA's
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 4
Packet Pg. 1629
1.5.j
estimates are incorrect. Classification of submitted data and information as either an appeal or a
comment is dependent on the factors outlined in Table 1.
Table 1 peal vs, Coirnirnein'
Appellant is either the community or the owner or I Submitter does not need to be the community or the
lessee of a property, and the appellant believes
their property rights have been impacted by the
proposed flood hazard determinations.
Data or information is received during statutory
90-day appeal period.
Data or information submitted relates to areas
where the Flood Risk Project, PMR, or LOMR has
introduced new or revised BFEs, base flood
depth, SFHA boundaries (including increases or
decreases in the extent of the SFHA), SFHA zone
designation, and regulatory floodway boundaries
(including increases or decreases in the extent of
the regulatory floodway).
Analyses and data submitted are certified by a
registered professional engineer or licensed land
surveyor, as appropriate, such as when providing
supporting data of the new data necessary for
FEMA to conduct a reanalysis when it is believed
the proposed BFEs are technically incorrect due to
a mathematical or measurement error or changed
physical conditions (44 CFR Section 67.6(b)(1))
or when alternate data utilized or measurements
made (such as topographic information) are
provided to demonstrate the proposed BFEs are
technically incorrect due to error in application of
hydrologic, hydraulic, or other methods or use of
inferior data in applying such methods (44 CFR
Section 67.6(b)(2)).
owner or lessee of a property or believe their property
rights are impacted by the proposed flood hazard
determinations.
Data or information is received before or after the
statutory 90-day appeal period.
Note: A submittal of data or information outside of the
statutory 90-day appeal period or related to areas
unrevised for the study is considered to be a
comment, regardless of the type of data and
documentation submitted. FEMA will review all such
comments and resolve them as appropriate.
Data or information submitted relates to proposed
flood hazard changes that were not introduced as a
result of the Flood Risk Project or PMR or are
unrelated to flood hazard determinations.
Analyses and data submitted are not certified by a
registered professional engineer or licensed land
surveyor when they otherwise would be required per
44 CFR Section 67.6(b)(1) or 44 CFR Section
67.6(b)(2).
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 5
Packet Pg. 1630
1.5.j
Appeals
Comments
• Data or information submitted identifies that
If data that would typically be classified as an appeal
the proposed flood hazard determinations are
are submitted outside of the statutory 90-day appeal
technically incorrect due to a mathematical or
period, or if data received during the appeal period
measurement error or changed physical
are determined to be incomplete, the data will be
conditions. The specific source of the error is
classified as a comment. However, FEMA will fully
identified. Supporting data are furnished to
assess all information provided, regardless of when it
FEMA necessary for FEMA to conduct a
was submitted, and resolve the comment as
reanalysis.
appropriate.
• Data or information submitted identifies that
the proposed flood hazard determinations are
technically incorrect due to error in application
of hydrologic, hydraulic, or other methods or
use of inferior data in applying such methods.
• Data or information submitted identifies the
proposed flood hazard determinations are
scientifically incorrect.
Although the statutory 90-day appeal period cannot be extended for any reason, FEMA will
evaluate all data and information submitted in support of a request to change the FIS Report or
FIRM during a Flood Risk Project, PMR, or LOMR and respond to the request as appropriate,
regardless of when it is received. Resolution may therefore not result in incorporation of the data
or information provided in the revised FIS Report or FIRM.
6.0 Tracking and Archiving of Incoming Appeals and Comments
Throughout a Flood Risk Project, PMR, or LOMR, impacted communities may provide data or
information related to the study area to FEMA or the designated Mapping Partner. Information
submitted by the public related to appeals must be sent directly to the community CEO.
Comments also should be sent directly to the community CEO for consideration. The
community should review and consolidate all appeals and issue a written opinion stating
whether there is sufficient scientific and technical data to justify an appeal on behalf of the
property owner or lessee. The community must forward all appeals and comments that it
receives, along with its decision to appeal or not appeal on behalf of the property owner or
lessee, to FEMA or the designated Mapping Partner such that it is received not later than 90
days after the appeal period start date, not including the date of the second newspaper
publication.
6.1 Tracking and Archiving
The Mapping Partner responsible for the Flood Risk Project, and the Mapping Partner
responsible for Due Process must track all incoming comment and appeal correspondence,
acknowledgement letters, and resolution letters, as these will all be required as part of the Flood
Elevation Determination Docket (FEDD) file, described in the Technical Support Data Notebook
and Flood Elevation Determination Docket FEMA Guidance document.
All correspondence pertaining to the appeal and comments received for a study should be
uploaded to this task, including, but not limited too; Acknowledgement Letters, Resolution
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 6
Packet Pg. 1631
1.5.j
Letters, and any intermittent correspondence pertaining to the resolution of the appeal/comment
must be uploaded through FEMA's Mapping Information Platform (MIP), "Record
Appeal/Comment" task. This task also tracks critical information that must be recorded within
the task that includes; community information, type of and status of the Appeal/Comment, basis
of the Appeal/Comment, whether sufficient data was received, the date the data was received,
acknowledgment and community contact dates. Information within this task needs to be updated
through the resolution period, until the Appeal/Comment is resolved.
