July 16, 2004 

 

MEMORANDUM FOR: Bill Blanton, CFM, Project Officer 

 Central Studies Team 

 

 Max Yuan, Project Officer 

 Western Studies Team 

 

 [Original signed] 

FROM: Doug Bellomo, P.E., CFM, Acting Chief 

 Hazard Identification Section 

 

SUBJECT: Procedure Memorandum No. 33  Processing of Letters of Map 
Change Involving Below-Grade Crawlspaces Constructed Within 
Identified Special Flood Hazard Areas 

Background: The general review criteria for Letters of Map Change (LOMC) are outlined in Parts 
65 and 70 of the National Flood Insurance Program (NFIP) regulations. Additional guidance for 
processing Letters of Map Revision and Letters of Map Revision Based on Fill was provided in 
Procedure Memorandum No. 22, Revised Processing Procedures for Letters of Map Revision 
(LOMRs) and Letters of Map Revision Based on Fill (LOMR-Fs). 

Issue: Subparagraph 60.3(c)(2) of the NFIP regulations requires that all new construction and 
substantial improvements of residential structures within Zones A1-A30, AE, and AH on a Flood 
Insurance Rate Map (FIRM) have the lowest floor (including basement) elevated to or above the 
base flood level. Further, Section 59.1 of the NFIP regulations defines a basement to be any area of 
a building having its lowest floor subgrade (below grade level) on all sides. By this definition, a 
crawlspace built below grade on all sides has been considered a basement and is subject to the 
requirements of Subparagraph 60.3(c)(2). 

The recent publication of Technical Bulletin 11-01, Crawlspace Construction for Buildings Located 
in Special Flood Hazard Areas, provides communities with guidance for the construction of 
below-grade crawlspaces within the Special Flood Hazard Area (SFHA) that would meet the 
minimum requirements of the NFIP regulations. 

Final Procedure: Effective immediately, we will review LOMC requests involving below-grade 
crawlspaces constructed within the SFHA following the general review criteria of Parts 65 and 70 of 
the NFIP regulations, the guidance provided in Procedure Memorandum No. 22, and the guidance 
provided in Technical Bulletin 11-01. Our determination (outcome) on LOMC requests involving 
below-grade crawlspaces will therefore depend on the review criteria outlined below. 

 




LOMRs and LOMR-Fs 

1. For LOMR or LOMR-F requests that meet the guidance and data requirements outlined in 
Procedure Memorandum No. 22, we will issue our determination based on the guidance 
established in that memorandum. 
2. For all LOMR or LOMR-F requests involving an existing structure with a crawlspace, whose 
Lowest Adjacent (exterior) Grade (LAG) is at or above the Base Flood Elevation (BFE), and that 
meet the data requirements of Subparagraphs 65.5(a)(4) or 65.6(a)(14) of the NFIP regulations, 
with the exception of item i (existing residential structures built in the SFHA have their lowest 
floor elevated to or above the base flood), the community may provide written assurance that the 
structure conforms to the technical standards for construction in or around SFHAs as provided in 
Technical Bulletin 11-01. These standards include: 
a. The interior grade of the crawlspace is not greater than 2 feet below the lowest exterior 
grade; 
b. The total difference between the interior crawlspace grade and the top of the crawlspace 
foundation (i.e., height) is not greater than 4 feet at any point; 
c. The crawlspace has an adequate drainage system capable of draining the crawlspace area 
within a reasonable timeframe after a flood event; and 
d. The velocity of floodwaters at the site will not exceed 5 feet per second. 


 

 

 

If the community provides these assurances, we will remove the structure from the SFHA. Upon 
the issuance of the LOMR or LOMR-F determination, we will notify the Community Assistance 
Branch of the LOMC request and provide them with pertinent information about the case 
(i.e., community name, affected NFIP map panel, LOMC type, outcome). 

 

3. For all LOMR or LOMR-F requests involving an existing structure with a crawlspace whose 
exterior LAG is not at or above the BFE, but still meets the other requirements of either of the 
above two criteria, we will issue a non-removal determination. Upon the issuance of the LOMR 
or LOMR-F determination, we will notify the Community Assistance Branch of the LOMC 
request and provide them with pertinent information about the case (i.e., community name, 
affected NFIP map panel, LOMC type, outcome). 
4. For all LOMR or LOMR-F requests that do not fall under the above three criteria, we will 
suspend processing of the request and follow the potential violation procedures outlined in 
Procedure Memorandum No. 22. 
5. If the community is unwilling or unable to provide any written assurances, we will suspend 
processing of the request in accordance with NFIP regulations. 


