FEMA Question - Contradiction
OK Gents, I have done an increasing number of elev certs in the last few years. I used to just turn over the cert + an MT-EZ, and let the client handle it, recently for the straight forward ones, I have registered and done the eLOMA for an additional fee (clients love the time savings).
On the current house I am working on, it is straight forward, with one issue that I just have come across, and never thought of before. On the MT-EZ and the eLOMA, the determining factor is that the LAG is above the BFE - that is all they care about. On this project, the LAG is above the BFE, so the house will pass the MT-EZ and eLOMA just fine. However it is a building diagram #9, with a subgrade crawl space, and the dirt floor of the crawl, item C2.1 is BELOW the BFE. So by eLOMA (and MT-EZ) standard this will pass OK, but if it gets audited, then I will have to complete the full cert, and then it will show the crawl below the BFE = FAIL?
Is that elev something that gets looked at on the full cert? or is it just there for info purposes? I thought that anything below BFE is trouble, yet the eLOMA and MT-EZ appear to pass some structures, while a full cert will fail them? I am worried that I will do an eLOMA (or client does an MT-EZ) and it looks like it will pass, then it gets audited, submit a full cert, and then I find trouble! I may have a whole subdivision with this issue, so it is something I would like to investigate.
In theory the crawl will not be an issue. I would be absolutely sure to state it is a crawl space in the comments section. More and more communities are requiring the crawl space on new construction to be above BFE. It gets them a better rating to be more restrictive. It doesn't prevent LOMA approval but it can prevent occupancy permits from being issued.
I have been audited on several where the crawl was below and every one was approved.
Good luck, Tom
CFedS, PLS ID-OR-WA-UT-NV
I've never had to submit an elevation certificate when audited. They typically require an elevation form, that only lists the site address and LAG, along with the deed or plat, FIRM, flood study profile and a tax map. The determining elevation for a LOMA is the LAG and not the lowest floor, so it shouldn't matter either way.
I am in a similar situation where at the house I just bought. I had a EC done and all checked out but one side of the house the LAG is ~8" below BFE. My first thought was to bring in fill and fill the small side area and submit a LOMR-F my only concern there is that FEMA will need the community sign off and that process might take forever to be resolved. Any recommendations?
I've found FEMA isn't consistent when doing LOMAs or LOMA-F when they compare LAG to the bottom of the lowest floor so believe it depends on the independent contractor or caseworker. I submitted a full elevation certificate which of course included photos but was denied because the lowest floor (crawlspace) is lower than the BFE (but the LAG is higher than the BFE). Since you can't actually talk with the caseworker to ask about their reasoning, I sent a letter asking how water would enter the crawlspace when the bottom of the vent is 0.3' HIGHER than the LAG which is already above the BFE and was replied by email with "any elevation below the BFE on the structure would prevent removal of the structure from mandatory flood insurance". Odd, the next 4 or 5 with the same elevation difference submitted were removed.
A structure with a natural LAG above BFE is not in the SFHA. When you add fill to raise the LAG the crawlspace must be above the BFE also.
The important part here is the definition of fill. Adding dirt is not 'fill' if your purpose is something else. In one case i did the dirt had washed away from the patio slab. Another Surveyor told the owner he could not fill the hole and sent in an ecert showing the lag 0.2 below BFE. I wrote up a letter and added extra photos. Saved the owner a few hundred a month.
The key is to be truthful and guide your clients to do the right thing. It aint that hard.
CFedS, PLS ID-OR-WA-UT-NV