Federal Emergency Management Agency_New Flood Area Maps DIFRMMasterpiece on the Mississippi
TO:
FROM:
SUBJECT:
DATE:
The Honorable Mayor and City Council Members
Michael C. Van Milligen, City Manager
Request to FEMA to change Flood Insurance Rate map
January 14, 2010
Planning Services Manager Laura Carstens is recommending approval of the issues
related to the Federal Emergency Management Agency new flood area maps.
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
Molly Grover, President & CEO Dubuque Chamber of Commerce
Rick Dickinson, Executive Director & Chief Operating Officer
Greater Dubuque Development Corporation
Dan LoBianco, Executive Director Dubuque Main Street
Teri Goodmann, Assistant City Manager
Laura Carstens, Planning Services Manager
Gus Psihoyos, City Engineer
Don Vogt, Public Works Director
Deron Muehring, Civil Engineer
Dubuque
had
all- America city
2007
Masterpiece on the Mississippi
TO:
FROM:
SUBJECT:
DATE:
Michael Van Milligen, City Manager
Laura Carstens, Planning Services Manager 145C-
Request to FEMA to change Flood Insurance Rate Map
January 13, 2010
Dubuque
Al- Amelca City
I r
2007
The City of Dubuque has repeatedly requested that the Federal Emergency
Management Agency (FEMA) remove new flood areas previously not designated from
the preliminary DFIRM (Digital Flood Insurance Rate Map).
Without the use of standard engineering computer models, FEMA has proposed a
DFIRM that would significantly expand the number of properties in the city designated
as being in a regulated flood plain from 70 structures to over 1,700 structures! Adoption
of the proposed DFIRM would place a heavy financial burden on approximately 1,000
low to moderate income households and approximately 120 local businesses and
industries resulting in neighborhood disinvestment and decline.
Planning Services staff has revised the enclosed talking points for Federal
Legislators. The talking points have been revised to reflect the latest map from FEMA,
which reduces the North End impact somewhat but adds Kerper Boulevard sites like the
old Pack site, the City Public Works facility, and Eagle Window & Door. Properties along
Peru Road, Kaufmann Avenue and Keyway /Keymeer continue to be affected.
Senators Harkin and Grassley want to send letters to FEMA that outline issues related
to North End flood plain designation, etc. The talking points provide that information.
Assistant City Manager Teri Goodmann has requested this information to take
advantage of the DC trip and perhaps meet with FEMA officials. I recommend that the
City Council approve the submittal of the revised talking points to our federal Legislators
to expedite resolution of this issue with FEMA.
Attachments
cc: Cindy Steinhauser, Assistant City Manager
Teri Goodmann, Assistant City Manager
Request to FEMA to change the City of Dubuque's preliminary DFIRM
(Digital Flood Insurance Rate Map)
Introduction
The City of Dubuque is requesting that the Federal Emergency Management Agency (FEMA)
remove new flood areas previously not designated from the preliminary DFIRM (Digital Flood
Insurance Rate Map). Without the use of standard engineering computer models, FEMA has
proposed a DFIRM that would significantly expand the number of properties in the city
designated as being in a regulated flood plain from 70 structures to over 1,700
structures! Adoption of the proposed DFIRM would place a heavy financial burden on
approximately 1,000 low to moderate income households and approximately 120 local
businesses and industries resulting in neighborhood disinvestment and decline.
Background
On July 15, 2009, the City of Dubuque received the preliminary DFIRM and the FIS (Flood
Insurance Study) 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 City of Dubuque was the first community in Iowa to join the NFIP on April 2, 1971. The
City's current flood insurance rate map is from 1989. The City has regulated floodplain
development since 1990. The City of Dubuque has been very conscientious in its application of
the NFIP requirements. The City has never approved a variance from the NFIP requirements.
The City has not allowed a single new residential structure to be built in any flood hazard area.
The only new structures built in flood hazard areas have been commercial structures elevated
and /or flood proofed in compliance with the NFIP requirements.
Discussion
Enclosed is a map that indicates new flood zones for Zone A (no base flood elevations
determined) and Zone AE (base flood elevations determined) proposed by FEMA. These zones
mark the 100 -year flood plain. In addition, this map shows the 500 -year flood plain and Zone X.
Zone X is areas outside the 500 -year flood plain and areas protected by the City's floodwall.
General Impact on Properties
The most significant impact of having a property in a flood plain is that new construction, new
additions and even the existing structures may have to be elevated or flood proofed as part of
any substantial improvement to a property. In Zone A, base flood elevations (BFEs) haven't
been determined, so the property owner first must hire an engineer to determine the BFEs in
order to determine how high an addition or a new structure must be elevated.
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. For example, flood
insurance for a single family home with a value of $75,000 and contents valued at $30,000
would cost about $260 annually outside a flood area. This insurance rises to about $844
annually for the same home in a designated flood area — and this assumes a $2,000 deductible
for both home and contents!
Concerns with New North End Flood Zones
We are concerned with all of the new Zone A areas on the DFIRM. We are particularly
concerned about the new Zone A in the North End. The North End includes some of the city's
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Request to FEMA to change the City of Dubuque's preliminary DFIRM
(Digital Flood Insurance Rate Map)
oldest housing (dating from the late 1800's) and long- standing businesses and industries. These
neighborhoods have a higher percentage of low to moderate households and racial and ethnic
minorities than the city as a whole.