Requirements for the "Record Appeal/Comment" task include; ensuring that data within this task
is updated as soon as possible upon receiving appeal/comment, updating the status of this task
every month during resolution, and ensure that this task is to be submitted and validate by
FEMA HQ or their designee, before KDP5 is submitted to the FEMA Regional Office.
For information on PPP deliverables to be uploaded to the MIP and the appropriate MIP tasks to
complete during the due process purchase, please see FEMA's Data Capture Technical
Reference and Post -Preliminary Deliverables Guidance documents. Both documents are
accessible from the FEMA Guidelines and Standards for Flood Risk Analysis and Mapping
webpage.
7.0 Evaluation of Data Submitted
To assist FEMA in the evaluation of data submitted during a Flood Risk Project, PMR, or LOMR,
the designated Mapping Partner should review and evaluate the submittal, determine if the data
and information fit the criteria for a comment or appeal, request additional data or clarifications
as appropriate, and recommend resolutions to FEMA for all appeals and comments submitted
during the statutory 90-day appeal period as well as for any comments submitted outside of the
statutory 90-day appeal period. The regulatory requirements for appeal data submittals are
outlined in 44 CFR Section 67.6(b) and in this document. For those seeking to submit an appeal
to FEMA, additional detail may be found in FEMA's Criteria for Appeals of Flood Insurance Rate
Maps.
FEMA and the designated Mapping Partner will evaluate and acknowledge the appeal or
comment in a timely manner as soon as the data or information are received. Appeals and
comments may not be resolved until after the statutory 90-day appeal period has ended and
additional community consultation has occurred.
Subsections 7.1 through 7.5 provide an overview of what data and information are important to @
receive to properly assess an appeal. If the data or information are not received as part of the
original submittal, FEMA, in coordination with the designated Mapping Partner, may choose to
request additional information or clarification to properly review the data or information
submitted during the 90-day appeal period. While FEMA may consider data and information for E
incorporation at any time throughout the Flood Risk Project or PMR, no new appeals will be
accepted after the 90-day appeal period has elapsed.
Appeal and Comment Processing February 2019
Guidance Document 26 Page 7
Packet Pg. 1632
1.5.j
7.1 Mathematical or Measurement Error or Changed Physical Condition
To determine if a mathematical or measurement error or changed physical conditions has
occurred, the specific source of the error must be identified as per 44 CFR Section 67.6(b)(1).
The following should be submitted:
• Information or data to demonstrate the application of the methodology included
indisputable mathematical or measurement errors.
o To show that a mathematical error was made, an appellant must identify the
error. FEMA will perform any required calculations and make the necessary
changes to the FIS Report and FIRM.
o To show that a measurement error (e.g., an incorrect surveyed elevation used in
the Flood Risk Project) was made, appellants must identify the error and provide
the correct measurement. Any new survey data must be certified by a registered
professional engineer or licensed land surveyor. FEMA will perform any required
calculations and make the necessary changes to the FIS Report and FIRM.
• Information or data to demonstrate the methodology did not account for the effects of
natural physical changes that have occurred in the floodplain.
o For appeals based on the effects of natural physical changes that have occurred
in the floodplain, appellants must identify the changes that have occurred and
provide the data FEMA needs to perform a revised analysis. The data may
include new stream channel and floodplain cross sections or coastal transects.
7.2 Technically Incorrect
The proposed BFEs, base flood depths, SFHA zone designations, or regulatory floodways are
considered technically incorrect if the methodology was not applied correctly or the methodology
was based on insufficient or poor -quality data, as per 44 CFR Section 67.6(b)(2).
7.2.1 Methodology Not Applied Correctly
To demonstrate that a hydrologic methodology was not applied correctly, the following should
be submitted:
• New hydrologic analysis in which the original methodology has been applied differently.
• An explanation for superiority of the new application.
• New hydraulic/floodway or coastal analysis based on flood discharge values from the
new hydrologic analysis.
• A revised summary of discharges table and/or Flood Profiles and, if applicable,
Floodway Data Table (FDT).
• Revised SFHA boundary delineations and, if applicable, regulatory floodway boundary
delineations
Appeal and Comment Processing February 2019
Guidance Document 26 Page 8
Packet Pg. 1633
1.5.j
To demonstrate that a hydraulic methodology was not applied correctly, the following should be
submitted:
• New hydraulic/floodway analysis, based on the original flood discharge values, in which
the original methodology has been applied differently.
• Revised Flood Profiles, FDT, and other FIS Report tables, as applicable.
• Revised SFHA boundary delineations and, if applicable, regulatory floodway boundary
delineations.
To demonstrate that a coastal methodology was not applied correctly, the following should be
submitted:
• New coastal analysis, based on the original stillwater elevations, in which the original
methodology has been applied differently.
• Revised SFHA boundary delineations and all applicable FIS Report tables, including the
transect data table.
7.2.2 Methodology Based on Insufficient or Poor -Quality Data
To demonstrate that insufficient or poor -quality hydrologic data were used, the following should
be submitted:
• Data believed to be better than those used in the original hydrologic analysis.
• Documentation for the source of the data.
• An explanation of the improvement resulting from use of the new data.
• New hydrologic analysis based on the better data.
• New hydraulic/floodway or coastal analysis based on flood discharge values resulting
from the new hydrologic analysis.
• A revised summary of discharges table, Flood Profiles and, if applicable, FDT.
