B.3. Structure Elevation

Structure elevation activities generally involve physically raising an existing structure. Structure elevation may be achieved through various methods, including elevating on continuous foundation walls; elevating on open foundations, such as piles, piers, posts or columns; elevating on fill; and converting the second story. Foundations must be designed to properly address all loads and be appropriately connected to the floor structure above. Utilities must also be properly elevated. Buildings proposed for elevation must be structurally sound and capable of being elevated safely.

FEMA requires applicants and subapplicants to design all structure elevation projects in accordance with the NFIP standards in 44 CFR Part 60 and the latest published edition of ASCE 24 or its equivalent as minimum design criteria. The scope of work narrative should clearly state the structure elevation will be designed to meet ASCE 24 criteria. Structure elevations in the flood hazard area must follow HMA’s Federal Flood Risk Management Standard requirements described in Part 4.I.

For a structure to be eligible for elevation, it must be structurally sound and capable of being elevated safely. Elevation projects must raise the lowest floor above the Base Flood Elevation or elevation required by FEMA, local ordinance or design flood elevation, whichever is highest.

In the case of an elevation project in a coastal flood zone, the lowest horizontal structural member must be raised above the Base Flood Elevation or elevation required by FEMA, local ordinance or design flood elevation, whichever is highest.

In cases where a building cannot be elevated, the ground floor living space can be filled in or repurposed and used solely for parking, storage or building access. The existing second floor is converted to the new living space or the roof is removed and additional living space is constructed over the existing living space. This project is called a second-story conversion. For second-story conversion projects, the bottom of the second story must be above the Base Flood Elevation or elevation required by FEMA (HMA’s Federal Flood Risk Management Standard), local ordinance or design flood elevation, whichever is highest.

The property owner must voluntarily agree to participate in the elevation program. During the development of an elevation project, property owners are responsible for notifying the subapplicant of their interest in participating in the proposed project. They must provide all the information requested by the subapplicant, and they must finish all the actions required to complete the subapplication and to carry out the structure elevation.

Table 22 outlines structure elevation activities eligible under the following programs:

Table 22: Eligible Structure Elevation Activities

Eligible Activities	HMGP	HMGP Post Fire	BRIC	FMA
Elevating on continuous foundation walls	Yes	Yes	Yes	Yes
Elevating on open foundations (e.g., piles, posts, piers)	Yes	Yes	Yes	Yes
Elevating on fill	Yes	Yes	Yes	Yes
Second-story conversion	Yes	Yes	Yes	Yes

Buildings proposed for structure elevation must be structurally sound and capable of being elevated safely. A report of an inspection completed by a qualified professional (e.g., licensed engineer or architect, local building code official) may be used to document the structural soundness. Important design considerations for structure elevations are as follows:

