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Memo to File M-81-302 -4- June 7. 1997 <br /> the issue of internal drainage is one of the primary FEMA <br /> criteria for evaluating the suitability of a flood control <br /> levee, we would also request that the approval of an amendment <br /> affecting internal drainage also be withheld. <br /> FEMA' s concerns with internal drainage of levee systems rise from <br /> the fact that areas behind levees are often subject to retention of <br /> runoff that would have otherwise flowed into the river or stream <br /> had it not been blocked by the levee system. Internal drainage <br /> problems can be severe when dealing with the extensive levee <br /> systems that have been installed in some locations in the United <br /> States, such as the levee systems along the Mississippi River and <br /> its tributaries. Internal drainage of the approximately 6000 foot <br /> long perimeter levee at the Deepe Farm Pit does not pose a <br /> technically difficult problem, and is not a basis for withholding <br /> approval of the Deepe Farm Pit amendment AM-002 . This position is <br /> only reinforced by the fact that drainage of the Deepe Farm Pit <br /> permit area is routed to the same location at the north permit <br /> perimeter under both the existing approved plan and under the plan <br /> Proposed in the amendment . . <br /> Conclusion <br /> The Division' s decision to recommend approval of the pending <br /> amendment to the Deepe Farm Pit permit over the objections of the <br /> Boulder County Commissioners, is appropriate . <br /> C:\WP51\D£EPEPIT-W43 <br />