• Revised SFHA boundary delineations and, if applicable, regulatory floodway boundary
delineations.
To demonstrate that insufficient or poor -quality hydraulic data were used, the following should
be submitted:
• Data believed to be better than those used in the original hydraulic analysis.
• Documentation for the source of the new data.
• An explanation of the improvement resulting from use of the new data.
• New hydraulic analysis based on the better data and the original flood discharge values.
• Revised flood Profiles and, if applicable, FDT.
• Revised SFHA boundary delineations and, if applicable, regulatory floodway boundary
delineations.
Appeal and Comment Processing February 2019
Guidance Document 26 Page 9
Packet Pg. 1634
1.5.j
To demonstrate that insufficient or poor -quality coastal analysis data were used, the following
should be submitted:
• Data believed to be better than those used in the original coastal analysis.
• Documentation for the source of the new data.
• An explanation for of the improvement resulting from use of the new data.
• New coastal analysis based on the better data and the original stillwater elevation
values.
• Revised SFHA boundary delineations and all applicable FIS report tables, including the
transect data table.
7.3 Scientifically Incorrect
Proposed BFEs, base flood depths, SFHA zone designations, or regulatory floodways are
scientifically incorrect if the methodology used in the determination of the BFEs, base flood
depths, SFHA zone designations, or regulatory floodways is inappropriate or incorrect, or if the
assumptions made as part of the methodology are inappropriate or incorrect, as per 44 CFR
Section 67.6(b)(3). To show that an inappropriate or incorrect coastal, hydraulic, or hydrologic
methodology has been used, the following should be submitted, if applicable:
• New hydrologic analysis based on an alternative methodology and, if applicable,
updated hydraulic/floodway or coastal analyses based on the updated discharge values.
• New hydraulic/floodway analysis based on an alternative methodology and the original
flood discharge values (if the appeal does not involve the hydrologic analysis).
• New coastal analyses based on an alternative methodology and the original stillwater
elevations (if the appeal does not involve the hydrologic analysis).
• An explanation for the superiority of an alternative methodology.
• As applicable, a revised Summary of Discharges Table, Flood Profiles, Transect Data
Table, Summary of Stillwater Elevations Table, and FDT.
• Revised SFHA zone boundaries and, if applicable, regulatory floodway boundary
delineations.
A list of hydrologic, hydraulic, and coastal models accepted by the National Flood Insurance
g vrvr.:irm �rir�u.irrm,irii ill im`Il irm::(.iiir�w.
Proram is avai a e on s we site at yr
ImiInilrnui (n-1r X� ,Alilr lrlE.Iir�ts-i"attioirC � °-fflo;���"liI --,-Ir InCE`�2r2gIr
7.4 Flooding Sources Studied by Approximate Methods
Typically, where BFEs or base flood depths are not available, flood zone boundaries are
delineated with the best available data, including flood maps published by other federal
agencies, information on past floods, and simplified hydrologic and hydraulic analyses. If more
detailed data or analyses are submitted, FEMA will use them to update the flood hazard
information shown on the affected map panels. For appeals related to approximate SFHAs,
some or all of the following should be submitted:
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 10
Packet Pg. 1635
1.5.j
• Published flood maps that are more recent or more detailed than those used by FEMA;
• Analyses that are more detailed than those performed by FEMA or that are based on
more detailed data than those used by FEMA;
• Topographic data that are more detailed and accurate than those used by FEMA, carried
through to revised SFHA boundaries.
7.5 Topographic Data
For submittals during the appeal period that involve topographic data, the following should be
submitted:
• The data, preferably in a digital geographic information system (GIS) format, should be
more detailed and/or accurate than the information used to develop the preliminary or
revised preliminary FIRM products for the Flood Risk Project. The submitter should
indicate when the topographic data was collected and the accuracy of the data. For
example, more detailed and/or accurate topographic data submitted on its own may be
considered an appeal if it was available prior to the release of the preliminary or revised
preliminary maps.
• If topography was submitted as part of hydrologic, hydraulic, or coastal analysis to
demonstrate that the study was scientifically or technically incorrect, refer to the above
sections for data and information associated with that analysis.
• The submittal should clearly state which flooding sources are being appealed, based on
the more detailed and/or accurate topographic data.
• Updated SFHA boundary delineations that reflect the submitted topographic data for
each appealed flooding source should also be provided, preferably in digital GIS format.
• All submitted topographic data should adhere to FEMA's current data capture standards
for such data.
• If necessary, a data sharing agreement should be provided.
8.0 Appeal and Comment Resolution Process
Throughout a Flood Risk Project, PMR, or LOMR lifecycle, FEMA and the designated Mapping
Partners work with local communities to resolve comments and appeals received before issuing
a Letter of Final Determination (LFD) or a LOMR 116-L Letter. FEMA remains committed to the
concept of community consultation for resolution in a less structured, cooperative format, which
typically leads to agreement on the appropriate data. On occasions when community
consultation cannot produce a mutually acceptable resolution and other qualifying conditions
are met, a Scientific Resolution Panel (SRP) may be made available. The SRP process is
discussed in Section 9.0 of this document.
An overview of the community consultation appeal and comment resolution process is depicted
in Figure 2.
