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Level 2 — Property Analysis · $79

Property Analysis
Zone Reclassification History, EC Assessment & Insurance Implications

1847 SW WILLOW CREEK DR · PORTLAND, OR 97219 · MULTNOMAH COUNTY
Report DateJune 5, 2026
Order IDMFR-2026-008
Prepared ByJohn Richardson · NPN 21235461
EC on FileYes — provided by owner (2023, pre-remapping)
Policy ReviewedNFIP policy — first-year following remapping
AE

Zone AE — Newly Mapped 2024 · EC Documents LFE at BFE +3.1 ft · LOMA Signal Present

The Elevation Certificate provided documents the lowest floor elevation at 55.1 feet NAVD88, which is 3.1 feet above the newly-established BFE of 52 feet. The Lowest Adjacent Grade is documented at 52.4 feet NAVD88 — 0.4 feet above BFE. This LAG value is the most significant data point in this report.

Key Findings — At a Glance
EC documents LAG at +0.4 ft above BFE. 52.4 ft NAVD88 vs. BFE 52.0 ft. LOMA criterion appears met.
LFE at +3.1 ft above BFE. Structure well elevated. Favorable insurance rating profile.
LOMA pathway viable. LAG exceeds BFE — mandatory requirement may be removable. See Level 3 for full assessment.
Portland CRS 20% discount applies. Estimated current NFIP: ~$1,240/year (after discount).
0.4-ft margin is thin. LOMA application warrants engaging original EC surveyor to minimize re-survey risk.
Private market option ~$600–$900/year. But LOMA may make all insurance optional — evaluate in that context.
Bottom line: Your EC documents above-BFE conditions that may support removing the mandatory insurance requirement entirely. The LOMA pathway is the priority finding — a successful application saves $1,240+/year with approximately 13-month payback on application costs. Level 3 provides the full assessment and referral guidance.
Zone Reclassification History — Willow Creek Basin
Pre-2000 — Historical Mapping
Zone B / Zone X — Low Risk Designation
Willow Creek basin mapped as minimal risk in early FIRM panels. Pre-LiDAR topographic data did not capture the detailed floodplain geometry that later studies would reveal. Property carried no mandatory insurance requirement during this period.
September 27, 2019
FIRM Panel 41051C0356H — Zone X Maintained
Panel updated but Zone X designation maintained for this location. No SFHA designation at this address. No mandatory insurance requirement. Property disclosed as low-risk flood zone in any real estate transactions during this period.
March 17, 2024 — MAP CHANGE
FIRM Panel 41051C0356J — Zone AE · BFE 52 ft · Willow Creek Restudy
City of Portland adopted revised FIRM panels following a FEMA-funded restudy of the Willow Creek basin using updated LiDAR terrain data and revised hydraulic modeling. BFE of 52 feet NAVD88 established for the first time at this location. Property remapped from Zone X to Zone AE — mandatory insurance requirement now applies.
Remapping Context — Why This Happened

The 2024 remapping reflects updated hydrologic and hydraulic analysis of Willow Creek, not a physical change in flood conditions. LiDAR-derived terrain data used in the 2024 study provides meter-level resolution compared to contour-map based data used in prior studies. This revealed floodplain extents that were not captured in earlier mapping. The flood risk existed before 2024 — the map simply did not reflect it. Properties remapped under these conditions are prime candidates for LOMA analysis because the new BFE is based on the same terrain that the property occupies — and if the property's own elevation exceeds the BFE, the zone assignment may be removable.

EC Analysis — Key Findings
EC Date2023 (pre-remapping — EC predates the 2024 FIRM revision)
Lowest Adjacent Grade (LAG)52.4 feet NAVD88
Lowest Floor Elevation (LFE)55.1 feet NAVD88
BFE (new, 2024 FIRM)52.0 feet NAVD88
LAG vs. BFE+0.4 feet — LAG above BFE
LFE vs. BFE+3.1 feet — structure well above BFE
Foundation TypeElevated — pier/post construction
Critical Finding — LAG Exceeds BFE

The documented Lowest Adjacent Grade of 52.4 feet NAVD88 is 0.4 feet above the BFE of 52.0 feet. This is the defining criterion for LOMA eligibility. When the LAG meets or exceeds the BFE, the property may qualify for a Letter of Map Amendment (LOMA) removing it from the SFHA — eliminating the mandatory purchase requirement. A 0.4-foot margin is thin but positive, and the 2023 EC was performed by a licensed surveyor whose measurements would form the basis of a formal LOMA application. This finding is the most financially significant in this report.

+0.4 ft
LAG Above BFE — LOMA Criterion Met
$1,240
Estimated Current NFIP Annual Premium (with CRS 20%)
$0
Annual Premium if LOMA Granted (mandatory req. removed)
Insurance Analysis — Current Policy & EC Premium Impact
EC-Adjusted Premium — Favorable Rating

With LFE at BFE +3.1 feet and CRS 20% discount applied, the current NFIP premium for this property is estimated at approximately $1,240/year (before CRS discount: ~$1,550; after 20% CRS discount: ~$1,240). Without the EC, rating would default to estimated structural characteristics and potentially produce a higher premium. The EC documents a substantially favorable elevation profile that private market carriers can also use for competitive pricing.

Private vs. NFIP Comparison — EC Dependent

Private market carriers offer competitive rates for newly-mapped Zone AE properties with above-BFE elevation documentation. For a structure with LFE at BFE +3.1 feet, private market premiums would be estimated at $600–$900/year — potentially $340–$640 less than the CRS-discounted NFIP rate. However, the LOMA pathway (Level 3 analysis) may make this comparison moot if the mandatory requirement can be removed entirely.

LOMA Pathway — Level 3 Strongly Recommended
Key Recommendation

This property presents the strongest LOMA signal of the three properties in this report set. The combination of: newly-mapped zone (2024), LAG documented above BFE by 0.4 feet in a recent professional EC, LFE well above BFE, and elevated pier/post construction creates a scenario where a LOMA application has a reasonable probability of success. A successful LOMA would remove the mandatory purchase requirement entirely — eliminating the current $1,240+ annual insurance obligation (voluntary coverage would still be advisable). The Level 3 Comprehensive Review includes a formal LOMA pathway assessment, BFE relationship analysis, and referral guidance for a licensed engineer or surveyor to prepare the LOMA application.

This report is an informational analysis of publicly available flood mapping data and owner-provided EC documentation. LOMA pathway assessment is based on available EC data and is not a formal LOMA application or eligibility determination — a licensed engineer or land surveyor must prepare formal LOMA applications. Premium estimates are based on NFIP rate methodology and available EC data — actual premiums depend on full underwriting review. CRS discount data from FEMA CRS community file. Not a formal flood zone determination for lender compliance, legal advice, or insurance recommendation.