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<br />. <br /> <br />Memorandum/Issues/Rules <br />September 22, 1987 <br /> <br />To demonstrate that our program interfaces with other <br />government programs, we could point out that the Board is <br />the state coordinating agency for the NFIP, so there is no <br />overlap or duplication of effort (although there may be an <br />issue on a technical matter). Furthermore, we could point <br />out that the proposed rules were developed using <br />guidelines and specifications previously prepared by the <br />CWCB, the U.S. Water Resource Council and FEMA. The <br />UD&FCD has been requesting (and receiving) the Board's <br />blessing on all of their studies since the District was <br />created by the Legislature almost 20 years ago. <br /> <br />Rule 3. Purpose and Scope <br /> <br />Some comments on previous drafts were concerned with the <br />scope of the rules. Specifically, there was concern that <br />the Board would become involved with sUbdivision reviews. <br /> <br />. <br /> <br />The draft rules were subsequently clarified to relate to <br />floodplain information developed for zoning purposes <br />only. Review of subdivision drainage reports and <br />development of optimum economic design criteria were <br />excluded, although designated floodplain information may <br />be useful for such purposes. Similarly, identification of <br />the dam failure floodplain is excluded from the rules <br />because it is not used as a standard for land use <br />regulation, although, many of the engineering techniques <br />in the proposed rules would be appropriate for delineation <br />such a floodplain. <br /> <br />An unresolved issue relating to scope is the determination <br />of limits when a community needs to bring a study before <br />the Board for designation and approval or redesignation of <br />an old study. For example, if the 100-year floodplain <br />boundaries are delineated by a developer to subdivide a <br />single lot covering only a very short reach of the river, <br />does that information need to be designated and approved <br />by the Board? Historically, the Board has encouraged <br />delineation of floodplains covering several miles of <br />stream. The staff has intentionally stayed away from <br />specifying a minimum stream reach length, number of lots, <br />lot size, or drainage area because there are so many <br />unique situations in Colorado. <br /> <br />Rule 4. Definitions <br /> <br />. <br /> <br />One of the important concepts to that we need to make <br />clear in adopting the rules is the distinction between <br />"approximate" and "detailed" floodplain information <br />(definitions 2 and 6). The difference should be <br /> <br />-2- <br />