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