COM 0176.083 2006-2008 - Laserfiche WebLink

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BILL 51 DRAFT 3 DPW COMMENTS - 5/23/07 Sec. 27-23(b): The changes may be in violation with the NFIP; and needs to be discussed with State NFIP Coordinator. Sec. 27-24(d) We would like to revise this section to read: (d) New construction, improvements to repetitive loss structures, and substantial improvements within the general floodplain shall satisfy the requirements set forth for Zones AE, AH, AO, X (shaded). or VE as is determined to be applicable by the director of public works based on base flood information and floodway data obtained through subsections 27-24(a) and 27-24(b). Sec. 27-24(e): There is no economic, scientific or technical justification that we are aware of that warrants raising elevations by a minimum of 1-foot. Further, the proposed language will result in a contradiction with section 27-23(b) as structures within V and VE zones do not have this 1-foot elevation requirement. If this section is to be retained, we suggest revising the section to read: (e) The director of public works may waive informational requirements if the director of public works has sufficient information to make an evaluation and determination regarding flood elevation or may request further information, including a detailed flood elevation study and a drainage report, to evaluate flood risks and determine the applicability of flood construction and development standards except that all structures within Zones AE AH. AO, or X (shaded) shall be at least one foot above the approved base flood elevation. Sec. 27-24(h): The intent of this requirement is vague, uncleaz and seems to make no sense. The word "elevation" is being misused and needs to be deleted. Base flood is a design parameter used to determine the amount of water a drainage facility can carry. Base flood elevation is a term use to describe the depth of flow at a particulaz location so base flood elevation has no meaning in the design of a drainage facility. It is unclear why or for what purpose the phrase "for disposal of stormwater" is included. We need to know the intent and purpose of this section before we are able to make a definitive analysis or suggest appropriate language. Sec. 27-25(a): This section addresses improvements adjacent to drainage facilities outside Special Flood Hazard. In many cases the drainage facility will be a minor structure such as a drywell or a Swale or ditch. The proposed change will mandate a property owner to pay for an engineered flood study regardless of whether it is needed or not. It should be within the Director's discretion and professional expertise to determine when such a study is needed. Page 7 of 8