Section 4 

Processing Procedures for Special Conversions 

This section outlines the standard procedures that the Department of Homeland Securitys 
Federal Emergency Management Agency (FEMA) and National Service Provider (NSP) staffs 
are to follow for converting communities to the Regular Phase of the National Flood Insurance 
Program (NFIP) using special conversion procedures. Under special conversion procedures, 
communities are converted to the Regular Phase of the NFIP without a detailed study being 
performed by or for FEMA or Base Flood Elevations (BFEs) being determined. 

Detailed flow diagrams for non-floodprone conversions, minimal floodprone conversions by 
letter, and minimal floodprone conversions with maps are provided in Figures 4-1 through 4-4 at 
the end of this section. Descriptions and copies of the documents cited in this section are 
provided in Appendix D of this Manual. 

4.1 Criteria for Special Conversions 


Communities are considered to be non-floodprone if FEMA determines that the communities 
are not subject to inundation by the base (1-percent-annual-chance, or 100-year) flood. FEMA 
considers the following three guidelines in determining whether a community is to be considered 
non-floodprone: 

1. All Special Flood Hazard Areas (SFHAs) identified in the community are permanently 
narrowed to less than 200 feet wide. 
2. All drainage areas in the community are less than 1 square mile. 
3. The identified SFHAs are considered non-developable land as a result of remoteness or 
physiography. 


If the flood hazard areas in the community do not fit these guidelines, the community may not be 
considered as non-floodprone. As discussed later in this section, FEMA handles non-floodprone 
conversions by letter only. No Flood Insurance Rate Map (FIRM) is issued, and the effective 
Flood Hazard Boundary Map (FHBM), if one exists, is rescinded. The entire community is 
designated as Zone X (unshaded). 

Communities are considered to be minimally floodprone if FEMA determines that the 
communities are subject to inundation by the base flood, but existing conditions indicate the 
floodprone areas are unlikely to be developed in the foreseeable future. 

For a community is to be considered minimally floodprone, FEMA must determine that the 
community meets one, or preferably a combination, of the following five criteria: 


1. The floodplain is publicly owned and is designated for open space or preservation. 
2. Zoning laws, sanitary codes, subdivision regulations, shoreland regulations, or other 
community regulations effectively prohibit floodplain development. 
3. Surrounding land use or topography limits development potential (e.g., surrounding land 
is used for agriculture and is likely to remain so for at least five years). 
4. The community population is decreasing or stable, and no pressure for development in 
the floodplain is likely in the foreseeable future. 
5. The floodplain in the community is remote and uninhabited, and future development is 
unlikely. 


In assessing the development potential of the floodplain in a community, FEMA also considers 
the size of the undeveloped floodplain relative to the size of the community. The larger the 
proportion, the more likely it is that the floodplain will be subject to development pressure. 

4.2 Initiation of Special Conversions 


FEMA Regional Office (RO), FEMA Headquarters (HQ), or NSP representatives may 
recommend that a community be converted to the Regular Phase of the NFIP using special 
conversion procedures. However, the FEMA RO staff will make the final decision to proceed 
with a special conversion. 

Once a special conversion is recommended, the FEMA RO staff, in consultation with the 
community, evaluates the flood hazards in the community based on the criteria in Subsection 4.1 
of this Manual. If the FEMA RO staff determines that special conversion procedures are 
appropriate, the FEMA RO staff prepares a Special Conversion Recommendation Report 
(SCRR). The FEMA RO staff then submits the SCRR (page D-63) and any supporting data to 
the Project Engineer in the Engineering Management Section of the Risk Analysis Branch at 
FEMA HQ and to appropriate Program Specialist in the Floodplain Management Section (FMS) 
of the Risk Reduction Bran ch at FEMA HQ. 

In the course of evaluating a physical map update, FEMA HQ or NSP staff may find that a 
community meets the criteria in Subsection 4.1 of this Manual. When this occurs, the NSP 
works with the FEMA Project Engineer to prepare and send a memorandum recommending the 
special conversion to the RO staff for review. If the FEMA RO staff concurs with the 
recommendation, the RO staff submits an SCRR to initiate the conversion process. The NSP 
shall not initiate special conversion procedures for any community without FEMA RO 
approval in the form of an SCRR or similar documentation and approval from the FEMA 
Project Engineer. 


In preparing the SCRR, the RO staff recommends one of the following conversion actions: 

 Non-floodprone conversion by letter (see Subsection 4.4 of this Manual); 
 Minimal conversion with current FHBM converted to a FIRM by letter (see 
Subsection 4.5 of this Manual); or 
 Minimal conversion with FIRM printed (see Subsection 4.6 of this Manual). 


