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FEMA Flood Mapping Update: City Program for Resident Support

Background:

The Federal Emergency Management Administration (FEMA) has adopted new flood maps for Scott County that will become effective on February 21, 2021. By mid-March 2021, FEMA and/or home lenders are anticipated to notify properties affected by the mapping and are required to purchase flood insurance.

Property Classifications Relative to the Floodplain

The FEMA maps illustrate the 100-year floodplain boundary. The City has compared the mapped boundary to property boundaries to identify properties that will be located within the 100-year floodplain. The maps also list the water surface elevation of the 100-year flood. In some cases, the mapped floodplain boundary does not fully reconcile with known structure elevations. In other cases, more detail is needed to confirm whether a property’s structure is within the floodplain. On properties where ambiguity exists, FEMA typically requires flood insurance.

Surveying efforts to verify structure elevations is recommended to potentially remove Jordan properties from the floodplain. In the event this surveying effort does not remove a property from the floodplain, survey efforts will still create two other beneficial options for such properties, including:

  1. Document the actual structure elevation(s) compared with the floodplain elevation, allowing lower flood insurance premiums to be paid, or
  2. Determine if adding a minor amount of fill around a structure would qualify the structure to be removed from the floodplain.

There are over 200 properties in Jordan that could benefit from such efforts, as illustrated in this map: Jordan Floodplain Mapping Evaluation. Therefore, the City has developed a program to assist Jordan property owners with these efforts to take advantage of efficiencies gained from having one centralized process. The program will be funded by its participants, but the costs to each participant will be lowered by completing the work together rather than as individuals.

City of Jordan Flood Mapping Resident Support Program: Details & Process

The City has developed a community program to provide property owners with information and support throughout this process with the intent of saving Jordan residents money by finding opportunities to reduce flood insurance premiums. For those properties that elect to participate in this program, the process is as follows:

  1. Property owners inform the City of their interest in the program no later than December 11, 2020.
  2. The City provides property owners with an agreement, which is signed and return to the City no later than December 31, 2020.
  3. A professional surveyor, contracted by the city, will visit each participating property to collect the FEMA required elevation information. Participating properties will be surveyed and the data reviewed to determine the appropriate documentation submittal for FEMA.
  4. The City’s certified floodplain manager reviews the data collected against the 100-year flood elevation at each property to determine the appropriate FEMA documentation and category your property will fall into.
  5. Property owners are informed of the following findings:
    1. If the structure elevation is found to be above the 100-year flood elevation at your property, a Letter of Map Amendment (LOMA) document will be completed to remove your structure from the floodplain.
    2. If the structure elevation is found to be below the 100-year flood elevation, two options will be explored by the City’s floodplain manager and communication will occur with the property owner accordingly. The two options to be evaluated at this step include:
      1. The option of placing fill around the structure to potentially remove the structure from the floodplain. Typically, this option will only exist where small amounts of fill are needed to achieve this goal. A second survey visit will be required and a Letter of Map Revision for Fill (LOMR-F) will be completed to remove the structure from the floodplain.
      2. If placement of fill is infeasible, an Elevation Certificate (EC) produced for the property which would be required to reduce flood insurance premiums.
    3. The appropriate documentation (LOMA, LOMR-F, or EC) will be completed and submitted to FEMA on property owner’s behalf. Documentation will be retained by the City and available to property owners upon request.
    4. Payment is due to the City by May 1, 2021. If no payment is received, properties that choose to participate will be assessed the associated costs for inclusion on tax payments over the next 5 years.

Public Information Meetings

The City is conducting an informational meeting series regarding the new FEMA flood maps and City program. Meetings will be held:

Monday, November 30th

Jordan City Council Chambers

116 First St E, Jordan MN

2:30 PM: LOMA & EC Properties Invited

4:00 PM: LOMA-OAS Properties Invited

5:30 PM: LOMA, EC, & LOMR-F Properties Invited

7:00 PM: EC Properties Invited

Property owners can attend any of the meeting times if they desire, but recognizing the complexity of this subject, targeted information will be presented to each group at their respective meetings for which an invitation was mailed. Residents with general interest in this topic may attend any session they desire. Invited residents should refer to the letter they received to understand which meeting option(s) they should attend.

