While many community officials and floodplain managers are called upon to review a Summary of Map Actions (SOMA) report, its contents and the process of developing it may seem complex. Here’s a look at deciphering the SOMA.
LOMCs and the SOMA
LOMCs comprise a few different types of Determination Documents, which include: a Letter of Map Amendment (LOMA), a Letter of Map Revision-Based on Fill (LOMR-F), and a Letter of Map Revision (LOMR). LOMAs and LOMR-Fs use individual legal property descriptions to identify the properties/structures in question, whereas LOMRs revise the physical FIS Report or FIRM panel itself. Since the SOMA records the status of each LOMC in a community, it specifies whether a current LOMC has been incorporated as part of a restudy, superseded by new data and information used to prepare a restudy, or revalidated.
There are four possible categorizations for LOMCs on the SOMA:
LOMCs Not Incorporated
LOMCs To Be Redetermined
Each LOMC included in Category 2 (LOMCs Not Incorporated) of the SOMA is listed on a Revalidation Letter. When the Revalidation Letter accompanies the original LOMC determination letter, a lender can see that the original change – Removal from the High Hazard Zone (A, AE, AH, AO, VE) to the Less Hazardous Zone (X) is still valid, and the structure/property is still eligible for a Preferred Risk Policy.
The SOMA is distributed twice during a Flood Insurance Study. The first distribution is the Preliminary SOMA; this is published along with the other Preliminary Map Products that may include the Preliminary FIRM panels, Preliminary FIS Report, and Preliminary FIRM Database. The second distribution is the Final SOMA; this is published along with the study’s Letter of Final Determination (LFD) following the Appeals and Comment Period.
Why Communities Should Review their SOMA
When a community receives their preliminary map products, they should review the SOMA report just as closely as they review the updated FIRM panels, FIS report, and FIRM Database. First, the SOMA provides an early indication of the impact of new study results on a community’s homeowners. Second, if LOMC determinations are missing from the SOMA, or the outcome does not appear correct, FEMA may review comments provided by communities, and make the necessary updates before the document becomes final at the Letter of Final Determination (LFD) stage. Third, addressing issues/concerns prior to finalization minimizes the amount of distress homeowners feel when they are subject to mandatory flood insurance requirements when the updated FIRM panels are issued as effective.
SOMA Contents, Explained
A comprehensive list of LOMCs is used to determine which LOMCs are included on the SOMA report; however, not all LOMCs in a community are shown on the community’s SOMA report. Knowing what is excluded from the report is half the battle of deciphering the SOMA. The other half is understanding each of the four SOMA categories and knowing what happens to the LOMCs in each SOMA category after the new FIRMs go effective.
Why Some LOMCs are excluded from the SOMA
First, only one Revalidation Letter is valid per community at a time. LOMCs that were issued prior to the community’s current effective Revalidation Letter (that are not included on the current Revalidation Letter) are excluded from consideration on the SOMA. Additionally, if a study is updating only a select number of FIRM panels within a community (i.e., a Physical Map Revision, or “PMR”), only the LOMCs affecting panels being updated by that study will be included on the SOMA report. This group of currently valid LOMCs will be referred to as the LOMCs In Question (described below). Furthermore, some LOMCs are issued as Conditional, meaning they were based on proposed elevations. Conditional LOMCs are not legally binding amendments to the FIRMs, so they are not included as valid LOMCs for consideration on the SOMA. Finally, LOMCs with Non-Removal/Denial, or Other Response/No-Change outcomes are also excluded from the SOMA report, because they do not alter the FIRMs.
Category 1: LOMCs Incorporated
Category 1 includes larger LOMCs In Question, such as LOMRs which physically revised a portion of the FIRM and/or FIS report. The LOMCs listed in this category are those that still provide the best-available data for the area. This best-available data has been incorporated into the updated FIRM panels and FIS report. The LOMR itself will no longer be valid once the new study is effective, because all the revisions the LOMR previously established are now a part of the updated study. LOMA and LOMR-F removal determinations are rarely included in Category 1, because without the property surrounding them, the subjects of the determinations are too small and sporadic to influence a reshaping of the Special Flood Hazard Area (SFHA).
Category 2: LOMCs Not Incorporated
Category 2 typically includes the bulk of the LOMCs In Question on the SOMA report. These are the LOMA and LOMR-F determinations that originally removed the structures or properties from the SFHA, or that declared the structures or properties as already Outside the SFHA As Shown on the current FIRM panel (“OAS determination”), which are still valid as removals or OAS outcomes even after the study has been updated. These LOMCs In Question, while their outcomes are still valid, are still too small to be incorporated into the updated mapping. Therefore, these LOMCs In Question are listed as Not Incorporated. However, all LOMCs included in Category 2 of the SOMA are placed on the Revalidation Letter.