For a minimal conversion with a FIRM printed, the FEMA RO staff recommends one of the 
following mapping options or specifies an alternative mapping option: 

 FIRM showing all SFHAs as Zone A; 
 FIRM Index only, with the FIRM Index noting that all areas are Zone D; or 
 FIRM with one or more panels showing Zones A and X for most populated areas with all 
areas of undetermined flood hazards shown as Zone D. 


Each of these actions is discussed in more detail later in Subsection 4.6 of this Manual 

4.3 Initial Processing 


FEMA and NSP staff shall handle the initial processing of a non-floodprone or minimal 
conversion as follows: 

1. Upon receipt of an SCRR or similar documentation from the FEMA RO, the FEMA 
Project Engineer forwards the SCRR and supporting data to the NSP. 
2. The NSP reviews the SCRR to determine the conversion type and assigns a unique 
identifier. The unique identifier for a special conversion request is a nine-digit number 
(e.g., 06-08-001NF), which represents the following: 
 The first two digits (06 in the example above) represent the fiscal year in which the 
request is received. 
 The next two digits (08 in the example above) represent the FEMA Region in 
which the community is located. 
 The last three digits (001 in the example above) represent the consecutive request 
number for that region during the fiscal year. 
 The two-letter suffix at the end of the identifier (NF in the example above) 
identifies the procedure under which the request is to be processed. 


In the example above, the unique identifier is for the first non-floodprone conversion by 
letter in FEMA Region VIII during Fiscal Year 2006. The suffix for a minimal 



conversion with a map is MM, and the suffix for a minimal conversion by letter is 
ML. 
3. The NSP enters appropriate information about the assignment into the Mapping 
Information Platform (MIP) and updates the Status of Studies (SOS) module on the 
FEMA Community Information System (CIS) database through batch updates. The NSP 
then updates dates and other status information regularly in all appropriate systems. 
4. The NSP establishes a case file for the assignment and places a copy of the SCRR in the 
file. The NSP then includes all correspondence, telephone conversation records, and 
other documents relating to the assignment in the case file. 
5. The NSP reviews the submittal package to determine whether sufficient information has 
been provided to begin the technical review and processing. 
6. If sufficient information has not been provided, the NSP coordinates with the FEMA 
Project Engineer and with FEMA RO staff, as appropriate, to obtain the required 
information. 
7. Upon receipt of all required information, the NSP begins the technical review and 
processing stage, as discussed in Subsections 4.4, 4.5, and 4.6 of this Manual. 


4.4 Technical Review and Processing of Non-Floodprone 
Conversions 


FEMA and NSP staff shall follow the procedures below in reviewing and processing requests for 
non-floodprone conversions. These procedures also are presented graphically in the flowchart in 
Figure 4-1. (See page 4-21.) 

1. The NSP confirms that a non-floodprone conversion is appropriate by: 
 Checking the drainage areas for all flooding sources affecting the community to 
determine whether they are less than 1 square mile; 
 Checking the SFHAs shown on the existing FHBM for the community to verify 
whether they are less than 200 feet wide; and 
 Checking other physiographic characteristics that could preclude floodplain 
development. 


2. If the NSP finds that none of the criteria in Item No. 1 have been met for at least one of 
the flooding sources in the community, the NSP informs the FEMA Project Engineer. 
3. The FEMA Project Engineer notifies the FEMA RO staff of the findings and obtains 
additional justification for the recommendation. 



4. When the criteria in Item No. 1 are met, the NSP prepares one of the following 
conversion letters: 
 205 letter (Appendix D, page D-47)For communities that are participating in the 
Emergency Phase of the NFIP with an FHBM; 
 205-NP letter (Appendix D, page D-51)For communities that are not participating 
in the Emergency Phase of the NFIP, and an FHBM has been issued; or 
 206 letter (Appendix D, page D-53)For communities that are participating in the 
Emergency Phase of the NFIP without an FHBM. 


The conversion letter includes the conversion effective date, which is 2 weeks from the 
anticipated date of the conversion letter. 
5. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits the conversion letter to the FEMA Project Engineer for review 
and signature. 
6. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 
7. The NSP verifies that the conversion effective date is at least 2 weeks from the date of 
the conversion letter, mails the signed and dated letter to the community Chief Executive 
Officer (CEO) and floodplain administrator, and distributes external and in-house file 
copies in accordance with the requirements detailed in Subsection 4.9 of this Manual. 
8. The NSP prepares the Community Map Actions (CMA) list and submits the list, in digital 
format, to the Map Service Center (MSC) contractor along with the conversion letter 2 
weeks before the conversion effective date. 
9. If the signed Certified Mail receipt is not received by the NSP within 2 weeks after the 
date the conversion letter is mailed, the NSP contacts the community to verify receipt of 
the letter. 
10. If the community has not received the conversion letter, the NSP notifies FEMA and 
forwards a duplicate copy of the conversion letter to the community CEO and floodplain 
administrator. 
11. Once the NSP confirms that the community has received the conversion letter, the NSP 
updates the MIP and FEMA CIS database records and archives the community file and 
all backup information. 


