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Federal Emergency Management Agency (FEMA_DIFRM)Masterpiece on the Mississippi TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: Response to 12/30/09 FEMA Letter on Flood Insurance Rate Map DATE: January 26, 2010 Dubuque An- America City I 2007 Planning Services Manager Laura Carstens requests City Council approval a proposed response letter to the December 30, 2009 Federal Emergency Management Agency (FEMA) letter transmitting FEMA's revised preliminary Digital Flood Insurance Rate Map (DFIRM). The City of Dubuque has repeatedly requested that FEMA remove new Zone A areas, determined by approximate methods and previously not designated, from the preliminary DFIRM. All the changes requested by the City's previous correspondence for the preliminary DFIRM have not been made. City staff has concerns with the revised preliminary DFIRM as well, due to new inaccuracies. I concur with the recommendation and respectfully request Mayor and City Council approval. MCVM:jh Attachment cc: Barry Lindahl, City Attorney Cindy Steinhauser, Assistant City Manager Laura Carstens, Planning Services Manager Michael C. Van Milligen TO: FROM: SUBJECT: DATE: Masterpiece on the Mississippi Dubuque bta Ma MOM 1 11 2007 Michael Van Milligen, City Manager Laura Carstens, Planning Services Manager P Response to 12/30/09 FEMA Letter on Flood Insurance Rate Map January 26, 2010 Introduction This memorandum transmits the recommended City response to the enclosed December 30, 2009 Federal Emergency Management Agency (FEMA) letter received by the City of Dubuque on January 4, 2010 transmitting FEMA's revised preliminary DFIRM (Digital Flood Insurance Rate Map). Discussion The City of Dubuque has repeatedly requested that the FEMA remove new Zone A areas, determined by approximate methods and previously not designated, from the preliminary DFIRM. All the changes requested in the City's previous correspondence for the preliminary DFIRM have not been made. City staff has concerns with the revised preliminary DFIRM as well, due to new inaccuracies. These are highlighted in the Mayor's letter to FEMA. City staff held a conference call on January 21, 2010 with FEMA staff to share our concerns. We learned that the FEMA public meeting on the DFIRMs is set for 6:30 p.m. on February 23, 2010 at the Dubuque County Fairgrounds. City staff is continuing to review the preliminary and revised DFIRMs for inaccuracies and issues. We plan to hold a series of informational meetings for affected property owners on February 9, 2010 to help them to prepare for the FEMA public meeting. Requested Action The requested action is for the City Council to review and approve the enclosed response to FEMA re: the revised preliminary DFIRM. Enclosures cc: Cindy Steinhauser, Assistant City Manager Teri Goodmann, Assistant City Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer Kyle Kritz, Associate Planner The Honorable Roy Buol Mayor, City of Dubuque City Hall 50 West Thirteenth Street Dubuque, Iowa 52001 -4864 NATIONAL FLOOD INSURANCE PROGRAM FEMA NATIONAL SERVICE PROVIDER Region VII 9221 Ward Parkway, Suite 300 Kansas City, Missouri 64114 -3372 December 30, 2009 JAN - 4 pp PLANNING CITY SERVICES DEPARTMENT RE: Revised Preliminary Digital Flood Insurance Rate Map (DFIRM) for City of Dubuque, Dubuque County, Iowa. Dear Mayor Buol, On July 13, 2009 we provided your community with two copies of the Preliminary Digital Flood Insurance Rate Map ( DFIRM) and Flood Insurance Study (FIS) report for the City of Dubuque, Dubuque County, Iowa. The DFIRM and FIS report were prepared in countywide format, which means that flood hazard information for the entire geographic area of the community was presented. The preliminary DFIRM panels have been revised to reflect the following changes: In a letter dated August 04, 2009, you identified panels where the new Zone A flooding does not properly reflect the recent storm water control facilities, or the Bee Branch Creek Restoration Project installed by the City. Based on your comments and the data you provided on October 7, 2009, the floodplain boundaries have been redelineated on DFIRM panels 237, 241, 243, and 244. We are providing two copies of the above - referenced Revised Preliminary DFIRM's for your review and comment. These four panels supersede the respective Preliminary panels dated July 13, 2009. 