Legislative Correspondence_HSB 608_500 Year Flood Plain RegulationVIA E -Mail &
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«Email»
« CompleteOFFICIALName Address»
Dear «Title» «Last»:
February 10, 2010
This letter provides a City of Dubuque position statement on House Study Bill 573, an
act relating to flood plain management. The Iowa League of Cities' Legislative Team
has asked for input from cities regarding this bill. HSB 573 is enclosed.
Background
Notable portions of the bill include:
• Regulating the 500 year ( ".2 percent or two- tenths percent ") flood plain instead of
the 100 year flood plain.
• Prohibiting reconstruction of flood damaged structures and infrastructure in the
floodway.
• Limiting reconstruction or new construction in a .2 percent flood plain to not more
than three vertical feet of fill above the natural ground line.
• Prohibiting building of new critical structures in the .2 percent flood plain
wherever practicable.
• Adopting statewide minimum stormwater standards to be implemented by July 1,
2011.
• Requiring the Iowa Department of Natural Resources (IDNR) to establish criteria
to prioritize investments in levees in situations where "no other practicable
alternatives exist" for mitigating flood damage risk.
Discussion
The City of Dubque has the following comments regarding the proposed legislation. Our
comments and recommendations are taken largely from the City of Dubuque's position
paper filed with the Water Resources Coordinating Council in November 2009 during
the public meeting process leading up to the development of HSB 573.
500 -Year Flood Plain Regulation
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February 10, 2010
Page 2
The proposed bill would require that the regulatory flood plain be changed from the 100 -
year flood to the 500 -year flood. The bill indicates that when an area of the state is
identified as being in the 500 -year flood plain on a flood insurance rate map (FIRM)
certified by the Federal Emergency Management Agency (FEMA) that the 500 -year
flood plain shall be the regulatory flood plain for the purposes of the regulations included
in this bill.
The City of Dubuque's primary concern is that the National Flood Insurance Program,
since its inception 40 years ago, has used the 100 -year flood plain as the regulatory
flood plain. Citizens have made decisions about the locations of their homes and
businesses based on this regulatory flood plain.
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 Zone X area, shown in yellow on the
enclosed aerial map, includes the entire Kerper Boulevard and Kerper Court industrial
areas, the 12 Street Peninsula where Peavey Grain and Koch Materials are located,
as well as the north and south Ports of Dubuque. Many of the businesses, industries,
and City facilities in these shaded Zone X areas were constructed after the City's flood
wall and levee system was built to protect the community's riverfront from the 100 -year
flood.
To change this regulatory flood plain at this point in time will hurt many Dubuque
industries located along Kerper Boulevard, Kerper Court, and the 12 Street Peninsula.
In a highly competitive environment, the City of Dubuque fights hard to attract and retain
industries such as these to provide jobs for Dubuque citizens. These properties are
currently outside of the 100 -year Mississippi River flood plain as they are protected by a
levee system that the City expends a significant effort to maintain. But the current FIRM
indicates that these businesses are within the 500 -year Mississippi River flood plain.
HSB 573 would place an additional burden on these industries, industries that employ
thousands of Dubuque citizens, and give them an economical reason to relocate to
another community.
The City of Dubuque recommends that rather than expand the regulatory flood plain to
the 500 -year flood, the State of Iowa should first look at the effectiveness of regulations
and whether they have been consistently applied by Iowa communities for the 100 -year
flood plain. If 40 years of regulating the 100 -year flood plain have not been effective
when reducing flood damage, how does expanding these same regulations to the 500 -
year flood plain improve matters?
It is important to note that whether you regulate the 100 -year flood or the 500 -year
flood, current flood plain management regulations allow development within a flood
plain as long as it is not in a flood way. A flood way is the portion of the flood plain
reserved for conveying the 100 -year flood. The City of Dubuque recommends that
before the State expands the regulatory flood plain beyond the 100 -year flood, a
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February 10, 2010
Page 3
thorough analysis be completed regarding the success of regulating property within the
100 -year flood plain.
The bill does provide for an exemption for flood plain areas protected by a levee that
meets certain criteria. Staff supports this recommendation, because it may exempt the
City's shaded Zone X areas along the riverfront -- Kerper Boulevard industrial area, the
12 Street Peninsula, and the Port of Dubuque -- if the current FIRM is 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.
