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Federal Emergency Management Agency_DFIRMTHE CITY OF ( T' \ Dubuque kraal $ E Atilinedca i I. Masterpiece on the Mississippi 2007 VIA EMAIL Kevin C. Long, Acting Chief Engineering Management Branch Mitigation Directorate Federal Emergency Management Agency 500 C Street SW Washington DC 20472 Beth Freeman, Administrator FEMA Region VII 9221 Ward Parkway, Suite 300 Kansas City MO 64114 -3372 Dear Mr. Long and Ms. Freeman: Service Office of the Mayor and City Council City Hall 50 West 13 Street Dubuque, Iowa 52001 -4864 (563) 589 -4120 office (563) 589 -0890 fax August 25, 2010 SUBJECT: City of Dubuque Technical Appeal of FEMA Preliminary DFIRM This letter provides the initial documentation from the City of Dubuque constituting a technical appeal of FEMA's preliminary DFIRM for the community. This letter transmits preliminary findings on behalf of the impacted property owners and lessees. The City of Dubuque requests an extension of our 90 -day technical appeal period to enable our consultants to complete their analysis. A hard copy of this letter and its enclosures will follow. As you are aware, after reviewing FEMA's preliminary DFIRM sent to the City in July 2009, City staff found extensive errors in the mapping of both existing and new flood plain areas. The City's issue with the preliminary DFIRM is the new areas designated as being in a Zone A. Zone A designation does not provide base flood elevations, but does carry a mandatory insurance requirement for those property owners with mortgages. In particular, the City of Dubuque is extremely concerned by the inclusion of over 1,700 structures, mainly on the North End, in a Zone A that has never been designated as a flood plain in the past. The City currently has approximately 70 structures in designated flood plains. People Integrity Responsibility Innovation Teamwork City of Dubuque Technical Appeal of FEMA Preliminary DFIRM Page 2 The North End of Dubuque is a predominantly older, low to moderate income neighborhood, where the City has promoted redevelopment and homeownership for many years. The designation of this area as a Zone A will reverse years of progress and likely contribute to disinvestment in this crucial area of our community. The City of Dubuque is on record as being supportive of FEMA's project to update the nation's flood maps. However, the methods used to determine the Zone A areas in Dubuque are not up to the standards that any community would be held to by FEMA to make changes to our flood plain maps, either currently or in the future. City staff has found errors in FEMA's preliminary DFIRM that include the Julien Dubuque Monument on top of a bluff being in a 100 -year flood plain, that a Zone A area is mapped going up the side of a bluff, that the elevation of the 100 -year flood is 20 feet higher on the right side on the bank than it is on the left side, to name just a few. FEMA did agree to use the City's two -foot contour data from our GIS, but indicated the revised DFIRM would likely not be available until after our 90 -day appeal period has expired on August 26, 2010. Consequently, the City of Dubuque has retained the services of CDM to do a more detailed analysis of the City's North End and Bee Branch areas as well as a segment of the North Fork of the Catfish Creek as a technical appeal of FEMA's preliminary DFIRM for the community. The consulting firm will complete work by the end of the August. This is an additional expense to the City of $50,000 that the citizens of Dubuque will have to spend to insure that the City has the most accurate flood plain map possible. The City continues to work with FEMA officials as well as keeping our elected representatives at the State and Federal levels informed on our efforts to have the most accurate DFIRM possible for our community. Thank you for your attention to this matter. Please feel free to contact Planning Services Manager Laura Carstens with any questions or information requests at 563.589.4210 or IcarstenAcityofdubuque.orq. Sincerely, Roy D. Buol Mayor Enclosures 4‘,/ cc: City Council Members Michael Van Milligen, City Manager Service People Integrity Responsibility Innovation Teamwork City of Dubuque Technical Appeal of FEMA Preliminary DFIRM Page 3 Barry Lindahl, City Attorney Tim O'Brien, Assistant City Attorney