If You Disagree with the Preliminary Flood Maps
When a preliminary flood map is issued, community members are provided an opportunity to review the new map. If you disagree with the new flood risk identified for your property, there are two ways to try to amend it:
- Appeal or Comment – This is a formal process which occurs after the preliminary flood maps are released, but before the final ones are issued (shown above as the 90-day Public Review and Comment Period); or
- Letter of Map Change – A property owner can submit a request for Letter of Map Change (LOMC), which if approved, will officially change the flood risk around a building from a high-risk area to a moderate-low risk area. This opportunity occurs after the new flood map becomes effective.
These two processes are described below:
APPEALS AND COMMENTS
When a new preliminary flood map is released, some residents, business owners, developers and others may disagree with how they are affected. FEMA provides for a 90-day Appeal and Comment Period when new or revised Base Flood Elevations (BFEs) are determined, or flood hazard zones or floodway boundaries change. Property owners, developers and others have opportunities to submit evidence on why they believe their property has been improperly mapped. However, it must be scientifically or technically based, not just “it hasn’t flooded in a while (or ever).”
During the 90-day Appeal and Comment Period, they can submit:
- An Appeal – which is a formal written objection to the addition/modification of the BFE, Special Flood Hazard Area (SFHA), floodway, or flood zone change, and which requires analysis or scientific evidence showing the information on the preliminary product is scientifically or technically incorrect.
- A Comment – which is an objection to any other information related to the new map that is not an Appeal.
Note that any Appeals and Comments would have been forwarded to the District to first review them and then forwarded on to FEMA for review and resolution. During its review, FEMA evaluates the submitted data and requests additional data, as necessary. Once all appeals and comments are resolved (if any are received), the flood map is finalized, and a Letter of Final Determination is then sent to each community stating that the flood map would become effective in six months.
The Appeal Period for Munds Park is targeted for Fall 2023.
LETTER OF MAP CHANGES (LOMCs)
Due to map scale limitations, some property owners with individual lots or structures may believe their building is incorrectly shown within the high-risk area (Zone A, known as a Special Flood Hazard Area, or SFHA). Once the preliminary flood maps become effective (targeted for Summer 2024), they may submit mapping and survey information to FEMA to request a Letter of Map Amendment (LOMA), or Letter of Map Revision Based on Fill (LOMR-F). This officially changes the property’s flood zone from a high-risk Zone A to a moderate-low risk Zone X on the new maps after they are effective.
This process may also remove the Federal Mandatory Purchase Requirement when the LOMA or LOMR-F becomes effective. While 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. More than 30% of flood claims in Arizona come from policyholders in moderate-low risk flood zones.
For more information on LOMAs and LOMR-Fs, visit these resources:
- Change Your Zone Designation
- How to Request a Letter of Map Amendment (LOMA) or Letter or Map Revision Based on Fill (LOMR-F) Fact Sheet
- Electronic Letter of Map Amendment (eLOMA) Fact Sheet