Due to the pandemic, the following measures are being taken to facilitate the meetings:

  • The meetings will be broadcast simultaneously on the City of Jordan’s website. They will also be recorded and available on the website for future viewing.
  • You can attend via Zoom Meetings. Please email jordanfloodmapping@bolton-menk.com and you will be senta link to the requested meeting time. Questions will be taken from Zoom attendees and answered by the presenter.

In-person attendance will be limited to 10 attendees per session to enable social distancing. RSVPs are required for in-person attendance and must be submitted by Nov. 24 to: jordanfloodmapping@bolton-menk.com. Please email your requested meeting attendance time and your property address. While not required, property owners are asked to limit in-person attendance to one representative per property to maximize available space.

City Program Benefits

Lenders frequently, if not always, require flood insurance for properties within the floodplain, typically at an annual cost greater than the City’s one-time program costs. Annual flood insurance premiums paid by residential properties in Jordan typically range between $1,000 per year to $2,500 per year, depending on the value of the property, the policy coverage amounts, and variations in the risk of flooding. The program will either remove participating properties from the floodplain to avoid mandatory flood insurance requirements or to reduce future flood insurance premium amounts by thousands of dollars over future years. The City is sending letters in early November 2020 to properties it anticipates may benefit from this program.

Not all specifics to each property’s situation will be known by the City. It is noted that this program may not benefit properties that:

  • Do not have a mortgage (which would require flood insurance, as all mortgages do) and do not desire to purchase flood insurance. If property owners do not have a mortgage, but still desire to purchase flood insurance due to their proximity to the floodplain, acquiring an elevation certificate through this program would provide you a lower flood insurance premium; or
  • Already have an elevation certificate for the property and have verified that it shows the structure elevation is below the new 100-year flood elevation. If property owners have an elevation certificate but are unsure how it relates to the newfloodplain elevations, it is recommended they provide the certificate to the City to evaluate (at no cost) whether this program would be beneficial.

Properties removed from the requirements for mandatory flood insurance by participating in this program may also choose to continue to carry voluntary flood insurance at a reduced rate.  Residents who live outside of the floodplain are also encouraged to maintain flood insurance, which can be purchased at a substantially reduced rates as compared to rates for structures within the floodplain. Additional information regarding flood insurance is available at www.floodsmart.gov.

City Program Costs

Participation in the City program is optional, though the program will be beneficial to those who participate. Costs for participation in the program will depend the category each property falls into, which depends on the needs for each specific property identified based on a survey and the number of participants who opt-in. Commonly, the category cannot be known until the survey is complete, though where it can be reasonably determined in advance property owners are notified in the initial letter they receive.

The following cost tables are provided to give you an estimate of the costs of participation. In general, the lesser the benefit received by each property, the lesser the cost of participation. While flood insurance burdens are obviously less than desirable, the City is hopeful numerous property owners will choose to participate in this program to the lower the costs for themselves and their neighbors.

Letter of Map Amendment (LOMA) & Letter of Map Amendment (LOMR-F) Properties

Properties in this Category that Choose to Participate Cost Per Property for a LOMA Cost Per Property for a LOMR-F
0 to 10 $ 1000 $ 1,500
11 to 20 $ 800 $ 1,300
21 to 30 $ 700 $ 1,200
31+ $ 600 $ 1,100

Elevation Certificate (EC) Properties

Properties in this Category that Choose to Participate Cost Per Property for an Elevation Certificate
0 to 10 $ 700
11 to 20 $ 650
21 to 30 $ 600
31+ $ 500

Property owner payment can be made in one of two ways:

  1. Make payment in full to the City of Jordan by May 1, 2021; or
  2. Be assessed for the associated costs over the next 5 years at a 5% interest rate, per the City’s assessment policy. Payment of assessments is made as an addition to your annual tax payment made to Scott County.

