FEMA_Digital Flood Insurance Rate MapsTHE CITY OF Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Response to FEMA regarding Digital Flood Insurance Rate Map (DFIRM)
and Flood Insurance Study (FIS) Report for City of Dubuque
DATE: July 27, 2009
Planning Services Manager Laura Carstens recommends that the City of Dubuque
transmit objections to the preliminary Digital Flood Insurance Rate Map's proposed new
flood zones, and provide documentation to support the position that the DFIRM is not
using current data on flood mitigation.
Laura further recommends that a letter be sent requesting a revision of the DFIRM to
reflect the City's recent and planned flood hazard mitigation projects and that the City of
Dubuque file an appeal of the preliminary DFIRM's new flood zones in the 90-day
appeal period. This appeal will be supported by additional technical analysis prepared
by the City's Bee Branch consultant. Strand & Associates, on flood mitigation impact of
the City's completed and planned storm water management/flood mitigation
improvements.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Michael C. Van Milligen
MCVM:Iw
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
Laura Carstens, Planning Services Manager
TO: Michael Van Milligen, City Manager
FROM: Laura Carstens, Planning Services Manager
SUBJECT: Response to FEMA regarding Digital Flood Insurance Rate Map (DFIRM)
and Flood Insurance Study (FIS) Report for City of Dubuque
DATE: July 27, 2009
INTRODUCTION
This memorandum transmits a recommended response to the Federal Emergency
Management Agency (FEMA) regarding the new DFIRM and FIS report for the City of
Dubuque. Enclosed is a letter from FEMA regarding the DFIRM and FIS report review
process. A draft letter from Mayor Roy Buol to FEMA in response is enclosed.
Additional background materials also are enclosed.
BACKGROUND
On July 15t", the City of Dubuque received the preliminary DFIRM and FIS report as
part of FEMA's Flood Map Modernization Program. The program is designed to update
on a nationwide basis the flood insurance rate maps of member communities and
counties in the National Flood Insurance Program (NFIP). The program will result in a
seamless nationwide format, update the aging inventory of flood maps and provide
maps and data in digital format available through the Internet.
The City of Dubuque is a member of the NFIP. The City's current flood insurance rate
map is from 1989. The City of Dubuque has regulated floodplain development through
the Flood Hazard Overlay District in the City's Zoning District since 1990.
The enclosed cover letter from FEMA addressed to the Mayor outlines the DFIRM and
FIS report review process, the 30-day review period, a 90-day appeal period, and the
process for submitting comments. A flood hazard mapping fact sheet from FEMA is
also enclosed. It outlines what the NFIP is, what a flood insurance rate map is, and the
process that is to be followed for commenting and appealing proposed changes to the
flood insurance rate map. A second FEMA handout on community comments
supporting data and documentation also is enclosed.
Response to FEMA regarding DFIRM and FIS Report Page 2
The City has 30 days to review the submitted information to identify changes or
corrections to the DFIRM or FIS report, such as corporate limits, road names bridges
and stream labels.
Following the 30-day review period FEMA will initiate a statutory 90-day appeal period
for the new or modified Base Flood Elevations. The City will receive a letter
approximately 2 weeks prior to the start of the 90-day review period.
®ISCUSSION
Enclosed are two maps that indicate new areas proposed by FEMA as flood hazard
zones. Exhibit A depicts new flood zones for Zone A (no base flood elevations
determined) and zone AE (base flood elevations determined). These zones mark the
100-year flood plain. Exhibit B depicts new and existing flood zones. In addition to
Zones A and AE, this map shows the 500-year flood plain and Zone X. Zone X is
divided into areas outside the 500-year flood plain and areas protected by the levee.
Location of New Flood Zones
The new flood zones proposed by FEMA are the North End of Dubuque and portions of
Kaufmann Avenue and 32"d Street, the Keyway/Keystone area, a small portion at the
end of Edmore Lane north of Four Mounds, and along Catfish Creek near Nordstrom's.