Flood Way Regulation: Utilities Exemption
Section 2A of the proposed bill prohibits reconstruction of structures and infrastructure
substantially damaged by a flood in a flood way. The City does have significant miles of
gravity flow sanitary sewers located in flood ways. The City of Dubuque, like many
other cities in Iowa, has used stream valleys to run our sanitary sewer lines as it makes
the most sense from a gravity flow situation. From time to time, these sewers are
damaged during high water events, requiring repair or reconstruction. Section 2A
appears to exempt structures and infrastructure necessary for construction or
maintenance of utility facilities, but it's not clear if the actual utilities themselves would
be exempt. If utilities such as sanitary sewer lines are exempt from this provision, the
City of Dubuque does not believe this bill will have a substantial impact on the local
area. We recommend the bill clearly indicate that it does not apply to utilities.
Flood Way Regulation: Three -foot Limit
Section 2B would limit reconstruction or new construction in the 500 -year flood plain to
not having more than three vertical feet of fill above the natural ground line. We
question what the rationale is for the three -foot height. Without knowing the rationale
behind the three -foot limit, one can only speculate as to its purpose. But it suggests a
lack of understanding of flood plain management as established by FEMA and
understood by flood plain managers. As stated previously, proper flood plain
management allows for development as well as construction of obstructions such as fill
or structures in the flood plain. In fact, this is assumed. And this is how the flood way is
established. The flood way is the portion of the flood plain where the construction of
obstructions is prohibited. Yet, the regulations do not even mention the flood way.
Section 2B goes on to say that local political subdivisions may permit other means than
fill to elevate structures, and thus it does not prohibit new construction in flood plains but
restricts how those structures are elevated above the flood plain. For example, if a
structure was to be built in a Zone AE and be required to be built five feet above the
base flood elevation, the structure could be built on three feet of fill and then would have
to be built up by other means, such as pilings. We question what will be the positive
impact for flood damage reduction in the State by adopting a limit of three -foot of fill in
the 500 -year flood plain? The flood plain along Kerper Boulevard is wide and shallow,
while the flood plain along Catfish Creek is steep and narrow...yet this bill would treat all
flood plains the same by arbitrarily establishing a three -foot limit of the placement of fill.
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February 10, 2010
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We recommend that the bill remove the arbitrary three -foot limit or allow for the
establishment of an alternative limit based on the characteristics of each particular flood
plain.
Critical Facilities
Section 2C requires that new construction of facilities critical for health and safety of the
public and the environment be located in areas that are outside the 500 -year flood
plains whenever practical. We believe this is a sensible approach and should be
expanded to include other important community assets, such as schools. Although, the
use of the word "practical" gives reason to pause because the proposed legislation does
not state who determines what is practical and what is not, or set out criteria. The bill
should be made clear on this point.
Sections 2 through 6 seem reasonable and the City supports their inclusion in the
proposed bill.
State -Wide Soil Moisture Monitoring Network
Section 7 -1 involves developing a state -wide soil moisture monitoring network for
assessing flood risk through the Iowa Water Center of Iowa State University of Science
and Technology, and the Leopold Center for Sustainable Agriculture. We question the
funds necessary to establish a state -wide soil moisture monitoring network. We
recommend that these funds would be much better spent in developing watershed
plans, education and training programs, or other ways of actually reducing damage from
flooding. We would note that flash flood warnings are already issued to all counties and
communities in the State of Iowa, and that soil moisture monitoring already takes place
in the State for the benefit of agricultural production. We wonder what additional
benefits would be gained by establishing a state -wide soil moisture monitoring network
beyond what already exists.
The City has no objections to the remainder of Section 7. The City has no objections to
the entirety of Sections 8, 9, 10, and 11.
Levee Investment
Section 12 deals with levee investment. As written, the IDNR is to encourage policies
and practices relative to the use of levees particularly in rural areas as a way to
reconnect streams and rivers to the flood plains through the modification and removal of
existing levees and to discourage the construction of additional levees. We believe this
is a step in the right direction and would like to have the bill direct the IDNR to require
and fund these practices, so they are implemented — not just encouraged. We would
note that the use of levees should be generally restricted to protection of high value
areas, such as cities, or where facilities need protection that there is no other alternative
than the construction of a levee.
