FEMA Flood Insurance Rate Maps Appeal Process

The Federal Emergency Management Agency (FEMA) provides communities with Flood Insurance Rate Maps (FIRMs) to determine flood zones and high-risk flood areas. Since 2019, FEMA has been studying flood risk along numerous streams, many of which have not been studied before. Using the study’s findings, FEMA released a preliminary update to Oʻahu’s FIRMs. This means that your property’s flood zone designation may have changed. Some properties may now be classified within a high-risk zone, known as Special Flood Hazard Area, for the first time. Property owners in these zones who have a federally-backed loan or mortgage will be required by their lenders to purchase flood insurance when the maps are finalized. It would also require property owners to comply with local flood hazard area ordinances (ROH Chapter 21A) for development. To view your property and determine if these changes affect you, click here. For instructions on how to use the viewer, click here. You may also download the preliminary maps.

As part of the FIRMs update process, the preliminary maps undergo a 90-day public appeal and comment period from March 13, 2025 to June 10, 2025, where the public can appeal changes to their property’s flood risk designation, provide comments on the maps, and ask questions about the updates. Community review and feedback can result in more accurate FIRMs, better informing our community of their flood risk.

Appeals vs Comments

  • An appeal is a formal written objection to the addition/modification of Base Flood Elevations/Flood Depths, Special Flood Hazard Area boundaries, Zone designations, or regulatory floodway boundaries depicted on the preliminary FIRMs. An appeal must be accompanied by data and documentation, certified by a registered professional engineer or licensed land surveyor, indicating how the proposed new or modified flood hazard information shown on the preliminary FIRMs is scientifically or technically incorrect. 

  • Comments are for changes to items such as road locations and names, place names, or other base map features.

Learn more about the appeal process and next steps:

How to Submit an Appeal, Comment or Question

If you would like to submit an appeal and/or comment, it must be submitted in writing via email or traditional mail during the formal appeal period, along with the required supporting data and/or documentation.

  • To submit a comment or appeal via email, send to:
    Eric Simmons at Eric.Simmons@fema.dhs.gov using the subject line “Preliminary for Honolulu dated July 31, 2024”

  • To submit a comment or appeal via traditional mail, send to: 

    Eric Simmons, Engineer
    FEMA Region IX
    1111 Broadway, Suite 1200
    Oakland, CA 94607

  • For questions or to request data used in developing the preliminary FIRMs, send an email to: 
    FEMA Mapping and Insurance eXchange at FEMA-FMIX@fema.dhs.gov, using the subject line “Preliminary for Honolulu dated July 31, 2024”

Letter of Map Amendment and Letter of Map Revision

If you are unable to submit an appeal during the appeal process, residents can work with FEMA to potentially change their designation at any time after the FIRMs become effective through processes called Letter of Map Amendment (LOMA) or Letter of Map Revision (LOMR). While the LOMA/LOMR is being reviewed, the current FIRMs designation by FEMA will be effective.

Learn More About FIRMs

Flooding occurs naturally and can happen almost anywhere at anytime. According to a 2024 City survey, one in three Oʻahu residents have first- or second-hand experience with flooding. Between 2018 and 2023, Oʻahu residents participating in FEMA’s National Flood Insurance Program (NFIP) filed over 360 claims totaling more than $27.4 million in loss and damages.

FIRMs show how likely it is for an area to flood, and apply a flood zone designation to a location based on a variety of factors that can influence their flooding risk. The FIRMs and the associated Flood Insurance Study report are the basis for Oʻahu’s floodplain management. Below are descriptions of the flood zones most commonly found on Oʻahu.

  • Special Flood Hazard Areas (Zones A, AE, AEF, AH, AO, V, and VE): areas regulated by the City and considered to have special flood or flood-related erosion hazard risk by FEMA

  • Flood Zone X: areas not regulated by the City and considered to have minimal flood hazard risk by FEMA

  • Flood Zone D: areas not regulated by the City and considered to have an undetermined flood hazard risk by FEMA

While some areas have lower or undetermined risk, there is no such thing as a “no-risk” zone. Additionally, FIRMs may not tell the full story of flood risk. They do not include future impacts from climate change and may not reflect current conditions as communities grow and land use changes.

Need flood risk resources in a different language? Find resources here!

Get a Discount on Flood Insurance Premiums

The City participates in FEMA’s National Flood Insurance Program (NFIP) so residents are eligible to purchase flood insurance as financial protection against flood losses. In addition, the City voluntarily participates in FEMA’s NFIP Community Rating System program which provides a 10% discount on flood insurance premiums for NFIP policyholders on Oʻahu based on actions the City has taken to reduce flood risk. If you need flood insurance and aren’t sure where to start, use the “Insure My Property“ button to view a list of NFIP providers or get an NFIP policy quote and learn more about protecting your home and belongings.

FIRM Update Timeline

Letter of Final Determination 

After the formal 90-day public appeal and comment period ends, FEMA will review and address all submissions. Afterwards, FEMA will issue a Letter of Final Determination. The Letter of Final Determination starts a 6-month compliance period before the FIRMs will become effective, and the City and property owners will prepare. The final FIRMs will be shared with the community, and the City will update the local floodplain regulations. Property owners with a federally-backed loan or mortgage located in the Special Flood Hazard Area will need to obtain flood insurance, as required by their lender, and should familiarize themselves with local flood hazard area ordinances (ROH Chapter 21A). At the end of the 6-month compliance period, the FIRMs become effective, along with all regulatory and flood insurance requirements.

