An EC only indicates that a house at a specific elevation lies above(or below) a "given"(established) BFE . . . not some idea or concept of what a BFE might/should be. Basically no BFE means NO BFE and no way of indicating a comparison of flood elevations and house elevations.
I don't have my EC form in my face at the moment, but without an established BFE, the surveyor's portion of the EC is not to be filled in. Rather, I believe the form indicates that the owner's portion needs to be filled in.
In essense, if this is correct, a surveyor cannot complete and certify an elevation certification without an established BFE, regardless of how absolute the degree of incorrectness the map might show. In other words, it's not possible to show a house is above something that doesn't exist(such as a BFE). And when the lines indicating the limits of flood pass through the house(even though they shouldn't have), I don't have the liberty to "move" that erroneous line to a place that makes more sense.
Instead, I have instead made a document(for the bank that's requiring insurance) that indicates the facts that exist on the property(a document that the flood plain administrator agrees is my only option). This document shows the flood limits(as marked) and shows that the house is almost 20 feet above a road which lies UPSTREAM and is very much out of the 100-year(and 500-year) flood limits.
The problem here is that without a BFE(or eligibility to use a simple method to determine one), I'm not qualified or authorized to indicate, "by the numbers", that the house sits 1, 2, 10 or 20 feet above the floodable area., unless my client would want to sink another $2k(NON-refundable) or so into a detailed study to show what a lobotamized monkey would already know.
As I see it(again the flood-plain administrator agrees), the use of a LOMA is also not in order without an established BFE.
So again, I ask . . . without an established BFE, what options exist?