Recommendation
«Title» «First» «Last»
February 10, 2010
Page 5
In summary, the City of Dubque supports HSB 573 in general, with the following
recommendations:
• Before the State expands the regulatory flood plain beyond the 100 -year flood, a
thorough analysis should be completed regarding the success of regulating
property within the 100 -year flood plain.
• The bill should clearly indicate that it does not apply to utilities in a flood way.
• The bill should remove the arbitrary three -foot limit or allow for the establishment
of an alternative limit based on the characteristics of each particular flood plain.
• Critical facilities should be expanded to include other important community
assets, such as schools. Also, the bill should clarify the word "practical" as to who
determines what is practical and what is not, or set out criteria.
• The funds to establish an unnecessary state -wide soil moisture monitoring
network will be much better spent in developing watershed plans, education and
training programs, or other ways of actually reducing damage from flooding.
• The bill should do more than direct the IDNR to encourage policies and practices
relative to the use of levees particularly in rural areas as a way to reconnect
streams and rivers to the flood plains through the modification and removal of
existing levees and to discourage the construction of additional levees. The bill
should direct the IDNR to require and fund these practices, so they are
implemented — not just encouraged.
Thank you for your consideration. Please feel free to contact me if you have any
questions or need further information regarding the City of Dubuque's position on the
proposed legislation.
MCVM:Ic
Enclosure
Sincerely,
Michael C. Van Milligen
City Manager
A - No Base Flood Elevations Determined
AE - Base Flood Elevations Determined
Bill/Amendments for HSB 573 Page 1 of 5
House Study Bill 573
PAG LIN
HOUSE FILE
BY (PROPOSED COMMITTEE ON
REBUILD IOWA AND
DISASTER RECOVERY BILL
BY CHAIRPERSON
SCHUELLER)
A BILL FOR
1 An Act relating to flood plain management.
2 BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF IOWA:
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1 1 Section 1. NEW SECTION. 455B.276A Flood plains.
1 2 1. When an area of the state is identified as a two = tenths
1 3 percent flood plain on a flood insurance rate map certified by
1 4 the federal emergency management agency or on a flood plain
1 5 map produced by the department, the two = tenths percent flood
1 6 plain shall be the applicable flood plain designation for the
1 7 purposes of this chapter and rules adopted pursuant to this
1 8 chapter. An area of this state on the landward side of a flood
1 9 control levee recognized by the federal emergency management
1 10 agency as protecting against a two= tenths percent flood shall
1 11 not be considered part of a two = tenths percent flood plain and
1 12 shall not be subject to regulations for a two = tenths percent
1 13 flood.
1 14 2. The department and political subdivisions of this state
1 15 shall do all of the following:
1 16 a. Prohibit the reconstruction of structures and
1 17 infrastructure substantially damaged by a flood in a floodway.
1 18 This paragraph shall not apply to structures and infrastructure
1 19 necessary for the construction or maintenance of utility
1 20 facilities, transportation infrastructure, water control
1 21 facilities, or public infrastructure if more restrictive local
1 22 ordinances, permitting requirements, or other regulations
1 23 apply.
1 24 b. Limit reconstruction or new construction in a two = tenths
1 25 percent flood plain to not more than three vertical feet
1 26 of fill above the natural ground line. The department and
1 27 political subdivisions may permit means other than fill to
1 28 elevate structures.
1 29 c. Require new construction of facilities critical for
1 30 health and safety of the public and the environment to be
1 31 located in areas that are not designated two = tenths percent
1 32 flood plains whenever practicable. If not practicable, new
1 33 construction of facilities critical for health and safety of
1 34 the public and the environment built in a two = tenths percent
1 35 flood plain shall be designed to ensure that the operation
2 1 and function of the facility can be maintained during the
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2 2 occurrence of a two = tenths percent flood. Facilities critical
2 3 for health and safety of the public and the environment include
2 4 hospitals and nursing homes; emergency operations centers
2 5 including fire, police, and rescue facilities; vital data
2 6 storage centers; power generation and other utilities including
2 7 related infrastructure such as principal points of utility
2 8 systems; and any facilities that produce, use, or store toxic
2 9 pollutants.