Territories annexed to the city since the 1989 Flood Insurance Rate Map are shown as
new flood zones. These territories were designated as being in flood hazard areas
when they were in the County, and the new map reflects that same status with their
annexation to the city of Dubuque.
General Impact on Properties
The new DFIRM significantly expands the number of properties designated as being in
a flood plain in the city. There are approximately 70 structures in the current flood
zones. The proposed new zones would include approximately 1,806 properties, with an
estimated 1,741 structures over 500 square feet. In general, a property owner whose
property is designated as being in a flood plain is impacted in 3 ways:
1) Flood insurance will be required by a commercial lender if the property owner
refinances an existing structure or buys a structure in a flood plain. Flood
insurance for properties in a flood plain is higher than flood insurance for
properties outside a flood plain.
2) If an existing structure's floor area is expanded by 25% or more, the entire
structure may be required to be elevated or flood proofed. If the cost of an
improvement (new addition) or repairing the structure after a flood event exceeds
50% of the market value of the structure, the entire structure may be required to
be elevated or flood proofed. In zone A, where there are no base flood elevations
determined, the property owner must hire an engineer to determine the base
flood elevation in order to determine how high the existing structure must be
elevated.
Response to FEMA regarding DFIRM and FIS Report
Page 3
3) New structures must be designed to be elevated at least 1 foot above the 100-
yearflood plain. In zone A, where there are no base flood elevations determined,
the property owner must hire an engineer to determine the base flood elevation
in order to determine how high the new structure must be elevated.
Concerns with New Westside Flood Zones
City staff is concerned with the new Westside flood zones.
The new Zone A shown along the Catfish Creek west of Iowa Highway 32 (Northwest
Arterial) does not reflect a Flood Plain LOMR (Letter of Map Revision) filed by the City
after a bridge crossing was removed. City staff is researching the status of this LOMR
submittal, and will provide FEMA with this information.
The new flood zone A near Keyway Drive does not reflect recent storm water control
facilities installed by the City along this drainage area. City staff is compiling information
on these improvements, and will provide FEMA with this information.
Concerns with New North End Flood Zones
City staff is particularly concerned about the flood hazard areas shown on the north end
of Dubuque from 20t Street north to Aquin Street north of Flexsteel Industries and
portions of Kaufmann Avenue and 32~d Street. This area is the primary beneficiary of
the Bee Branch Creek Restoration Project. The Bee Branch Creek was converted into
a storm sewer system in the early 1900's.
The large area shown as a new flood zone A for the North End is based on the City's
drainage basin master plan for flooding related to the Bee Branch storm sewer. FEMA's
use of this drainage study to create the new zone A in the North End does not reflect
the most current information on flood mitigation.
The City's drainage study is a planning study; it is not a detailed study of what
structures would be impacted. It identifies a generalized area that appears to be at risk
from storm sewer backups or overflows. FEMA's preliminary DFIRM is thus, in City
staff's opinion, identifying a storm sewer problem rather than a flooding issue connected
with a flood plain along a stream or river.
City staff has been gathering additional data and information on planned drainage basin
improvements like the Bee Branch Creek Restoration Project as well as storm water
improvements such as the Carter Road dam and 32"d Street detention areas that
address existing storm water issues. This information will be provided to FEMA in an
effort to ensure that the new DFIRM accurately reflects the enhanced flooding mitigation
in these areas due to the City's recent and planned storm water control projects.
Two aerial maps are enclosed. Figure 1 shows the conditions at the time of the
drainage study, and Figure 2 shows projected flooding mitigation resulting from the new
Carter Road and West 32"d Street detention basins. Strand & Associates, the Bee
Response to FEMA regarding DFIRM and FIS Report Page 4
Branch project consultant, will prepare a similar aerial map and supporting analysis of
the expected flooding mitigation for the Bee Branch Creek Restoration Project.
