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<br /> BILL 51 DRAFT 3 DPW COMMENTS - 5/23/07 <br /> Sec. 27-18(c)(6): We do not believe that controlling the amount grading to be the best <br /> approach to address flooding and erosion. Chapter 10, 23 & 25 already <br /> addresses these issues in the urban environment. There are many other <br /> stormwatet management techniques that should be first considered, such as <br /> limiting the amount of impermeable surface and/or infiltration treatments to <br /> retain a given volume of water rather than just limiting the amount of <br /> grading which will have many serious unintended consequences. We suggest <br /> discussing this matter further with Planning Department and DPW. Should <br /> this issue be pursued in it's present form, we will need to discuss impacts <br /> with our Planning Department, Real Property Division and Finance <br /> Department as the 10 and 20 percentage requirements seems to have no <br /> economic or technical justification that we can see. <br /> Sec. 27-18(d): We would like to add a new section labeled 27-18(d)(5) be added that would <br /> read as follows: <br /> (51 Within Zone X (shaded): <br /> f~ For new construction. the lowest floor shall be elevated at least <br /> one foot above the hi¢hest adjacent ¢rade. <br /> f~ New construction shall be required to provide adequate <br /> drainaee paths around structures on slopes to ruide floodwaters <br /> around and away from proposed structures. <br /> Sec. 27-18(d): There is no economic or technical justification that we are aware of that <br /> warrants raising elevations by a minimum of 1-foot. FEMA's repetitive loss <br /> data shows that damages are reoccurring in coastal high hazard areas (V & <br /> VE), yet these zones do not have the additional 1-foot requirement that have <br /> been applied to the other zones. <br /> Sec. 27-18(e): We would like to revise this section to read: <br /> All new construction, improvements to repetitive loss structures and <br /> substantial improvement within areas of special flood hazard and Zone X <br /> shaded shall be certified as required by the standards of section 27-17. <br /> Sec. 27-20(a): We would like to revise this section to read: <br /> (a) All subdivisions and other developments within areas of special flood <br /> hazards, Zone X (shaded). and flood-prone areas shall: <br /> Sec. 27-20(a)(4): This section may be in violation with the NFIP; and needs to be discussed <br /> with State NFIP Coordinator. <br /> Sec. 27-20(d): The changes may be in violation with the NFIP; and needs to be discussed <br /> with State NFIP Coordinator. <br /> Page 5 of 8 <br /> <br />