1997-09-15_REVISION - M1981302

• Permit No: M1981302
• IBM Index Class Name: Revision
• Doc Date: 9/15/1997
• Doc Name: RATIONALE FOR APPROVAL OF TR TR-06 WESTERN MOBILE BOULDER INC DEEPE FARM PIT PN M-81-302
• Type & Sequence: TR6
• Media Type: D
• Archive: No

Rationale for 7R-06 Approval-Western Mobile Page 12
Deepe Farris Pit, Permit No. M-81-302
September 15, 1997
risk-based aspects of flood management that address this concern are discussed
previously in this document.
Other Agencies' Considerations
During the hearing on July 23, 1997, the Mined Land Reclamation Board expressed an
interest in the jurisdictions of the various agencies having an interest in flood plain
management and directed the Division to solicit the input of these agencies regarding the
technical revision TR-06 application. A discussion of these agencies and their input is
provided here:
1. FEMA did not respond to the Division's request for input to the technical revision
TR-06 application. It is the Division's understanding that FEMA's flood plain
management responsibilities are primarily to certify flood plain mapping and analysis
efforts, provide guidelines and information on flood plain management, and, together
with the Federal Insurance Administration, administer the National Flood Insurance
Program. While FEMA does not have regulatory authority over flood plains, they do
have the authority to exclude areas from eligibility for the National Flood Insurance
Program if their flood plain management guidelines are not adopted and enforced
through local codes. It appears that FEMA does not have the authority to specify if,
how or where a flood control structure, such as the Deepe Farm Pit perimeter levee,
should or should not be constructed. However, once a levee or other flood control
structure is built, FEMA must make a finding that the structure meets federal
standards before the flood plain maps can be changed to exclude areas protected by
the structure from the area of special flood hazard.
2. The Urban Drainage and Flood Control District was established by the Colorado
legislature in 1969, for the purpose of assisting local governments in the Denver
metropolitan area with multi jurisdictional drainage and flood control problems. The
District operates five programs: Master Planning, Design and Construction,
Maintenance, Floodplain Management, and South Platte River. It is the Division's
understanding that the District has the authority to regulate flood plains but has
chosen not to do so as long as the local governments implement their own regulations.
The District did provide written comments regarding technical revision TR-06 in a
letter to the University of Colorado dated June 11, 1997. In that letter, it is stated:
"We believe that this dike, or levee as we prefer to call it, should definitely remain in
place unless or until an alternative flood control or flood mitigation strategy is in
place." It is further stated in the District's letter that "...Flatiron Companies offered
to add a foot to the freeboard, making a total of four feet, to account for potential
inadequacies in past hydrologic analyses of South Boulder Creek. We felt that the