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 AECOM, 2405 Grand Boulevard, Suite 1000, Kansas City, Missouri 64108. FEMA will contact you shortly to discuss the maps and schedule a county /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 2 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. Your community's comments on the Revised Preliminary DFIRM panels 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. List of Enclosures: DFIRM Sincerely, cc: Mr. Bill Cappuccio, State NFIP Coordinator Laura Carstens, Community Floodplain Administrator Ms. Melissa Janssen, Chief Risk Analysis Branch S&I Masterpiece on the Mississippi Melissa Janssen, Chief Risk Analysis Branch FEMA Region VII 9221 Ward Parkway Ste 300 Kansas City MO 64114 Dear Ms. Janssen: Dubuque ANImedca i I I 2007 Office of the Mayor & City Council City Hall 50 West 13 Street Dubuque, IA 52001 -4864 www.cityofdubuque.org February 2, 2010 This letter is in response to your December 30, 2009 letter received by the City of Dubuque on January 4, 2010 transmitting the revised preliminary DFIRM (Digital Flood Insurance Rate Map) for the City of Dubuque. The City of Dubuque has repeatedly requested that FEMA remove new Zone A areas, determined by approximate methods and previously not designated, from the preliminary DFIRM. This revised preliminary DFIRM does not respond to the City's requests. Enclosed for your consideration are a set of talking points with respect to the City of Dubuque's concerns with FEMA's DFIRM for our community. The enclosed letter dated August 4, 2009 to Roger Benson of FEMA Region VII Consultant Coordination Officer, is acknowledged in your letter of December 30, 2009. Letters dated September 9, 2009, September 22, 2009, and December 21, 2009 to Rick Nusz, FEMA Region VII Hydraulic Engineer, however, are not acknowledged in your December 30, 2009 letter. Copies of these letters are enclosed for your consideration and a response. The enclosures referred to in these letters were provided to Mr. Benson and Mr. Nusz. In addition, questionnaires from over 100 Dubuque property owners impacted by the preliminary DFIRM were sent to Mr. Nusz in September, 2009. We ask you to review and respond to these citizens' comments. All the changes requested in the City's previous correspondence for the preliminary DFIRM have not been made. The City of Dubuque has concerns with the revised preliminary DFIRM panels 237, 241, 243, and 244 as well, due to new inaccuracies. For example, the revised preliminary DFIRM no longer shows historic flood plains in the Couler Valley -- but places about over 1,600 structures in Zone A flood hazard areas in the North End and Kerper Boulevard industrial area. The DIRM shows the flood plain along Peru Road on a hillside but not on the area at a lower elevation below the hillside. Letter to Melissa Janssen, FEMA February 2, 2010 Page 2 Although flood elevations have not been provided, based on the topography the DFIRM indicates that at the intersection of Kleine Street and Kaufmann Avenue the flood depth will be approximately eight feet deep on the south side of Kaufmann but only six feet deep on the north side of Kaufmann. A similar discrepancy can be found at the intersection of Main Street and Kaufmann Avenue. Intermittent flood areas are shown as islands in the North End. These are only a few examples of inaccuracies City staff has found in the preliminary and revised preliminary DFIRMs. The City's current FIRM indicates the area along the Mississippi River inundated by the 500 -year flood plain as a shaded Zone X. This shaded Zone X is still noted on the revised preliminary DFIRM as being protected from the 100 -year flood. The revised preliminary DFIRM should be updated to reflect the U.S. Army Corps of Engineers' 2008 Upper Mississippi River Comprehensive Plan that concludes that the levee protects the city from the 500 -year flood. There remain these concerns and other issues with the preliminary DFIRM dated July 13, 2009 and with the revised preliminary DFIRM that the City received in January of 2010. In some cases, the maps are inconsistent with the Flood Insurance Study for Dubuque County. In other cases, the mapping methodology is inconsistent with the Floodplain Management Desk Reference produced by FEMA and the Iowa DNR. City staff is continuing to review the preliminary and revised DFIRMs for inaccuracies and issues. Please feel free to contact Laura Carstens, Community Floodplain Administrator, at 563.589.4210 or Icarsten @cityofdubuque.orq for more information. Sincerely, Roy D. Buol Mayor Enclosures cc: Beth Freeman, FEMA Regional Administrator, FEMA Region VII Roger Benson, Consultant Coordination Officer, FEMA Region VII Rick Nusz, Hydraulic Engineer, FEMA Region VII Bill Cappuccio, Iowa Department of Natural Resources Michael C. Van Milligen, City Manager Teri Goodmann, Assistant City Manager Laura Carstens, Planning Services Manager Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Office of the Mayor City Hall 50 West 13th Street Dubuque, Iowa 52001 -4864 www.cityofdubuque.org 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. Service People