Teri Goodmann, Assistant City Manager Laura Carstens, Planning Services Manager Kyle Kritz, Associate Planner Gus Psihoyos, City Engineer Deron Muehring, Civil Engineer Roger Benson, FEMA Region VII Melissa Janssen, FEMA Region VII Rick Nusz, FEMA Region VII Bill Cappuccio, Iowa Department of Natural Resources Anna O'Shea, Dubuque County Zoning Administrator/ Flood Plain Administrator The Honorable Tom Harkin, U.S. Senate The Honorable Charles Grassley, U.S. Senate The Honorable Bruce Braley, U.S. House of Representatives Sherry Kuntz, Legislative Aide, Senator Grassley's Office, Washington D.C. Richard Bender, Senior Legislative Assistant, Senator Harkin's Office, Washington D.C. Dan Smith, Senator Harkin's Office, Cedar Rapids, IA Linda Lucy, Senator Harkin's Office, Dubuque, IA Mike Goodman, Legislative Director, Representative Bruce Braley's Office, Washington D.C. Pete DeKock, District Administrator, Representative Braley's Office, Davenport, IA John Murphy, Representative Bruce Braley's Office, Dubuque, IA Amanda Wilson, AECOM, 2405 Grand Blvd, Suite 1000, Kansas City MO 64108 Service People Integrity Responsibility Innovation Teamwork Memorandum To: Deron Muehring, Engineering Department, City of Dubuque, IA From: Susen Gali, CDM Date: August 25 2010 Subject: Data Used for Developing the Bee Branch Watershed Preliminary Floodplain Map CDM has been tasked to develop preliminary floodplain mapping based on a detailed study for the Bee Branch Watershed. This memorandum serves to present preliminary results and present the data used and assumptions made for developing the preliminary floodplain mapping. 1. Hydrology and Hydraulic Modeling • In accordance with FEMA guidelines, CDM is using a hydrology model that they built in 2004 using HEC -HMS; a computer program developed by the US Army Corp of Engineers. The HEC -HMS model was updated to reflect the Carter Road Detention Basin that was constructed in 2003 and the W. 32nd Street Detention Basin that was constructed in 2008 -09. Per FEMA guidelines, the 100 -year 24 -hour storm was used for producing the peak runoff flows. • In accordance with FEMA guidelines, CDM is using a SWMM 4, hydraulic model that they built in 2004. The SWMM 4 computer model that was developed by the US EPA was used for routing the hydrographs through the storm sewer conduits. • 594.3 elevation was used for the Mississippi River stage as the is the normal, or 50% exceedance, river stage based on data from the US Army Corp of Engineers. • CDM is in the process of updating the 2004 hydrology and hydraulic models in accordance with the FEMA's guidelines, policies and specifications. 2. Topography Data • 2009 electronic contour data from City of Dubuque was used for delineating the floodplain. The contours are 2 -foot contours with a stated accuracy of one foot Based 1 Bee Branch Watershed August 25th, 2010 Page 2 on City survey data, the accuracy of the City's contour data has been found to be within a half foot. 3. Assumptions • Consistent with the US Army Corp of Engineers' conclusion, the Bee Branch watershed peak stages are independent of Mississippi River peak stages. • Free outfall from the 16th Street detention basin to Mississippi River • Levee along the Mississippi River is certified and the Mississippi River peak stages will not have impact on the Bee Branch Watershed. • 100 -year 24 -hr is assumed to be the critical storm for the Bee Branch Watershed. Further critical duration analysis is required to identify the critical storm which produces the peak discharges and stages for the watershed. Depending on the identified critical storm the floodplain boundary will change for the watershed. 4. Preliminary Findings • The preliminary peak runoff flows predicted using the detailed HEC -HMS model is significantly less than the flows predicted by FEMA using approximate regression equations. • The preliminary flood plain limits for the Bee Branch are significantly less than the limits reflected in the DFIRM currently being considered for adoption by FEMA. This could be attributed to the decreased peak flows and the use of 2 -foot contours utilized by CDM versus the 10 -meter contours utilized by FEMA. 2 600 1200 2,400 Feet 1 1 inch =692 feet Bee Branch Watershed (Downstream Reach) Preliminary Floodplain Map Preliminary100Yr Floodplain (CDM) SH FA 2009 Bee B ranch (FEMA) 1