Higher Regulatory Zone?
Scott Fraser
Might it be somewhere in CFR 44 as well?
Also, in this instance, a lateral addition was constructed to a preFIRM residence (share common supporting wall). The preFIRM portion is in an AE-8 zone, while the addition is entirely within an AE-7. It was my conclusion that by default, the addition must comply with the AE-8 requirements.
Despite the addition being entirely within an AE-7 zone, it's an extension of the original building's footprint, therefore becomes part of the original structure, and therefore must comply with the requirements applicable to the zone in which original structure rests.
Your thoughts?
Scott
Scott Fraser
FEMA Coordinator/Floodplain Administrator
305-809-3810 o.
305-923-4964 c.
sfr...@keywestcity.com
Mike Gambino
That is because I do not believe it is specifically written anywhere. You could establish a policy, and it would be well-founded, and FEMA would back you up on it. You could also espouse the benefits of the safety margin and lower flood insurance to offset the cost.
I just added it to my floodplain code, so I know where it is written, not trying to be a wise guy.
I totally agree with you on the second situation as well, if it is an addition it has to match the existing structure, regardless if zones have changed through the years.
M. Gambino, CFM
Floodplain Administrator
City of Miami Gardens
Public Works Dept.
1050 NW 163 Drive
Miami Gardens, Fl. 33169
Tel. 305.622.8039
Email: mgam...@miamigardens-fl.gov
Skarvelis, Frank N
From: NFIP Flood Insurance Manual, Revised October 2011; “General Rules” Section; Part 10, “Special Rating Situations”; Item D, “Buildings In More Than 1 Flood Zone/BFE”; Page GR 14:
“Buildings, not the land, located in more than 1 flood zone/BFE must be rated using the more hazardous zone/BFE.”
Frank N. Skarvelis, CFM
Brevard County Floodplain Administrator
Legislative Director - Florida Floodplain Managers Association
From: fl_flo...@googlegroups.com [mailto:fl_flo...@googlegroups.com] On Behalf Of Scott Fraser
Sent: Thursday, November 03, 2011 10:00 AM
To: Florida Floodplain Managers Association-List serve
Subject: Higher Regulatory Zone?
I've got an attorney questioning where it's written that when a flood line touches a structure the higher regulatory zone applies, and I can't seem to put my finger on that FEMA guideline.
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Rebecca C. Quinn
While it isn’t explicit in the federal regulations, but it doesn’t have to be explicit. If it is partly in a higher zone (or affected by higher BFE) then the building simply would not comply. That concept applies whether two different zones (e.g., A and V), two different BFEs, or even if a building is partially in the floodway and part in the fringe (in which case it must still meet the floodway encroachment test).
Attached is an article I wrote in 2008. Also, please note that the 2010 FBC will make this requirement very clear. You can download the “pre-publication” excerpts of the flood provisions from DEM’s webpage. And on FEMA’s Building Science webpage you can download “Highlights of ASCE 24” (ASCE 24 is referenced standard in the FBC, B for flood).
• State Floodplain Management Office (scroll down to “Building Code Resources”) www.floridadisaster.org/Mitigation/SFMP/Index.htm
• FEMA Building Science webpage (click on “Building Code Resources”) http://www.fema.gov/rebuild/buildingscience/index.shtm
Rebecca C. Quinn, CFM
RCQuinn Consulting, Inc.
104 4th St NE #2
Charlottesville VA 22902
434-296-1349 (voice)
443-398-5005 (cell)
320-514-3513 (FAX)
Rebecca C. Quinn
Now I want to reply to the question of additions. Rather than attempt to describe all the permutations here, please refer to FEMA P-758 (link below). In that publication, see Tables 6-1a and 6-1b – easy to see what has to happen to the base building depending on whether it is pre-FIRM or post-FIRM, and whether the addition is or is not substantial improvement. Also, DEM has “Guidance on Additions” State Floodplain Management Office (scroll down to “Building Code Resources”) www.floridadisaster.org/Mitigation/SFMP/Index.htm
FEMA P-758: Substantial Improvement / Substantial Damage Desk Reference http://www.fema.gov/library/viewRecord.do?id=4160
Rebecca C. Quinn, CFM
RCQuinn Consulting, Inc.
104 4th St NE #2
Charlottesville VA 22902
434-296-1349 (voice)
443-398-5005 (cell)
320-514-3513 (FAX)
From: fl_flo...@googlegroups.com [mailto:fl_flo...@googlegroups.com] On Behalf Of Mike Gambino
Sent: Thursday, November 03, 2011 10:22 AM
To: fl_flo...@googlegroups.com
Subject: RE: Higher Regulatory Zone?
That is because I do not believe it is specifically written anywhere. You could establish a policy, and it would be well-founded, and FEMA would back you up on it. You could also espouse the benefits of the safety margin and lower flood insurance to offset the cost.