30-Day Review Period
As part of FEMA's review process there is a 30-day review period for the City to
respond to non-technical information on the preliminary DFIRM and FIS Report. This
30-day review is from July 15 -August 14.
FEMA will be holding acounty-wide information meeting sometime in mid August. The
purpose of the meeting is to present and discuss the information presented on DFIRM
and the results of the FIS report, discuss the impact on the community's participation in
the NFIP, and provide an opportunity for comments and questions. `
Prior to the FEMA community meeting, the Planning Services Department will be
holding a local information meeting to review the preliminary DFIRM and answer
questions from property owners in the new flood zones proposed by FEMA. Our intent
is to have property owners better informed about the preliminary flood maps prior to the
FEMA meeting.
90-Day Appeal Period
Following the 30-day review period, FEMA will initiate a 90-day appeal period for new or
modified base flood elevations. City staff plans to submit technical analyses to support
the removal of the proposed new flood zones due to the City's completed and planned
storm water management/flood mitigation improvements.
REC®t~iVIEN®AT'I®N
City staff recommends that the City of Dubuque transmit our objections to the
preliminary DFIRM's proposed new flood zones, and provide documentation to support
our position that the DFIRM is not using current data on flood mitigation.
Enclosed is a draft letter from Mayor Buol to FEMA that will transmit additional
information that City staff is compiling for FEMA's review within the 30-day comment
period. The letter requests a revision of the DFIRM to reflect the City's recent and
planned flood hazard mitigation projects.
City staff further recommends that the City of Dubuque file an appeal of the preliminary
DFIRM's new flood zones in the 90-day appeal period. We recommend that this appeal
be supported by additional technical analysis prepared by the City's Bee Branch
consultant, Strand & Associates, on the flood mitigation impact of the City's completed
and planned storm water management/flood mitigation improvements.
Enclosures
cc: Gus Psihoyos, City Engineer
Deron Muehring, Civil Engineer II
Kyle L. Kritz, Associate Planner
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Region VII
9221 Ward Parkway, Suite 300
Kansas City, Missouri 64114-3372
The Honorable Roy Buol
Mayor, City of Dubuque
City Hall
50 West Thirteenth Street
Dubuque, Iowa 52001-4864
RE: Digital Flood Insurance Rate Map (DFIRM) and Flood Insurance Study (FIS) Report
for Dubuque County, Iowa and Incorporated Areas
Dear Mayor Buol,
The Department of Homeland Security's Federal Emergency Management Agency (FEMA) has produced
the DFIRM and FIS report in Countywide Format, showing the flood hazard information for the entire
geographic area of the county, including both incorporated and unincorporated areas. FEMA is providing
two copies of the above-referenced DFIRM and FIS report for your review and comment. Your
community has 30 days from the receipt of this letter to review the enclosed copies. The review period
provides your community with an opportunity to identify changes or corrections to non-technical
information presented on the DFIRM or in the FIS report, such as corporate limits, road names (within or
adjacent to the SFHAs), bridges, and stream labels. Comments or changes received during this 30-day
review period will be assessed and incorporated, as appropriate, before the DFIRM and FIS report
become effective. Comments should be sent to Watershed Concepts, 2405 Grand Boulevard, Suite 1000,
Kansas City, Missouri 641-08.
In preparing the countywide DFIRM and FIS report, Base Flood Elevations (BFEs) were created or
modified. Following the 30-day review period, FEMA will initiate a statutory 90-day appeal period for
the new or modified BFEs. You will receive a letter approximately two (2) weeks before the start of the
90-day appeal period detailing the appeal process. The letter will include a list of the BFEs to be
published in your local newspaper in a "Notice of Proposed Flood Elevation Determinations" and will
provide the first and second publication dates. The 90-day appeal period will start on the second
publication date. During the appeal period, community officials andlor, other interested parties may
submit technical information that would serve to refute the new or modified BFEs.