The Revalidation Letter becomes effective one day after the new FEMA products (FIRM panels, FIS) become effective. An original LOMC determination references the FIRM panel that was effective at the time the LOMC was issued. When the original LOMC determination is paired with the effective Revalidation Letter, the determination for that LOMC case number is paired with a newly effective FIRM panel. Using both documents together provides the credentials required to verify that the structure or property is still in a less hazardous flood zone (Zone X).
Only one Revalidation Letter is valid per community at a time. A new Revalidation Letter always supersedes the previous Revalidation Letter. All the LOMC determinations included on a Revalidation Letter were issued prior to the updated FIRM panels becoming effective and remain valid on the updated FEMA products being issued.
When a study only updates a select number of FIRM panels within a community, the Revalidation Letter is issued in a secondary format with two tables. The first table lists all the LOMCs that were in Category 2 on the study’s SOMA report for the newly updated panels. The second table will include any LOMCs that were on the previous Revalidation Letter, but were not on an updated FIRM panel in the recent study. In this way, the entire previous Revalidation Letter can be superseded. This secondary format is called a Revalidation 2 Letter.
After the Appeal Period and after comments have been addressed and the FIRMs have been finalized, the Final SOMA is issued to each community with the Letter of Final Determination. This starts the 6-month compliance period leading up to the study’s effective date, and at this point in the study, the Final SOMA is no longer eligible for updates. LOMA and LOMR-F applications that are actively being processed and issued during this phase of a study may still be included on the Revalidation Letter after the Final SOMA is issued; however, most LOMCs will be put on hold for the final 60 days prior to the new effective date. Once the new maps are effective the LOMCs will be processed and issued on the new FIRM panels.
Category 3: LOMCs Superseded
Category 3 includes LOMCs In Question that will no longer be valid once the updated FIRM panels and FIS become effective. The Preliminary SOMA report provides an early indication of the impact of the updated study results on homeowners with LOMCs in Category 3. The table in Category 3 will list one of five possible reasons for each LOMC to be superseded by the new study or updated information, as follows:
Insufficient information available to make a determination
Lowest Adjacent Grade to the structure (LAG) is below the proposed Base Flood Elevation
Lowest Ground/Lot Elevation (LLE) is below the proposed Base Flood Elevation
Revised hydrologic any hydraulic analyses
Revised topographic information
Each LOMC listed in Category 3 has been examined in detail and typically the elevation of the structure (LAG) or of the property (LLE) is now below the revised BFE. These results show Reasons 2 and 3 on the SOMA report. LOMRs which are completely superseded by a new detailed study are listed under Reason 4. LOMA and LOMR-F OAS determinations which did not submit structure or property elevations and are now shown as being mapped inside the SFHA are listed with either Reason 4 or 5, depending on whether a new study was performed or if the current study was remapped on updated topographic data. The remaining reason for a LOMC being superseded is Reason 1 - Insufficient Information. When the Preliminary SOMA is created, all necessary backup data may not have been located from the FEMA library. This results in cases being superseded for Reason 1 on the Preliminary SOMA, though these cases may be subsequently updated before the Final SOMA is issued.
Category 4: LOMCs To Be Redetermined
Category 4 includes LOMCs In Question which can be neither entirely revalidated nor entirely superseded. These LOMCs would originally have had multiple structures or multiple properties identified as the focus of the determination. With the revised BFE, at least one structure or property would still be valid (elevations equal to or above the BFE) and at least one structure or property would no longer be valid (elevations now below the BFE). With this mixture of new resultant zones (at least one structure in Zone X and at least one structure in the SFHA), the case cannot be placed in Category 2 or Category 3. LOMCs listed in Category 4 will need to be re-evaluated by a LOMC Analyst under a new related case number once the updated study is effective. The structures or properties still eligible for removal from the SFHA will be removed under that new case number.
As floodplain mapping techniques advance, and as multiple studies may be simultaneously underway within a single community, multiple SOMA reports and Revalidation Letters may create confusion. Remember these key points:
The SOMA reports will only include the currently valid LOMCs In Question for the panels that are being updated for a specific FIRM revision
There is only one Revalidation Letter effective at any given time per community
FEMA and its mapping partners are available to answer your questions.
Additional InformationIn 2012, FEMA issued a Fact Sheet entitled Understanding FEMA’s Summary of Map Actions and Revalidation Letter. It answers the top ten questions regarding SOMAs and Revalidation Letters and is available here.