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<br />.- <br /> <br />. <br /> <br />. <br /> <br />September 4, 1997 <br /> <br />6. Not approve any flood protection levee certification without the agreement of the City of <br />Boulder and Boulder County, as regulatory and interested government entities who are <br />potentially damaged by the certification if the flood protection levee fails. <br /> <br />The City of Boulder has identified significant errors and omissions in the G&O South Boulder Creek <br />floodplain study that we believe warrant FEMA's reconsideration of the studies adoption for local <br />floodplain regulation. A detailed discussion ofthese errors and omissions is provided as Attachment <br />D, and is based on recent review and analyses of the G&O study completed by City technical staff <br />and local professional engineering consultants having expertise in floodplain analysis. Professional <br />engineering consultant review was provided in the studies enclosed as Attachments E and F. <br /> <br />The G&O South Boulder Creek floodplain study was originally prepared under contract for the <br />UDFCD and Boulder County, and did not involve City funds or approvals. The majority of South <br />Boulder Creek is located outside the City of Boulder in unincorporated Boulder County. The G&O <br />study and previous FIRMs identified no South Boulder Creek floodplain impacts to incorporated <br />lands upstream of South Boulder Road. Because the G&O study failed to identifY any potential for <br />flooding into local neighborhoods north ofD.S. 36, it was virtually impossible for City officials to <br />realize that the G&O mapping placed land within the City in the lOO,year floodplain while it <br />removed unincorporated lands from the IOO,year floodplain. As a result the City was unable to <br />make an informed decision about the reliability and accuracy of the G&O study. <br /> <br />Ii <br /> <br />The City of Boulder recommended in good faith to FEMA that the G&O study be included in the <br />1988 revisions to the local PIS and FIRM based on an assumption that the study, which was adopted <br />by Boulder County and the UDCFD, was complete and accurate. Given this belief, the G&O was <br />not the subject of critical City review in the unincorporated areas and did not undergo a City of <br />Boulder public review process prior to FEMA adoption. <br /> <br />The City now believes that we were in error in accepting the results of the G&O study, and in our <br />recommendation for its inclusion in the 1988 FIS and FIRM. Since we had no previous knowledge <br />that the G&O study was incomplete and misrepresented physical changes in the stream corridor, we <br />are requesting that FEMA now take corrective actions in addressing the issues the City has raised. <br /> <br />The City feels that it is urgent that the danger to its citizens be addressed by suspending the use of <br />the misleading regulatory maps and going back to the use of previous maps that do not rely on the <br />existing Flatiron Property berm. CertifYing the berm as a flood protection levee prior to a thorough <br />examination of the alternatives, such as a larger opening under U.S. 36, would force reliance on a <br />less reliable alternative that unnecessarily prolongs the current risk to our citizens. This is an <br />unacceptable situation. <br /> <br />Accordingly, we are seeking FEMA cooperation in proceeding on an immediate and expedited <br />master plan, considering all the risks and all the alternatives. The City of Boulder is willing to invest <br /> <br />4 <br />