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<br />I feel that there are a few loose ends in the regulation that ought to <br />be covered and I will cover these in written comments rather than take <br />your time now. But for instance, the type of loose end I am thinking' <br />about is related to the low hazard area which has not been delineated <br />in some rural area which is about to undergo subdivision. In other <br />words, only the intermediate regional flood has been delineated at this I <br />point. I think the model floodp'lain regulation should speak stronger, <br />let's say to the actions of the county commissioners or the city or <br />whoever adopts it as to how to handle the situation when it has not <br />been delineated. You don I t have any defined line and there will be a <br />lot of jockeying around in the low hazard area even though it has not <br />been defined. I am sure the purpose of course is that if the low hazard <br />area has not been defined that there would be no exceptions along that <br />line. But it seems to me that this should be made quite clear. <br /> <br />This leads to many problems because then after it is defined if the <br />building is found to be in the high hazard area, you immediately have <br />a problem and liability for the commission or for the city relative to <br />giving the permit in a high hazard area and now it is a nonconforming <br />use~ This can go on and be quite difficult for the local municipality. <br /> <br />I would like to comment very briefly on the low hazard area definition. <br />I think that many of our streams out in the plains we sort of charac- <br />teristically think of them as flowing a mile wide and six inches deep. <br />If we use, and let's say the flow of the velocity is 2.9 feet per <br />second, the regulation for appearances would tend to indicate that the <br />floodplain could be pretty well filled up as long as we kept a foot <br />above the flood profile. However, we all know what this would lead to <br />if we had a mile wide floodplain and six inches deep and then of course <br />the channel in the center which carries maybe ten percent of the flow. <br />What would happen is that the waters would then want to rise creating <br />new flooding. In other words, flooding people who were not in the <br />floodplain but now are in the floodplain because we allowed them to <br />build in a six-inch zone. So I do have a recommendation that would <br />cover that. <br /> <br />In regard to the low hazard area, I feel that your selection, Mr. Sparks <br />and the board, of the one-foot depth is very good and it is supportable <br />by engineering evidence and by experience that when you get in excess <br />of one foot you are beginning to get into problems of floating trailers, <br />floating butane tanks, debris and other hazards. I cannot, however, <br />support the three feet per second. I feel it is too high by approxi- <br />mately one foot per second. I believe that you will find after studying <br />it further that a more supportable velOCity for the definition of the <br />low hazard area would be two feet per second. I think that the three <br />feet per second will lead to some problems. <br /> <br />In regard to one question that was made regarding to small buildings, <br />I think Mr. Sparks answered that when he was talking about debris. I <br />do feel that the small buildings and the miscellaneous things that are <br />less than one hundred square feet in area are the very things that <br />cause debris blockage which occurred in the Denver flood of '65 and <br /> <br />I <br /> <br />-16- <br />