A flood zone line gets drawn across a whole stretch of landscape, and now and then a house on the high side of that stretch ends up inside it. If that house has a mortgage, the lender will usually require flood insurance, and the buyer hears about it a couple of weeks before closing. FEMA has a process for the cases where the map is wrong about one specific building, and it doesn't come up much in listing conversations.
I covered the buyer-risk side of flood zones in this earlier post about April, so this one is only about the paperwork side of a flood zone designation: how you contest one, what it takes, and what it might save.
Where this came from
Karol Grove, a Licensed Professional Surveyor and Certified Floodplain Manager with Alpine Land Surveying in Hartland, presented at our office, and it stuck with me enough that I went and read FEMA's own pages. I'm not going to characterize what she said beyond that. What I can point to is her website, floodzoneexpert.com, which lists flood zone review, elevation certificates, Letter of Map Amendment applications to FEMA, free preliminary consultations and flood zone dispute support, and says she serves all of Michigan. Everything below about how the process works comes from FEMA and NFIP pages, not from her.
LOMA or LOMR-F
There are two routes, and the difference is how the house got above the water. A Letter of Map Amendment (LOMA) is for a building on natural ground that sits at or above the base flood elevation but got mapped into the high-risk zone anyway. A Letter of Map Revision Based on Fill (LOMR-F) is for a building on fill, and the fill has to have been placed legally. FEMA's test for both is whether the lowest adjacent grade, which is the ground touching the house, is at or above the base flood elevation (the water height expected in a flood with a 1 percent chance each year) shown on the current map.
FEMA says a LOMA is free to submit and a LOMR-F carries a fee. I'd check FEMA's flood map fee page for the current amount instead of trusting a number from me. FEMA also says nearly all determinations come back within 35 days of receiving an application, though an incomplete application takes longer.
The elevation paperwork, and who can sign it
Both routes need elevation documentation from a professional, either an Elevation Certificate or a FEMA form completed by a surveyor or engineer. For a LOMA only, LiDAR data can stand in if it meets FEMA's standards. I don't know how often that gets accepted on a lake lot, so ask. FEMA's NFIP pages say an owner can hire a land surveyor, engineer or architect to complete a certificate. A seller can't do it, and neither can I.
Does a certificate change the premium?
Under Risk Rating 2.0, FEMA no longer requires an elevation certificate to buy a policy. Its FAQ says an owner may still submit one to their NFIP insurer to see whether it affects the rate, and it doesn't promise more than that, so I can't tell you a certificate lowers a premium. It might. Your agent can price the policy with and without it. In Zone A and Zone V areas, FEMA also notes owners may need certificates to show the property meets local floodplain ordinances, which is a different question from the premium.
The bigger lever is the designation itself. If a LOMA takes the house out of the high-risk area, the lender's requirement is what's in question, and your lender decides which documents it will accept. Call them before you order anything. Whether you can cancel an existing policy afterward and what comes back to you is a question for your insurance agent.
Survey cost against the premium
I don't have a Michigan price for a survey or a certificate and I'm not going to guess one. Get it quoted (Karol's site offers a free preliminary consultation, so that call costs nothing), get a flood insurance quote on the house as mapped, and compare the survey fee with the yearly premium times the years you plan to own the place. Thirty years with a mortgage looks different than selling in four.
If you're buying, it's worth asking the seller whether a LOMA or an elevation certificate already exists for the property. It fits right alongside the questions in our post on seller disclosures.
That 85 percent figure
Her website says about 85 percent of the structures that lenders are forcing to carry flood insurance qualify for a LOMA. That is her number and a marketing claim, and I couldn't find an approval rate from FEMA to put next to it. FEMA's pages describe how to apply and how long it takes, and say nothing about how often applications succeed. A surveyor's business is built on these applications, which doesn't make the figure wrong, but treat it as the best case. A LOMA needs the ground at the house to be at or above the base flood elevation, and a low lot near the water won't pass no matter who files the paperwork.
If the maps are being redrawn
This is separate from a LOMA. When FEMA issues preliminary flood maps for an area, there's a 90-day appeal and comment period. FEMA says residents, business owners and others can submit during that window, and an appeal needs technical or scientific evidence that the preliminary map is wrong. A house that has never flooded doesn't count as evidence on its own. I haven't seen a current preliminary map notice for Grand Traverse, Leelanau or Antrim counties and I don't know the schedule, so check FEMA's Flood Map Service Center or your county planning office.
Confirm every step with your own lender and insurance agent, since the lender decides what paperwork satisfies the loan and the agent prices the policy. If you're looking at a house up here with a flood zone on it and want a second set of eyes on the question, send it over. You can also browse what's on the market on our current listings page.
Taylor Brown, Realtor
Taylor@taylorbrownrealtor.com