Integrity Responsibility Innovation Teamwork August 4, 2009 J OAA/1-64--- Letter to Roger Benson, FEMA August 4, 2009 Page 2 Thank you for your consideration of these requested changes and submittal of additional information related to the submitted preliminary DFIRM. If you have questions or need additional information, please contact Laura Carstens, Community Flood Plain Administrator at 563.589.4210 or Icarsten(a�cityofdubuque.orq. Sinc er ly, Roy U. Buol Mayor Enclosures 5. The large area shown as new flood zone A on the city's North End does not reflect the existence of recent storm water control facilities, such as the Carter Road and West 32 Street detention basins that were constructed after the City's drainage study. 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 planned Bee Branch Creek Restoration Project will address the flooding experienced in the North End due to storm sewer constraints. 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 the City of Dubuque's opinion, identifying a storm sewer problem rather than a flooding issue connected with a stream or river. 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 Street detention basins. The City of Dubuque will prepare a similar aerial map and supporting technical analysis of the expected flooding mitigation for the Bee Branch Creek Restoration Project. cc: Watershed Concepts, 2405 Grand Blvd, Suite 1000 , Kansas City MO 64108 Michael C. Van Milligen, City Manager Laura Carstens, Planning Services Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Masterpiece on the Mississippi September 9, 2009 Rick Nusz Hydrologic Engineer FEMA Region 7 9221 Ward Parkway Suite 300 Kansas City MO 64114 Dear Mr. Nusz: Dubuque All-AmdicaCtly 11111 2007 Office of the Mayor & City Council City Hall 50 West 13 Street Dubuque, IA 52001 -4864 www.cityofdubuque.org This letter provides follow -up non - technical comments to, FEMA regarding the preliminary DFIRM for the City of Dubuque. This letter outlines changes the City of Dubuque would like to see incorporated into the preliminary DFIRM for the community. The City of Dubuque is very supportive of the map modemization 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. The City of Dubuque is requesting a revision of proposed floodplain boundary delineations or regulatory floodway boundaries, and alerting FEMA to possible base map errors, in accordance with FEMA's Flood Hazard Mapping Fact Sheet, based on the following points: 1. FEMA has asked the City of Dubuque to send comments from property owners about the DFIRM. Enclosed are over 120 comment forms received to date. We asked property owners to provide information about flooding on their property, especially after the large rains in 1993 and 1999. We also asked them to indicate any changes they have noticed in flooding since the City installed detention basins along the Iowa 32 (Northwest Arterial), Carter Road, and West 32 Street. Our engineering consultants tell us that these field observations in connection with known rain events serve to calibrate the models used to determine and delineate flood - prone areas. Please consider these comments. 2. The flood zone boundaries of Dubuque shown on the preliminary DFIRM map do not accurately reflect the topography of the community throughout these zones. In some Zone A areas, the side of a street that is at a higher elevation is in a flood zone, while the lower side of the street is not. One area that we noticed immediately is at the intersection of Kaufmann Avenue and North Main Street. As shown on the enclosed aerial view, the flood zone appears to move up the steep slope of North Main Street to an elevation of 646 MSL while across the intersection, the flood elevation only rises to 630 MSL. How is this possible? Therefore, we believe that the flood hazard area is incorrectly shown, and the Kaufmann Avenue flood zone should be removed from the L� Letter to Rick Nusz, FEMA September 9, 2009 Page 2 DFIRM. This same discrepancy may apply to other areas mapped as Zone A on the DFRIM. Another area that we noted is the Zone AE at the Julien Dubuque monument, which sits atop a river bluff. The DFIRM shows a flood level up to the base of the monument at approximately 746 MSL. The Flood Insurance Study, however, indicated the base flood elevation is 610 MSL. The flood boundaries . in this area need to be revised due to this discrepancy, and should reflect actual topography. Again, this discrepancy may be present on other new flood zones depicted on the DFIRM. The current city two -foot contours are enclosed in a digital format. Please consider this data: We believe that further analysis of the city contours, especially in the new Zone A areas, will result in the removal of these areas from the DFIRM. 