For newly identified non-floodprone communities that are included in a countywide study, 
processing requirements are documented in Subsection 4.6.3.3 of this Manual. 


4.5 Technical Review and Processing of Minimal 
Conversions by Letter 


If no changes to the SFHAs shown on the effective FHBM are required, the FEMA RO may 
submit an SCRR recommending that a minimally floodprone community be converted without a 
FIRM. In such cases, FEMA and NSP staff shall follow the procedures below. These 
procedures also are presented graphically in the flowchart in Figure 4-2. (See page 4-25.) 

1. The NSP confirms that the conversion without a map is appropriate by: 
 Checking the correctness of the corporate limits, floodplain boundary delineations, 
and other physical and cultural features shown on the FHBM; and 
 Comparing the FHBM to readily available community maps, FIRMs, and/or FHBMs 
for adjacent communities, and readily available topographic maps. 


2. If the NSP determines that the corporate limits, floodplain boundary delineations, or 
other physical or cultural features shown on the effective FHBM are incorrect or the NSP 
locates sufficient data to warrant the preparation of a DFIRM with BFEs and collateral 
Flood Insurance Study (FIS) report, the NSP notifies the FEMA Project Engineer. 
3. The FEMA Project Engineer notifies the FEMA RO of the findings and obtains 
additional justification for the recommendation or concurrence on the preparation of a 
DFIRM with BFEs and FIS report or a special conversion with a map. 
4. If FEMA RO and HQ staff agree that a FIRM with BFEs and an FIS report should be 
prepared, the DFIRM and FIS report are processed in accordance with the requirements 
of Section 1 of this Manual. 
5. If FEMA RO staff and the FEMA HQ staff agree that the community should be 
converted without a map, the NSP prepares one of the following conversion letters: 
 196-C-FHBM letter (Appendix D, page D-19)For communities that are compliant 
with NFIP regulations according to RO staff; or 
 196-NC-FHBM letter (Appendix D, page D-31)For communities that are not 
compliant with NFIP regulations according to RO staff. 


The conversion letter includes the conversion effective date, which must be on the first 
day of a month. The conversion effective date for a 196-C-FHBM letter must be at least 
1 month after the date of the letter; the conversion effective date for a 196-NC-FHBM 
must be at least 6 months after the date of the letter. 



6. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits the conversion letter to the FEMA Project Engineer for review 
and signature. 
7. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 
8. The NSP verifies that the dating requirements in Item No. 4 are met and mails the signed 
and dated letter to the community CEO and floodplain administrator. With the letter, the 
NSP mails a copy of the effective FHBM, annotated to show the FHBM has been 
changed to a FIRM, and a copy of the NFIP regulations. The standard note that appears 
on the FHBM shall read as follows: 
THIS FHBM CONVERTED BY LETTER TO FIRM DATED 
(EFFECTIVE DATE OF FIRM). 


9. The NSP then distributes external and in-house file copies in accordance with the 
requirements detailed in Subsection 4.9 of this Manual. 
10. If the signed Certified Mail receipt is not received by the NSP within 2 weeks of the 
date the conversion letter is mailed, the NSP contacts the community to verify receipt of 
the letter. 
11. For a compliant community that has not received the conversion letter, the NSP notifies 
FEMA and forwards a duplicate copy of the conversion letter to the community CEO and 
floodplain administrator. 
12. For a noncompliant community that has not received the conversion letter, the NSP 
coordinates with the FEMA Project Engineer to decide whether the conversion effective 
date should be changed or the compliance period should be extended to allow the 
community a full 6-month period to adopt compliant floodplain management ordinances. 
13. The NSP prepares the CMA list and the 198 notice (Appendix D, page D-41) and submits 
them to the MSC contractor. The NSP must submit the CMA list and 198 notice to the 
MSC contractor no later than 4 weeks before the conversion effective date for 
compliant communities. The NSP must submit the CMA list and 198 notice to the MSC 
contractor no later than 4 months before the conversion effective date for 
noncompliant communities. 
14. The MSC contractor distributes the 198 notice, which notifies users of the conversion of 
the FHBM to a FIRM. 



15. For communities that did not have compliant ordinances when the conversion letter was 
issued and that have failed to submit compliant ordinances to the FEMA RO within the 
first 90 days after the conversion letter is sent, the FEMA FMS requests that the NSP 
prepare a suspension letter in accordance with the procedures detailed in Subsection 4.7 
of this Manual. 
16. The NSP updates the MIP and FEMA CIS database records and archives the community 
file, FIRM, and all backup information. 