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 11
Packet Pg. 1636
ili�pl
i tounalli ,7� m
Ui
0 r
2
1 0
lb
2w -0
w 00
'd
0
4D �
Qj r
0 V.
=0
4D 0 0 v
c
W qj 0
ILL.
CV)
tD
M CN 4)
CD a) m
CN o) IL
co
co CL
LL
0)
0
2
co
CN
E
E E
0 =
C) 0
0
Co C-)
co a
cu
0
1.5.j
Appeals and comments received during a Flood Risk Project, PMR, or the LOMR process
should be acknowledged and resolved by FEMA, in coordination with the designated Mapping
Partner and the communities, following the procedures below. Templates for appeal and
comment acknowledgment and resolution letters are accessible through the
Flood Risk Templates and Other Resources page on FEMA.gov and the password -
protected Risk Management Directorate SharePoint Portal. Mapping Partners should
coordinate directly with the Regional Office for Regional templates that may be available.
Table Appeal aind oirnirnein't II Resolllutiiioin IPiroceduires
Task
Steps;
• Acknowledgment by FEMA of the receipt of a submittal (data, comments,
etc.) in writing, and optionally through a documented telephone conversation
between FEMA or the designated Mapping Partner and the community that
submitted the comments.
• At a minimum, FEMA must notify the community in writing that it did not
receive any comments or appeals. This can be done by separate
correspondence (LOMR 116-L Letter) or by the inclusion of language in the
Acknowledgement
LFD (for Flood Risk Projects or PMRs). See FEMA's Letter of Final
Determination Guidance document for additional detail for Flood Risk
Projects and PMRs.
• An acknowledgment letter or response after receiving an appeal or comment
should be sent in a timely manner to the community.
• All correspondence must be prepared and issued on FEMA HQ or FEMA
Regional letterhead, which requires signature concurrence from FEMA HQ
or the FEMA Region.
• FEMA or the designated Mapping Partner will evaluate all data and
Evaluation
information submitted, including any scientific or technical data submitted for
compliance with current statues, regulations, or guidelines and standards,
and will perform technical analysis if requested and/or appropriate.
• FEMA in coordination with the designated Mapping Partner may request
additional scientific or technical data or clarifications required to properly
Additional Data or
review the data or information submitted during the 90-day appeal period.
Clarification and
While FEMA may consider data and information for incorporation at any time
Community
throughout the Flood Risk Project or PMR, no new appeals will be accepted
Consultation
after the 90-day appeal period.
• All correspondence is to be prepared and issued on FEMA HQ or FEMA
Regional letterhead.
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 13
Packet Pg. 1638
1.5.j
Task
Steps;
• FEMA or the designated Mapping Partner will review the scientific or
technical data provided and determine whether they are more correct than
those used for the Flood Risk Project, PMR, or LOMR and whether changes
to the FIS Report and/or FIRM and/or LOMR determination documents are
warranted as a result.
The designated Mapping Partner will make a recommendation to FEMA on
Recommendation
the resolution of the appeal or comment.
• Consultation with the community(ies) should continue during this phase.
• While LOMRs and their related appeal and comment resolutions are
managed through FEMA HQ and the designated Mapping Partner and
archived in the MIP, the applicable FEMA Region should have awareness
for informational purposes.
• The designated Mapping Partner will prepare updates to the FIS Report,
materials (usually, Flood Profiles and/or data tables), FIRM panels, and/or
database if appropriate and requested by FEMA.
• FEMA or the designated Mapping Partner will prepare a draft appeal
resolution letter (if all the criteria for an appeal are met) or comment
resolution letter.
• When applicable, Flood Risk Project, PMR resolution letters must offer
communities the option to go through the SRP process, which is discussed
in Section 9 of this document.
If community(ies) did not submit the original appeal or comment but flood
hazard information within their jurisdictional boundaries have been modified as
a result of the resolution, outreach to those communities should be performed
and they should also receive a resolution letter. In these cases, a new or
second appeal period may be required for the communities that did not submit
Resolution
the appeal or comment and are impacted by the resolution. See Section 8.1 for
additional detail.
• The designated Mapping Partner will dispatch the signed FEMA appeal or
comment resolution letter. If changes to flood hazard information were made
as a result of the appeal or comment the community, the designated Mapping
Partner must provide the community with a copy of the revised FIRM, FIS
Report, and/or database, or LOMR documents and enclosures to the
community CEO and floodplain administrator and all appellants, as applicable.
• All correspondence must be prepared and issued on FEMA HQ or FEMA
Regional letterhead.
• FEMA provides a comment period of 30 days following the date the resolution
letter is issued to allow the community/appellant to review FEMA's findings.
Any comments received during the 30-day comment period must be
addressed and resolved before proceeding with the LFD or LOMR 116-L
letter. Extensions to this 30-day period following resolution can only be
granted with FEMA HQ approval.
• If required, the designated Mapping Partner should coordinate to initiate a
Due Process
new or second appeal period. Please refer to Section 8.1 for additional
details.
YA
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 14
Packet Pg. 1639
1.5.j
For Flood Risk Projects and PMRs, following appeal and comment resolution, FEMA will make
a final determination within a reasonable amount of time and provide notification of the final
determination directly to the CEO via an LFD. Additional guidance on this process may be found
in FEMA's Letter of Final Determination Guidance document, which is also accessible from the
FEMA Guidelines and Standards for Flood Risk Analysis and Mapping webpage.