3. The new Zone AE shown along the Catfish Creek west of Iowa Highway 32 (Northwest Arterial) has been enlarged near the former location of the Radford Road bridge. The DFIRM does not reflect that this bridge crossing was removed. In August of 1990 the City of Dubuque submitted the enclosed Joint Application to the Iowa Department of Natural Resources and the Corps of Engineers to allow fill in this area for a future industrial project (now the site of Nordstrom's distribution center). The grading and filling of the site was to raise the site out of the 100 -year floodplain. In addition, the Radford Road bridge was removed; this eliminated the backwater created by the bridge abutments and therefore, should reduce the expected flooding levels. Please review the enclosed information to determine whether the subject area should still be in a special flood hazard area. The City can submit a LOMR -F if the enclosed information is not sufficient. 4. The City of Dubuque requests that all new Zone A areas have base flood elevations determined, so that they are converted to Zone AE areas on the DFIRM — if in fact these are special flood hazard areas. Section 8.4.1 of the FEMA Floodplain Management Desk Reference states: "Regulating development in approximate or unnumbered A Zones is one of the tougher jobs you'll face, especially in counties that have large areas of such zones." Section 8.3 states that: "The applicant for a permit in an approximate A Zone is required to provide the data necessary for the DNR — Water Quality Bureau staff to calculate the 100 -year flood elevation. This process can take up to a year." The new DFIRM significantly expands the number of properties designated as being in a flood plain. There are approximately 70 structures in the current special flood hazard areas. The proposed new special flood hazard areas include approximately 1,806 properties, with an estimated 1,741 structures over 500 square feet. 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, where there are no base flood elevations 'determined, the property owner must hire an engineer to f:\users\mrettenb \wp \dfirm \fema dfirm change Itr #2.doc Letter to Rick Nusz, FEMA September 9, 2009 Page 3 Sincer Iy, Enclosures determine the base flood elevation in order to determine how high an addition or a new structure must be elevated. The single largest Zone A area is. the North End of Dubuque. This area includes the Washington Neighborhood and the North End Neighborhood. These areas are characterized by some of the city's 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 of Dubuque has focused reinvestment efforts in these neighborhoods, and has installed upstream storm water management facilities to alleviate problems with the stormwater system. The delineation of these neighborhoods as a Zone A flood hazard area will reverse the progress the City has made. The Zone A designation will result in neighborhood disinvestment and blighting conditions. Placing this burden on approximately 1,400 property owners in the new Zone A areas is unacceptable. The burden of determining the base flood elevations (BFEs) must rest with FEMA, not the citizens of Dubuque. As FEMA determines the base flood elevations in the proposed Zone A areas, we believe that the accuracy of the DFIRM will increase, and the extent of the special flood hazard areas will decrease in size. Thank you for your consideration of these requested changes to the Dubuque preliminary DFIRM. If you have questions or need additional information, please contact Laura Carstens, Community Flood Plain Administrator at 563.589.4210 or Icarsten Psj, 4 Roy I BuoI Mayor cc: Watershed Concepts, 2405 Grand Blvd, Suite 1000, Kansas City MO 64108 Roger Benson, Consultant Coordination Officer, FEMA Region 7 Michael C. Van Milligen, City Manager Laura Carstens, Planning Services Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Bill Cappuccio, Iowa Department of Natural Resources f: \users\mrettenb \wp\dfirm \fema dfirm change Itr #2.doc Masterpiece on the Mississippi September 22, 2009 Rick Nusz Hydraulic Engineer FEMA Region VII 9221 Ward Parkway Ste 300 Kansas City MO 64114 Dear Mr. Nusz: Dubuque AI- Amerkalfty 11111 2007 Office of the Mayor & City Council City Hall 50 West 13 Street Dubuque, IA 52001 -4864 www.cityofdubuque.org This letter transmits a GIS shape file prepared by HDR, who worked with the City on the City of Dubuque Drainage Basin Master Plan. The shape file reflects the area of the North End within the new Zone A proposed by FEMA that HDR predicts would witness flood depths in excess of one foot during a 100 -year event. HDR's shape file reflects the existence of the Cater Road Detention Basin completed in 2004 and the W. 32 Street Detention Basin completed this