Comparison
CLOMA vs LOMA
Understand when a Conditional Letter of Map Amendment applies versus a final LOMA determination.
A CLOMA is a conditional determination issued before construction or development is complete. A LOMA is the final determination based on as-built conditions. If a project is not yet finished, CLOMA is often the appropriate first step.
Key takeaways
Comparison
CLOMA versus LOMA
The difference is timing relative to construction, not the underlying property question.
| Topic | CLOMA | LOMA |
|---|---|---|
| When it applies | Before construction or grading is complete | After as-built conditions are verified |
| Evidence basis | Proposed elevation plans and engineering drawings | Actual surveyed elevations (Elevation Certificate) |
| Effect on flood zone | Conditional — does not formally change the designation | Final — formally amends the map for that property |
| Lender acceptance | Some lenders accept; others require final LOMA | Universally accepted as the official determination |
Frequently asked questions
What is a CLOMA?
A Conditional Letter of Map Amendment is FEMA's preliminary indication that a proposed project, once built as designed, would qualify for a LOMA. It is based on engineering plans and proposed elevations rather than as-built survey data.
Does a CLOMA remove the property from the flood zone?
No. A CLOMA is a conditional statement, not a final determination. The property remains in the mapped flood zone until a final LOMA is issued after construction is complete and as-built elevations are verified.
When should I pursue a CLOMA instead of waiting for a LOMA?
A CLOMA is useful during active construction or development when a lender, buyer, or insurer needs some form of FEMA indication before the project is finished. It can help with financing and insurance decisions during the construction period.
How do I convert a CLOMA into a final LOMA?
After construction is complete, submit a final LOMA request with as-built elevation data, typically a new Elevation Certificate showing the completed structure. FEMA reviews the final conditions and, if they match the CLOMA proposal, issues the LOMA.
Does a CLOMA cost the same as a LOMA?
FEMA does not charge fees for either, but the professional preparation costs are similar. The total cost is often higher because two submissions are required — one for the CLOMA and one for the final LOMA.
Can a CLOMA be denied even if the plans look correct?
Yes. If the proposed plans do not clearly show that the finished project would meet LOMA criteria, FEMA can deny the CLOMA. Common issues include insufficient elevation detail, unclear grading plans, or ambiguity about whether fill will be used.