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<br />High Country Citizens' Alliance <br /> <br /> <br />8/29/05 <br /> <br />Colorado Water Conservation Board <br />1313 Sherman Street, Rm. 721 <br />Denver, CO 80203 <br /> <br />Re: Rules and Regulations for Regulatory Floodplains in Colorado <br /> <br />Thank you for this opportunity to comment on the proposed new Rules and Regulations for <br />Regulatory Floodplains in Colorado. These comments are being submitted on behalf of <br />members of the Western Slope Water Network. The Network is composed of High Country <br />Citizens' Alliance, San Juan Citizens Alliance, Western Colorado Congress and Colorado Trout <br />Unlimited. The Network wishes to voice general support for the proposed new rules but wish to <br />propose two specific additions for your consideration related to technical standards. <br /> <br />Rule 11, (L) prohibits a rise of more than 1.0' in the water surface from floodplain impacts. It is <br />not clear whether this is meant to be cumulative or per activity. It is our understanding that this <br />is meant to be cumulative. We suggest adding a sentence to provide clarity on this issue. <br /> <br />Rule 9, (B) requires a total of 4.5' of freeboard for bridges and other structures within levees. <br />But, Rule 11 does not discuss freeboard requirements for floodways and floodplains. High <br />water from floods is often accompanied by debris floating down streams and rivers. This <br />debris, when snagged by bridges can act as a dam, raising water levels, putting additional <br />pressure on bridge abutments. We suggest that the same language from Rule 9, (B) be <br />inserted into Rule 11 so that there is at least 4' of freeboard under bridges at high water as a <br />margin of safety to prevent the snagging of floating debris. We understand that this is likely to <br />increase the cost of streamlriver crossings but the need to have this margin of safety <br />outweighs the additional cost. <br /> <br />Thank you again for this opportunity to offer suggestions to improve the proposed rules and <br />regulations related to regulatory floodplains. <br /> <br />Sincerely, <br /> <br />~~ <br /> <br />HCCA Water Program Director, for the WSWN <br /> <br />P.O. BOX 459, CRESTED BUTTE, CO 81224 <br />970349-6646,970349-0164 (t), e-mail: steve@hccaonline.org <br />