Elevation Certificates: Common Errors and Challenges

February 16, 2022

Susanna Pho, CFM

Introduction

In many ways, Elevation Certificates (ECs) are central to the work of floodplain managers across the country. As surveyed documents, they detail crucial information (like lowest floor elevation) and are utilized for everything from enforcing floodplain compliance to obtaining flood insurance. Since they are often collected to meet minimum National Flood Insurance Program (NFIP) requirements it's likely that, if you're a floodplain manager, you're well-acquainted with the document.

Despite their ubiquity, staying on top of Elevation Certificate compliance and maintenance can be a huge burden for communities with limited resources. This is particularly true for communities in the Community Rating System (CRS), for whom maintenance of correctly completed ECs can mean the difference between millions of dollars in flood insurance discounts for residents and upset property owners whose premiums have skyrocketed. The 2021 CRS Addendum raises the stakes even higher on EC precision – CRS communities are now required to submit ECs for review every year and have one less complementary check to rely on to reach the crucial 90% bar of accuracy. On top of that, the context is changing rapidly with big shifts like Risk Rating 2.0. While the role of ECs will morph with an evolving NFIP, they'll likely remain an important tool for enforcing local compliance.

Our team at Forerunner spends a lot of time learning about challenges faced by floodplain managers to build tailor-made software for individuals in government working with flood risk. We provide software to communities ranging from very small (Bay Head, NJ) to very large (Harris County, TX) that allows them to leverage existing property-level flood risk data to streamline compliance and outreach.

Almost all of our users have historically struggled with EC management and review. To address these pain points, Forerunner recently built upon our EC storage and data extraction capabilities to launch an EC Error Detection Feature. In doing so, we conducted interviews with a diverse group of floodplain managers and gathered data from our pilot users that sheds light on common EC errors encountered by communities of all sizes.

Challenges to Compliance

Through user research, we have gathered and assessed the challenges that floodplain managers face when managing incoming Elevation Certificates. Some of these challenges found include:

It's hard to keep track of ECs for internal record-keeping and the CRS. Some interviewees noted that they don't have a system for tracking ECs and many more rely on spreadsheets. Almost everyone spoke about the difficulty of maintaining up-to-date records, regardless of whether or not they had a digital tracking system in place. Communities that reported being successful on this front often maintained databases and spreadsheets on a schedule – so that they had dedicated time each week to update EC info. We see this reflected in our software usage as well. Forerunner acts as an EC repository for our partner communities, and we see trends in users uploading documents at specific times. Our software also generates CRS-specific exports to fulfill 310 requirements, so we see an uptick in exporting when it comes time for community recertification visits.
It can be difficult to communicate flood risk to residents and get them the documents they need. Federal and local floodplain regulations can be incredibly difficult to communicate with residents, but keeping them informed is crucial to enforcing compliance and encouraging risk reduction. Interviewees reported spending a lot of time responding to resident requests and providing documentation (like access to historic ECs) to stakeholders. Those that invest in sharing data digitally, using public websites and automated emails, found that it alleviated some of the day-to-day burden of response. Our users have anecdotally reported that using our white-labeled flood information websites is useful for providing residents with a self-service platform to get flood risk information 24/7.
Checking ECs for accuracy and compliance to local regulations is onerous for all communities. Depending on internal capacity, Elevation Certificates might be reviewed by staff members who are not trained to evaluate floodplain compliance and those with insufficient experience may face difficulties in conducting a thorough review. If ECs are not completed correctly, communities run the risk of permitting construction in floodplains that do not adhere to regulatory standards and facing penalties from FEMA. Once a non-compliant structure is built, enforcing changes or reversing a permitting decision can be very complicated. Communities that are successful at minimizing errors typically put into place redundancy using multiple EC reviewers, checklists, and tools like Forerunner's EC Error Detection.

Common Elevation Certificate Errors

Tackling Elevation Certificate errors programmatically helps to minimize human slip-ups and catch clerical mistakes that might otherwise be overlooked, but have big consequences. Part of what makes EC reviews complex is that certain requirements are triggered by the values reported in individual fields. For example, if a structure is elevated (Building Diagrams 5, 6, 7, 8, and 9), its C2.a Top of Bottom Floor should be above the C2.f Lowest Adjacent Grade. Keeping track of this logic can be difficult, especially if someone isn’t reviewing certificates daily. Utilizing software can help reduce complexity and lower the amount of total time spent on Elevation Certificate review.

We designed Forerunner's EC Error Detection feature to flag clerical errors, discrepancies between EC fields and FEMA NFHL data, and potential issues with building descriptions or measurements. The tool utilizes data that is extracted from each EC uploaded into Forerunner to run over 100 validation checks, which surface potential issues ranging from urgent (like the possibility of incorrect elevations) to noncritical (like a reminder to check for a V-Zone Design Certificate). If you'd like to compare our checks to yours, feel free to use our Issues Guide as a resource. Within the Issues Guide, noncritical issues are marked as "warnings", while urgent issues are marked as "errors".

To pilot our Error Detection feature, we checked residential ECs issued after 1/1/2019 for our partner communities. A total of 5,082 ECs fell within these parameters, of which 3,475 had at least one flagged error. Put another way, there were errors in 68.4% of the ECs we ran our Error Detection check on. 2,260 ECs had at least two flagged errors (44%) and we saw an average of two errors flagged per EC. Here are some of the most frequent types of problems surfaced:

B4. Map/Panel Number does not match the Map/Panel Number provided by FEMA. Since Map/Panel numbers are long, typos are common in this field. Our Error Detection validates EC fields against FEMA's data, which helps to minimize time spent checking Section B FIRM Information.
C2.f Lowest Adjacent Grade lower than Base Flood Elevation: Unless an Elevation Certificate being submitted is for LOMA or LOMR-F purposes, the Lowest Adjacent Grade is typically below the Base Flood Elevation. Often, surfacing this issue can uncover additional potential issues – like an incorrect Building Diagram Number.
Regulatory Lowest Floor below Design Flood Elevation: Because ECs are often collected to ensure the enforcement of local regulations, our software checks ECs for compliance to communities' individual standards. A common issue found on the ECs we've processed thus far is that a structure's regulatory Lowest Floor (as defined by FEMA's Lowest Floor Guide) is lower than the community's Design Flood Elevation (most commonly, Base Flood Elevation + Freeboard).
C2.e Lowest Elevation of Machinery below Design Flood Elevation: Similarly, another common issue is that the Lowest Elevation of Machinery for a structure falls below a community's Design Flood Elevation. Catching these errors early can mitigate costly changes for property owners down the line.
Elevated Building Diagrams with Attached Garages: FEMA's guidance now states that garages in structures with elevated building diagrams should be considered enclosures. This means that garage areas and venting should be reflected in fields A8.a-c. Elevated structures should not have non-zero values in A9.a-c or in C2.d. Since this change recently took effect, we've found that many surveyors haven't yet adopted it in their EC practices.

Depending on a community's individual context, common errors might vary significantly. We've found that communities with lower error rates typically have floodplain managers who invest in developing strong relationships with local surveyors. When this happens, requests for specific document changes and practice shifts can be passed along quickly and seamlessly.

If you'd like to learn more about our EC research (we did a lot of it!) or our work at Forerunner, please feel free to reach out to us at hello@withforerunner.com. We're always happy to have a chance to learn more about your work and share our knowledge!