spring. Also enclosed is a project summary prepared by HDR outlining the engineering models and techniques used to establish the predicted flooding limits. The City of Dubuque is still on record as being concerned about the designation of the North End of Dubuque, including Kaufmann Avenue and 32 Street, as an A zone as it does not, in our opinion, accurately represent the flooding potential in this area. The City's Drainage Basin Master Plan was intended to address long standing issues with urban storm sewer conveyance problems in this area of the community — not flooding associated with a creek or river. These types of urban storm water problems are not uncommon throughout the United States. The City of Dubuque does not believe that the history of localized street flooding and basement flooding experienced in the North End rises to a level of being designated as a regulatory flood plain, unless this has been the approach FEMA has taken throughout the United States in urban areas as part of the DFIRM Project. We also have enclosed additional comment forms submitted by property owners in the potential new flood hazard areas for your consideration. The City of Dubuque is requesting revision of the proposed flood plain boundary delineations on the preliminary DFIRM based on the enclosed GIS shape file prepared by HDR. Letter to Rick Nusz, FEMA September 22, 2009 Page 2 Thank you for your consideration of the enclosed information to the Dubuque preliminary DFIRM. If you have any questions or need additional information, please contact Laura Carstens, Community Flood Plain Administrator, at 563.589.4210 or by email at Icarsten(a,citvofdubuque.orq Sincerely, Ro b. Buol Mayor Enclosures cc: Watershed Concepts, 2405 Grand Blvd, Suite 1000, Kansas City MO 64108 Roger Benson, Consultant Coordination Officer, FEMA Region 7 Michael C. Van Milligen, City Manager Laura Carstens, Planning Services Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Bill Cappuccio, Iowa Department of Natural Resources f:lusers\mrettenb\wp\dfirm\nusz letter 09_14 -09 final.doc. Masterpiece on the Mississippi Rick Nusz Hydraulic Engineer FEMA Region VII 9221 Ward Parkway Ste 300 Kansas City MO 64114 Dear Mr. Nusz: Dubuque ,I A1�ta y 1. 2007 Office of the Mayor & City Council City Hall 50 West 13 Street Dubuque, IA 52001 -4864 www.cityofdubuque.org November 17, 2009 This letter is in response to your request for the City of Dubuque to provide data for the Zone A covering a large portion of the North End of Dubuque on FEMA's preliminary DFIRM (Digital Flood Insurance Rate Map). The City of Dubuque is not comfortable supplying any additional data related to the area currently designated as a Zone X that might be used to increase the size of the proposed new Zone A shown in the City's North End. As indicated in previous correspondence, the City believes that the new Zone A shown on the preliminary DFIRM is unfounded as the storm water drainage issues are related to basement flooding due to storm sewer and street storm water conveyance capacity limitations. North End History and Impacts The North End is laid out in a traditional grid street system and has been fully developed for approximately 100 years. With the construction of the original Bee Branch storm sewer system, many of the problems associated with storm water were resolved; otherwise, the area would not have fully developed in its present configuration. The historical records since the construction of the Bee Branch Storm sewer system would suggest the only problems have been associated with storm water creating relatively minor street flooding and water in basements. The City's latest project to rebuild the Bee Branch storm sewer system addresses problems associated with the age of the system and additional storm water created by development in upland areas since the original Bee Branch storm sewer was constructed. It is very typical for cities to design their storm sewer systems to handle the 10 -year storm. Obviously, this can be exceeded from time to time in any given year; in those instances streets are asked to carry this additional flow. The fact that cities' storm sewer systems can be overwhelmed by particular storm events and there is street flooding does not render all those areas throughout the United States as being in a regulated flood plain. Many streets in Dubuque actually have curbs that are nearly two feet in height to allow the street to carry more storm water. Letter to Rick Nusz, FEMA November 17, 2009 Page 2 From the time that the City's Drainage Basin Master Plan (DBMP) was completed in 2001, the City has never indicated that there are 1,150 properties in the 100 -year flood plain. The City has simply indicated that there are 1,150 properties at risk of flood damage during heavy rains. While the DBMP findings were based on sophisticated models (the US Army Corps of Engineers' HEC -HMS and the US EPA's SWMM models), it was not the intent to identify a flood plain — only quantify /qualify a drainage issue and present potential solutions. The City has already started implementing the solutions with the last to be completed in 2013. The proposed designation of the North End of Dubuque as a Zone A would increase the number of structures over 500 square feet located in special flood hazard areas from approximately 70 to approximately 1,741.