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Data updated October 22, 2026

Data updated October 22, 2026

LOMA: removing a building from the flood zone

Updated October 22, 2026

A Letter of Map Amendment (LOMA) is FEMA's official finding that a building or lot on naturally high ground sits at or above the base flood elevation, which removes it from the high-risk flood zone and from the federal flood insurance requirement. FEMA charges no fee to review a LOMA request and answers within 60 days of receiving all required data.

A LOMA is a letter from FEMA amending the effective Flood Insurance Rate Map (FIRM) for one property. It confirms that an existing building or parcel on naturally high ground, not raised by fill, would not be flooded by the base (1%-annual-chance) flood. FEMA explains that map scale and source data limits can place small high spots inside a Special Flood Hazard Area, and the LOMA is the fix (FEMA, How to Request a LOMA or LOMR-F).

LOMA, LOMR-F, LOMR and the conditional letters

All of these are Letters of Map Change (LOMCs), but they answer different questions. FEMA’s definitions in 44 CFR 72.2 and its map change page separate them as follows.

Letter What it does When it applies
LOMA Amends the map for a building or lot Existing structure or land on natural ground at or above the base flood elevation (BFE)
LOMR-F Revises the high-risk zone shown for a property Ground raised by earthen fill outside the regulatory floodway
LOMR Modifies the effective FIRM, floodway map or both Generally based on physical measures that alter a flooding source’s hydrology or hydraulics
CLOMA FEMA’s comment on a proposed structure Planned building on existing natural ground above the BFE
CLOMR-F FEMA’s comment on a proposed fill project Planned fill outside the floodway
CLOMR FEMA’s comment on a proposed project Planned work that would change the floodway, BFEs or high-risk zone

The conditional letters tell a developer whether a project would qualify once built. They do not change the map; the final letter does that after construction.

Who qualifies for a LOMA

The test is elevation, not distance from water. FEMA’s rules are:

  • A building: the lowest adjacent grade (LAG), meaning the lowest ground touching the structure, must be at or above the BFE.
  • A lot: the lowest point on the lot must be at or above the BFE.
  • Raised by fill: the property needs a LOMR-F instead. The LAG must still be at or above the BFE, and community floodplain officials must determine that the filled land and any buildings are protected from flooding to NFIP standards.
  • Raised on supports: if a building’s lowest floor is elevated on posts, piers or pilings above the BFE but any part of them is still below the BFE, the MT-EZ instructions say the building will not be removed.

Some requests need no survey at all. If FEMA’s review shows the building is already outside the mapped high-risk zone, the result is an “out as shown” determination.

The evidence FEMA needs

A request has to show where the property is on the map and how its ground compares with the BFE. The usual package includes:

  • a copy of the recorded deed or plat map showing its recordation details;
  • a map showing the property’s location, such as a FIRMette printed from FEMA’s map service;
  • certified elevation data, unless the request is out as shown.

The elevation data can come from the elevation form in the MT-EZ or MT-1 package, or from an Elevation Certificate that includes the LAG. Either way, the LAG must be certified by a licensed land surveyor, engineer or architect. Owners cannot self-certify elevations for a LOMA. FEMA notes that a certificate “may be available from the community,” so check with the local floodplain office before ordering a new survey.

Where FEMA has not set a BFE for the zone, it will try to calculate one for requests covering fewer than 50 lots or 5 acres. Larger requests must supply their own BFE.

Forms and ways to apply

  • MT-EZ. The paper form for a single residential structure or lot. FEMA’s MT-EZ instructions let the owner, a licensed land surveyor or a registered professional engineer complete Section A.
  • MT-1. The application package for conditional and final LOMAs and LOMR-Fs that the MT-EZ does not cover, including every LOMR-F.
  • eLOMA. A web tool for licensed land surveyors and professional engineers to submit simple LOMA requests. FEMA calls it “a faster alternative,” and most requests that qualify for the MT-EZ can go through it.
  • Online LOMC. FEMA’s tool for submitting requests eLOMA cannot handle. It lets applicants upload documents and check status instead of mailing paper forms.

