The City of Key West, Florida

The Southernmost City in the Continental United States

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Map Changes/Amendments

Letter of Map Change/Amendment (LOMC/LOMA)

When FEMA maps flood zones, it does so with a broad brush.  Invariably, within these zones, there are going to be lots where the land is higher than the Base Flood Elevation (BFE).  Therefore, absent a basement, buildings on this lot will be higher than the BFE.

Where this occurs, flood insurance rates or mandates could be excessive.  

FEMA has a procedure for resolving such scenarios, the Letter of Map Amendment (LOMA) process.

A LOMA ruling can effectively change a building or entire lot's flood zone rating, irregardless of flood zone in which it's physically located.

For example: An Olivia Street residence located within and AE-6 flood zone had an elevation certificate showing the lowest ground height on the lot at 6.4' (sec. C2f) above mean-sea-level (msl).  Therefore, by default this lot is already above the height of the six-foot flood zone. 

FEMA approved a LOMA application, reclassifying this lot from a regulated AE-6 flood zone to an unregulated X-zone.  As a result, any mandatory flood insurance requirement was relieved, and the now optional flood insurance is considerably less expensive.

Completing a LOMA application mostly involves the collection of a number of certified documents.  The application begins with an Elevation Certificate, completed during the past few years.

If the Elevation Certificate shows the lowest height of the grade (Sec. C2f) as higher than the BFE (Sec. B9), then a LOMA application is likely to be approved.  

Helpful Tips:

  • Applications receive quicker processing if the paper forms are accompanied by digital versions of the same on CD or flashdrive. 
  • Don't make any marks, notes or highlights on an Elevation Certificate.  To do so invalidates the certificate.
  • If the building or lot is higher than BFE because fill has been placed, there's a different application known as the LOMA-F.
  • The application advises against including original documents.  That only referrers to the attached documents.  The application itself must be the original.
  • You may encounter the term Letter of Map Revision (LOMR).  This usually isn't applicable to property owners, as it seeks to change the boundaries of flood zones rather than the status of a specific building or lot, and is a much more involved process using professional hydraulic engineers.
  • As of mid-August 2016, LOMA application processing times are now being projected at 8 weeks.

Effect of LOMA or LOMA-F on Flood Insurance Requirements

The issuance of a LOMA or LOMA-F eliminates the Federal flood insurance purchase requirement as a condition of Federal or federally backed financing; however, the mortgage lender retains the prerogative to require flood insurance as a condition of providing financing, regardless of the location of a structure.

The purchase of a flood insurance policy is wise even if a structure is located outside the Special Flood Hazard Area (SFHA). More than 25 percent of flood claims are made by property owners located outside the SFHA. The issuance of a LOMA or LOMA-F does not mean the structure or lot is safe from all flooding; it means that the risk of flooding is not as high as it is in the SFHA. Events greater than the 1-percent-annual-chance event can and do occur. It is also to important to note that the flood insurance premium rate for structures located outside the SFHA are lower than the premiums for structures located in the SFHA.

Revalidation of Letters of Map Change

Occasionally, FEMA may issue a minor map revision that could cause some mortgage companies to not accept any Letter of Map changes related to the same map.  While this is standard procedure when entirely new flood maps are issued or existing maps significantly modified, some mortgage companies may take the same stance when a very minor map change has occurred; despite FEMA's final determination documents stating:  "NO REVISION TO THE FLOOD INSURANCE STUDY REPORT” results from this action.  Base flood elevations and flood zone boundaries were not changed by this case."

Therefore, anyone with a Letter of Map Change on the affected map panels caught in this quagmire should re-apply to FEMA for a new one.  There is no charge from FEMA for this review.

This application can now be submitted online at www.fema.gov/online-lomc.

This application requires these documents:

  • The original LOMA or LOMA-F Determination Document (Removal). Please note:  If you don't have your copy, contact sfraser@cityofkeywest-fl.gov.
  • FEMA MT-1 Form: Complete and sign this form.  Please note:
    • To expedite these revalidations, submit the form as a LOMA without regard for fill. The existing LOMA or LOMA-F will provide the fill-related information.
    • Not sure of the legal description for your parcel? Look on the current LOMA or LOMA-F (under LOT, BLOCK/SECTION, SUBDIVISION).  If it's not there, you can look it up on the Monroe County Property Appraiser web site: www.mcpafl.org/PropSearch.aspx.
    • No need to include documents on the page 2 check list.  Your existing LOMA or LOMA-F will provide this information.
    • No need to complete the Processing Fee section.  There is no charge for this.
  • Request a Letter of Explanation from the City's Floodplain Administrator, to accompany your application.

Mail all three of these documents to:
    LOMC Clearinghouse
    847 South Pickett Street
    Alexandria, VA 22304-4605

If questions, please contact Scott Fraser by e-mail at sfraser@cityofkeywest-fl.gov or by phone at (305) 809-3810. 

UPDATE:  FEMA has recently created the "e-LOMA" process for the electronic submission of Letter of Map Amendment Applications.  Click here for more information on e-LOMA submission.

Helpful LOMA Forms & Publication

Example of a LOMA application

FEMA's LOMA Web Page

LOMA Online Tutorial  For submitting the MT-EZ online.  

FEMA's MT-1 form & Instructions LOMA Form (If you already have an Elevation Certificate)

Not RecommendedFEMA's MT-EZ LOMA form & Instructions (If you don't already have an Elevation Certificate) Note: If you use this method, you'll still need to hire a Land Surveyor to complete this application, and you won't receive an Elevation Certificate when it's done. An Elevation Certificate can be uses for multiple purposes, but this MT-EZ can't, and the cost difference between the two isn't worth the savings. 

Contact Us

Scott Fraser,
FEMA Coordinator/Floodplain Administrator
  • Staff Directory
  • Tuesday, 9:00 a.m. - 5:00 p.m. Wednesday, Noon - 5:00 p.m. Thursday, 9:00 a.m. - 5:00 p.m.

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