2 10 Sec. 2. NEW SECTION. 466.10 Hydrological tiling study.
2 11 The department of agriculture and land stewardship shall
2 12 conduct a hydrological tiling study in conjunction with
2 13 hydrology experts from the Iowa flood center and Iowa state
2 14 university of science and technology to determine the impact
2 15 tile drainage has on infiltration, surface runoff, and flooding
2 16 and to evaluate the feasibility of seasonal retention of water
2 17 in tile drained fields as a drainage management strategy. The
2 1B impact of potholes, wetlands, and water retention structures
2 19 shall also be considered in the study.
2 20 Sec. 3. Section 466B.4, subsection 2, Code Supplement 2009,
2 21 is amended to read as follows:
2 22 2. Marketing campaign. The water resources coordinating
2 23 council shall develop a marketing campaign to educate Iowans
2 24 about the need to take personal responsibility for the quality
2 25 and quantity of water in their local watersheds. The emphasis
2 26 of the campaign shall be that not only is everyone responsible
2 27 for clean water, but that everyone benefits from it as well
2 28 and that everyone is responsible for and benefits from reducing
2 29 the risk for flooding and mitigating possible future flood
2 30 damage. The goals of the campaign shall be to convince Iowans
2 31 to take personal responsibility for clean water and reducing
2 32 the risk of flooding and to equip them with the tools necessary
2 33 to effect change through local water quality improvement
2 34 projects and better flood plain management and flood risk
2 35 programs.
3 1 Sec. 4. NEW SECTION. 466B.10 Multipurpose wetlands.
3 2 The department of agriculture and land stewardship, in
3 3 cooperation with the council, shall initiate programs to
3 4 integrate multipurpose wetlands into watersheds with drainage
3 5 districts or larger drainage systems and shall prioritize
3 6 funding for such programs that incorporate a holistic approach.
3 7 Existing drainage systems shall be retrofitted to provide for
3 8 nutrient trapping and treatment, more water infiltration and
3 9 evapotranspiration, greater water runoff retention, and habitat
3 10 to support biodiversity.
3 11 Sec. 5. NEW SECTION. 466B.11 Watershed demonstration pilot
3 12 project.
3 13 The department of natural resources and the department of
3 14 agriculture and land stewardship, in collaboration with the
3 15 United States department of agriculture's natural resources
3 16 conservation service and the Iowa flood center established
3 17 pursuant to section 466C.1, and in cooperation with the
3 18 council, shall seek funding to plan, implement, and monitor a
3 19 watershed demonstration pilot project for urban and rural areas
3 20 involving a twelve =digit hydrologic unit code subwatershed as
3 21 defined by the United States geological survey. The pilot
3 22 project shall include features that seek to do all of the
3 23 following:
3 24 1. Maximize soil water holding capacity from precipitation.
3 25 2. Minimize severe scour erosion and sand deposition during
3 26 floods.
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3 27 3. Manage water runoff in uplands under saturated soil
3 28 moisture conditions.
3 29 4. Reduce and mitigate structural and nonstructural flood
3 30 damage.
3 31 Sec. 6. NEW SECTION. 466B.12 Flood plain managers.
3 32 The council shall encourage and support the formation
3 33 of a local chapter of the association of state flood plain
3 34 managers in Iowa that would provide a vehicle for local flood
3 35 plain managers and flood plain planners to further pursue
4 1 professional educational opportunities.
4 2 Sec. 7. NEW SECTION. 466B.13 Flood education.
4 3 The Iowa state university agricultural extension service,
4 4 the council, and agency members of the council shall work
4 5 with flood plain and hydrology experts to educate the general
4 6 public about flood plains, flood risks, and basic flood plain
4 7 management principles. This educational effort shall include
4 8 all of the following:
4 9 1. Developing a statewide soil moisture monitoring network
4 10 for assessing flood risk through the Iowa water center of Iowa
4 11 state university of science and technology and the Leopold
4 12 center for sustainable agriculture established in section
4 13 266.39, and make extensive use of existing tools and knowledge
4 14 focused on soil health, specifically the soil conditioning
4 15 index of the United States department of agriculture's natural
4 16 resources conservation service as a common metric for improved
4 17 agronomic and conservation practices.