FEMA will contact you shortly to discuss the maps and schedule acounty/community coordination
meeting. The purpose of this meeting is to present the results of the study, discuss the information
presented on the DFIRM and FIS report, discuss the impact of the DFIRM and FIS report on your
community's participation in the National Flood Insurance Program (NFIP), and give your community a
chance to comment or ask questions regarding the DFIRM and FIS report and the NFIP in general. We
encourage you to circulate the enclosed copies among elected officials, staff, and other individuals or
organizations in your community who have an interest in the DFIRM and FIS report.
After the appeal period has ended and all appeals have been addressed, final preparation of the DFIRM
and FIS report will be initiated. The new Countywide DFIRM and FIS report for your community will
2
become effective approximately six (6) months later. Prior to the effective date, FEMA will contact your
community regarding the adoption of new floodplain ordinances or modification of existing ordinances as
necessary to reflect any changes in the DFIRM or FIS report. If you have any questions regarding
floodplain ordinances for your community, you may discuss those issues with your State NFIP
Coordinator, Bill Cappuccio, or you may raise them at the county/community coordination meeting.
Your community's comments on the Preliminary DFIRM panels and FIS report are an important part of
the review process, and will be considered carefully before final publication of the DFIRM and FIS
report. If you have additional questions or comments regarding the enclosed documents, please contact
Roger Benson, the Consultation Coordination Officer designated for your community at (816) 283-7031.
Sincerely,
Melissa Janssen, lief
Risk Analysis Branch
List of Enclosures:
DFIRM Index and panels
FIS report
Summary of Map Actions
Dubuque County Brochure
Community Comments -Supporting Data and Documentation
State Coordinators List
Vertical Datum Fact Sheet
cc: Bill Cappuccio, State NFIP Coordinator
Bob Schiesl, Community Floodplain Administrator
FEMA Region VII
9221 Ward Parkway
Kansas City, MO 64114
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Any community and/or individual property owner or lessee can appeal proposed new or
revised (referred herein as proposed) Base Flood Elevations (BFEs) or provide comments on
other flood risk information, such as the 1-percent annual chance floodplain boundaries
shown on preliminary Digital Flood Insurance Rate Maps (DFIRMs). Both appeals and
comments affecting flood risk information must be supported by technical or scientific data
and submitted to the appropriate community official within the designated 90-day appeal
period. Comments regarding non-flood hazard features on the maps, such as political
boundaries and road name corrections, can also be submitted.
When proposed BFEs are shown within a community on the preliminary DFIRM, the
community will be granted a statutory 90-day appeal period. If the BFEs were published
previously on a FEMA map or via a Letter of Map Revision (LOMR) and the BFEs did not
change, the community will not be granted an appeal period. Following release of the
preliminary map, the community will receive a 30-day comment period. Comments may
also be submitted during the 90-day appeal period. With the release of the preliminary maps,
community officials will receive a transmittal letter from FEMA specifically referencing the
90-day appeal period and/or the 30-day comment period.
This document provides guidance for developing the technical and/or scientific data to
support community comments.
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Community comments generated during the 30-day comment period or the 90-day appeal
period (if applicable) should be submitted to the Chief Executive Officer (CEO) of the
community or a community official designated by the CEO. Comments should not be
submitted directly to FEMA by individual property owners, but should be submitted to the
CEO or community designated official. Upon receipt of comments from individual property
owners, the CEO or designated community official should review the comments and state
whether community officials support the request. The CEO or community official should
forward all comments to the location identified in the transmittal letter or the Flood Hazard
Mapping Fact Sheet.
Community Comments: Supporting Data and Documentation
Community comments generally involve changes to items such as floodplain boundary
delineations, corporate limits, and/or road names and configurations. The types of
community comments and the data and documentation that must be submitted to support
them are discussed below. The data and documentation must prove that the preliminary
DFIRM and/or Flood Insurance Study (FIS) report data are incorrect.