4.6 Technical Review and Processing of Minimal 
Conversions With Maps 


If changes to the SFHAs shown on the FHBM are required, the FEMA RO submits an SCRR 
recommending that a minimally floodprone community be converted to the Regular Phase of the 
NFIP with a map. FEMA and NSP staff shall follow the procedures documented in Subsections 
4.6.1, 4.6.2, and 4.6.3 in performing the technical review, preparing the FIRM/DFIRM, and 
preparing and processing the required documents. These procedures also are presented 
graphically in the flowchart in Figure 4-3, if an FHBM was published (see page 4-31), and in the 
flowchart in Figure 4-4, if an FHBM was not published (see page 4-39). 

4.6.1 Technical Review 


The NSP performs the technical review in accordance with the procedures below. 

1. The NSP compiles the most current data available relative to the FHBM, including the 
following: 
 U.S. Geological Survey topographic maps and Floodprone Area Maps; 
 All supporting data and artwork for the effective FHBM; 
 NFIP maps and reports for adjacent communities; 
 Community maps; and 
 Floodplain Information Reports and other reports available from the U.S. Geological 
Survey, Natural Resources Conservation Service, and U.S. Army Corps of Engineers. 


2. The NSP reviews information in the SOS module of the FEMA CIS database, the MIP, 
and the NSP files to ascertain whether information from earlier map amendments and 
revisions, Annual Reports, and Biennial Reports exists. 
3. The NSP reviews all available materials and notifies the FEMA Project Engineer if 
problems are encountered or if sufficient data exist to prepare a DFIRM with BFEs and 
an FIS report. 



4. The FEMA Project Engineer notifies the FEMA RO of the findings and obtains 
concurrence on how problems will be resolved or on the initiation of a DFIRM with 
BFEs and an FIS report. 
5. If the FEMA RO staff and the FEMA HQ staff agree that the community should be 
converted under special conversion procedures with a FIRM/DFIRM and all technical 
problems identified by the NSP are addressed, the NSP prepares a FIRM/DFIRM and 
appropriate correspondence. 
6. If the FEMA RO staff and the FEMA HQ staff agree that a DFIRM with BFEs and an 
FIS report should be prepared, the DFIRM and FIS report are processed in accordance 
with the requirements of Section 1 of this Manual. 


4.6.2 Map Preparation 


The NSP prepares the FIRM/DFIRM Index and FIRM/DFIRM panels in accordance with 
Appendix K in Guidelines and Specifications for Flood Hazard Mapping Partners (FEMA, 
2003). These Guidelines may be viewed on, or downloaded from, the FEMA Flood Hazard 
Mapping Website at http://www.fema.gov/plan/prevent/fhm/dl_cgs.shtm. 

The NSP labels all SFHAs as Zone A and generally labels all areas outside the SFHAs as Zone 
X (unshaded). At the request of the FEMA RO, the NSP labels the areas outside the SFHAs as 
Zone D when the areas are remote and uninhabited (i.e., sparsely populated). The FEMA Project 
Engineer must approve any exceptions to this labeling. 

At the request of the FEMA RO, the NSP also may prepare a FIRM Index only for communities 
that are considered remote and uninhabited. In such cases, the NSP includes a note on the FIRM 
Index indicating that all areas in the community are in Zone D, areas of undetermined but 
possible flood hazard. 

4.6.3 Map and Correspondence Processing 


The procedures to be followed in processing the Preliminary copies of the FIRM and related 
standard documents vary, depending on whether an FHBM is already in effect for the 
community, whether the community is included in a countywide study, and whether the 
community is considered remote and uninhabited (i.e., sparsely populated). 


4.6.3.1 Communities with Effective Flood Hazard Boundary Maps 


The NSP prepares special conversion notification and transmittal letters as follows if an FHBM 
is in effect for the community: 

