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~ The Honorable Bill Tedesko, Mayor July 19, 1993 Page 2 There was, however, another change that was important to several of those in attendance at the June 23 meeting, That change was that the area of shallow flooding to the west of the Oak Creek channel, which includes the subject property, is now shown as experiencing up to 3 feet of overbank flooding, as opposed to a lesser depth on the previous draft. Obviously the depth of flooding will affect the need for fill, grading, or installation of drainage and flood control improvements to mitigate the flood hazard on the site, At this point I want to stress that the work by Love and Associates is still in draft form, It has not been through the review and approval process at FEMA's headquarters in Washington, D,C. That means that decisions regarding the development of that site cannot be made simply by reviewing the draft floodplain maps and using those maps as the basis for a design, The draft information should definitely be considered in arriving at an engineering design for the site, but the official maps are the Florence FlS for the "old" part of the City and the Fremont County FlS for the newly annexed part of the City. Given the nature of the floodplain in Florence, I would strongly advise any developer in that area to retain a professional engineer familiar with floodplain hydraulics so that engineer can properly utilize the information in all three studies, Steps to be Taken by the City of Florence Two steps need to be taken by the City and the developers to assure compliance with the City's adopted floodplain ordinance and to assure that the final product of FEMA's current restudy effort is the most accurate floodplain available for Florence, First, the City must obtain from the developers an application with all of the supporting engineering documentation needed for a floodplain development permit. Essentially any activity in an identified floodplain in a community participating in the National Flood Insurance Program must be preceded by an approved floodplain development permit issued by the local government. The work performed on the site so far has been done without a permit, which is a violation of the City's floodplain regulations. No further work should take place on the site until a permit has been issued, Second, since the floodplain has been substantially altered, the developers should submit to the City all of the engineering information that would be necessary for the City to be able to request from FEMA a Letter of Map Revision (LOMR), The LOMR is the way that a floodplain delineation is officially changed by FEMA to reflect physical or other alterations to the floodplain, The draft analysis by Love & Associates does not reflect the changed topography at the site. As a result, it does not adequately represent flood conditions at the site. Given that change in floodplain topography and the apparent desire by the City and the developers to remove the floodplain designation from the site, a LOMR submittal seems to be the best way to meet everyone's needs.