~hang~~ ~®~i®®dplain ~®unda~ie~ f®~ i'i®®ding ~®u~c~~ studied by ®~~ail~d
Meth®d~
When BFEs are shown on the preliminary DFIRM, this signifies a flooding source has been
studied by detailed methods.
The detailed floodplain boundaries were delineated using topographic maps and the BFEs
that resulted from the hydraulic analyses performed by FEMA. If topographic maps or other
ground elevation data with greater detail or that show more recent topographic conditions are
submitted in support of a community comment, FEMA may use the submitted
maps and/or data to revise the floodplain boundary delineations shown on the affected map
panel(s). Topographic/terrain data must be referenced to a standard coordinate system,
employ a standard projection, and specify both the horizontal and the vertical datums used.
All planimetric and topographic features must be collected and referenced to this coordinate
system and projection. Refer to Section L-2 of Appendix L in FEMA's Guidelines and
Specifications for Flood Hazard Mapping Part~Zers (G&S). These data can be contained in a
single file or in a tiled set of files. Any tiled data must have an accompanying index spatial
file. The G&S can be viewed on the FEMA website at
http•/Iwww fema Gov/plai~/prevent/flrn~/gs main.shtm.
Any proposed floodplain delineations must be submitted with more detailed or revised
topographic information. In addition, all data must be based on the preliminary map datum.
~hange~ ~®~i~®dplain ~®unda~ie~ f®r ~!®®ding ~®urce~ studied by Apps®~i~ate
Vieth®d~
When BFEs are not shown on the preliminary DFIRM, this signifies a flooding source has
been studied by approximate methods.
Approximate floodplain boundaries are delineated using the best available data, including
information about past floods, U.S. Geological Survey (USGS) Stream gage records, and
simplified hydrologic and hydraulic analyses. The analyses are based on methods developed
by the USGS and the U.S. Army Corps of Engineers (USAGE). Where an FIS report has
been prepared, the report may contain additional details about the approximate analysis.
If more detailed data or analyses are submitted in support of a community comment, FEMA
may use the submitted data or analyses to revise the floodplain boundary delineations shown
on the affected map panel(s). Such data and analyses would include the following:
o Published flood maps that are more recent or more detailed than those used by
FEMA, such as flood studies performed by other Federal agencies;
2
Community Comments: Supporting Data and Documentation
o Analyses that are more detailed or that are based on better data than those used by
FEMA, such as analyses prepared by local communities for stream improvement or
bridge replacement projects; and/or
o Terrain/topographic data and revised floodplain delineations as described in the
previous section.
NOTE: While more detailed data or analyses may be submitted to support a community
comment regarding floodplain delineations, detailed studies to establish BFEs must be
submitted through the LOMR process. The LOMR process is outlined in Section 2.4.6 of
Volume 2: Map Revisions and Amendments, of the G&S, located at the above-referenced
website.
Changes ~® ~®rp®rat~ ~imi~~
The corporate limits shown on the preliminary flood maps were obtained from the best
available sources at the time the map was prepared, and may not represent the current limits.
If changes to the corporate limits shown on the preliminary snaps are necessary, a community
must submit an up-to-date community map, such as a geo-referenced tax or plat map, and/or
annexation ordinances, to support the community comment. FEMA may use the submitted
map to revise the corporate limits shown on the affected map panel(s). If the submitted data
is not used, FEMA will explain to local officials, in writing, why no changes could be made.
Chang~~ ~® ~®ad ~4ann~~ and ~®n~igura~i®n~
An aerial photo is typically used as a base map. The roads and other features present at the
time the photo was made are visible on the preliminary map. Roads located in or adjacent to
the 1-percent-annual-chance floodplain are labeled. If corrections are needed, community
officials must provide a map showing the updated information to support a community
comment concerning the names of roads in or adjacent to floodplains. Digital files are
preferred, but as an alternative community officials may submit amarked-up copy of the
preliminary DFIRM that clearly identifies road name changes.
