Scenario

LOMA for new construction

Understand when new construction in a flood zone may qualify for a LOMA, CLOMA, or LOMR-F and how to plan the submission.

New construction in a mapped flood zone often involves elevation requirements, and the finished structure may sit above the Base Flood Elevation. Whether the correct path is a LOMA, CLOMA, or LOMR-F depends on whether the elevation comes from natural ground or placed fill.

Key takeaways

The natural-grade versus fill distinction applies to new construction just as it does to existing homes.
A CLOMA during construction can help with financing, followed by a final LOMA after completion.
Builders and developers should plan the LOMA or LOMR-F timeline into the construction schedule.

When this page applies

A home is being built on a lot mapped in a flood zone.
The builder is elevating the pad and wants to know whether a map change is possible.
A buyer is purchasing a to-be-built home and the lender has flagged the flood zone.

When a different path is more likely

The structure will remain below the BFE after construction.
The project involves a levee or channel change affecting a broader area.
The fill was placed before the current FIRM and the case may qualify as natural ground.

Planning a LOMA for new construction

Determine natural grade versus fill early

Review the grading plan and site conditions before construction begins to know whether the path is LOMA or LOMR-F.

Consider a CLOMA during construction

If financing or insurance needs arise before the structure is complete, a CLOMA provides a conditional indication from FEMA.

Obtain as-built Elevation Certificate

After construction, have a licensed surveyor prepare an EC showing the finished elevations relative to the BFE.

Submit the final LOMA or LOMR-F

Use the as-built evidence to submit the final request through Online LOMC for a permanent determination.

Frequently asked questions

Can new construction qualify for a LOMA?

Yes, if the finished structure sits above the Base Flood Elevation on natural high ground. The key is whether the elevation is natural or was created by fill. Natural ground qualifies for LOMA; fill requires the LOMR-F path.

Should I get a CLOMA or wait for a LOMA?

If you need a FEMA indication before construction is finished — for example, to satisfy a lender during the build — a CLOMA can help. If the structure is already complete, go straight to the final LOMA.

Does the builder usually handle the LOMA?

Practice varies. Some builders include LOMA or LOMR-F preparation as part of the construction package, while others leave it to the buyer. Clarifying responsibility early avoids surprises after closing.

What if the lot is in a flood zone but the house will be elevated?

Elevated construction on natural ground may qualify for a LOMA after the as-built survey confirms the lowest adjacent grade or lowest floor is above the BFE. If fill is used to achieve that elevation, the path is LOMR-F instead.

How does new construction LOMR-F differ from standard LOMR-F?

The evidence requirements are similar, but new construction files often have cleaner documentation because grading plans, fill compaction records, and as-built surveys are created during the build process. Community Acknowledgment is still required.

When should the LOMA process start relative to construction?

Ideally, routing should happen during the design phase so the builder knows whether to plan for LOMA or LOMR-F. The formal submission happens after the Elevation Certificate is prepared on the completed structure.

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