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o We are unaware of any jurisdiction that requires <br /> fully conveying or disposing of the 100 year Flood. <br /> 0 100 year standard would significantly limit the use <br /> of affected properties. <br /> o Would result in less dense growth and more sprawl. <br /> <br /> • Pertaining to Agricultural Lands/ Subdivisions: <br /> o Much of Ag lands are unimproved and the flooding <br /> that occurs on those are a natural phenomena. <br /> o The imposition of the 100 year standard is of serious <br /> concern. If it can be accomplished, will be at <br /> additional significant cost and likely not meet <br /> current cost/benefit ratios to determine feasibility. <br /> <br /> • 10% Grade and 20% Develouable Area: <br /> o Appears unworkable and a provision of great <br /> concern. <br /> o Example -flat lands can have flooding as we have <br /> seen in Hilo in the Bay Front area. <br /> o There needs to be a methodology to evaluate and <br /> address this. Believe this task that may be un- <br /> achievable and that current practice and mapping <br /> can be improved to address suspect areas/regions. <br /> o We already have FEMA Flood Maps. These are the <br /> source documents used in determining in what areas <br /> development in the flood plain should be a concern. <br /> o For FEMA Flood Maps that do not address a <br /> certain specific location, a Flood Study and <br /> modeling is currently required by Civil Engineers to <br /> address flooding. <br /> o Could seriously affect affordable housing. <br /> o Could seriously affect farming and pasture <br /> enhancements. <br /> o Seriously affect quarrying, building of Roads and <br /> other improvements. <br /> <br />