Interpretation #9065

Published February 28, 2025

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Original Request

Code Version
2023
Code
EXTBLDG
Code Description
Chapter
2
Section
202
Topic
Substantial Improvement

Question

Can the statement "...50% of the market value of the structure..." be interpreted as the replacement value of the structure?

Answer Published 02/06/2025 at 8:21 AM

FEMA P-758 is the desk reference that provides the NFIP language. See the Preface in this publication. This is a guide. The language in the Local jurisdiction Floodplain Requirements should contain specific methods of determination of SI/SD.

The value of the structure is based on the structure market value without the land; which is determined by either, the listed property appraisers value or a licensed appraiser that can determine the legal market value. The replacement value is not the same. The simple answer is No.

Commentary

None.