- The most significant impact of having a property in a flood plain is that new construction, new additions, and even existing structures, which may be undergoing rehabilitation, may have to be elevated or flood proofed as part of any substantial improvement to a property. In Zone A, where there are no base flood elevations, an engineer must be hired to determine the base flood elevation, in order to determine how high an addition or new structure must be elevated. The area proposed for inclusion in the new Zone A on the North End of Dubuque includes some of the City's oldest housing stock (dating from the late 1800s) and long- standing businesses and industries. These neighborhoods have a higher percentage of low to moderate income households and racial and ethnic minorities than the City as a whole. The City of Dubuque has focused reinvestment efforts in these neighborhoods for many years and has installed upstream storm water management facilities to alleviate problems with the storm water system. The delineation of these neighborhoods as a Zone A flood hazard area will reverse the progress the City has made. The Zone A designation will result in neighborhood disinvestment and blighting conditions. Placing this burden on approximately 1,400 low to moderate income households in the new Zone A is unacceptable. The burden to determine base flood elevations (BFEs) must rest with FEMA and not the citizens of Dubuque if FEMA is determined to designate this area as a special flood hazard area because of storm water issues. National Flood Insurance Program in Dubuque The City of Dubuque was the first community in Iowa to join the National Flood Insurance Program (NFIP) on April 2, 1971. The City's current flood maps were revised in September 1989. These maps updated a previous set from the 1970s. The North End of Dubuque was not shown as a special flood hazard area in either of the two previous FIRM maps. 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 Special Letter to Rick Nusz, FEMA November 17, 2009 Page 3 Flood Hazard Area (SFHA). The only new structures built in SFHAs have been commercial structures that have been elevated and /or flood proofed in compliance with NFIP requirements. 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 SFHA. 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 having ever occurred. This error 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 that designation as a 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. Flood Boundary Methodology The accuracy of the preliminary DFIRM also calls into question the methodology used to establish the flood boundaries initially. In the conference call of October 22, 2009 with FEMA, City staff and AECOM / Watershed Concepts staff, it was stated that FEMA did not use a standard model for the new Zone A areas. The Nebraska model, INSECT, was used. This model depicts normal depth at cross sections. You confirmed that FEMA was using Iowa regression analysis. It was further discussed at the conference call that FEMA was using new modeling, and it was not done to an engineering standard that would enable elevations to be published. You stated that FEMA has limited funding to do an engineering study that would determine BFEs. Therefore, this burden will be placed on citizens in the City of Dubuque who have the least means; the City finds this unacceptable. If FEMA does not have the funding to do an engineering study, using sufficiently sophisticated models to produce BFEs, then no new Zone A areas should be mapped. By failing to do more than a rudimentary planning study, FEMA fails to provide the BFEs needed for the City to regulate development in the North End. The Zone A in the North End, in particular, will create neighborhood disinvestment. It also will subject low and moderate income households to costly flood insurance that they cannot afford, further acerbating disinvestment in this historic neighborhood. 