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<br />M r. John Matticks <br />Mr. Ross McKay <br />September 14, 1993 <br />Page 2 <br /> <br />Preliminary Efforts at Correction <br /> <br />On June 23, 1993 I attended a meeting at Florence at which Dr. John Liou of your Region VIII <br />Office was a participan':. One of the results of that meeting was that a consultant retained by <br />the City obtained a copy of the HEC-2 run performed for FEMA by Love & Associates. If I <br />understand correctly, that consultant will modify that run to include current topography instead <br />of the "old" topography which was provided by the city to Love & Associates. Presumably the <br />developer will then have that consultant compute fIll elevations from the revised HEC-2 run and <br />complete the preparation of their site for development. This is where the hydraulics get <br />complicated. <br />Because the flow splits result in overbank flooding that is deemed "shallow flooding" by <br />FEMA's definition, a f100dway was calculated based only on that portion of the lOa-year flow <br />that remains in the channel. The portion of the total flow that splits and flows overland is <br />several thousand cubic f'~et per second. That flow is not included in the f100dway computations, <br />Clearly some explicit provisions must be made for that water to go somewhere if there is <br />massive filling in the overbank. That would be a primary purpose of a floodplain development <br />permit. In an effort to encourage consideration of such problems I sent a letter (attached) dated <br />July 19, 1993 to the mayor of Florence. To date I have received no response, <br /> <br />Problems for the NFIP' <br /> <br />I am writing the two of you for two reasons. The first is that I feel the expenditure of LMMP <br />funds for Florence has been a waste of public funds, It has been a waste of public funds <br />because the floodplain delineated for FEMA by Love & Associates no longer exists. It was <br />substantially changed before the delineation was ever published. In retrospect the floodplain <br />should have been studied by the developer and/or the City of Florence, We have many other <br />communities in Colorado where that $35,000 could have been spent. I do not blame Dr. Liou <br />or our own office. We acted in good faith. So did Love & Associates, I believe we need to <br />learn from this experience and do better in the future, but in the meanwhile I feel the City <br />should know that allowing a floodplain to be substantially altered in the middle of a Federally <br />funded study without notifying any of the parties involved is unacceptable. Such activities are <br />detrimental to the NFIP's mapping efforts. <br /> <br />The second reason I am writing is that I don't feel that Florence's failure to require a floodplain <br />development permit for this project has been dealt with forcefully enough. I have not heard any <br />serious mention of possible probation or suspension. I have seen no letters reprimanding the <br />City or requiring immediate corrective action. This is despite the fact that Florence city officials <br />have been advised for several years by FEMA's Region VIII staff and by Colorado's CAP <br />Coordinator of the need to issue permits fo all floodplain development. The City cannot, <br />