June 4, 2003 

MEMORANDUM FOR: 
Doug Bellomo, P.E., Project Officer 
Eastern Studies Team 

Bill Blanton, Project Officer 
Central Studies Team 

Max Yuan, Acting Project Officer 
Western Studies Team 
FROM: 
[original signed] 
Mary Jean Pajak, Acting Chief 
Hazard Study Branch 
SUBJECT: Procedure Memorandum 32 – Levee Review Protocol 
Background: Levees are shown on Flood Insurance Rate Maps (FIRMs) with direct and often 

complex relationships to mapped flood hazards. Levees shown within or adjacent to identified 
1-percent annual chance floodplains must be mapped according to the requirements detailed in 
FEMA’s Guidelines and Specifications for Flood Hazard Mapping Partners and in conformance 
with Section 65.10 of the National Flood Insurance Program regulations. 

Issue: The FEMA Levee Inventory System (FLIS) now provides the opportunity to categorize 
all levees on FIRM panels. It is therefore important that a protocol be followed to ensure that 
each time a FIRM panel is created or revised, all levees that have an impact on the 1-percent 
annual chance flood be evaluated and documented in the FLIS. Although there is FEMA 
guidance on the mapping protocol for levees in areas of new or revised study, there are less 
formal protocols for addressing the evaluation of existing levees that are not part of a specific 
study or restudy but that exist on the affected FIRM panel(s). 

Action Taken: A tiered system of review protocol has been developed to guide the evaluation 
of levees in or adjacent to identified 1 percent annual chance floodplains on FIRM panels being 
created or revised. 

New Procedure: When Mapping Coordination Contractors (MCCs) are processing map actions 
each levee that is identified within or adjacent to identified 1-percent annual chance floodplains 
must be evaluated using the protocol specified in Table 1 on the following page. Inherent to this 
new review protocol is the requirement that the MCC keep a watchful eye for levees that were 
not properly identified, classified and/or inventoried in past map actions. In addition to 
reviewing levees on existing FIRM panels, MCCs are expected to validate information that exists 
in FEMA’s Levee Inventory System (FLIS), much of which was added to the system years ago 
when it was known as the Credited Structures Inventory System. See FEMA Procedure 
Memorandum 30 (FEMA Levee Inventory System), dated December 23, 2002, for more details 
on the FLIS. 


Procedure Memorandum 32 - Levee Review Protocol 

Table 1 describes 3 typical scenarios that may be encountered during the FIRM creation or 
revision process, and the appropriate action or escalation required. In each case described below 
the identified levees are within or adjacent to the 1-percent annual chance floodplain and have a 
direct relationship on mapped floodplain boundaries and flood elevations. 

Table 1 – Levee Review Protocol 
Description Action 
The levee is part of a new or revised flood 
hazard analysis. 
Full review and certification of compliance 
(no change in current review protocol) 
The levee is not part of new or revised flood 
hazard analysis but does appear to be mapped 
properly (as clarified below). However, there is 
no immediate evidence of certification of 
compliance with 65.10 and/or USACE 
certification. 
Concurrently pursue documentation of 
certification while proceeding with the map 
action. If something is uncovered that 
shows that the levee is mapped incorrectly, 
consult with FEMA for a decision on how 
to proceed. 
The levee is not part of new or revised flood 
hazard analysis but does not appear to be 
mapped properly, and no evidence is available to 
validate compliance with 65.10 and/or USACE 
certification. 
Consult with FEMA for a decision on how 
to proceed. 

The term “appears to be mapped properly” (for levees that are outside the scope of a specific 
map action) is solely based on a quick visual assessment for obvious anomalies in the mapping. 
Obvious anomalies for levees shown as providing protection from the 1- percent annual chance 
flood include the following: 

• 
No indication in the Flood Insurance Study (FIS) report that the levee has minimum 
freeboard; 
• 
No note in the protected area warning of residual flood risks; and/or 
• 
Floodway (when present) is not delineated at the inside toe of the levee. 
In addition, if a levee located within the 1-percent annual chance floodplain is not shown as 
providing protection from the 1-percent annual chance flood, an obvious anomaly would include 
the FIS not including before- and after-overtopping flood profiles and no apparent impact on 
flood elevations on the FIRM. 

