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<br />I <br /> <br />I <br /> <br />and the date..of hearing thereon shall be published." It makes better <br />reading. I think, and more sense. That is all I have. IYIr; Chairman. <br /> <br />Mr. Stapleton: All right. Mr. Ken Wright, please. <br /> <br />Mr. Wright: Mr. Chairman, my name is Kenneth Wright, a consulting engi. <br />neer, a partner in Wright-McLaughlin Engineers. Our work deals with <br />water resources and flood control matters. We do floodplain zoning <br />work and floodplain delineation work. <br /> <br />I, too. am laboring under the problem of not having seen the December 4 <br />draft until just a few minutes ago. I did have the September 11 copy <br />sent and assumed then that no changes had been made from the original <br />draft by the staff. <br /> <br />I would like to turn to section 1.4 under definitions and specifically <br />to low hazard zones. The point I would like to make here is that we <br />need to be cognizant of the fact that larger floods do occur. The lines <br />that are set as low hazard zones in this model floodplain regulation, <br />or let's say the lines that will be set by the municipalities using <br />this model as their regulation, will in effect become encroachment lines. <br />I think over a period of time we will find the development of buildings <br />and fill encroaching up to the low hazard zone delineation line. This <br />does become au encroachment line in effect. I think that we need to <br />give special consideration to the fact that larger floods will occur and <br />we should keep that in mind. Because of that point and because munici- <br />palities and counties are regularly rezoning lands. whether they be <br />zone from industrial to high density residential. or from residential <br />to industrial, or from residential to commercial, I do believe that the <br />aspect of the regulation having two types of low hazard zone criteria <br />it is impractical. I think on a local level it will cause some degree <br />of confusion and over a period of time some chaos in administering the <br />floodplain regulation. I-feel that because local zoning does change <br />you should not have one type of definition for residential and one type <br />for nonresidential. <br /> <br />Relative to the establishment of these lines as in effect being encroach- <br />ment lines, I think you should also be cognizant of the fact that it <br />will be very difficult in the futu~~ to ever move the encroachment <br />lines outward, but they can move inl~ard very easily by merely an act of <br />the local legislative body. Moving outward once development is in there <br />is not practical. I think it would be very difficult to do once the <br />development had reached those encroachment lines. <br /> <br />The comments that were made on the September 11 draft, I don't remember <br />the date. maybe it was september 14 or so. I felt that the comments <br />made by staff at that time were good comments. I am somewhat disappointed <br />to see the change in the definition of a low hazard zone at this step <br />without providing the people, particularly myself, people who wished to <br />comment in greater depth, with facts and figures. I feel that there <br />is some problem with the public being given an opportunity to respond <br />to this very substantial change in the regulation. <br /> <br />Another point which I would like to make is that the floodplain <br /> <br />-52- <br />