4 18 2. Developing educational materials and programs in
4 19 consultation with flood plain experts.
4 20 3. Expanding use of existing integrated farm and land
4 21 resource management tools to assist planners, landowners,
4 22 and farmers in planning and creating infiltration systems to
4 23 accommodate rainfalls of up to one and one = quarter inch and
4 24 support conservation and business planning.
4 25 Sec. 8. NEW SECTION. 466B.14 Climate criteria.
4 26 The department of natural resources and the department
4 27 of agriculture and land stewardship, in cooperation with
4 28 the council, shall work with the United States department
4 29 of agriculture's natural resources conservation service to
4 30 reassess criteria for conservation practices due to changing
4 31 climate. This shall include all of the following technical
4 32 standards and manuals:
4 33 1. The field office technical guide of the natural resources
4 34 conservation service for conservation criteria.
4 35 2. The engineering field manual of the natural resources
5 1 conservation service for design criteria.
5 2 Sec. 9. Section 558A.4, subsection 1, Code 2009, is amended
5 3 to read as follows:
5 4 1. The disclosure statement shall include information
5 5 relating to the condition and important characteristics
5 6 of the property and structures located on the property,
5 7 including significant defects in the structural integrity of
5 8 the structure, the type of flood plain where the structure
5 9 is located, and whether alluvial soils are present on the
5 10 property, as provided in rules which shall be adopted by the
5 11 real estate commission pursuant to section 543B.9. The rules
5 12 may require the disclosure to include information relating
5 13 to the property's zoning classification; the condition of
5 14 plumbing, heating, or electrical systems; or the presence of
5 15 pests.
5 16 Sec. 10. STORM WATER STANDARDS. The department of natural
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5 17 resources shall adopt minimum storm water standards to be
5 18 implemented by July 1, 2011. The standards shall limit
5 19 water runoff, reduce potential future flood damage, assess
5 20 the effects of stream channelization, and improve watershed
5 21 management in terms of both water quality and water quantity.
5 22 Sec. 11. NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
5 23 PERMITS FOR STORM WATER DISCHARGE. The department of natural
5 24 resources shall modify permits valid on July 1, 2010, and
5 25 issued under the national pollutant discharge elimination
5 26 system permit program to require the mitigation of soil
5 27 compaction and replacement of topsoil as part of completing
5 28 the construction for permitted actions involving one or more
5 29 acres of land disturbance. The department shall include such
5 30 requirements in new permits issued on or after July 1, 2010.
5 31 Sec. 12. LEVEE INVESTMENT.
5 32 1. The department of natural resources shall establish
5 33 criteria to prioritize investments in levees in situations
5 34 where no other practicable alternatives exist for mitigating
5 35 flood damage risk.
6 1 2. In lieu of levees in rural areas, the department
6 2 shall encourage policies and practices that give priority to
6 '3 reconnecting streams and rivers to their flood plains through
6 4 modification or removal of existing levees and discourage the
6 5 construction of additional levees.
6 6 3. The department shall work cooperatively with state and
6 7 federal departments and agencies and with private organizations
6 8 to develop an interagency assessment and prioritization
6 9 process to guide easement and land purchase decisions and
6 10 other infrastructure management efforts in flood plain areas.
6 11 The department shall utilize all available state and federal
6 12 resources to provide project planning and support for rural
6 13 levee modification and compensatory agreements with rural
6 14 landowners.
6 15 EXPLANATION
6 16 This bill relates to flood plain management.
6 17 The bill designates the proper flood plain percentage
6 18 for purposes of applicability to Code chapter 455B and rules
6 19 adopted pursuant to that Code chapter. The bill requires
6 20 the department and political subdivisions in the state to
6 21 prohibit the reconstruction of structures and infrastructure
6 22 substantially damaged by a flood in a floodway, limit
6 23 reconstruction or new construction in an applicable flood
6 24 plain to not more than three vertical feet of fill above
6 25 the natural ground line, and require new construction of
6 26 facilities critical for health and safety of the public and
6 27 the environment to be located in areas that are not designated
6 28 two = tenths percent flood plains whenever practicable.
6 29 The bill requires the department of agriculture and land
6 30 stewardship in conjunction with hydrology experts from the
6 31 Iowa flood center and Iowa state university to conduct a
6 32 hydrological tiling study.