For LOMRs, following appeal and comment resolution, the LOMR effective date will be
confirmed via a 116-L Letter from FEMA to the community. For information related to LOMRs,
please request more detailed information from FEMA HQ or their designee
(Production and Technical Services provider). Additional coordination by FEMA or their
designee with FEMA's Flood Map Service Center (MSC) is required when, as a result of appeal
and comment processing or other circumstances, the LOMR effective date is delayed. In this
situation, the case should not be posted to the MSC or it should be removed from the MSC if
posted already. The case should not be included in the National Flood Hazard Layer until all
comments and appeals are resolved.
New or modified flood hazard determinations for Flood Risk Projects, PMRs, and LOMRs will be
finalized through a final notice published in the Federal Register, as discussed in FEMA's
Federal Reaister Notices Guidance document.
8.1 Determine if a Second Appeal Period is Required
The resolution of a comment or appeal may result in the need for a new appeal period to be run
for a community that had previously received an appeal period under the same Flood Risk
Project or PM R.
Any changes to flood hazard information that occur after preliminary issuance and prior to the
initial appeal period as a result of comment incorporation would require a revised preliminary
issuance of the modified FIRM panels and/or FIS Report to all communities determined by the
Region and Mapping Partner to be impacted by the flood hazard information change.
This would be followed by initiation of the statutory 90-day appeal period. If an appeal period
was already run and changes in flood hazard information are being made because of resolution
of comments submitted outside of the appeal period (i.e., data received outside of the statutory
90-day appeal period) then a revised preliminary issuance and a second appeal period would
be required for impacted communities. Flood hazard information changes as a direct result of
appeal resolution will typically not require a new appeal period unless flood hazard changes are
being introduced to a new community that did not originally receive an appeal period.
Changes resulting from comments may be incorporated at the time that the final reproduction
materials are prepared if they do not involve flood hazard information changes and impact due
process. However, if the changes are significant, FEMA may direct the designated Mapping
Partner to prepare and distribute revised preliminary copies of the revised FIS Report, FIRM,
and/or database.
Appeal and Comment Processing February 2019
Guidance Document 26 Page 15
Packet Pg. 1640
1.5.j
9.0 Scientific Resolution Panel (SRP)
FEMA's SRP process reinforces FEMA's commitment to work with communities to ensure the
flood hazard information depicted on FIRMs and in FIS Reports are developed collaboratively,
using the best science available. When proposed changes to a FIRM and FIS Report as part of
a Flood Risk Project, PMR, or LOMR are met with conflicting technical and/or scientific data
during a statutory 90-day appeal period, an independent third -party review of the information
may be appropriate. An SRP serves as an independent third party.
The use of an SRP is not intended to be the first step for resolving conflicting technical and/or
scientific data. FEMA remains committed to the concept of community consultation for resolving
issues regarding data submitted during the appeal period. On occasions when community
consultation does not result in a mutually acceptable resolution and other qualifying conditions
are met, an SRP may be made available.
The designated Mapping Partner should coordinate with FEMA to confirm that the technical or
scientific data submitted during the appeal period for a Flood Risk Project, PMR, or LOMR meet
the appropriate requirements for SRP eligibility. Data submitted outside of the 90-day appeal
period will not be eligible for evaluation through the SRP process. FEMA will move an SRP
request forward based on eligibility discussed in FEMA's Scientific Resolution Panels fact sheet.
This document is found by searching by document title at rvrvr.:im �r�lliilkir ir.
9.1 SRP Process
The objective of the SRP process is to assist FEMA and communities by efficiently, impartially,
and fairly resolving conflicting technical or scientific data or appeals to proposed flood hazard
information. To meet this objective, it is imperative that all parties follow the guidelines,
timeframes, and procedures throughout the SRP process. The chart in Figure 3 outlines the
SRP process, and Figure 4 outlines the timeline for processing SRPs. Additional detail may be
found in FEMA's Scientific Resolution Panels fact sheet. This document is found by searching
by document title at rrr.:irm �rlliilkir airy.
The SRP process is under the operational direction of the National Institute of Building Sciences
(NIBS), an organization independent of and contracted by FEMA to manage the procedures and
processes related to the SRP. Additional information regarding procedures and processes
followed by NIBS to initiate an SRP and provide recommendations to the FEMA Administrator
may be found at www, 11 � sir .oir .
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 16
Packet Pg. 1641
Ui
.g4 w,N
w
�qnwg��q�
gWqRg'�Mq�
WR'M
qq�„xWnW'
WxiWi
qq�miwu
I@IIILIqqi�IIP�'i.I
gnllNulbuiu
umN�
�miwggu
wuiW
I
0
v
T
a
rn r-
o
N o) d
�co
c�
L
LL
0)
U
O
^L
LL co
.. N
N C
E N
E E
O =
U o
� 0
c �
Co U
co a
N CB
Q
Q �
Q 0
I
MCI
13
L
A 9L
dl
C
Ilium
�
cja
a
Awe
wa
,Q w f5 ��l 12
W
fo
, 74
RIB R,iiw IK*
'A
ki
ILL.