• Structure elevations in the flood hazard area must follow HMA’s Federal Flood Risk Management Standard requirements described in Part 4.I.
• In cases where HMA’s Federal Flood Risk Management Standard does not apply, elevation projects must meet requirements by the latest published edition of ASCE 24. FEMA also encourages consideration of future conditions, including sea level rise, when determining the elevation height and will assist elevations higher than the minimum requirements if they remain cost-effective. Upon completion of the elevation work, an Elevation Certificate (FEMA Form 086-0-33) verifying “as-built” elevations must be completed to ensure the structure complies with the local floodplain ordinance and NFIP floodplain management and HMA requirements.
• Sea level rise can be applied to projects in any U.S. coastal area where relative sea level rise data are available. This includes areas subject to coastal flooding as identified in the current NFIP flood study or coastal rivers and streams located as far inland as the extent of estimated tidal influence or storm surge. When performing structure elevation projects or projects that have freeboard requirements, sea level rise estimates should be added to the state or local jurisdiction’s freeboard requirements if those freeboard requirements do not exceed the projected sea level rise during the project’s useful life.
• Elevation projects must be designed and adequately anchored to prevent flotation, collapse and lateral movement of the structure due to hydrodynamic and hydrostatic loads, including the effects of buoyancy. FEMA recommends that an engineer certify that the design elevation will withstand the depth and velocity of 1% annual chance flood events (hydrostatic and hydrodynamic loads), any potential increase in wind load or any other relevant load factors.
• For elevation projects in Zone V with open foundations (piles, piers, posts or columns), the space below the lowest floor must be free of obstructions or constructed with non-supporting breakaway walls, open wood latticework, or screening intended to collapse under wind and water loads without causing collapse, displacement or other structural damage to the elevated portion of the building or supporting foundation system. Guidance on free-of-obstruction and breakaway wall requirements is available in FEMA Technical Bulletin 5, Free-of-Obstruction Requirements: For Buildings Located in Coastal High Hazard Areas in Accordance with the National Flood Insurance Program (March 2020) and Technical Bulletin 9, Design and Construction Guidance for Breakaway Walls: Below Elevated Located in Coastal High Hazard Areas in Accordance with the National Flood Insurance Program (Sep. 2021).
• For elevation projects on continuous foundation walls with fully enclosed areas below the lowest floor, the area must be used solely for parking of vehicles, building access or storage.^[429]
• Elevation projects on continuous foundation walls must be designed to equalize hydrostatic flood forces on exterior walls automatically by allowing for the entry and exit of floodwaters. Designs to meet these criteria must be certified by a licensed professional engineer or meet or exceed the criteria in 44 CFR § 60.3((5). Guidance on meeting this requirement can be found in NFIP Technical Bulletin 1 (TB-1), Requirements for Flood Openings in Foundation Walls and Walls of Enclosures (March 2020).
• Elevation projects on constructed fill must meet or exceed criteria in 44 CFR § 60.3(e)(6). Guidance on meeting these criteria can be found in FEMA Technical Bulletin 10-01, Ensuring That Structures Built on Fill In or Near Special Flood Hazard Areas Are Reasonably Safe from Flooding (May 2001).
• In Zone A, second-story conversions above the Base Flood Elevation are allowable. These projects involve converting the usage of the ground floor to parking, storage or building access and modifying or replacing the walls; filling below-grade areas and basements; or elevating the building. Additional information about second-story conversions is available in FEMA P-312, Homeowner’s Guide to Retrofitting: Six Ways to Protect Your Home From Flooding^, 3rd Edition (June 2014) and the Second Story Conversion—Elevation Project Design Considerations for Hazard Mitigation Assistance Applicants FEMA fact sheet.
• Elevations of existing slab-on-grade foundations attached to existing buildings must only occur if the slab is certified by a licensed structural engineer to be usable as a structural slab (i.e., reinforced sufficiently to be self-supporting) and meets the design requirements of the latest International Code, ASCE standards, and the American Concrete Institute (ACI) Building Code Requirements for Structural Concrete (ACI 318) and Commentary on Building Code Requirements for Structural Concrete (ACI 318R). If the slab is non-structural in nature, then an alternate foundation elevation method should be considered. Additional information is available in FEMA P-312

A general list of ineligible activities is included in Part 4.

Refer to Part 12.B.3.3.2.2 for specific activities that are considered ineligible for structure elevation projects. A general list of ineligible activities is included in Part 4

Applicants and subapplicants must demonstrate that mitigation projects are cost-effective. Projects must be consistent with Part 5.

FEMA will fund hazard mitigation projects that include sea level rise estimates. To incorporate considerations for sea level rise in the development of a BCA, recipients and subrecipients should add the estimated sea level rise to the current 10%, 4%, 2% and 1% annual chance flood elevations for their area. Generally, sea level rise can be included in flood elevations when conducting BCAs in coastal areas using the full data flood module. Sea level rise can be applied to projects in any U.S. coastal area where relative sea level rise data are available. This includes areas subject to coastal flooding as identified in the current NFIP flood study or coastal rivers and streams located as far inland as the extent of estimated tidal influence or storm surge.

When performing structure elevation projects or projects that have freeboard requirements, sea level rise estimates should be added to the state or local jurisdiction’s freeboard requirements if those freeboard requirements do not exceed the projected sea level rise during the project’s useful life.