Performing this visual inspection for levees that are not within the scope of a map action enables 
the revision to proceed while a back check is done to validate the 65.10 criteria. If, during the 
back check, problems are determined, those problems may be addressed separately. Depending 
on the gravity of the identified problems, the map action may either be halted (in extreme cases) 
or the problem can be dealt with in a follow-up action. 

cc: See distribution list 

Procedure Memorandum 32 – Levee Review Protocol 
Distribution List (electronic distribution only) 
Federal Insurance and Mitigation Administration, Office of the Administrator 

· Coughlin, Joe · Lowe, Anthony 
· Howard, Mike · Loyd, Paul 
· Leiken, Howard · Shea, Bob 
Hazard Mapping Division 
· Bellomo, Doug · Lynch, Cecelia 
· Blanton, Bill · Magnotti, John 
· Cohn, Helen · McAfee, Scott 
· Crowell, Mark · Miller, Kathy 
· Croxdale, Cynthia · Pajak, Mary Jean 
· Flowers, Anne · Pearson, Agnes 
· Grimm, Mike · Rooney, Paul 
· Hake, Tony · Scruggs, Jay 
· Hirsch, Emily · Scruggs, Priscilla 
· Lichtenfels, Allyson · Sharrocks, Fred 
· Long, Kevin · Yuan, Max 
· Lyle, Mary Anne 
FEMA Regional Offices 
· Region I · Region VI 
• 
Archiles, Robert 
• 
Lee, Dennis 
• 
Goetz, Mike 
• 
Orwat, Jim 
• 
Knowles, David 
• 
Pagano, Frank 
• 
Merli, Kevin 
• 
Quarles, Jack 
• 
Savramis, Dean 
• 
Zimmerer, Gary 
· Region II · Region VII 
• 
Dabney, Mike 
• 
Bissell, Bob 
• 
Rizzo, Sam 
• 
Franke, Robert 
• 
Swiren, Bruce 
• 
Kirk, Phil 
• 
Weberg, Paul 
· Region VIII 
· Region III 
• 
Hillenburg, Michael 
• 
Frengs, Marty 
• 
Ives, Robert 
• 
Janowicz, Jon 
• 
Liou, John 
• 
Roberts, Nikki 
• 
Olsen, Steve 
• 
Thomas, Dave 
· Region IX 
· Region IV 
• 
Eldridge, Jack 
• 
Algeo, Laura 
• 
Lenaburg, Ray 
• 
Buckerfield, Bruce 
• 
Sakumoto, Les 
• 
Davison, Todd 
• 
Ziolkowski, Sally 
• 
Loar, Brad 
• 
Plisich, John · Region X 
• 
Vieira, Mark 
• 
Atkinson, Denise 
• 
Waliullah, Mohammed P. 
• 
Carey, Mark 
• 
Cook, Carl 
· Region V 
• 
Key, Debbie 
• 
Fell, Terry 
• 
Massey, Pat 
• 
Hinterlong, Ken 
• 
Weber, Joe 
• 
Odeshoo, Janet 
• 
Schwartz, Norbert 


Procedure Memorandum 32 – Levee Review Protocol 

Mitigation Planning and Delivery Division 

· Lawless, Margaret 
Outreach and Partnership Branch 

· Gambel, John 
· Mull, Melissa 
NFIP Bureau and Statistical Agent 

· Berman, Eric 
Program Marketing and Partnership Division 

· Grimm, Michael 
· Lesser, Bill 
· Pasterick, Edward 
· Robinson, Mike 
Office of Legislative Affairs 

· Fabrizio, Vince 
· Schaffer, Loretta 
Program Finance and Industry Relations Division 

· Fowler, Carmen 
· Riggs, Verna 
Office of General Counsel 

· Neal, Rick 
· Herman, Mike 
Administration and Resources Planning; Financial and Acquisition Division 

· Lewis, Chandra 
Flood Map Production Coordination Contractors (MCCs) 

· DiCamillo, Vince (PBS&J) 
· Momeni, Zekrollah (D&D) 
· Pasquel, R. Fernando (MBJ) 
MCC G&S Team 

· Eckhart, Chris (PBS&J) 
· Kalaf, Stephen (D&D) 
· Wild, Richard (MBJ) 
Map Service Center 

· Walguarnery, Brenda 
Harvard Design and Mapping 

· Wolpert, Nat