0)
0
2
co
CN
E
E E
0 =
C) 0
0
Co C-)
co a
CID
0
1.5.j
9.2 Supporting an SRP Evaluation
The designated Mapping Partner should be prepared to provide FEMA with the data used to
generate the relevant flood hazards, the contesting data submitted by the community during the
90-day appeal period, and any correspondence between FEMA, the designated Mapping
Partner, and the community. The information should include specific sections of the Technical
Support Data Notebook used to determine proposed flood hazards relevant to the appeal or
challenge and a summary of the issue.
The designated Mapping Partner may also support FEMA in any requests from the panel for
clarifications or for an oral presentation on the submitted data when it is deemed necessary.
9.3 SRP Outcomes and Recommendations
The panel must present its written report to the community and FEMA within 90 days of being
convened, and that report will be used by the FEMA Administrator for making the final
determination. A panel determination must be in favor of either FEMA or the community on each
distinct element of the dispute, and the panel may not offer any alternative determination as a
resolution. In the case of a dispute submitted by the community on behalf of an owner or lessee
of real property in the community, the panel determination must be in favor of FEMA, the
community, or the owner/lessee on each distinct element of the dispute.
If changes to the FIRMs are recommended in the panel's determination, and FEMA elects to
implement the panel's determination, FEMA and the designated Mapping Partner should:
• For a Flood Risk Project or PMR, incorporate the changes into a revised preliminary
FIRM and, if appropriate, FIS Report, and issue a resolution letter prior to issuing an
LFD.
• For a LOMR, incorporate the changes into a revised LOMR determination that will serve
as the final resolution to the appeal. The LOMR 116 Letter will then be distributed to
notify the community that all appeals have been resolved and the LOMR is effective. The
effective date on the originally issued LOMR may need to be modified as a result.
Once the SRP provides its determination and FEMA's resolution letter is issued to implement
the recommendations, the SRP recommendations are binding on all appellants and not subject
to judicial review.
If the FEMA Administrator elects not to accept the panel's findings, the Administrator will issue a
written justification within 60 days of receiving the report from the SRP. Under these
circumstances, the appellants maintain their right to appeal FEMA's final determination to the
appropriate federal district court.
The panel's report will be made public at vrww, lloz�sir -oir jp The panel's report and the
Administrator's final determination should be added to the community's FEDD file by the
designated Mapping Partner along with all other correspondence between FEMA and the
community. The FEDD file will contain the information described in 44 CFR Section 67.3 to
show that FEMA has provided due process to communities impacted by new or updated flood
hazard information.
E
Appeal and Comment Processing February 2019
Guidance Document 26 Page 19
Packet Pg. 1644
1.5.k
MONROE COUNTYCOASTAL RAG,,,,MAPPING OUTREACH ACTIVITIES
m
PRE -DRAFT MAP RELEASE PHASE: JANUARY—JULY 2019 w/o=week of
Create outreach activity plan and talking point/messaging
Mark/Bruce
w/o Jan 7
Identify existing coastal material that is available for use (i.e., FEMA HQ, Region IV, NOAA)
Create an electronic Community Outreach Activity Log (COAL) to track all outreach that has
been and will be performed. Information captured should include date and type of activity,
Mark/Bruce
w/o Jan 14
where it occurred, who the audience was or who received it, and a section for any comments
Create PPT and outreach material for FIRM meeting
Mark/Bruce
w/o Jan 14
Hold Stakeholder Meeting with FIRM et al
Team
w/o Jan 24
Identify key stakeholders (e.g., industry and civic organizations) to reach out to as well as
Team
w/o Feb 4
HOAs, businesses and Chambers of Commerce; identify ones to reach out to one-on-one
Create PPT and material for BOCC meeting
Mark/Bruce
w/o Feb 1'
DRAFT MAP RELEASE PHASE: AUGUST-DECEMBER 2019
Based on draft maps, identify areas of impact; e.g., newly in/out of SFHA, A to V change, BFE
Karl
w/o Aug 26
increase, LiMWA
w/o Sep 1E
Meet with surrounding communities to discuss their planned outreach and timing
Team
w/o Sep 1E
Identify 4 potential locations for FEMA to hold Open House(s) and County to hold
Karl/Christine/
w/o Oct 7
Stakeholder Workshop(s)
Bruce
Identify locations for County to hold additional Open Houses and Stakeholder meetings, if
Karl/Christine/
w/o Oct 7
needed
Bruce
Update existing coastal outreach material and website; create additional material (e.g.,
media backgrounder, press release, stakeholder newsletter article, insurance impacts and
Bruce
w/o Nov 1:
options). Create draft letters/postcards to mail to affected property owners (in/out of SFHA,
A to V/V to A, increase in BFE).
Define the Appeals & Comments process in writing; create appropriate document(s)
Karl/Bruce
w/o Nov 1:
RELEASE OF PRELIMINARY MAP: JANUARY-FEBRUARY 2020
Upon receipt of preliminary maps, review for noticeable errors. Perform a CSLF if not
provided by FEMA. Then identify those structures (or properties) that are newly identified to
Karl
w/o Jan 6 -
be in/out of the SFHA and those identified to have gone from A to V (and any V to A). If
w/o Jan 2C
possible, identify those in SFHA with no change and identify any changes in BFE.