Based on extensive analysis, FEMA determined pre-calculated benefits for elevation projects located in the SFHA. This analysis demonstrates a national average for benefits of $205,000 for elevation projects. Therefore, FEMA has determined the elevation of a structure located in the 1% annual chance floodplain for which costs are equal to or less than $205,000 is cost-effective.

Alternatively, if a structure’s Lowest Floor Elevation (Zone A) or lowest horizontal structural member (Zone V) is lower than the Base Flood Elevation, the pre-calculated benefit may be used even if the structure is not in a mapped SFHA. For projects that contain multiple structures, the average cost of all structures in the project must meet the stated criterion.

To qualify for these pre-calculated benefits, the applicant or subapplicant must include maps with each structure’s footprint clearly identified and the SFHA delineated as part of the application. If a structure or any part of a structure lies in the 1% annual chance floodplain, the applicant or subapplicant can use the pre-calculated benefits for the structure.

If the applicant or subapplicant cannot clearly demonstrate a structure is in the SFHA, then the finished floor elevation and Base Flood Elevation should be included in the BCA for the structure. If the finished floor elevation is less than Base Flood Elevation, the applicant or subapplicant can use the pre-calculated benefits for the structure. No other detailed analysis will be required. These pre-calculated benefits can be used for both riverine and coastal areas.

Additionally, the specific geographic location of structures can greatly increase elevation costs. The benefits identified above may be adjusted by the recipient and subrecipient using locality multipliers included in industry-accepted cost and pricing guides for construction. If a multiplier is used, a copy of the source document must be included as part of the application for review and the methodology demonstrated for the increase of benefits. Also, the applicant or subapplicant should use the most up-to-date locality multiplier at the time of application.

For up-to-date information on the dollar value of pre-calculated benefits, visit the FEMA “Benefit-Cost Analysis” webpage.

Projects must be consistent with Part 4. Mitigation projects assisted by HMA must be both feasible and effective at mitigating the risks of the hazard(s) for which the project was designed. A project’s feasibility is demonstrated through conformance with accepted engineering practices, established codes, standards, modeling techniques or best practices.

For structure elevation, the subapplicant must include a statement from a local official certifying the community will retain a qualified licensed professional to design the project in conformance with latest published edition of ASCE 24 and will meet the feasibility and effectiveness requirements.

FEMA will use the latest published edition of ASCE 24 or its equivalent as the minimum design criteria for all HMA-assisted structure elevation projects in flood hazard areas. These flood hazard areas include floodways, coastal high-hazard areas and other high-risk flood hazard areas such as alluvial fans, flash flood areas, mudslide areas, erosion-prone areas and high-velocity areas. ASCE 24 addresses design and construction requirements for new buildings and Substantial Improvements to existing buildings (including repair of substantial damage) located, in whole or in part, in flood hazard. ASCE 24 sets forth requirements for elevation, foundation designs, enclosures below elevated buildings, materials, wet and dry floodproofing, utility installations, building access and miscellaneous structures (e.g., decks, porches, patios, garages, chimneys and fireplaces, pools and above- and below-ground storage tanks).

In addition, all elevation projects in flood hazard areas must also comply with the requirements established by the Federal Flood Risk Management Standard, conform to local floodplain regulations, and be permitted by the local floodplain administrator. ^[430] Refer to Part 4.I for more information about these requirements.

All subapplications submitted to FEMA must meet the EHP criteria in Part 4. All subapplications must provide the information described in Part 6 so that FEMA may perform the EHP review.

Mitigation projects sited within the SFHA are eligible only if the jurisdiction is participating in the NFIP. For FMA only, all properties included in a subapplication must be NFIP-insured at the time of the opening of the application period. The flood insurance policy must be maintained throughout the period of performance and for the life of the structure. For more information, refer to Part 4.J.

For structures in the SFHA at the completion of the project and all structures receiving FMA regardless of location in the SFHA, flood insurance must be maintained for the life of the property.^[431] For more information, refer to Part 4.J.

All subapplications submitted to FEMA must meet the eligibility criteria in Part 4. All subapplications must have a scoping narrative in accordance with Part 6. Project-specific criteria are highlighted below.

