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Levee Accreditation Review and Often Misunderstood Freeboard Requirements

In order to be accredited, a levee or a levee system must meet minimum standards listed in the National Flood Insurance Program's (NFIP) Code of Federal Regulations(CFR) at Title 44, Chapter 1, Section 65.10 (44 CFR Section 65.10), including design, operation plans, maintenance plans, and certification.

According to Procedure Memorandum No. 63 - Guidance for Reviewing Levee Accreditation Submittals (PM 63), issued on September 2, 2010, FEMA's levee accreditation review process, also known as the "completeness check," is performed to ensure that all data demonstrating compliance with 44 CFR Section 65.10 has been submitted. The submitted documents must include all back-up data and supporting information for all calculations. Certified summary reports without all the required back-up data are not accepted.

According to PM 63, FEMA has established a three-tiered approach to perform a completeness check:

Tier 1

  • Step 1: Certification
  • Step 2: Freeboard check

Tier 2

  • Step 3: Regulations
  • Step 4: Operation and maintenance plan
  • Step 5: "With levee" and "without levee" analysis

Tier 3

  • Step 6: Levee system and cross-reference check
  • Step 7: Interior drainage analysis
  • Step 8: Structural design requirements
  • Step 9: Inspection reports

This approach is very interactive and intended to make the levee review process more efficient. The reviewer shall not proceed to the subsequent tiers if data for one tier is missing.

Freeboard Requirements

Minimum freeboard (distance between normal water level and the top of a structure) requirements for a levee to be accredited, as specified under Section 65.10 (b)(1)(i) , include:

  • A minimum freeboard of three feet
  • An additional one-half foot above the minimum at the upstream end of the levee, tapering to no less than the minimum at the downstream end of the levee
  • An additional one foot above the minimum, within 100 feet of either side of the structure

Occasionally, exceptions to the minimum riverine freeboard requirements may be approved, but appropriate engineering analysis demonstrating adequate protection with a lesser freeboard must be submitted. Under no circumstances will freeboard of less than two feet be accepted. However, according to PM 63, requests for exceptions may be coordinated with FEMA prior to submitting the accreditation request.

Once the completeness check is finished and all the submitted data, showing compliance with 44 CFR Section 65.10, has been completed, FEMA will accredit the corresponding levee or a levee system on the NFIP maps. The submittal of incomplete or erroneous data may result in denial of the request.