Finalize venues for County stakeholder workshop(s) and the FEMA Open House(s) and PDCC
Karl/Bruce
w/o Jan 6
meetings
Finalize venues for additional stakeholder meeting(s) and Open Houses
Karl/Bruce
w/o Jan 6
Provided updated information to the County's central call number staff (if needed)
Karl/Bruce
w/o Jan 13
Create and send out invitations to Stakeholder workshop(s)
Bruce
w/o Jan 2C
Finalize material, timing, personnel, security and other logistics with FEMA for open house(s)
and internally at County for Stakeholder workshop(s), and any additional stakeholder
Bruce/Karl
w/o Jan 27
meetings.
Update outreach material and website with any new dates, affected property counts, etc.;
Bruce
w/o Jan 27
create media packets and packet for elected officials/staff
Create and finalize presentation for Stakeholder workshop(s)
Bruce
w/o Feb 3
Present updated information and timetable to County staff and to commissioners; meet one-
Karl/Christine
w/o Feb 3
on-one with commissioners in affected area; coordinate meetings with other communities
Provided addl updated information to the County's central call number staff (if needed)
Karl/Bruce
w/o Feb 3
Meet with local media (e.g., brown bag meeting; editorial board meeting) to review the
Christine
w/o Feb 3
project, identify where changes are occurring and what the effects and options are, and
Packet Pg. 1645
1.5.k
MONROE COUNTYCOASTAL RAG,,,,MAPPING OUTREACH ACTIVITIES
where to go for more details; provide packet of information including fact sheet, media
backgrounder, press release and possibly CSLF
Send material to individual stakeholders (e.g., HOAs, businesses, organizations). Begin
meeting with individual stakeholders. Send reminder notice for stakeholder workshop
Bruce/Christin
e/Karl
w/o Feb 1(
Mail letters/postcards to affected property owners; invite them to Open House
Karl
w/o Feb 1(
Write and issue Press Release (if not provided when met with local media)
Bruce/Karl
w/o Feb 1(
Finalize logistics for FEMA PDCC meeting and Open House(s) including material needed
(identified earlier)
Karl/Bruce
w/o Feb 1(
Hold stakeholder workshop(s)
w/o Feb 1;
POST -PRELIMINARY RELEASE PHASE: FEBRUARY 2020 —JULY 2021
CCO and FEMA Open House(s) are held
Team
w/o Feb 2z
Additional Stakeholder workshops and Open Houses are held
Team
w/o Feb 2z
Continue one-on-one stakeholder meetings as needed
Karl/Christine
Ongoing
Public Comment Period (guesstimate; e.g., Jun 1, 2020 — Sep 30, 2020)
After notice appears in the Federal Register, FEMA will publish 2 notices in local
newspapers. Public Comment Period starts on the issuance of the second notice.
Update material and website; create newsletter article for stakeholders
Meet with key elected officials, administrators and department staff; inform call center
Send material to key stakeholders (HOAs, businesses)
Create a press release; notify media
Hold any follow-up meetings during Public Comment Period with affected property owners
and concerned parties
With 30-days left in the Public Comment Period, create letter/postcard and mail affected
property owners; issue follow-up enewsletter article to stakeholders
"Compliance" Period (Issuance of Letter of Final Determination; e.g., Jan 1-Jun 30, 2021)
Update outreach material (talking points, fact sheets, media backgrounder)
Update key elected officials, administrators and department staff as well as Call Center
Update website including updated CSLF
Create and issue follow-up enewsletter article to HOA(s) and stakeholders to print
Meet with media; provide updated media packet including press release
Create and mail letters to affected property owners with a copy of an updated CSLF for their
property, both those whose structures are affect and for those whose lot is just affected.
Include in the letter the effective date of the maps and options available; invite to Open
House
Hold a Stakeholder workshop and Open House(s)
If needed, meet with specific property owners and concerned parties
Create and issue final enewsletter article to HOA(s) and stakeholders to print
Create and issue a final Press Release as the map becomes effective
Post -Effective Date (e.g., July 1, 2021)
Create material for stakeholders (and update website) explaining post -effective date options
for building and insurance requirements; distribute as needed
YA
Packet Pg. 1646
I h_MA - heis Wolniaton al�o'rri
ncal flood helzards and their risk
ui I:lose cocrdilmtlon with the
17,nnmunity to pllolltize future
niopplul„ nil, assessment, o1
nntll?aliun p4lnningassistance
k
or
e rr
i �
-o-o.
Del:erlT1ination
to Itlove,
m
LJ� `
F--c
forward with
Risk MAP
'r'
stlldv.
{;;rrlvllty lN{Y p
�'YurPli�`�tr;lu
r/Il
F'im0
& �°+,�l��tlulnl111`4t.11
Mrr? f CMA allnlym(s the Into) rnation
gatheled (duIing, Discoveryand
om.972 i develops the, tirst draft of the maps.
11A called "wol k malls
v FLOOD DllldtK REVIEW (if needed)
Crnrnmmity ot'Ir ils Ievlew mid htcmde Initial
feedhack on the work maps in enginceltng,
decisions, I LMA uses the teedback to modify thr-r
traps and develol, the plonrnlnaly Flood
Itlsurance Rate Map (FIRM), usnlglhis
niormatlon. oliwials boi,w to Irlantifv sand
�ldwlrce mlli;aiion actlon III tht;lr comnliuuty.