1. If the communitys floodplain management ordinances are compliant with the NFIP 
regulations according to FEMA RO staff, the NSP prepares a 196-C-O letter (Appendix 
D, page D-21). This letter notifies the community of the special conversion and transmits 
Preliminary copies of the FIRM to the community for a 30-day review period. The NSP 
mails the letter and enclosures to the community CEO and floodplain administrator at 
least 6 months before the conversion effective date cited in the letter. 
2. If the communitys floodplain management ordinances are not compliant with the NFIP 
regulations according to FEMA RO staff, the NSP prepares a 196-NC-O letter (Appendix 
D, page D-35). This letter also notifies the community of the special conversion and 
transmits Preliminary copies of the FIRM for a 30-day review period. The NSP mails the 
letter and enclosures to the community CEO and floodplain administrator at least 6 
months before the conversion effective date cited in the letter. 
3. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits a hard (paper) copy of the conversion letter to the FEMA 
Project Engineer for review and signature. 
4. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 
5. The NSP mails the letter to the community CEO and floodplain administrator along with 
two Preliminary copies of the FIRM and a copy of the NFIP regulations. 
6. The NSP distributes external and in-house file copies of the letters and FIRM in 
accordance with the requirements detailed in Subsection 4.9 of this Manual. 
7. If the signed Certified Mail receipt for the conversion letter is not received by the NSP 
within 2 weeks after the date the conversion letter is mailed, the NSP contacts the 
community to verify receipt of the letter. 
8. For a compliant community that has not received the conversion letter, the NSP notifies 
the FEMA Project Engineer and forwards a duplicate copy of the conversion letter to the 
community CEO and floodplain administrator. 
9. For a noncompliant community that has not received the conversion letter, the NSP 
coordinates with the FEMA Project Engineer to determine whether to change the 
conversion effective date or extend the compliance period to allow the community a full 
6-month period to adopt compliant floodplain management ordinances. 
10. The NSP updates the MIP and FEMA CIS database records for the community and 
archives the community file, the FIRM, and all backup information. 



4.6.3.2 Communities Without Effective Flood Hazard Boundary Maps 


If a community does not have an effective FHBM, the FEMA RO will submit an SCRR 
recommending that a FIRM be prepared. In such cases, FEMA and NSP staff shall follow the 
procedures below. 

1. If the community is participating in the Emergency Phase of the NFIP, the NSP prepares 
a 196-NC-I letter (Appendix D, page D-33). This letter notifies the community of the 
special conversion, transmits two Preliminary copies of the FIRM, and provides the 
conversion effective date. The NSP mails the letter to the community CEO and 
floodplain administrator at least 6 months before the conversion effective date. 
2. If the community is not participating in the Emergency Phase of the NFIP, the NSP 
prepares a different letter (196-NP-I, Appendix D, page D-37). The 196-NP-I letter also 
notifies the community of the special conversion, transmits two Preliminary copies of the 
FIRM, and provides the conversion effective date. This letter also is mailed to the 
community CEO and floodplain administrator at least 6 months before the conversion 
effective date. 
3. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits a hard (paper) copy of the conversion letter to FEMA for 
review and signature. 
4. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 
5. The NSP verifies that the dating requirements in Item Nos. 1 and 2 are met and mails the 
letter to the community CEO and floodplain administrator along with two Preliminary 
copies of the FIRM and a copy of the NFIP regulations. 
6. The NSP distributes external and in-house file copies of the letter and FIRM in 
accordance with the requirements detailed in Subsection 4.9 of this Manual. 
7. Within newly identified, noncompliant communities, the following periods commence 
simultaneously on the date the letter and Preliminary copies of the FIRM are issued: 
 A 6-month appeal period, during which scientific or technical data may be submitted 
to refute the determination by FEMA that SFHAs exist in the community; and 
 A 1-year compliance period, during which the community must adopt floodplain 
management ordinances that meet the minimum requirements for participation in the 
Regular Phase of the NFIP detailed in Paragraph 60.3(b) of the NFIP regulations. 


8. If the signed Certified Mail receipt for the conversion letter is not received by the NSP 
within 2 weeks after the date the conversion letter is mailed, the NSP contacts the 
community to verify receipt of the letter. 



9. If a compliant community did not receive the conversion letter, the NSP notifies the 
FEMA Project Engineer and forwards a duplicate copy of the conversion letter to the 
community CEO and floodplain administrator. 
10. If a noncompliant community did not receive the conversion letter, the NSP coordinates 
with the FEMA Project Engineer to determine whether to change the conversion effective 
date or extend the compliance period to allow the community a full 6-month period to 
adopt a compliant floodplain management ordinance. 
11. The NSP updates the MIP and FEMA CIS database records for the community and 
archives the community file, maps, and all backup information. 


4.6.3.3 Communities Included in Countywide Map Update 


The processing of special conversions for communities included in a countywide map update is 
different because of the length of time it takes for the countywide map update to become 
effective. Unlike other conversions with a map, the conversion/effective date is not established at 
the time that the Preliminary copies of the DFIRM are issued; rather, the conversion/effective 
date is established when statutory and regulatory requirements (i.e., appeal periods, compliance 
periods) for all of the affected communities in the county are met. The FEMA and NSP staff 
shall follow the procedures below for these types of special conversions. 