 

 

 

Letters of Map Amendment (LOMAs) 

As written assurance from communities is not required for the processing of LOMA requests, we 
will only abide by the criteria outlined below if information has been submitted for a request 
involving a Post-FIRM constructed building (structure) having a LAG below the BFE and a below-


grade crawlspace. In such a situation, we will request a community's written assurance that the 

 

structure conforms to the technical standards of Technical Bulletin 11-01. Depending on what is 
received from the community in response to this request, we will do one of the following: 

 

 If the submitted assurance states that the subject of the request conforms to the technical 
standards of Technical Bulletin 11-01, we will issue a non-removal determination based on 
the general review criteria of the NFIP. In addition, we will notify the Community 
Assistance Branch of the request and provide them with pertinent information about the case 
(i.e., community name, affected NFIP map panel, LOMC type, outcome). 
 If, however, this assurance states that the subject of the request does not conform to the 
technical standards of Technical Bulletin 11-01, we will suspend processing of the request 
and follow the potential violation procedures outlined in Procedure Memorandum No. 22. 
 If the community is unwilling or unable to provide the written assurances, we will suspend 
the processing of the LOMA request in accordance with NFIP regulations. 


Conditional LOMRs, LOMR-Fs, and LOMAs 

We will review requests for Conditional LOMRs, LOMR-Fs, and LOMAs in accordance with the 
guidance provided in Procedure Memorandum No. 22 and as outlined above. Our review and 
Comment Document will be based on proposed conditions. In instances where the proposed 
conditions would result in a potential violation, we will issue a conditional non-removal 
determination. 

 

cc: See Distribution List 


Distribution List (electronic distribution only) 

 

Office of the Mitigation Director 

 

 David Maurstad 
 Priscilla Scruggs 


 

Risk Assessment Branch 

 

 Cliff Oliver 
 Mike Grimm 
 Lois Forster 
 Errol Garren 
 Bret Gates 
 Bill Lesser 


 

Risk Identification Branch 

 

 Mike Howard 
 Fred Sharrocks 
 Mary Jean Pajak 
 Doug Bellomo 
 Bill Blanton 
 Max Yuan 
 Kelly Bronowitz 
 Mike Godesky 
 Emily Hirsch 
 Allyson Lichtenfels 
 Kevin Long 
 John Magnotti 
 Kathy Miller 


 

FEMA Regional Offices 

 

Region I 

 

 Kevin Merli 
 Bob Archila 
 Mike Goetz 


 

Region II 

 

 Mike Dabney 
 Bruce Swiren 


 

 

 

 

 

 

 Virginia Desautels 
 LaBrina Jones 
 Cynthia Pollnow 
 Mike Robinson 
 David Stearrett 
 Juanita Thompson 
 Helen Cohn 
 Cynthia Croxdale 
 Anne Flowers 
 Cecelia Lynch 
 Agnes Ross 
 Jay Scruggs 
 Daphne Thornton 
 Dee Woodard 
 Eric Berman 
 Claire Drury 
 John Gambel 
 Paul Rooney 
 Scott McAfee 
 David Knowles 
 Dean Savramis
 Paul Weberg


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 






 

Region III 

 

 Gene Gruber 
 Michael Craghan 
 Marty Frengs 


 

Region IV 

 

 Todd Davison 
 Laura Algeo 
 Bruce Buckerfield 
 John Plisich 


 

Region V 

 

 Norb Schwartz 
 Terry Fell 
 Ken Hinterlong 


 

Region VI 

 

 Frank Pagano 
 Dennis Lee 
 Jim Orwat 


 

Region VII 

 

 Bob Bissell 
 Kathleen Strange 
 Bob Franke 


 

Region VIII 

 

 Steve Olsen 
 Robert Ives 


 

Region IX 

 

 Sally Ziolkowski 
 Mike Shore 


 

Region X 

 

 Carl Cook 
 Mark Carey 


 Jon Janowicz 
 Nikki Roberts 
 Ken Wallace
 Clayton Saucier 
 Mark Vieira 
 Mohammad Waliullah 
 Mary Jo Mullen 
 Lee Traeger 
 Jack Quarles 
 Gary Zimmerer 
 Phil Kirk 
 Rick Nusz 
 Marijo Camrud 
 John Liou 
 Ray Lenaburg 
 Les Sakumoto
 Dave Carlton 
 Joe Weber 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 






 

 

 

Office of Legislative Affairs 

 

 Vince Fabrizio 


 

Office of General Counsel 

 

Rick Neal 

 

FEMA Contractors 

 

 Zekrollah Momeni (Dewberry) 
 Fernando Pasquel (Baker) 


 

 

 Loretta Schaffer 
 Don McEvoy (PBS&J)