FEMA Conditional Letter of Map Revision (CLOMR) Process. Shawn Arden, PE, CFM OTEC 2017

Transcription

1 FEMA Conditional Letter of Map Revision (CLOMR) Process Shawn Arden, PE, CFM OTEC 2017

2 What is a CLOMR? CLOMR = Conditional Letter of Map Revision Letterissued by FEMA stating that a proposed project, if built per plan, is consistent with the requirements of the National Flood Insurance Program (NFIP).

3 How Does This Affect Me? ODOT Floodplain Coordination Process L&D Manual: ORC D: State Self-Permit Authority

4 How Does This Affect Me?

5 How Does This Affect Me?

6 How Does This Affect Me?

7 How Does This Affect Me? Title 44 CFR 60.3(d): Zone AE with Floodway

8 How Does This Affect Me? Title 44 CFR 60.3(c): Zone AE, no Floodway

9 How Does This Affect Me? Projects that encroach into these areas require hydraulic analysis as part of floodplain compliance documentation: Any part of a Zone AE floodplain where no floodway has been mapped by FEMA on the FIRM(s). The mapped floodway portion of a Zone AE floodplain.

10 When is a CLOMR Required? Zone Floodway Mapped? Floodway Encroachment? Hydraulic Analysis Results AE No N/A Rise > 1.00 ft AE Yes Yes Rise > 0.00 ft

11 Levels of Modeling Duplicate Effective Model (DEM) Corrected Effective Model (CEM) Post-Project Model (POST) Pre-Project Model (PRE)

12 When is a CLOMR Required? Zone Floodway Mapped? Floodway Encroachment? Hydraulic Analysis Results AE No N/A Rise > 1.0 ft AE Yes Yes Rise > 0.00 ft NOTE: Rise is measured by comparing results between pre-project and post-project models. Do not include model influences due to software changes (HEC-2 to HEC-RAS) or other projects constructed since FEMA effective models were developed.

13 When is a CLOMR Required? Be aware local floodplain regulations may exceed CFR minimum requirements

14 When is a CLOMR Required? Consult with ODOT PM if CLOMR appears to be required: Assess design alternatives to mitigate BFE rise Assess project schedule impacts CLOMR mayreduce project costs if project schedule will accommodate

15 How to Obtain a CLOMR? Submittal Requirements: MT-2 Application Forms H&H Calculations Compliance Floodplain Workmap Annotated Information ESA Documentation Public Notice Preliminary Plans Data Disk

16 How to Obtain a CLOMR? MT-2 Forms Signature required by each affected local community. Allow time for local review and processing.

17 How to Obtain a CLOMR? Compliance Verify project does not cause BFE rise on existing structures in excess of 0.0ft.

18 How to Obtain a CLOMR? ESA Documentation Recent addition to the process: Letter from Applicant stating if a Take is expected USFWS coordination can supplement USACE permit approval

19 FAQ How long is the FEMA review process? Typically 6 to 9 months

20 FAQ Is approval guaranteed? No. Calculations are reviewed by FEMA s consultant team.

21 FAQ What do I receive at the end of the process? FEMA will issue a letter stating if the project, as proposed, will comply with the NFIP. This determination will establish if a local floodplain permit can be issued (by ODOT).

22 FAQ What happens if my plan changes after CLOMR approval? A CLOMR can be issued based on preliminary plans. Applicant is responsible for determining if any plan changes would affect compliance with NFIP. Local community may require resubmittal of CLOMR application for additional FEMA review.

23 Items to Verify Prior to Submittal START HERE Duplicate Effective Model (DEM) Post-Project Model (POST) Corrected Effective Model (CEM) Pre-Project Model (PRE) Track Model Datum Across All Models

24 Items to Verify Prior to Submittal Cross sections in same locations across all models Upstream and downstream terminus section match DEM Post-Project to Published BFE Tie-in: 0.50 ft +/ Compliance Do not adjust n values for vegetation changes

25 Items to Verify Prior to Submittal Model to Map Cross Section top width compliance Must match within 5% of FIRM scale (1 =500 FIRM scale = 25 fttolerance)

26 CLOMR Post Project Requirements LOMR = Letter of Map Revision Letterissued by FEMA that revisesofficial Flood Insurance Study and FIRM panels based on a constructed project using as-built data. This process generally does not result in a new FIRM panel. Application process is similar to the CLOMR. Requires consultant work effort post construction!

27 Questions? Shawn Arden, PE, CFM EMH&T