Public Outreach Events

To help the community better understand the FIRM updates and their implications, two Open Houses were held November 4 and 6 where FEMA, City, and DLNR representatives provided information on the FIRM update process, flood risks, potential changes to flood insurance requirements, and steps residents can take to protect their property from flooding. Additional outreach events will be posted here throughout the update process. Updates will also be posted via social media and newsletter.

Virtual Open House November 4, 2024:

What Actions Can You Take?

Carefully examine the new flood map to understand if and how your property is affected.

  • Attend a public meeting or open house to learn more about the preliminary map revisions and ask questions.

  • If you believe the new flood hazard determinations are technically incorrect, submit appeals or comments during the 90-day appeal period in Spring 2025. Instructions on how to complete an appeal will be provided at that time.

  • Now is a good time to re-evaluate what financial protections you have in place for your home and business. In addition to taking steps to make your property more flood resistant, talk to your insurance agent about your flood insurance options.

Contact

If you have any additional questions or concerns, please contact the FEMA Mapping and Insurance exchange, or FMIX, via FEMA-FMIX@fema.dhs.gov, live chat, or at 1-877-336-2627 (2:00 am to 1:00 pm HST). Self-service options are 24 hours a day, 7 days a week.

Frequently Asked Questions

  • FEMA works with communities across the country to identify flood hazards and promote ways to reduce the impact of those risks and other hazards. The preliminary flood map is a version of the FIRM circulated for community review and comment before it becomes effective.

    FIRMs are official flood maps issued by FEMA showing a community’s flood zones with an applied risk designation based on a variety of factors. High-hazard flood zones, known as Special Flood Hazard Areas (SFHA), show where there’s a 1% annual chance of flooding. While some areas have lower or undetermined risk, there is no such thing as a “no-risk” zone.

    FIRMs are used for floodplain management in the City’s Revised Ordinances of Honolulu (ROH) Chapter 21A, by financial lenders to determine the level of risk a property may face, and if flood insurance is required for a property.

  • Flood risks change over time. Changes can be due to new land uses, community development, or natural forces (changing weather, terrain changes, wildfires, etc.). FEMA works with local communities and uses the latest technology to update and issue flood maps nationwide. Every year, thousands of homeowners and renters across the U.S. experience devastating flood events even though they may not live near a body of water. On Oʻahu, extreme flooding has impacted communities like Waimānalo, ʻĀina Haina, Hawaiʻi Kai, and North Shore in recent years.

    The City is working with FEMA to understand our flood risks and how they may have changed over time. Much of the mapping being revised was produced over 25 years ago. Today’s flood maps are clearer in the risks they show. This aids our community members, property owners, and other stakeholders in taking steps to address flood risks to protect our families, homes and businesses.

  • As the City works with FEMA to update our flood maps, you may find the risk of flooding around your property has changed. This could have impacts on building and flood insurance requirements.

    Now is a good time to re-evaluate what protections you have in place for your home or business. In addition to taking steps to make your property more flood resistant, talk to an insurance agent about flood insurance options based on any flooding-related changes that could potentially be putting your property more at risk.

    Properties newly mapped into a Special Flood Hazard Area: If your property has a federally-backed mortgage, you will be notified by your lender once the FIRMS are effective if you are subject to the mandatory flood insurance purchase requirements. . The City and County participate in the NFIP Community Rating System making residents eligible for a 10% reduction on annual full risk rated NFIP policy premiums. You may also qualify for the NFIP's one-time Newly Mapped Discount. Check with your insurance agent to see if you qualify. These discounts are not available for non-NFIP private flood insurance policies.

  • Properties newly mapped into a Special Flood Hazard Area: If your property has a federally-backed mortgage, you will be notified by your lender once the FIRMS are effective if you are subject to the mandatory flood insurance purchase requirements. . The City and County participate in the NFIP Community Rating System making residents eligible for a 10% reduction on annual full risk rated NFIP policy premiums. You may also qualify for the NFIP's one-time Newly Mapped Discount. Check with your insurance agent to see if you qualify. These discounts are not available for non-NFIP private flood insurance policies.

    Properties newly mapped out of a Special Flood Hazard Area into a low to moderate risk flood zone: If your structure has a federally-backed loan, your lender, at their discretion, may remove the mandatory purchase requirement. Talk to your insurance agent about your changed flood risk and insurance options. Consider protecting yourself with flood insurance. NFIP insurance premiums are determined based on your property’s unique flood risk, regardless of zone. Flooding can happen anywhere on O'ahu and having flood insurance enables folks to recover faster.

  • No, flood damage is not typically covered by standard homeowner’s or renter’s insurance policies. Flood insurance is available for homeowners and renters through the NFIP or private insurance providers. Homeowners can obtain a flood insurance policy that includes building and contents coverage. Renters can obtain a flood insurance policy to cover contents. NFIP coverage for individual condominium units and condo associations is also available. Talk to your local insurance agent for more information.

  • If you think your property is incorrectly designated as a high-risk area, FEMA has a process allowing property owners to appeal the designation of their property. There will be a formal public comment and appeal period of 90 days. Check back to learn more about when this will open and how to submit an appeal and/or comment.