CONCORDIA, Kan. — The City of Concordia is pleased to share that the Federal Emergency Management Agency (FEMA) approved the City’s request for a Letter of Map Revision (LOMR) on April 4, 2025. This action is related to the mapped floodplain and affects property owners within the city limits of Concordia.
After more than a decade of research and advocacy, an estimated 200 structures in Concordia are no longer located within the Special Hazard Flood Zone A, and have been re-assigned a Shaded Zone X designation. This means a 1% chance of flooding (also known as the 100-year storm) may still cause flooding on property but only to an average depth of less than one foot (12 inches). There were also a handful of properties that have now been added to the Special Hazard Flood Zone A designation, though City staff believes the impact to structures on those properties is minimal.
“This LOMR shows how important it is to continue to advocate for what we believe is right, even if it takes several years,” said Bruno Rehbein, City floodplain administrator. “The FEMA floodplain maps went into effect in July 2014 without consideration given to the new 21st Street Dam and Plum Road Dam that were under construction. We are grateful the City Commission continued to support us, and the Kansas Department of Agriculture Division of Water Resources listened to our story in 2021. Their technical assistance grant allowed us to prove the value of these dams and our underground storm sewer system that ultimately resulted in this LOMR approval.”
BACKGROUND INFORMATION
On July 16, 2014, FEMA floodplain maps went into effect putting a number of citizens in the City of Concordia into the floodplain. The impact of this mapping was that a number of homeowners with federally backed mortgages were required to purchase and carry flood insurance on their homes and businesses, at a significant expense. While Concordia staff had raised red flags in that previous mapping process, they were unable to get significant changes made to the mapping before it went effective. The City continued to express concerns and in 2021 the City was able to secure technical assistance funding from the Kansas Department of Agriculture, Division of Water Resources (KDA-DWR) to restudy this area, which was completed in March 2022. The results of this project appeared favorable for Concordia homeowners and more accurate of actual flooding conditions, reducing the size of the floodplain. Therefore, the city decided to move forward with a Letter of Map Revision process (LOMR) to change the floodplain maps.
Benesch was retained by the City of Concordia to provide services associated with the development and submission of a LOMR request to FEMA via a Consulting Services Agreement that was authorized by the city and dated March 2023. The expectation at the time was to use the data previously developed as part of the KDA-DWR technical assistance project and provided to the City, which included updated flood modeling and mapping developed by one of KDA-DWR’s on-call consultants, AECOM, for the LOMR submittal. The scope of the FEMA LOMR project included a review of the modeling and mapping for FEMA compliance, preparation of the documentation, datasets, and panels needed for a LOMR submittal package, and assistance with public notice and outreach. Upon review of the modeling and mapping data, Benesch identified several errors and issues that needed to be resolved to achieve FEMA compliance and ultimately obtain LOMR approval. Benesch coordinated with the City of Concordia staff and KDA-DWR staff to discuss these concerns. KDA-DWR staff were under the impression that the modeling and mapping would be suitable for LOMR submittal and wanted to follow through with providing the city with high quality data.
Therefore, KDA-DWR, with support from FEMA, agreed to fund a second phase of the technical assistance project for the City of Concordia and utilized Benesch, another one of their on-call consultants, to develop a new rainfall-runoff model for the City of Concordia that limits model instability, flow losses and addressed errors; thus being of the quality suitable for FEMA compliance. The project also included the development of draft floodplains that adequately represent the flood risk. The modeling was also done in a software package that is more widely accepted in the industry and more useful to the community in the future. The second KDA-DWR technical assistance project for Concordia concluded in February 2024. Draft floodplains were developed for the tributary to the Republican River, which crosses through town, to represent the 1% annual chance (100yr) and 0.2% annual chance (500yr) storm events. The majority of the flooding associated with the 1% annual chance draft floodplain for the subject stream is very shallow in nature, much of which is only a couple inches in depth. In addition, for much of this floodplain there is no channel with defined bed and banks.
Typically, FEMA defines a regulatory Zone A special flood hazard area as a hazard zone that corresponds to the 1% annual chance floodplains. However, in the case of shallow flooding areas, FEMA defines 1% annual chance flooding where average depths are less than 1.0 foot as a Zone X (shaded) moderate flood hazard, which would only be considered an advisory floodplain. The average 1% annual chance flood depths for the tributary to the Republican River are less than 1 foot and there is a lack of continuous channel through town. Given these conditions, at Benesch’s recommendation, the City requested concurrence with FEMA Region 7, with support from the KDA-DWR, to change the Zone A special flood hazard area for the tributary to the Republican River to a shaded Zone X flood hazard with average depths less than 1 foot. FEMA Region 7 concurrence has already been obtained for this zone change. The shaded Zone X designation would result in advisory floodplains that do not have mandatory flood insurance purchase requirements for homeowners with federally backed mortgages and have minimal regulatory requirements which are generally only tied to critical infrastructure. It should be noted that backwater from the Republican River will still be a Zone A Special Flood Hazard Area. The proposed floodplains are significantly smaller in many locations than the effective floodplain, and larger at other locations. However, the identified risk and associated regulation is significantly reduced for this proposed mapping.
Benesch prepared and submitted the LOMR package to FEMA in April 2024. Following several rounds of review and clarification questions by FEMA, the LOMR was ultimately approved on April 4, 2025.
WHY IS THIS WORK SIGNIFICANT?
The Shaded Zone X designation means a property owner is no longer required to obtain flood insurance if they have a federally-backed mortgage. This designation also lifts some development restrictions, allowing the property greater flexibility for property improvements.
“We are grateful for Bruno’s tenacious work on behalf of the residents and business owners of Concordia,” said Concordia city manager Amy Lange. “His tireless efforts have made property ownership less expensive and property improvements less cumbersome in the heart of Concordia as a result of this LOMR. We also want to thank the KDA for their grant-funded technical assistance work, and our floodplain consulting engineer, Benesch, for their extremely detail-oriented and technical efforts related to this LOMR application submittal. As always, success requires teamwork.”
Revised maps are available for viewing at City Hall. Limited assistance is available for those property owners requiring an elevation certificate and/or a Letter of Map Amendment – Out As Shown (LOMA-OAS). Please contact Bruno Rehbein, floodplain administrator, at (785) 243-2670 or building@concordiaks.org with questions about a specific property.
