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<br /> BILL 51 DRAFT 3 DPW COMMENTS - 5/23/07 <br /> Further, should this condition be retained the Department of Public Works <br /> does not have the hardware, software or expertise to address the storage of <br /> electronic copies. The implementation of this requirement needs to be <br /> discussed with the Data System Department. <br /> Sec. 27-16(c): The change is not in compliance with the NF]P; and needs to be discuss with <br /> State NFIP Coordinator. For FEMA map revisions, the process is described <br /> in the following section 27-16(d) through the Letter of Map Revision <br /> process. The intent of this section is to interpret boundaries of approved <br /> FEMA maps. <br /> Sec. 27-16(f)(1): Because many natural watercourses are not able to carry the volume of water <br /> generated by a 100-year storm, bank overflows are not uncommon. As a <br /> result, the proposed language, if applied indiscriminately, will result in the <br /> redirection of downstream flows in unstable areas such as South Kona where <br /> watercourses are still very immature. The County will then be liable for any <br /> resulting flood damages. Further, would a property owner have to improve a <br /> channel if he just wants line a channel to protect his property from erosion? <br /> We see little benefits and a lot of risks and costs to a property owner to have <br /> this provision. Alteration or relocation of watercourses must be done <br /> prudently and analyzed on a case by case basis by a licensed engineer to <br /> ensure that there is minima] disturbance of natural flow pattern onto adjacent <br /> properties. <br /> Sec. 27-16(f): We would like [o add a new section labeled 27-16(f)(3) be added that would <br /> read as follows: <br /> f~ Whenever a nronosed alteration or relocation occurs within a snecial <br /> f[nnd nroa that inap chance the base Rood elevation, technical and <br /> scientific data through the Conditional Letter of Man Revision <br /> yroceess shall be submitted to and by annroved by FEMA. Within <br /> six months of the completion of the alteration or relocation, the <br /> Federal Insurance Administration shall be notified through the <br /> Letter of Man Revision process in accordance with section 27-16(d) <br /> of this chanter. <br /> Sec. 27-17: We would like to revise the first paragraph of this section to read: <br /> Pre-construction and post-construction certification of elevation and <br /> floodproofing of new construction, improvements to repetitive loss <br /> structures, development, and substantial improvements within areas of <br /> special flood hazards and Zone X (shaded) shall be submitted to the <br /> director of public works and shall be maintained as a matter of public <br /> record. <br /> Page 4 of 8 <br /> <br />