The elevation certificate: who signs it and why it is required

It is FEMA’s current form — FF-206-FY-22-152 — documenting the elevations of a structure and the surrounding ground, to compare them with the base flood level of the regulatory flood maps adopted by the Planning Board. The Board is FEMA’s State Coordinating Agency for flood insurance in Puerto Rico, by virtue of Act No. 3 of 27 September 1961, Act No. 75 of 24 June 1975 and Act No. 38 of 30 June 2017, and under Title 44 of the Code of Federal Regulations, Section 60.3 (d and e).

It applies to anyone building, extending or improving a structure located in a regulatory flood zone: presenting the certificate is mandatory for the evaluation and approval of that construction permit. Whoever certifies it is not the owner: Section D may only be signed by a licensed surveyor or a professional authorised to practise surveying in Puerto Rico. The guidelines are also addressed to municipal permit offices, participating communities, planning consortia and the Permit Management Office.

• That Section D be signed and certified by a licensed surveyor or a professional authorised to practise surveying in Puerto Rico, with licence number, seal, signature, date, telephone and email.Verified against the official source
• Completing the certificate using the Flood Insurance Study (FIS) and the Board’s regulatory flood maps (FIRM) in force at the time of certification.Verified against the official source
• Recording in the Section D comments the ABFE map information under Resolution JP-ABFE-02 of 3 October 2018, with its effective date and the flood zone.Verified against the official source
• Accompanying each certificate with evidence of stamp cancellation, traditional or through the Special Digital Stamp (EDE).Verified against the official source

• At least two — and where possible four — colour photographs of each side of the structure, at least 3"x3", taken within 90 days of the certification date, showing the whole structure including the foundation.
• The property’s cadastre number per the Municipal Revenue Collection Center or as it appears in the deed, for box A3.
• The owner’s authorisation letter, where Section F is completed by an authorised representative.
• If FEMA has issued a LOMA, LOMR-F or LOMR, the date of the letter and the case number, for the Section D or G comments.

1. 1

   Step 1: What it is really for

   The certificate was born with an insurance purpose: adjusting the flood policy rate. The Planning Board adopted it through the Special Flood Hazard Areas Regulation and gave it a second use, the one that shows up in permits: comparing the elevations of the structure and the ground with the base flood level of the regulatory maps, to determine compliance with the rules for areas subject to flood regulation. That is why the same sheet can be requested by your insurer and your permit office for different reasons.

2. 2

   Step 2: The sentence that decides whether the permit moves

   The guidelines say it without hedging: presenting this certificate is mandatory for the evaluation and approval of a construction permit locating the structure in a regulatory flood zone. It is not a supporting document or an optional annex. If your lot is in a regulatory zone, the certificate is part of the file.

3. 3

   Step 3: Who signs what

   The form is split between three hands. Section D — information of the certified surveyor, engineer or architect — may only be signed by a licensed surveyor or a professional authorised to practise surveying in Puerto Rico, with their licence number, seal, signature, date, telephone and email. Section F is the certification of the property owner or their authorised representative, and does not require a surveyor where one has already certified Section D. Section G, the community information, is recommended to be completed and signed by the municipal permit office, OGPe or the participating community; for Community Rating System purposes completing it is compulsory.

4. 4

   Step 4: Sections A and B: property and map

   Section A identifies the property. The address in A2 is the structure’s physical one: the guidelines declare invalid the owner’s address where they do not live there, the tenant’s, and the postal or physical address of the proponent, developer or surveyor. A3 takes the cadastre number. A5 takes the coordinates, using the Lambert Conformal Conic Projection and NAD 83, at least six decimals, preferably referenced to the front of the structure or the water utility meter. A7 selects the structure diagram that best represents it. Section B is completed with the FIS and the FIRM panel in force at the time of certification, available on the Board’s site or FEMA’s portal.

5. 5

   Step 5: The ABFE maps go in the comments

   This is the detail that gets forgotten and sends files back. Puerto Rico also uses the Recommended Base Flood Elevation maps adopted by the Board on 18 April 2018, after Irma and María, considered the best available information. The guidelines ask that this information be included in the Section D comments space, and even suggest the wording: "Under the ABFE maps effective 13 April 2018, the lot is in zone ____ with a base flood elevation or base flood depth of ____." The guidelines write the map adoption date and the effective date they suggest for the note with different days, 18 and 13 April; we reproduce both as they appear and do not choose between them.

6. 6

   Step 6: The photographs and their ninety days

   The owner or their authorised representative must provide at least two photographs, and where possible four, showing each side of the structure, taken within 90 days of the certification date. They must be in colour, at least 3"x3", and show the whole structure including the foundation. Digital is accepted. The caption states whether it is front, right side, left side, rear, openings or floodproofing, and the date taken. If there is no structure yet because it is new construction, photos of the lot and of the plan page the elevation was taken from go instead.

7. 7

   Step 7: Under construction and finished construction

   In Section E you must state whether the elevations are based on construction drawings, a building under construction, or finished construction. If you pick either of the first two, an elevation certificate will be required again once construction is complete. The finished-construction option is chosen only when all equipment and machinery — boilers, water heaters, heat pumps, air conditioners, elevators and their equipment — are installed and the grading around the building is fully complete. That is: a certificate taken during the works does not close the matter.

8. 8

   Step 8: What Section C does not do

   The guidelines clarify this so nobody confuses documenting with complying: Section C records the elevation of several components of the structure, but does not determine the elevation of the building’s lowest floor nor verify whether the building as built complies with the flood-zone rules in force. That is why the responsibility for completing boxes G5 to G11 and documenting that data falls on the permit offices. A well-filled certificate does not amount to a compliance determination.

9. 9

   Step 9: The stamps

   The Board asks that each certificate come with evidence of stamp cancellation, whether through the traditional stamp or the Special Digital Stamp. The EDE is available as a substitute for the traditional one exclusively for work by professionals whose role is not that of a designer certifying plans for construction projects, and is designed to be combined with the digital signature.

The certificate is submitted with the permit file to the municipal permit office, OGPe or the participating community, as applicable. For questions on the document the guidelines give a contact: Puerto Rico Planning Board, Geology and Hydrogeology Division, comentariosjp@jp.pr.gov, telephone 787-723-6200, extensions 16701 and 16006. Whoever prepares it is a private surveyor; the Board does not issue or process it for you.

• Believing the certificate is only for insurance: it is mandatory to approve the permit in a regulatory flood zone.
• Putting the owner’s or proponent’s mailing address in A2 rather than the structure’s physical address.
• Leaving boxes blank instead of writing "N/A" and explaining the reason in the comments.
• Using photographs taken more than ninety days ago or that do not show the foundation.
• Forgetting the ABFE map note in the Section D comments.
• Stopping at the certificate taken from drawings: it must be repeated once construction is finished.
• Thinking the owner can sign Section D: only a licensed surveyor or professional authorised to practise surveying signs it.
• Submitting it without evidence of stamp cancellation.

These are the government pages this guide is based on.

• Junta de Planificación de Puerto Rico (JP)

  Junta de Planificación

  portaldeinundacion.jp.pr.gov

• Planning Board Flood Portal

  jp

  portaldeinundacion.jp.pr.gov

• Elevation Certificate form FF-206-FY-22-152, as published by the Flood Portal

  jp

  portaldeinundacion.jp.pr.gov