6 33 Currently, the water resources coordinating council is
6 34 required to develop a marketing campaign to educate Iowans
6 35 regarding water quality and watersheds. The bill provides that
7 1 the campaign must also include information regarding reducing
7 2 the risk of flooding and mitigating possible future flood
7 3 damage.
7 4 The bill requires the department of agriculture and
7 5 land stewardship, in cooperation with the water resources
7 6 coordinating council, to initiate programs to integrate
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7 7 multipurpose wetlands into watersheds with drainage districts
7 8 or larger drainage systems and shall prioritize funding for
7 9 such programs that incorporate a holistic approach.
7 10 The bill requires the department of natural resources
7 11 and the department of agriculture and land stewardship, in
7 12 collaboration with the natural resources conservation service
7 13 and the Iowa flood center, and in cooperation with the water
7 14 resources coordinating council, to seek funding to plan,
7 15 implement, and monitor a watershed demonstration pilot project
7 16 for urban and rural areas involving a twelve =digit hydrologic
7 17 unit code subwatershed as defined by the United States
7 18 geological survey.
7 19 The bill requires the water resources coordinating council
7 20 to encourage and support the formation of a local chapter of
7 21 the association of state flood plain managers in Iowa.
7 22 The bill requires the Iowa state university agricultural
7 23 extension service, the water resources coordinating council,
7 24 and agency members of the council to work with flood plain
7 25 and hydrology experts to educate the general public about
7 26 flood plains, flood risks, and basic flood plain management
7 27 principles.
7 28 The bill requires the department of natural resources
7 29 and the department of agriculture and land stewardship, in
7 30 cooperation with the water resources coordinating council, to
7 31 work with natural resources conservation service to reassess
7 32 criteria for conservation practices due to changing climate.
7 33 The bill requires disclosure statements for certain real
7 34 estate transactions to include disclosures regarding the type
7 35 of flood plain where the structure is located and whether
8 1 alluvial soils are present on the property.
8 2 The bill requires the department of natural resources to
8 3 adopt minimum storm water standards to be implemented by July
8 4 1, 2011.
8 5 The bill requires the department of natural resources to
8 6 modify permits valid on July 1, 2010, and issued under the
8 7 national pollutant discharge elimination system permit program
8 8 to require the mitigation of soil compaction and replacement of
8 9 topsoil as part of completing the construction for permitted
8 10 actions involving one or more acres of land disturbance. The
8 11 department must also include such requirements in new permits
8 12 issued on or after July 1, 2010.
8 13 The bill requires the department of natural resources to
8 14 establish criteria to prioritize investments in levees in
8 15 situations where no other practicable alternatives exist for
8 16 mitigating flood damage risk.
8 17 The bill requires the department of natural resources,
8 18 in lieu of levees in rural areas, to encourage policies and
8 19 practices that give priority to reconnecting streams and rivers
8 20 to their flood plains through modification or removal of
8 21 existing levees and discourage the construction of additional
8 22 levees.
8 23 The bill requires the department of natural resources
8 24 to work cooperatively with state and federal departments
8 25 and agencies and with private organizations to develop an
8 26 interagency assessment and prioritization process to guide
8 27 easement and land purchase decisions and other infrastructure
8 28 management efforts in flood plain areas.
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The Honorable Pat Murphy
Speaker of the House
Iowa State Representative
155 N. Grandview Avenue
Dubuque, IA 52001
The Honorable Tom Hancock
Iowa State Senator
310 E. Main Street
Epworth, IA, 52045
The Honorable Chuck Isenhart
Iowa State Representative
P.O. Box 3353
Dubuque, IA 52004 -3353
The Honorable Steven Lukan
Iowa State Representative
7365 Columbus Street
New Vienna IA 52065
The Honorable Pam Jochum
Iowa State Senator
2368 Jackson
Dubuque, IA 52001
The Honorable Roger Stewart
Iowa State Senator
3936 317 Avenue
Preston, IA 52069
The Honorable Thomas Schueller
Iowa State Representative
503 W. Platt Street
Maquoketa, IA 52060
The Honorable Ray Zirkelbach
Iowa State Representative
526 N. Cedar Street
Monticello, IA 52310 -1209