Wednesday, December 2, 2020

Options If You Disagree with the Preliminary Flood Maps

When a preliminary flood map is issued and you disagree with the new flood risk identified for your property, you have two ways to try to amend it.

Appeal or Comment This option involves a formal process that occurs after the preliminary flood maps are released, but before the final ones are issued (shown below as the 90-day Public Review-Appeal and Comment Period); or

Letter of Map Change A property owner can submit information to request a property-specific Letter of Map Change (LOMC). If it is approved, the LOMC will officially change the building’s flood risk from high to moderate or low. This typically reduces the cost of flood insurance. This opportunity occurs at any time after the new flood map becomes effective.

These two processes are described below.

Appeals and Letters of Map Change


When a preliminary flood map becomes available, some residents, business owners, developers and others may disagree with the flood risk shown in certain areas. FEMA provides a 90-day appeal and comment period for new or revised Base Flood Elevations (BFEs), flood hazard zones, and/or floodway boundaries. Members of the community have opportunities to submit evidence on why they believe their property has been improperly mapped. However, the evidence must be scientifically or technically based. Even if “it hasn’t flooded in a while (or ever),” technical analysis can show that the risk exists. 

During the 90-day appeal and comment period, you can submit:

        An appeal – which is a formal written objection to a new or modified BFE, Special Flood Hazard Area (SFHA), floodway, or flood zone This must be supported by an analysis or scientific evidence showing that the information on the preliminary map is scientifically or technically incorrect.

        A comment – which points out changes needed for any other information related to the new map (such as a street name or jurisdictional boundary). 

After the appeal period, FEMA will evaluate the data and/or analysis in the appeals and comments provided during the 90-day period. Once all appeals are resolved, FEMA will send an appeal resolution letter to the community and all appellants and revise the preliminary FIRM as appropriate. After that, FEMA will finalize the flood map and send a Letter of Final Determination to each community, stating that the map will become effective in 6 months.

For more details on filing an appeal or comment, visit these resources:


Due to scale limitations, a preliminary map may inadvertently show a building (or part of it) within a high-risk flood zone (a Special Flood Hazard Area, or SFHA). When the new maps become effective, property owners may submit mapping and survey information to FEMA to request a Letter of Map Amendment (LOMA) or a Letter of Map Revision Based on Fill (LOMR-F). The more precise details you provide may allow FEMA to officially change the building’s flood zone from an SFHA to Zone X, a moderate- to low-risk flood zone. 

While this process may also remove the federal mandatory purchase requirement for flood insurance when the map becomes effective – and your lender may no longer require flood insurance – it does not mean the risk of flooding has been removed; it is only reduced. You are strongly encouraged to continue to carry flood insurance using the lower-cost Preferred Risk Policy. More than 40% of flood claims in Texas come from policyholders in moderate- to low-risk flood zones. 

For more information on LOMAs and LOMR-Fs, visit these resources:

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