1. If the community is participating in the Emergency Phase of the NFIP, but no SFHAs 
have been identified within the community, the NSP prepares a 204-CW letter (Appendix 
D, page D-43). This letter informs the community that the community has been included 
on a countywide DFIRM, but no SFHAs exist in the community. If the community is 
located on one or more printed DFIRM panels, the NSP sends the Preliminary copies of 
these panels to the community for review. 
2. If SFHAs in the community are identified on the countywide FIRM, the NSP prepares a 
letter to inform the community CEO and floodplain administrator of the conversion and 
transmit Preliminary copies of the affected DFIRM panels for review. If required, the 
letter may include a paragraph inviting the community to attend a community 
coordination meeting. If the FEMA RO and community officials agree not to hold a 
community coordination meeting, the letter notifies the community officials that they 
have 30 days to review and comment on the Preliminary copies of the DFIRM. The 
conversion letters that the NSP may prepare are as follows: 
 195-CW letter (Appendix D, page D-7)Community participating in Emergency 
Phase of NFIP; FHBM published; 
 195-CW-I letter (Appendix D, page D-9)Community participating in Emergency 
Phase of NFIP; FHBM not published; 
 195-CW-I-NP letter (Appendix D, page D-11)Community not participating in 
Emergency Phase of NFIP; FHBM not published; and 
 195-CW-NP letter (Appendix D, page D-15)Community not participating in the 
NFIP; FHBM published. 





3. If there are no special circumstances in the letter requiring FEMA review and signature, 
the NSP includes the conversion letter in a list with other conversion letters and submits 
the list to the FEMA Project Engineer via docket. If special circumstances do exist, the 
NSP submits a hard (paper) copy of the conversion letter to the FEMA Project Engineer 
for review and signature. 
4. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 
5. The NSP mails the letter to the community CEO and floodplain administrator along with 
two Preliminary copies of the FIRM and a copy of the NFIP regulations. 
6. The NSP distributes external and in-house file copies of the letter and FIRM in 
accordance with the requirements detailed in Subsection 4.9 of this Manual. 
7. Within newly identified, non-participating communities, the following two periods 
commence simultaneously on the date the NSP mails the letter and Preliminary copies of 
the FIRM: 
 A 6-month appeal period, during which scientific or technical data may be submitted 
to refute the FEMA determination that SFHAs exist in the community; and 
 A 1-year compliance period, during which the community must adopt floodplain 
management ordinances that meet the minimum requirements for participation in the 
NFIP detailed in Paragraph 60.3(b) of the NFIP regulations. 


8. Once all statutory and regulatory requirements are met for the other communities 
included in the countywide study and an effective date for the countywide study is 
established, the NSP prepares one of the following letters to notify the community of the 
effective date and the deadline for submission of compliant floodplain management 
ordinances: 
 205-CW letter (Appendix D, page D-49)Non-floodprone community; 
 196-CW letter (Appendix D, page D-23)Community participating in Emergency 
Phase of NFIP; FHBM published; 
 196-CW-I letter (Appendix D, page D-25)Community participating in Emergency 
Phase of NFIP; FHBM not published; or 
 196-CW-NP letter (Appendix D, page D-27)--Community not participating in 
Emergency Phase of NFIP. 


9. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits a hard (paper) copy of the conversion letter to the FEMA 
Project Engineer for review and signature. 
10. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 



11. The NSP mails the letter to the community CEO and floodplain administrator at least 6 
months before the conversion effective date. 
12. The NSP distributes external and in-house file copies of the letter and FIRM in 
accordance with the requirements detailed in Subsection 4.9 of this Manual. 
13. If the signed Certified Mail receipt for the conversion letter is not received by the NSP 
within 2 weeks after the date the conversion letter is mailed, the NSP contacts the 
community to verify receipt of the letter. 
14. If a compliant community did not receive the conversion letter, the NSP notifies the 
FEMA Project Engineer and forwards a duplicate copy of the conversion letter to the 
community CEO and floodplain administrator. 
15. If a noncompliant community did not receive the conversion letter, the NSP coordinates 
with the FEMA Project Engineer to determine whether to change the conversion effective 
date or extend the compliance period to allow the community a full 6-month period to 
adopt compliant floodplain management ordinances. 
16. The NSP updates the MIP and FEMA CIS database records for the community and 
archives the community file, FIRM, and all backup information. 


4.6.3.4 Remote and Uninhabited Communities 


When the FEMA RO requests that only a FIRM Index showing the community as all Zone D be 
prepared, FEMA and NSP staff shall follow the procedures below. 