FEMA may request additional information after the subapplication has been submitted to ensure all necessary information is received. However, all information required by the regulations and the HMA Guide must be received before an assistance decision and award or final approval can be made.

For structure elevation projects, the subapplication must include the following for each structure:

• Physical address and property owner(’s) name(s).
• Longitude and latitude coordinates to the nearest sixth decimal place.
• Clear color photographs of each side of the building to be elevated.
• Color photographs of the surrounding neighborhood taken from the site of the building to be elevated.
• Estimated cost to elevate each structure.
• Name and location of flooding source (e.g., creek, river, watershed or location of stormwater ponding) and location of the property on the applicable FIRM.
• The proposed elevation of the lowest finished floor for each structure to be mitigated, the Base Flood Elevation and the current elevation of the lowest finished floor. If future conditions are being considered, documentation that supports those conditions and their impacts on the elevation must be included.
• Type of existing foundation (slab-on-grade, crawl space, basement or open foundation) and the proposed elevation method and standard to be used.
• Statement that the project will be designed in compliance with NFIP standards in 44 CFR § 60.3.
• Schedule showing anticipated start and completion dates, significant milestones, activities and deliverables.

All subapplications must include a line-item breakdown of all anticipated costs.

Subapplicants may apply for subrecipient management costs to cover administrative costs. Management costs must be included in the subapplication budget as a separate line item. More information about the requirements for management cost requests can be found in Part 13.

Allowable costs are costs that are necessary and reasonable for the proper and efficient performance and administration of the federal award. The following costs associated with structure elevation projects are generally allowable:

• Engineering services for design, structural feasibility analysis and budget preparation.
• Surveying, soil sampling, completion of Elevation Certificate (FEMA Form 086-0-33), title search, deed recordation fees, legal and/or permitting fees, project administration and construction management.
• Disconnection of all utilities.
• Building of a foundation so that the lowest floor is at the Base Flood Elevation or higher if required by local ordinance or FEMA.
• Physical elevation of the structure and subsequent lowering and attachment of the structure onto a new foundation.
• Construction of a floor system that meets minimum building code requirements when the existing floor system cannot be elevated or is not appropriate for the new foundation.
• Reconnecting utilities and extending lines and pipes as necessary and elevating all utilities and service equipment.
• Debris disposal and erosion control.
• Repair of lawns, landscaping, sidewalks and driveways if damaged by elevation activities.
• Construction of a utility room above the Base Flood Elevation only if there is no existing space within the house for this purpose or there is no alternative cost-effective way to elevate the utilities.
• Elevation of existing decks, porches or stairs.
• Construction of new stairs, landings and railings to access the elevated living space per minimum code or local ordinance.
• Construction of ADA-compliant access facilities or ramps when an owner or a member of the owner’s family has a permanent disability and a physician’s written certification. An ADA-compliant access to ingress/egress is allowable for assistance unless specified otherwise in applicable state or local codes. If ramps are not technically feasible, a mechanical chair lift may be installed.
• Documented reasonable living expenses (except food and personal transportation) that are incurred while the owner is displaced by the elevation construction.
• Abatement of asbestos and lead-based paint.
• Filling basements with compacted clean fill.

Certain structure elevation activities and their associated costs are not eligible. Ineligible costs for structure elevation include but are not limited to the following:

• Elevating structures that were not in compliance with current NFIP standards at the time of construction.
• Costs related to building additions or auxiliary structures.^[432]
• Construction of new decks or porches.
• Any improvements for purely aesthetic reasons, unless required by the EHP compliance review.
• Costs to replace or repair utility service components that are undersized, inadequately designed or unsafe, unless required by code (except utility rooms noted as eligible costs).
• Exterior finish on the exposed foundation of the elevated building, unless required by EHP compliance review and or local code.
• Additional landscaping for ornamentation beyond what existed on the site prior to construction of the project (e.g., trees, shrubs).