C~rti~ica~i®n ~equirern~n~~ ~®r ~~chnical Cupp®r$ ®a~a and ®®cum~n~a~i®n ~®r
~®mrnunit~ C®mmen$~ .
All maps, except community maps showing corporate limits and roads, and other submitted
supporting data, must be certified by a Registered Professional Engineer or a Licensed Land
Surveyor and must reflect existing conditions. Maps prepared by an authoritative source,
such as a Federal agency - e.g., the USACE or USGS, - or a State department of highways
or transportation, are acceptable without certifications as long as the sources and dates of the
maps are identified.
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When developing technical support data or documentation, commenters should consider the
information below:
Community Comments: Supporting Data and Docunzentatio~z
o New flooding information cannot be added to a map panel in such a way that creates
mismatches with the flooding information shown for adjacent map panels. Therefore,
in performing new analyses and developing revised flooding information,
commenters must tie floodplain boundaries into those shown on the map panel(s) for
areas that are not affected by the community comment.
o Community comments cannot be based on the effects of proposed projects or future
conditions.
o Grading plans or topographic maps that reflect existing conditions may be submitted
to support a floodplain boundary change as long as the plan meets the certification
and other requirements stated herein. Digital files are preferred. Non-digital data
may be submitted, but may not be incorporated.
o Topographic survey data may be submitted to support a floodplain boundary change
as long as the data meets the certification and other requirements stated herein.
o Certified "as-built" plans may be submitted to support a floodplain boundary change
as long as the data meets the certification and other requirements stated herein.
o Elevation Certificates, which are used to provide building elevation information to
ensure compliance with community floodplain management ordinances, should be
submitted via FEMA's Letter of Map Amendment process rather than as supporting
documentation to a floodplain boundary change. Because the size of a building is
generally small in relation to the size of a floodplain, a change to the floodplain
cannot usually be shown on the revised DFIRM panel when a building is removed
from the floodplain because of scale limitations. The largest scale of a DFIRM panel
is 1"= 500.'
o If community comments involve changing the floodplain boundaries shown on the
preliminary map, the commenter may submit revised delineations of both the 1-and
0.2-percent-annual-chance floodplain boundaries if those delineations are shown on
the preliminary map.
o If FEMA included analyses of only the 1-percent-annual-chance flood for the
flooding source that is the subject of a community comment, then the commenter
must submit only the 1-percent-annual-chance floodplain boundary delineations in
support of the community comment.
4'
August 4, 2009
Roger Benson
Consultant Coordination Officer
FEMA Region 7
9221 Ward Parkway Suite 300
Kansas City MO 64114
Dear Mr. Benson:
Please find attached to this letter information related to changes the City of Dubuque
would like to see incorporated into the preliminary Digital Flood Insurance Rate Maps
(DFIRM) for the city of Dubuque.
The City of Dubuque is very supportive of the map modernization program that FEMA
has undertaken. We hope that the following information will -aid in the creation of a
DFIRM that will accurately reflect the flooding potential within the city of Dubuque.
Requested changes:
1. The cover letter from FEMA indicated under the carbon copy list that Bob
Schiesl was the community flood plain administrator. This is incorrect.
Laura Carstens is the community flood plain administrator.
2. The corporate boundaries of Dubuque shown on the preliminary DFIRM
map do not reflect several recent annexations. The current city corporate
boundaries are included in a digital format.
3. The new Zone A shown along the Catfish Creek west of Iowa Highway 32
(Northwest Arterial) does not reflect a LOMR (Letter of Map Revision) filed
by the City after a bridge crossing was removed. City staff is researching
the status of this LOMR submittal, and will provide you with this
information.
4. The new flood zone A near Keyway Drive does not reflect recent storm
water control facilities installed by the City along this drainage area. City
staff is compiling information on these improvements, and will provide
FEMA with this information.