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<br />. <br /> <br />Memorandum/Issues/Rules <br />September 22. 1987 <br /> <br />the standards such as contained in Subpart C <br />of this part. In some instances. community <br />officials may have access to information or <br />knowledge of conditions that require. <br />particularly for human safety. higher <br />standards than the minimum criteria set forth <br />in Subpart A of this part. Therefore. any <br />flood plain management regulations adopted by <br />a State of community which are more <br />restrictive than the criteria set forth in <br />this part are encouraged and shall take <br />precedence." <br /> <br />Subpart C of 60.22. CFR. cited above states in <br />part: <br /> <br />"In formulating community development goals <br />and in adopting flood plain management <br />regulations. each community shall consider at <br />least the ... adverse effects of flood plain <br />development on existing development " <br /> <br />. <br /> <br />Colorado counties have the authority to adopt a Master Plan <br />which may include plans for the development of a drainage <br />basin in all or portions of the county or region (Section <br />30-28-106(d). CRS). <br /> <br />Proposed Rule 5.B.5. Detention. could pose a problem for <br />private entities that are required by local governments to <br />provide detention in order not to increase runoff above <br />historic peak discharges. An understandable argument is <br />why should a developer be required to build a detention <br />pond if government won't give it any credit? However. the <br />problem lies in a demonstrated lack of any significant long <br />term maintenance by private entities of such private <br />facilities. <br /> <br />The proposed rules are silent on the following hydrologic <br />issues: <br /> <br />a. expected probability (a statistical refinement used by <br />the COE but not allowed by FEMA) <br /> <br />b. mixed populations (how to handle flooding types from <br />more than one source. such as rain and snow) <br /> <br />. <br /> <br />c. adjustments in the stream gage records for historic <br />flow or "outliers" (high or low) <br /> <br />-5- <br />