Final costs for each property will be known in January 2021 once the number of participants in each category is known by the City.

How to Participate in the City of Jordan’s Flood Mapping Resident Support Program

Letters are being sent in early November to properties identified by the City that may benefit from the program. The letter includes a form to be returned to the City indicating an interest in participating.

  1. Property owners inform the City of their interest in the program no later than December 11, 2020.
  2. The City provides property owners with an agreement, which is signed and return to the City no later than December 31, 2020.

If you did not receive a letter, and would like to understand why you did not receive one (i.e. your neighbor received one, but you did not), you may email jordanfloodmapping@bolton-menk.com to get more information specific to your property.

Related Documents & Information

City of Jordan Flood Mapping Resident Support Program Fact Sheet (insert link to fact sheet)

Preliminary Copy of Flood Maps to be Adopted:

The City has completed a preliminary evaluation of the FEMA maps as compared to ground contour lines to assume building floor elevations. Individual properties were then identified that would benefit from completing various types of FEMA documentation to potentially reduce flood insurance premiums. A map of the City was produced to illustrate these preliminary findings: Jordan Floodplain Mapping Evaluation

Additional Information from the MN DNR: https://www.dnr.state.mn.us/waters/watermgmt_section/floodplain/map_appeals.html

The City is pursuing a flood control project involving construction of certified levees which will largely replace and raise the existing, uncertified levees. Flood Control Project Website: https://clients.bolton-menk.com/jordanengineering/sandcreekfloodcontrolimprovements/

Additional information regarding flood insurance is available at www.floodsmart.gov.

Frequently Asked Questions (FAQ):

Q: Is my house in the floodplain?  

A: Parts of some property might be within the floodplain, but not necessarily the structure. However, FEMA and lenders typically consider a structure to be located in the floodplain if the property boundary touches the floodplain, except when documentation can be provided to FEMA that shows the structure within that property is sufficiently elevation above the 100 year flood elevation. The City has created a map comparing the FEMA floodplain boundary to property boundaries which is available here: Jordan Floodplain Mapping Evaluation. This map primarily illustrates properties which are located within or touch the floodplain, but not necessarily the house or structure, which depends on the lowest opening/adjacent ground elevation of the structure as compared to the 100 year flood elevation. The City of Jordan Flood Mapping Resident Support Program will help with these structure documentation efforts and submittals to FEMA.

Q: Will the City’s program reduce my flood insurance premiums?

A: The City’s program outlined on this site is intended to either eliminate or reduce flood insurance premiums for participating properties. Outside of this program, comparison between current premiums and future premiums will also be heavily influenced by what happens with subsidies for the National Flood Insurance Program (NFIP). Flood insurance premiums are on the rise as federal subsidies for the NFIP are being phased out. As subsidies from the federal government are removed, the insurance rates in the NFIP must be increased at the federal level to keep that program solvent. The removal of federal subsidies is outside the control of the City of Jordan.

Properties opt in will see their insurance premiums lowered or nor rise as quickly as those properties that choose to participate, though it is possible premiums will continue to rise due to loss of federal subsidies for the NFIP.

Q: What is a LOMA?