FLOOD RISK
t as
rn
All
Es
DIII'I' d'lL1111111dIIIIDDD'd' Ift P 11111111111 d'Ddlllll:
Community Coordination and Outreach Meeting
CoimlilwllV ofhclols ioirl1 the Irupllc�rtlorls of tha` updatod snap
anrd fhu steps and timelin(, to adopt the updated slap.
• Open House
Cltlzens learn about their local flood risks, and what resources are
ovailiahle 11om the State, TMA, and other partners to reduce risk
�� I UPI( WIII(;tWO {iLIhIIC IwYI(l"i COIYI Illlll lty Itlf II:bC15
C,lu suhmrt technlrzu data to support a I'equestta
wvlso the FIRM though the, 90-day appeals pmcc95
Al! appeal.,, Inrluculg all Suppol Ling docunlenttiium.
must bo:3urirwircd through the applopnate
comilliw1iy othrlal
ilkDOPTION Ilk ( III DIDdlllAll1111110E
r
C ounnuliltes o ll ticipatFig In the
NFIP I'lLlSt.,Idu(Jt l (r)I h)l0llt
i s
l C ilOc(.,)lall� nl�uiaf,(.nlc,l��ordinan (,
by the mcipl (.ffectivo data to reln;wi
'i1 `4,
in good slandirp, as ar NI`IP
�rp
.:'.
pm lwipant
�i'tlINWf�rewwuwuw!�uwrvumi�um�n�nrlrlm�r�m��m�rv�umw,vmw,w�araamwr�mmwrwumv�wimiruwmwwvr�uuimnunmviv!aus�aiwvir�nsvuuvamriaimrw�naNiri�ttNplusuma�;m��mw;�,u�miommr�
Il'dd@III IENCE MEETING
FFMA, Slate ❑ ul loch' oltclals.
�1nd porinels work l.o Idontlty
and review n sl iF:n(;r strntoc,,l(ir;,
tj_1,
flotr.ntlai
WFacto 15aro rrtclure Ili,k
PUBLIC NOTICE PUBLIC NOTICE
/lLIE"ITEIR
t
OF "�'k
il�IINAI ADD
A[tei rill appeals are resolved,
I FMA sends ri Letter of filial
Determination, kicking; off
o six naorlih penod for
colamnanities to adopt the
new flood reaps.
Once effective, now leaps and products
are avallahlc through FF:MA's Flood Mtap
Service. Center- 1 he new data will Iriform
flood nlsul;IIWO, der lions and local
huddnlg regulations Community
mel,lhets cf,in suhnut data to amend or
--.— f1,., CIrJM — „-„ I n4 _, I "tt". A
1.5.m
CHART'F IMPACT F MAP CHANGES INSURANCE
Land Newly Identified
No Change — but strongly
Most lenders won't require flood
in High -Risk Area but
encourage to purchase a Preferred
insurance.
Building Is Not (e.g.,
Risk Policy (PRP) if there is no
You are close to a high -risk area and
Zone X to A; Zone X to
coverage in place
encouraged to buy a PRP as Mother
V)
Nature doesn't read flood maps.
About 25% of all flood claims come
from these moderate -low risk areas.
Building Newly
Newly Mapped Procedure — buy
Flood insurance will be required by
Identified in High -Risk
w/in 12 months of map change
most lenders.
Area (e.g., Zone X to A;
and maintain coverage; rates will
Cost -saving options are available.
Zone X to V)
go up no more than 18% annually
Have a PRP in effect before the maps
until they reach a full risk rate. If
change and renew it each year.
lapses, pre -FIRM buildings must
The cost -saving policy can be
be rated w/new maps; post -FIRM
transferred to a new owner.
can be grandfathered.
High -Risk to Higher -Risk
Grandfathering— have a policy
Cost -saving options available.
(e.g., Zone A to V,
effective before the maps change
Have a policy in effect before the
increase in Base Flood
to lock in the lower risk zone or
maps change to lock in the lower risk
Elevation (BFE))
lower BFE for future rating. If
zone or BFE for future rating; and
lapses, pre -FIRM buildings must
renew it each year.
be rated w/new maps; post -FIRM
The cost -saving policy can be
can be grandfathered again.
transferred to the new owner.
Decrease in Level of
Re -rating— Policy should be re-
Still at risk, but flood insurance just
High -Risk (e.g., Zone V
rated when new maps become
got cheaper. Contact your insurance
to A, decrease in BFE)
effective.
agent to re -rate your policy (when
the maps become effective).
Most lenders will continue to require
flood insurance.
No Longer in High -Risk
Conversion — Convert current
Flood insurance just got cheaper.
Area (e.g., Zone V to X,
high -risk policy to a PRP and
Most lenders will no longer require
Zone A to X)
receive a refund in difference in
flood insurance.
premium. Contents are
However, the risk has only been
automatically included.
reduced, not removed.
Convert your current policy to a
lower -cost PRP and receive a refund
in the difference in premium — and
contents is automatically included.
Seaward of Limit of
No Change — Insurance rates are
Most lenders require flood insurance.
Moderate Wave Action
the same on either side of the
No impact on insurance costs;
(LiMWA) (e.g., Coastal
LiMWA in Zone A; however, the
however, the risk is even higher due
Zone A)
seaward -side risk is higher.
to stronger wave action.
Fully insure all buildings.
E
Packet Pg. 1648