Cost and timing

FEMA “does not charge a fee to review a LOMA request.” LOMR-F and other revision requests carry FEMA review fees, which FEMA lists on its flood map fee page. Any survey or engineering work is billed separately by the professional who does it.

FEMA’s MT-EZ instructions state that, under 44 CFR 70.4, FEMA “will notify the requester of the determination in writing within 60 days of the date of receipt of all required data.” The clock starts only once the file is complete. Missing documents delay the answer.

What a LOMA does to the insurance requirement

A LOMA or LOMR-F that places the building outside the high-risk zone ends the federal mandatory purchase requirement (when flood insurance is mandatory). The lender still decides whether to keep requiring coverage as a loan condition.

If the lender agrees to waive the requirement, the owner can cancel and is eligible for a pro-rata refund of the current policy year’s premium, provided no claim is pending or has been paid that policy year. The refund requires sending the LOMA and the lender’s waiver to the agent or broker who sold the policy.

FEMA also points out that a LOMA does not mean there is no flood risk, and it recommends keeping coverage. Under Risk Rating 2.0 the premium for a building outside the zone still reflects its own elevation and exposure. The flood insurance cost guide explains how that works.

What happens to a LOMA when new maps take effect

A LOMA amends a specific map panel, so a new map puts it back under review. FEMA’s Summary of Map Actions guidance states that when a revised FIRM panel takes effect, “all previous map actions for that panel are superseded.” Every valid LOMC on it must then be re-evaluated against the new flood data.

FEMA sorts existing LOMCs into categories in a Summary of Map Actions (SOMA), issued with the preliminary maps and again with the final determination:

  • Revalidated. The determination still holds on the new map, for example because the LAG is still at or above the new BFE. These LOMCs appear on a Revalidation Letter that is effective one day after the new FIRM effective date, and the original letter stays valid without being reissued.
  • Superseded. The new flood data replaces the basis of the determination, for instance because the LAG is now below the new BFE, or there was not enough information to decide. The old letter is no longer valid.
  • To be redetermined. Some multi-lot or multi-structure LOMAs cannot be revalidated or superseded as a whole and need new determinations.
  • Incorporated. Some LOMRs, and occasionally large-area amendments, are built into the new map itself.

FEMA’s revalidation status note advises contacting the local community official when a LOMA’s status is unclear. Its LOMA database can include letters that are no longer effective.

The Miami-Dade 2027 map change

Miami-Dade County’s revised FIRMs take effect on February 19, 2027 (91 FR 65238, published October 14, 2026, docket FEMA-B-2166). Owners holding a LOMA or LOMR-F in the county should confirm whether FEMA listed it for revalidation or as superseded. The Revalidation Letter for the new panels takes effect one day after the maps, on February 20, 2027.

If a letter is superseded, the building will be judged against the new map. A new LOMA request would then compare the certified LAG with the new BFE. Buildings that move into the high-risk zone on the new map trigger lender requirements under the existing rules. The guide to the 2027 Miami-Dade flood maps covers the map change itself, and each Miami-Dade ZIP report shows its current flood zone mix.

Questions

How much does a LOMA cost?

FEMA does not charge a fee to review a LOMA request. The requester supplies the mapping and survey information, and if certified elevations are needed, the surveyor or engineer sets their own fee. LOMR-F requests carry a FEMA review fee.

How long does a LOMA take?

Under 44 CFR 70.4, FEMA notifies the requester of its determination in writing within 60 days of receiving all required data.

Does a LOMA cancel my lender's flood insurance requirement?

It removes the federal requirement, but the lender can still require flood insurance as a loan condition. If the lender waives it, the owner may get a pro-rata refund of the current year's premium, provided no claim is pending or paid that policy year.

Is a LOMA still valid after new flood maps take effect?

Only if FEMA revalidates it. When a revised map panel takes effect, earlier map actions on that panel are superseded, and a Revalidation Letter effective one day after the new map date lists the LOMCs that remain valid.

Sources

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