A: A Letter of Map Amendment (LOMA) is a letter from FEMA confirming that a portion of the map is incorrect. More information on LOMAs is available here: https://www.dnr.state.mn.us/waters/watermgmt_section/floodplain/map_appeals.html

There are several types of LOMAs depending on the situation, including the following three common types:

  1. LOMR-OAS, or Letter of Map Amendment, Out As Shown – Typically used where a structure can be easily viewed as located outside the floodplain through use of aerial photos and simple contour maps. If the structure on a property fits the criteria, property owners can typically complete these on their own using these instructions: https://files.dnr.state.mn.us/waters/watermgmt_section/floodplain/how_to_apply_for_loma-oas.pdf
  2. LOMR-F, or Letter of Map Revision Based on Fill – When more simple tactics such as the LOMA-OAS process is not or will not be successful, a LOMR-F is typically used when a survey is completed by a professional surveyor to demonstrate that the property is elevated above the 100 year floodplain. Typically to receive this approval, both the structure and the ground area 15-feet around the structure both need to be elevated above the 100 year flood elevation. Sometimes the survey will show the structure is not located above the floodplain, and a property owner needs too add fill surrounding the structure. In those cases, a follow up survey is needed to verify the work is complete and then the LOMR-F documentation can be submitted.
  3. CLOMR, or Conditional Letter of Map Revision – This document is used when a new structure is proposed on a property within the floodplain. The proposed plans illustrating the building elevation are submitted to FEMA for review and approval via a CLOMR before investment in the construction is made. Following construction and submittal of an asbuilt survey, FEMA then issues a LOMR or LOMR-F for the property.

Q: How do I complete my own LOMA-OAS?

A: Some properties may be able to secure a Letter of Map Amendment – Out as Shown (LOMA-OAS). These properties are typically ones where the structure on a property is clearly visible outside the floodplain on a map containing both an aerial photo and the floodplain. Property owners can typically complete this work on their own, using the DNR’s instructions: https://files.dnr.state.mn.us/waters/watermgmt_section/floodplain/how_to_apply_for_loma-oas.pdf

Q: What is an Elevation Certificate?

A: An Elevation Certificate (EC) is used to document the elevation of a structure relative to the 100 year base flood elevation. In the downtown/lowertown areas of the City of Jordan where structures were built long before flood maps were first published in 1982, EC’s are used to provide FEMA with documentation so the flood risk can be more accurately quantified. Without an EC submitted for a structure built before 1982, FEMA and lenders effectively assume that structures within the floodplain will be submerged by 3 feet or more of floodwater during a 100 year event, and flood insurance premiums are calculated accordingly. Most structures within the floodplain in Jordan are not estimated to be at that great of depth, though. Therefore, producing elevation certificate can demonstrate a reduced risk to FEMA for most lowertown Jordan properties and reduce flood insurance premiums accordingly from what would otherwise be due.

Q: My neighbor’s house is at about the same elevation as mine, maybe even lower than mine and they are participating in the City’s program to hopefully have their house removed from the floodplain. If FEMA removes their house from the floodplain, will mine be removed too? Or do I need to participate in the program as well?

A: The City’s program involves completed survey efforts and producing documentation specific to each property for FEMA. This documentation is property specific and reviewed by FEMA on a property-by-property basis for those properties listed in the submitted documentation. Each property needs to participate if they wish to receive benefits from the City’s program.

The program is being funded by the benefitting property owners on a cost scale that is ‘sliding’ based on the number of properties participating. In general, the more properties that participate, the lower the individual cost for each participating property. In addition to the City’s desire to help each property owner individually, the City is hopeful more property owners choose to participate to lower the cost for themselves and their neighbors.

Q: I’m a renter of a property in the floodplain. If my landlord purchases flood insurance, are my belongings covered by the policy?

A: While your landlord may have flood insurance to cover the building you live in, their insurance will not cover a renter’s personal belongings. FEMA has created a flyer dedicated to this subject: https://www.fema.gov/media-library-data/1590166588393-140299a632495d08b2a6162af4eb0890/101927-002_FEMA_Renters-Brochure_55x85_v7_urban_508.pdf

Contacts:

Mike Waltman, City Engineer, (952) 890-0509, mikewa@bolton-menk.com

Roberta Cronquist, MS, PE, CFM, Program Administrator, 952-890-0509 x3095, jordanfloodmapping@bolton-menk.com