FEMA Compliance for LOMR-F, Loading Dock below BFE

[Andy_]

We are looking to obtain a LOMR-F for a structure with a loading dock with elevation below the BFE (this would put the lowest adjacent grade for the structure below the BFE). I know that there is provision for such areas when applying for a LOMA/LOMR-F, assuming you have natural intervening high ground protecting the area from flooding (as described in this FEMA guidance document, pgs 46-49: https://www.fema.gov/sites/default/files/documents/mt-1_technical_guidance_dec_2020.pdf). However, for our development, while there will be intervening high ground protecting the loading dock, the intervening high ground will not be "natural" - it will be raised above the BFE with fill. There is no enclosed portion of the building on the other side of the loading dock wall where the LAG is below the BFE (there's no basement).

I know an option that is often used in such situations is a portion of the property is filled above the BFE, a LOMR-F is obtained for the portion of the property, and then construction (including excavation) is commenced after the LOMR-F is obtained.

My question is, is there another option for obtaining a LOMR-F for this building / property (assuming the location of the loading dock is fixed)? As I mentioned above, there's nothing on the other side of wall at the loading dock; the area will have drains and can be floodproofed with other measures if necessary to satisfy FEMA for purposes of the LOMR-F.

Thanks ~

Andrew