Elevation project implementation entails:

• Pre-construction activities.
• Construction.
• Inspection of the completed foundation and engineering certification.
• Obtaining an Elevation Certificate (FEMA Form 086-0-33) and certificate of occupancy.
• A recordation of deed restriction requirements for property maintenance and flood insurance.

Before the construction of the foundation begins, it is very important to conduct an inspection of the condition of the structure, survey the site and complete a soil inspection to ensure the proposed elevation project is feasible on the site.

Standard structure elevation methods are identified in FEMA P-312; FEMA P-347, Above the Flood: Elevating your Floodprone House; and the Second-Story Conversion FEMA fact sheet. In addition, FEMA has developed guidance for the design of appropriate foundations based on the requirements of the International Codes and other applicable standards. That guidance is provided in FEMA P-550, Recommended Residential Construction for Coastal Areas: Building on Strong and Safe Foundations, Second Edition (Dec. 2009), and is available for use with HMA structure elevation projects. FEMA also requires applicants and subapplicants to design all structure elevation projects in accordance with the latest published edition of ASCE 24 and requirements established by the Federal Flood Risk Management Standard as described in Part 4.I.

Available elevation methods, thoroughly described in FEMA P-312, FEMA P-347 and the Second-Story Conversion FEMA fact sheet include:

• Elevating the existing structure on piles, posts or piers.
• Elevating the structure on fill.
• Filling in the basement and replacing it with an elevated floor.
• Elevating by vertically extending the foundation walls of the home.

Activities that result in the construction of new living space at or above the Base Flood Elevation are considered only when they are consistent with mitigation reconstruction requirements. Activities include structure elevations that abandon a lower enclosed area and add a second story above the Base Flood Elevation to an existing structure.

The method that is selected for elevating a house depends on factors such as:

• Foundation type—the most common foundation types are:
  • Crawl space on foundation walls.
  • Slab-on-grade.
  • Open type foundation—piles and posts or piers.
• Condition of the house.
• Applicable state and local building codes.
• Soil type and bearing capacity.
• Weight of the house and lateral forces on the house from water and other natural hazards, such as winds and earthquakes.
• Height of proposed elevation above the grade level.
• Number of additions to the original structure.

Additional information can be found in the resources on the FEMA “Building Science” webpage.

FEMA encourages surveying and inspections throughout the construction process. Certifications of the surveys ensure the work has been performed in compliance with the structure-specific plans and specifications, applicable codes and standards, and minimum NFIP requirements. Figure 15 identifies important inspection and survey considerations.

Graphic

Recipients are required to report deviations from budget, project scope or objectives in accordance with Part 8. Recipients must request prior approvals from FEMA for budget and program plan revisions.^[433]

If the results of inspections indicate the structure cannot be elevated, the subapplicant may request a change in scope to substitute another structure. This option is only available if alternative structures were identified in the original subapplication. If the final design is not complete prior to award, once the project is awarded, the design must be finalized by a licensed design professional. Any changes to the scope of work or budget because of completing the final design or to address permitting requirements must be consistent with Part 8. Construction design activities are defined as construction activities; therefore, budget changes involving them must be consistent with Part 8.F.2.

Recipients and subrecipients must close out projects in a timely manner consistent with Part 9.

In addition to the typical HMA program closeout procedures, close out of structural elevation projects generally includes:

• A certificate of occupancy and the final Elevation Certificate (FEMA Form 086-0-33) for each structure on the project to certify the structure is code compliant and was elevated to the required elevation.
• A copy of the recorded deed for each property, including structure elevation project deed requirements for property maintenance and flood insurance requirements.
• A signed Acknowledgement of Conditions for Properties Using FEMA Hazard Mitigation Assistance form for each structure.
• A certification from a building official or licensed design professional verifying that the structure was designed and constructed to the minimum standard of the two most recently published editions of the International Codes, even in locations where no code has been adopted.
• Front, rear and side photographs of the final structure(s), including the date of the photograph, property address, latitude/longitude to the nearest sixth decimal place and the source of the photograph.
• Verification of flood insurance policy for each structure.
• Update of the property site information and address in the respective HMA electronic system database for each structure indicating if each property was mitigated or withdrawn.