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<br />delineation for the intermediate regional flood will be designated by <br />the Water Conservation Board as a matter of course as the floodplains <br />are delineated. However, it will be sometime after that in the usual <br />course of events before the low hazard zones are delineated. In some <br />,cases, this might follow by a year or two or perhaps even more than <br />that, depending on the pressure to delineate the low hazard zone. With <br />that in mind, it would seem important to me that the regulation should I <br />state that when the low hazard zone has not yet been designated or <br />delineated, the entire floodplain ~ou1d be managed without reference to <br />the paragraph on exceptions. I would presume, Mr. Sparks, that you <br />probably intend that they be administered that way anyway, but it would <br />certainly help in the clarification and the understanding by the local <br />governmental entities if that was actually stated. <br /> <br />Relative to ad hoc decisions when one building permit comes up. which <br />is questionable, I think there is a tendency on the part of the local <br />governmental unit or the administrators to look at it from the stand- <br />point of what effect will that one building, or one fill. or one sub- <br />division. or one shopping center have on the floodplain. No matter <br />what your intent is, the tendency for the local legislative bodies <br />would be still to look at it in terms of that one imposition because it <br />is difficult to look down the road and assume that there will be many <br />other encroachments of a similar nature. I do feel that it would be <br />important to include at the end of. I had section 3 and I don't know if <br />the sections have changed, I had the end of section 3. paragraph 3.1(5). <br />This refers to the old draft and it may still be applicable for the <br />new draft. At the end of that paragraph (5), that the modification be <br />made. by changing the period at the end of the sentence to a comma and <br />adding the fOllowing words. ". assuming equal degree of encroachment on <br />both side of the stream with obstruction of similar character." <br /> <br />When defining the low hazard zones. I don't know if this would be appro- <br />priate to actually have in a regulation or in the guidelines to the <br />regulation. I think I would like to leave that up to staff interpretation <br />and recommendation. When defining the low hazard zone it is my opinion <br />that the low hazard zone should take into consideration the matter of <br />bridge plugging. particularly in urban areas. At our earlier meeting <br />of September we talked about the 1965 flood. We talked about the large <br />number of trailers which plugged tile bridges in the Denver area. My <br />feeling is that when defining the low hazard zone bridge pluggi~g. ,cif <br />fifty percent should be utilized in the hydrological determinations <br />when defining the depth and backwater impacts. What that amounts to is <br />realistically appraising the typical situation which exists in an <br />urban area during a flood period; namely. that the bridges do get <br />plugged. I believe that a fifty percent of plugging of the bridges <br />would be a reasonable value to use in those cases. <br /> <br />Mr.. Sparks.mentioned the survey taken at the Urban Drainage and Flood <br />Control District Seminar on floodplain management. As I recall, it <br />probably was split fifty-fifty down the middle relative to whether or <br />not the one foot or three feet would be satisfactory or not. There was <br />no poll taken of course on what appears in the regulation or the pro- <br />posed regulation at this time. One of the staff members was at the <br />seminar and he did point out that there was valid engineering and <br /> <br />I <br /> <br />-53- <br />