1. If the FEMA RO indicates that the communitys floodplain management ordinances are 
compliant with NFIP regulations, the NSP prepares a 196-C-D letter (Appendix D, page 
D-17). This letter notifies the community of the special conversion and provides the 
conversion effective date. The NSP mails letter to the community CEO and floodplain 
administrator at least 6 months before the conversion effective date cited in the letter. 
2. If the FEMA RO indicates that the communitys floodplain management ordinances are 
not compliant with the NFIP regulations, the NSP prepares a 196-NC-D letter 
(Appendix D, page D-29). This letter notifies the community of the special conversion 
and provides the conversion effective date. The NSP mails this letter to the community 
CEO and floodplain administrator at least 6 months before the conversion effective date. 
3. If no special circumstances are included in the letter, requiring FEMA review and 
signature, the NSP includes the conversion letter in a list with other conversion letters 
and submits the list to the FEMA Project Engineer via docket. If special circumstances 
do exist, the NSP submits a hard (paper) copy of the conversion letter to the FEMA 
Project Engineer for review and signature. 
4. The FEMA Project Engineer returns concurrence on the docket or the signed letter to the 
NSP. 



5. The NSP verifies that the dating requirements in Item Nos. 1 and 2 are met and mails the 
signed letter to the community CEO and floodplain administrator along with two 
Preliminary copies of the FIRM Index and a copy of the NFIP regulations. 
6. The NSP distributes external and in-house file copies in accordance with the 
requirements detailed in Subsection 4.9 of this Manual. 
7. If the signed Certified Mail receipt for the conversion letter is not received by the NSP 
within 2 weeks after the date the conversion letter is mailed, the NSP contacts the 
community to verify receipt of the letter. 
8. If a compliant community has not received the conversion letter, the NSP notifies the 
FEMA Project Engineer and forwards a duplicate copy of the conversion letter to the 
community CEO and floodplain administrator. 
9. If a noncompliant community did not receive the conversion letter, the NSP coordinates 
with the FEMA Project Engineer to determine whether to change the conversion effective 
date or extend the compliance period to allow the community a full 6-month period to 
adopt compliant floodplain management ordinances. 
10. The NSP updates the MIP and FEMA CIS database records for the community and 
archives the community file, FIRM Index, and all backup information. 


4.6.4 Processing of Revised Preliminary Maps and Final 
Reproduction Materials 


FEMA and NSP staff shall follow the procedures below in processing Revised Preliminary 
copies of FIRMs/DFIRMs and final (camera-ready) reproduction materials. 

1. If community comments on the Preliminary copies of the FIRM/DFIRM are received, the 
NSP evaluates whether Revised Preliminary copies of the FIRM/DFIRM are required and 
obtains approval from the FEMA Project Engineer before preparing the Revised 
Preliminary copies. 
2. If the FEMA Project Engineer directs the NSP to prepare Revised Preliminary copies, the 
NSP revises the FIRM/DFIRM as appropriate and prepares a 197-RP letter (Appendix D, 
page D-39). 
3. The NSP submits a hard (paper) copy of the 197-RP letter to the FEMA Project Engineer 
for review and signature. 
4. The FEMA Project Engineer returns the signed letter to the NSP. 
5. The NSP mails the 197-RP letter and two Revised Preliminary copies of the 
FIRM/DFIRM to the community CEO and floodplain administrator. 
6. The NSP distributes external and in-house file copies in accordance with the distribution 
requirements detailed in Subsection 4.9 of this Manual. 



7. If the community does not have compliant ordinances and fails to submit compliant 
ordinances to the FEMA RO within the first 90 days after the date that the letter is 
mailed, the FMS staff may request that the NSP prepare a suspension letter. If required, 
the NSP prepares the suspension letter in accordance with the procedures detailed in 
Subsection 4.7 of this Manual. 
8. The NSP prepares the final reproduction materials and paperwork for delivery to the 
MSC contractor at least 4 months before the conversion effective date. The map and 
report materials and U.S. Government Printing Office printing paperwork that the NSP 
produces are detailed in Volume 1 of Guidelines and Specifications for Flood Hazard 
Mapping Partners (FEMA, 2003). These Guidelines may be viewed or downloaded on 
the FEMA website at http://www.fema.gov/plan/prevent/fhm/dl_cgs.shtm . 
9. The NSP prepares and submits a presigned transmittal letter (179-M, page D-5) to the 
MSC contractor with the final reproduction materials. 
10. The NSP updates the MIP and FEMA CIS database records for the community and 
archives the community file, FIRM, and all backup information. 


4.7 Suspension Letter Processing 


For communities that did not have compliant ordinances when the conversion letter was issued 
and that have failed to submit compliant ordinances to the FEMA RO within the first 90 days 
after the date that the conversion letter is mailed, FEMA and NSP staff shall follow the 
procedures below. 

1. The NSP prepares one of the following 90-day suspension letters and submits it to the 
appropriate FMS program specialist for review and signature: 
 S-90.FHBM letter (Appendix D, page D-59)For community converted using 
existing FHBM; or 
 S-90.FIRM letter (Appendix D, page D-61)For community converted using new 
FIRM. 


