Comparison
LOMA vs LOMR-F
Use the natural-grade versus fill distinction to route a flood map change request correctly before submitting anything.
The fastest way to avoid the wrong workflow is to answer one question early: is the property on natural high ground, or was it raised by fill? Natural grade points toward LOMA. Fill points toward LOMR-F.
Key takeaways
Comparison
Core comparison
The practical difference changes the evidence, routing, and likely timeline of the case.
| Topic | LOMA | LOMR-F |
|---|---|---|
| Ground condition | Naturally high ground above the mapped level | Raised by earthen fill |
| Common evidence | Elevation Certificate or survey tied to BFE | Elevation support plus fill and development context |
| Main intake question | Was the parcel already high without fill? | How was the site elevated and what documents support it? |
Use this page when
What to capture in the intake
Who this page is for
Frequently asked questions
How do I tell whether a property needs a LOMA or a LOMR-F?
Answer one question first: was the elevation created by natural ground or by imported earthen fill? Natural high ground points to LOMA. Fill points to LOMR-F. Everything else follows from that distinction.
Can the same property switch between LOMA and LOMR-F?
Files sometimes start as a LOMA and get redirected to LOMR-F after fill is confirmed, or the opposite. This is exactly why routing up front prevents wasted survey and submission costs.
Is one path faster than the other?
LOMA is usually faster because LOMR-F requires a Community Acknowledgment Form from the local floodplain administrator and more technical fill evidence. A clean LOMA can process in weeks; a LOMR-F often takes 60 to 90 days or more.
Which path is more expensive?
LOMR-F is typically more expensive because fill compaction evidence, grading documentation, and engineering review add cost. A LOMA supported by an existing Elevation Certificate is usually the cheapest path.
Does FEMA charge a fee for either request?
No. FEMA does not charge property owners a fee to submit a LOMA or LOMR-F. Costs come from surveyors, engineers, and document preparation.
If my home sits on a pad raised by fill, am I stuck with LOMR-F?
If fill is the reason the pad sits above the Base Flood Elevation, yes — LOMR-F is the correct path. Running the file as a LOMA usually ends in denial.
Can a single file cover multiple structures on one parcel?
Yes. A single LOMA or LOMR-F can cover multiple structures if the evidence is consistent. The scope section controls what is actually granted.
What happens if fill was placed before the current FIRM?
Fill placed before the effective FIRM date may be treated as natural ground for LOMA purposes in some cases. This is a nuanced call and usually requires surveyor or engineer judgment.