The City has focused reinvestment efforts in these neighborhoods, and installed upstream storm
water management facilities to alleviate problems with the storm water system. Delineation of
these neighborhoods as a Zone A flood hazard area will reverse the progress we've made. The
Zone A designation will result in neighborhood disinvestment and blighting conditions.
Placing this burden on 1,400 property owners in the new Zone A areas is unacceptable.
Inaccuracies of Preliminary DFIRM
The inaccuracies that City staff found in the preliminary DFIRM maps will make it difficult to
enforce NFIP requirements in areas newly designated as a flood hazard. The preliminary
DFIRM shows flooding heights on Kaufmann Avenue such that vehicles would be submerged,
when the 100+ year history that shows no such flooding had ever occurred. The parking lot for
the Julien Dubuque Monument on top of a bluff is designated as being in a flood plain. The
flood plain along Peru Road stops before reaching the Couler Valley. These egregious errors
will make citizens question the validity of the new maps, and rightly so.
The City of Dubuque cannot stress enough the far reaching negative impacts to the North End
and other areas newly designated as Zone A will have. If this area had a history of flood
damage, the City would not question its designation as a special flood hazard area; however,
the written record of over 100 years does not support such a designation.
Inadequate Study
The large Zone A for the North End and Kerper Boulevard area reflects the City's Drainage
Basin Master Plan findings on flooding related to the Bee Branch storm sewer. The City's
Drainage Basin Master Plan was intended to address storm sewer conveyance problems — not
flooding associated with a creek or river. These types of urban storm water problems are
common throughout the U.S. The history of localized street flooding and basement flooding
experienced in the North End does not rise to the level of being designated as a regulatory flood
plain, and there is no historical flooding in the Kerper Boulevard area with construction of the
floodwall and levee system along the Mississippi River.
The City's Drainage Basin Master Plan is a planning study; it did not detail precisely which
structures would be impacted. It identifies a generalized area that appears to be at risk from
storm sewer backups or overflows. We believe that FEMA is identifying a storm sewer problem
rather than a flooding issue connected with a flood plain along a stream or river.
City staff provided FEMA with 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 Street detention areas that address existing storm water issues.
City staff held a conference call with FEMA staff and their engineering consultants on October
22, 2009. FEMA staff acknowledged they did not use a standard model for the new Zone A
areas. They discussed that FEMA was using new modeling, and it was not done to an
engineering standard that would enable BFEs to be published. FEMA has limited funding to do
an engineering study that would determine BFEs.
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Request to FEMA to change the City of Dubuque's preliminary DFIRM
(Digital Flood Insurance Rate Map)
We hoped this information would help remove properties from the flood plain. Unfortunately, it
appears that FEMA will map new Zone A areas without adequate study.
If FEMA does not have the funding to do an engineering study correctly, using sufficiently
sophisticated models to produce BFEs, then no new flood areas should be mapped. The
burden of determining the base flood elevations (BFEs) must rest with FEMA, not the
citizens of Dubuque. The City of Dubuque requests that FEMA eliminate all new Zone A areas
not previously designated. In the alternative, the City of Dubuque requests that FEMA show all
new Zone A areas with BFEs determined, so that they are converted to Zone AE areas on the
DFIRM — if in fact these even are special flood hazard areas.
The shallow flooding experienced in the new Zone A areas on the preliminary DFIRM is due to
local drainage problems with the capacity of the City's storm sewer system. These areas do not
rise to the level of a regulatory flood plain, and should not be mapped as Zone A by FEMA.
Increasing Dubuque's inventory of structures in the flood plain from 70 to over 1,700
through non - standard mapping would be a mistake as it would place a heavy financial
burden on approximately 1,000 low to moderate income households and over 120 local
businesses resulting in neighborhood disinvestment and decline.
Requested Action
Because of the significant impact the preliminary DFIRM will have on property owners in the
City of Dubuque and the inadequate data used by FEMA's consultant to establish new "A"
zones, the City of Dubuque's position is as follows:
1. No new "A" zones should be depicted on the City's DFIRM except for "A" zones in areas
annexed into the City.
2. Information supplied to FEMA regarding the City's Dubuque Industrial Center West
(December 21, 2009) should be incorporated into a revised preliminary DFIRM.
3. The changes depicted along the Mississippi River are acceptable as they are based on
the Corps of Engineers "Upper Mississippi River System Flow Frequency Study."
The City of Dubuque is extremely concerned that adoption of the latest preliminary DFIRM
supplied by FEMA will cause significant harm to the credibility and enforcement of the National
Flood Insurance Program and cause disinvestment and decline in areas of the City that have
over 100 -year history that does not support designation as a flood plain.
If you have questions or need additional information, please contact Laura Carstens,
Community Flood Plain Administrator at 563.589.4210 or Icarsten(cityofdubuque.orq.
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Legend
New Flood Zones
A - No Base Flood Elevations Determined
AE - Base Flood Elevations Determined