2. If the FEMA RO staff has not updated the FEMA CIS database or otherwise notified the 
FMS staff that the communitys floodplain management ordinances are compliant with 
the NFIP regulations, FMS returns the signed letter to the NSP. If the FEMA RO has 
updated the FEMA CIS database or otherwise notified the NSP or FMS staff that the 
communitys floodplain management ordinances are compliant, FMS returns the letter 
unsigned and the NSP does not send the letter. 
3. The NSP mails the signed letter, if required, to the community CEO and floodplain 
administrator and distributes the external and in-house file copies in accordance with the 
distribution requirements detailed in Subsection 4.9 of this Manual. 



4. If the community submits compliant ordinances to the FEMA RO at least 30 days before 
the effective date, the FEMA RO updates the FEMA CIS database or otherwise notifies 
FMS and NSP staff. If the FEMA RO does not update the FEMA CIS database and the 
FEMA RO does not notify the NSP or FMS staff that the communitys floodplain 
management ordinances are compliant with NFIP regulations, the procedures below are 
followed. 
5. The NSP prepares a 30-day suspension letter (S-30.SPECL, Appendix D, page D-57) and 
submits the letter to the appropriate FMS program specialist for review and signature. 
6. If the FEMA RO has not updated the FEMA CIS database or otherwise notified the FMS 
staff that the communitys floodplain management ordinances are compliant, FMS 
returns the signed letter to the NSP. If the FEMA RO has updated the FEMA CIS 
database or otherwise notified the NSP or FMS staff that the communitys floodplain 
management ordinances are compliant, the FMS returns the letter unsigned and notifies 
the NSP that the letter is not to be sent. 
7. The NSP mails the signed letter and enclosures (copies of Sections 59.24 and 60.3 of the 
NFIP regulations), if required, to the community CEO and floodplain administrator. 
8. The NSP distributes the external and in-house file copies in accordance with the 
distribution requirements detailed in Subsection 4.9 of this Manual. 


4.8 Reinstatement Letter Processing 


If the community is suspended and is reinstated because it enacted compliant ordinances after the 
effective date and the FEMA RO updates the FEMA CIS database records or otherwise notifies 
the NSP or FMS staff, NSP and FMS staff shall follow the procedures below. 

1. The NSP prepares a reinstatement letter (RINSTATE, Appendix D, page D-55). 
2. The NSP submits the reinstatement letter to the appropriate FMS program specialist for 
review and signature. 
3. The FMS program specialist returns the signed letter to the NSP. 
4. The NSP mails the signed letter to the community CEO and floodplain administrator. 
5. The NSP distributes the external and in-house file copies in accordance with the 
distribution requirements detailed in Subsection 4.9 of this Manual. 
6. The NSP archives the reinstatement letter and related information. 



4.9 Distribution Requirements 


In addition to the community CEOs and floodplain administrators for the affected communities, 
many other individuals and agencies received copies of the standard documents used in 
processing special conversions. The distribution requirements for these documents are provided 
in Table 4-1. FEMA staff shall establish distribution requirements for non-standard documents 
when appropriate. 

 

 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Document 
Number 

 

 

State NFIP 
Coordinator 

Regional Flood 
Insurance and 
Mitigation Division 
Director 

 

 

NSP Case 
File 

 

Map 
Service 
Center 

 

 

 

FMS 

 

State 
Insurance 
Commissioner 

 

 

 

CSC 

4.9.1 


Table 4-1 179-M 

 

X 

 

X 

 

X 

 

X 

 

 

 

 

 

 

 

195-CW 

 

X 

 

X 

 

X 

 

 

 

X 

 

 

 

 

 

195-CW-I 

 

X 

 

X 

 

X 

 

 

 

X 

 

 

 

 

 

195-CW-I-NP 

 

X 

 

X 

 

X 

 

 

 

X 

 

 

 

 

 

195-CW-NP 

 

X 

 

X 

 

X 

 

 

 

X 

 

 

 

 

 

196-C-D 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-C-FHBM 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-C-O 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-CW 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-CW-I 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-CW-NP 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-NC-D 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-NC-FHBM 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-NC-I 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

196-NC-O 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 




 

196-NP-I 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

197-RP 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

198 

 

X 

 

X 

 

X 

 

X 

 

 

 

 

 

X 

 

205 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

205-NP 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

206 

 

X 

 

X 

 

X 

 

X 

 

X 

 

 

 

X 

 

RINSTATE 

 

X 

 

X 

 

X 

 

 

 

X 

 

X 

 

 

 

S-30.SPECL 

 

X 

 

X 

 

X 

 

 

 

X 

 

X 

 

 

 

S-90.FHBM 

 

X 

 

X 

 

X 

 

 

 

X 

 

X 

 

 

 

S-90.FIRM 

 

X 

 

X 

 

X 

 

 

 

X 

 

X 

 

 

 

SCRR 

 

 

 

X 

 

X