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 A Zones by FEMA. Increasing our inventory of structures in the flood plain from 70 to over 1,700 through non - standard mapping would be a mistake. Letter to Rick Nusz, FEMA November 17, 2009 Page 4 Flood Insurance Study By definition, a Flood Insurance Study (FIS) Report is an appraisal of a community's flood problems, including historic floods. The City of Dubuque's FIS Report from FEMA, revised on September 6, 1989, does not mention any flooding hazards in the North End. The July 2009 FIS Report for Dubuque County and incorporated areas provided by FEMA to the City of Dubuque earlier this year does not mention any flooding hazards in the North End. On page 4, the 2009 FIS Report indicates the 1989 FIS Report for the City of Dubuque is a reference document. On Page 5, the 2009 FIS Report described the Scope of Study for the area studied. The report states, "the areas studied were selected with priority given to all known flood hazard. areas and areas of projected development or proposed construction." The City of Dubuque is not included in the following section entitled Community Description on pages 6 -9. The City of Dubuque is not listed in the next section, Principal Flood Problems, on pages 9 -11. On page 12, the City of Dubuque is identified as having no flood protection measures in existence or proposed. The City has a floodwall and levee system along its Mississippi Riverfront that provides protection from the 100 -year and 500 -year flood events. Shouldn't this levee system be acknowledged in the 2009 FIS Report? The 2009 FIS Report lists Engineering Methods for hydrologic analyses (pages 13 -17) and hydraulic analyses (pages 18 -23). The North End is not mentioned in either of these analytical descriptions with respect to flooding. The 2009 FIS Report describes flood plain management applications on pages 23 -25. This section speaks to streams with respect to regulated flood plains, floodways, and floodway fringes. Urban storm water in the North End of Dubuque is never mentioned in this context. Conclusion The point of the NFIP is for communities to regulate floodplain development. In Dubuque, we have an excellent record of flood plain management. The Zone A areas shown on the preliminary DFIRM are not supported by the FIS Reports, and therefore including them in the DFIRM would be a mistake that would burden low and moderate income households with costly flood insurance that they cannot afford, further acerbating disinvestment in their historic neighborhoods. The new Zone A areas should be removed entirely from the City of Dubuque's DFIRM before the FEMA public meeting, for the benefit of everyone. Sincerely Roy D,/fBuol Mayor 6„." Letter to Rick Nusz, FEMA November 17, 2009 Page 5 cc: Watershed Concepts, 2405 Grand Blvd, Suite 1000, Kansas City MO 64108 Roger Benson, Consultant Coordination Officer, FEMA.Region 7 Michael C. Van Milligen, City Manager Laura Carstens, Planning Services Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Bill Cappuccio, Iowa Department of Natural Resources Masterpiece on the Mississippi Rick Nusz Hydraulic Engineer FEMA Region VII 9221 Ward Parkway Ste 300 Kansas City MO 64114 Dear Mr. Nusz: Please find enclosed information regarding base flood determinations obtained through a detailed study by IIW Engineers & Surveyors, P.C. for property in and around the City of Dubuque's Dubuque Industrial Center West (DICW). The City of Dubuque developed the DICW in the mid 1990s. As part of the development of the industrial park, a substantial amount of grading was completed to create building pads as well as made changes to the Middle Fork of the Catfish Creek as it runs through the DICW. Currently there are portions of the industrial park, designated as a special flood hazard area, Zone A, that the enclosed study completed by IIW Engineers & Surveyors addresses. The City hired IIW Engineers & Surveyors to do the study in an effort to clearly define the new limits of the special flood hazard area within the industrial park. Attached to this letter is a letter from Dennis Waugh, professional engineer with IIW Engineers & Surveyors, as well as a disc containing all the pertinent study data. Please contact Associate Planner Kyle Kritz in the City's Planning Services Department if you need additional information or clarification of information in this letter. Sincer Roy [0. Buol Mayor Enclosures Dubuque bettal mia.dragi 1' I' 2007 Office of the Mayor & City Council City Hall 50 West 13th Street Dubuque, IA 52001 -4864 www.cityofdubuque.org December 21, 2009 cc: Watershed Concepts, 2405 Grand Blvd, Suite 1000, Kansas City MO 64108 Roger Benson, Consultant Coordination Officer, FEMA Region 7 Michael C. Van Milligen, City Manager ✓Laura Carstens, Planning Services Manager Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer II Kyle L. Kritz, Associate Planner Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator Bill Cappuccio, Iowa Department of Natural Resources