Letter of Map Amendment (LOMA): Removing Properties from Flood Zones

A Letter of Map Amendment (LOMA) is a formal determination issued by the Federal Emergency Management Agency (FEMA) that officially removes a property or structure from a Special Flood Hazard Area (SFHA) designation on a Flood Insurance Rate Map (FIRM). This page covers what a LOMA is, how the application process works, the scenarios that justify filing one, and the critical boundaries that determine whether a LOMA — or a different map revision instrument — is the appropriate path. For property owners carrying mandatory flood insurance requirements solely because of their map designation, a successful LOMA can eliminate that obligation and reduce carrying costs.

Definition and Scope

FEMA's National Flood Insurance Program (NFIP) designates land through Flood Insurance Rate Maps (FIRMs), which classify parcels into risk zones such as Zone AE, Zone A, Zone VE, and Zone X. When a property falls within a high-risk Zone A or Zone V designation, federal law — specifically the Flood Disaster Protection Act of 1973 and its amendments codified at 44 CFR Part 65 — triggers mandatory flood insurance purchase requirements for federally backed mortgages.

A LOMA addresses a narrow but common problem: FIRM mapping relies on broad topographic data, and individual lots or structures may sit physically above the Base Flood Elevation (BFE) even though the surrounding parcel polygon falls within a mapped SFHA. The LOMA process allows property owners to submit site-specific elevation evidence to demonstrate that the natural ground elevation of their property meets or exceeds the BFE, warranting removal from the high-risk zone.

FEMA distinguishes two primary LOMA variants:

LOMA (standard) — Removes a legally described parcel, lot, or structure based on natural grade elevation without any physical fill or alteration.
LOMA based on fill (LOMAF) — Applies to properties where fill was placed before the community's first FIRM was issued; FEMA evaluates whether that historical fill raises the ground above the BFE.

A LOMA does not alter the underlying FIRM itself. The map zone designation for the broader area remains unchanged; the amendment applies only to the specific property identified in the determination letter. This distinguishes a LOMA from a Letter of Map Revision (LOMR), which does modify the FIRM and typically applies to larger areas or engineered flood control projects.

How It Works

The LOMA application process runs through FEMA's MT-EZ or MT-1 form packages, depending on the complexity of the request. As of FEMA's administrative guidance, the MT-EZ form handles single-lot, single-structure residential requests, while the MT-1 package covers more complex submissions.

The process follows these discrete steps:

Obtain an Elevation Certificate. A licensed land surveyor, engineer, or architect must complete FEMA's Elevation Certificate (FEMA Form FF-206-FY-22-152), documenting the lowest adjacent grade (LAG) around the structure and the lowest lot elevation relative to the published BFE for that FIRM panel.
Confirm the FIRM panel and BFE. The property owner or their surveyor identifies the relevant FIRM panel number and effective date through FEMA's Flood Map Service Center (MSC), confirming the current zone designation and BFE contour applicable to the site.
Complete the MT-EZ or MT-1 application. The submission includes the signed Elevation Certificate, a copy of the recorded plat or legal description, and the applicable FEMA application form. No application fee applies for standard LOMA submissions under the NFIP program.
FEMA technical review. FEMA's Map Specialist team reviews the submitted elevation data against the FIRM's water surface profiles. Standard processing targets 60 days from receipt of a complete application, though complex cases may extend that timeline.
Issuance of determination letter. If elevation data supports removal, FEMA issues an official LOMA letter specifying the property address, FIRM panel, and effective removal date. If the request is denied, FEMA issues a determination explaining why the property cannot be removed — typically because the lowest lot or structure elevation falls below the BFE.
Notification to the lender. The property owner provides the LOMA letter to their mortgage servicer, who is then required to release the mandatory flood insurance purchase requirement. This does not prevent the owner from voluntarily maintaining a flood insurance policy for low-to-moderate risk zones.

Common Scenarios

Three situations generate the majority of LOMA filings:

Incorrect map placement. FIRM panels are generated from topographic datasets that predate high-resolution LiDAR in many communities. A lot that appears within the SFHA polygon may have natural ground elevations consistently above the BFE by 1 foot or more. A surveyed Elevation Certificate typically resolves these cases in favor of removal.

Structures on elevated foundations. Even where surrounding lot grade falls within the SFHA, a structure built on a raised foundation, crawlspace, or slab may have its lowest adjacent grade above the BFE. FEMA evaluates the structure's lowest adjacent grade independently from the parcel's lowest lot elevation — allowing a structure-only LOMA when the lot itself does not qualify.

Newly platted lots. When a subdivision is recorded after the effective FIRM date, individual lots may carry zone designations that reflect the pre-platted parcel's aggregate topography. Site-specific surveys frequently show individual lots above the BFE after grading and final plat recordation.

A LOMA is not appropriate when physical modifications — such as grading fill placed after the community's first FIRM — are the basis for the elevation claim. Post-FIRM fill requires a LOMR-F (Letter of Map Revision Based on Fill), a distinct process with community floodplain administrator involvement and different documentation standards under 44 CFR § 65.5.

Decision Boundaries

Determining whether to pursue a LOMA requires evaluating four threshold questions:

1. Does the property sit in a mapped SFHA?
Only Zone A, AE, AH, AO, AR, and Zone V/VE designations trigger mandatory purchase requirements and LOMA eligibility. Zone X (shaded or unshaded) properties do not require a LOMA to avoid mandatory insurance. The flood zone designations reference provides the full classification hierarchy.

2. Is the elevation basis natural ground or fill?
Natural ground elevation at or above BFE → standard LOMA (MT-EZ or MT-1).
Elevation achieved through fill placed after the community's initial FIRM → LOMR-F process, not LOMA.
Fill placed before the community's first FIRM → LOMAF, handled within the MT-1 package.

3. Is the request for a single lot/structure or a larger area?
Single lot or structure: LOMA pathway.
Multiple lots, a subdivision, or community-wide area: LOMR pathway, which requires engineering data on water surface profiles and formal community concurrence.

4. Does the community participate in NFIP?
LOMA issuance applies within NFIP-participating communities. A property in a non-participating community lacks the FIRM-based designation that a LOMA would amend. Non-participation status also affects available policy types — covered under private flood insurance options and the NFIP vs. private flood insurance comparison.

When a LOMA is granted, the mandatory insurance requirement is lifted, but the physical flood risk of the surrounding area does not change. Properties removed via LOMA remain eligible to purchase lower-cost preferred risk policies as long as the community participates in NFIP and the property maintains its amended status. A LOMA determination can also be rescinded if FEMA issues a revised FIRM that remaps the area — at which point a new application would be required to restore the amended status.

References

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