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Home My WebLink AboutA005 - Letter dated September 20, 1991 from FEMA outlining deficiencies a� �NCY M^Y Q` Federal Emergency Management Agency { z a`c\ 0 Region VII 911 Walnut Street, Room 200 Kansas City, MO 64106 SN 2 p The Honorable F. Paul Goodland Mayor, City of Ames 515 Clark Avenue, Box 811 Ames, Iowa 50010 Dear Mayor Goodland: On September 10, 1991, Ross Richardson of this office met with your staff (see enclosed attendence record) and Bill Cappuccio, Iowa Department of Natural Resources (DNR) . The purpose of the meeting was to assess the effectiveness of your community's flood plain management program in meeting the criteria for participation in the National Flood Insur- ance Program (NFIP) . Additionally, the visit provided an opportunity for this office to provide technical . assistance to your staff. During the visit, the following areas of flood plain management were reviewed: 1. The adequacy of existing local flood plain management ordinances in meeting the provisions for participation in the NFIP, outlined in 44 CFR 60.3 . 2. The adequacy of existing mapping supplied by FEMA in the form of a Flood Insurance Study/Flood Boundary and Floodway Map (FBFWM) and a Flood Insurance Rate Map (FIRM) . 3. The adequacy of the existing flood plain development permit system in regulating new developments or substan- tial improvements in the flood plain. 4 . The adequacy of the community's records keeping system. This includes the system for verifying and recording "as built" elevations for elevated or floodproofed develop- ments. 5. The adequacy of the community's enforcement of floodway provisions of the NFIP and those other provisions dealing with watercourse alteration or maintenance of carrying capacity. 6. The conformance of the community's variance procedures to FEMA guidelines. Based on the results of our review, the following assessment and timetable for corrective action is provided. On October 1, 1986, the NFIP standards were revised requiring participating communities to update their flood plain management regulations. Our office has approved the City's flood plain management Ordinance Number 2976, which was passed on May 26, 1987. However, on August 15, 1989, new NFIP standards were issued involving the "substantial damage" concept. Therefore, the City must amend its flood plain management regulations by adding, into the ordinance definitions section, a definition of "substantial damage" to read as follows: t "Substantial damage" means damage of any origin sustained by a structure whereby the cost of restoring the structure to its before damaged condition would equal or exceed 50% of the market value of the structure before the damage occurred. In adding the above definition, the existing definition of "substantial improvement" must be revised to read as follows: �. "Substantial improvement" means any reconstruction, rehabilitation, addition, or other improvement of a structure, the cost of which equals or exceeds 50% of the market value of the structure before the "start of construction" of the improvement. This term includes structures which have incurred "substantial damage" regardless of the actual repair work performed. The term does not, however, include either (1) any project for improvement of a structure to correct existing violations of state or local health, sanitary, or safety code specifications which have been identified by the local code enforcement officer and which are the minimum necessary to assure safe living conditions or (2) any alteration will not preclude the structure's continued designation as a "historic structure" . Once these definitions are adopted, the City's regulations will be fully compliant with the new NFIP standards. Please submit this ordinance amendment to our office within 180 days from the date of this letter. The mechanism for administering the NFIP is the flood maps. Our review of the existing maps, dated January 2 , 198'-Lr indicate they are suitable for issuing flood plain development permits for new development or substantial 2 improvements. However, the City has adopted a more restrictive floodway which was provided by the Rock Island Corps of Engineers. Our office encourages communities to exceed NFIP minumum standards and this type of regulatory tool will assist in reducing future flood losses. If changes are made to this requirement, please inform our office. In 1981, a project was completed on College Creek in which a map revision request was initiated but never completed. Therefore, the City must re-submit this request to our office for processing within 180 days from the date of this letter. The City should understand that this revision will be based on FEMA's one foot floodway. The City has established administrative procedures for regulating new development or substantial improvement in the flood plain. It must be stressed that the City regulate the replacement of manufactured homes in existing manufactured home parks. This requirement is stated in Ordinance Number 2976, Section 9.5, (2) , (e) , (ii) . A separate procedure is suggested in order for the City to meet the above requirement. A reconnaissance of the flood plain was completed prior to our meeting. At 511 S. Maple, it was discovered that fill was placed in the floodway. Evidence of removal must be provided to to our office within 90 days from the date of this letter. During the review, we discovered that the City has regulated flood plain development and recorded and maintained most documentation. However, there are instances where documentation for past development was not available. Please provide our office the "as-built" elevation certificates on the following structures within 90 days of the date of this letter: 1. Storage buildings on 1906-1908, 1910, 1912, 1914, 1918 and 1920 E. Lincolnway. 2. Central Landscape building on E. 16th Street. An area of concern is the City's ability to regulate State-owned development in the flood plain. DNR is going to request an Attorney General's opinion on this matter. Our office will await this opinion before any action is taken. 3 A new program was recently instituted by FEMA called the Community Rating System (CRS) . The CRS was created to provide an incentive for activities that reduce flood losses and support the sale of flood insurance. Any community participating in the NFIP may apply for CRS classification in order to obtain flood insurance premium rate credits for its residents. The community must demonstrate that it is implementing flood plain management activities that exceed the minimum requirements of the NFIP. Ames has indicated an interest in the CRS in the past. Contact our office if the City wishes to make CRS application. There is a potential for future development in the flood plain. This was reviewed in the meeting and the City is aware of all requirements necessary to fulfill its obligation as a participant in the NFIP. Also, we discussed the potential for substantial improvement on existing structures. The following summarizes the City's timetable for corrective action: 1. We request a copy of the ordinance amendment adding the "substantial damage definition and revising the "substantial improvement" definition within 180 days from the date of this letter. 2. We request the after-the-fact map revision request on College Creek within 180 days from the date of this letter. 3. We request evidence of the removal of the fill at 511 S. Maple within 90 days from the date of this letter. 4 . We request copies of the seven elevation certificates within 90 days from the date of this letter. In conclusion, we would like to thank the City in taking the time in meeting with our office. Should there be any questions, please contact Ross Richardson of my staff at 816-283-7005. y R. Harrell, A ting Chief Na r hnologic 1 Hazards D vision cc: Brian O'Connell, Planning Director Don Jackson, Building Official 4