HomeMy WebLinkAbout0346.000•
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15
June 7. 1990
THE HONORABLE CITY COUNCIL
Palo Alto. Calitornia
flood Hazar4 Regulations SUMary and RecQmmendations
Members of the council:
Over the past six: months" oS number of issues bave-arisen concerning
the Federal Emerqency Xa.nagement Agency 1FEMA) and the National
Flood Insurance ProqraD~ This report summarizes past and current
activities on ~lood-related issues and makes recommendations
regarding fl.ltur-e actions.
Background
Following is a summary of staff's Involvement with Council on FEMA
issues. On January 22, 1990, Cou·neil received an informational
report describing: the City's flood hazard regulations and their
impact on building construction In Palo Alto (O!R: 124: 0) .. Cn
February 1.2. 1990, council received a flood hazard regulation
status report which provided additional information and
clarification in response to questions received :from the public
{CHR.: 162 :0).. At that Ileeting, Council directed star.! to: (1)
~or~ with FEMA to set up a homeowner's ~orkshop on understanding
special flood hazard area regulatIons; (2) work with EEMA and
congressman CampbE~l and Senators Cranston and Wilson to revise the
regulation regarding the 50 pe~cent rule and to redefine the types
of flood zones; and P) report on the cost and benefits of a
hydroloqical study.. Cou·ncil receivea an infoncational status
report (CMR.:19B:O) on March 12 .. 1990,. 'Which was followed by two
study sessions.. The first study session .. held April 26" 1990"
focused on freshwater fl.ooding and improvements to M3ta.dero .. Adobe,.
Barron and: San Francisquite> Creeks.. The seccnd study session, held
Hay 7, 1990 .. related to saltwater flooding and improvements to the
outboar~ levee system. en May 14.. 1990, council received
supplamental information on special flood hazard a~ea certificates
which was raised as an issue during the May 1 .. 1990 study sessi~n
(CMR:299: 0).
ActionS and Issyes
In response to Council direction and citi~en feeQback, the
following is a summary of administrative# legal# legislative and
physical issues regarding the FEMA/flood regulations matter. Past
actions .. if any .. are listed aLong 'With the current activity en
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these issues. 1..150, a staff recommendation is made to Council,
where approprIate.
AdministratIye -Past Astiops
December 1989
February 1990
February 21 ~ 1990
February 26, 1990
March 21, 1990
CM]O:346:0
st~ff received ,.,·ritten quic!ellnes from
FEMA which clearly indicate that economic
hardship Is not a valid reason Cor
qranting a variance. Previously, staff
interpreted the regulatl~s to allow
variances based on financial
considerations.
Over 150 consultants and contractors ~ho
do business in Palo Alto were sent
letters reminding them of FEMA.
requirements. The handout ... -Requirements
tor Construction in a special Flood
Hazard Area~· and a question and answer
sheet bi9hllghting FEMA" requirements,
were made available to the public at the
plan check counters in the Public Works
and Planninq Depart~ents.
Staff attended a panel discussion
conc:erninq FEMA. regulations, which 'Was
hosted by t.l1Q Palo Alto Board of
Realtors e Staff and repr-ese!'tatives from
the Santa Clara Valley Water District
(District} and the Anny Corps of
Engineers (Corps) responded to questions
from the public.
In response to public concern,. staff
established $120/square foct as a -rule
of thumb-for the market value of
property in determining ·substantial
improvements· under FEMA's SO percent
rule. Thirty-five of over 2~O building
permit applications backloqqed in the
Inspection Services Division yere
originally found to be in non-compliance
with FEKA requlations. As a result of
the $120/square -toot market valuation,.
this number ~as reduced to six.
Statf conducted a bomeovner 1 s workshop at
David Starr Jordan Middle School on
special flood hazard area resulations.
Staff and representatives from FEMA, the
District,. and Corps made presentations
and responded to citizen questions.
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April 1990 The first edition of -FloodW'atch .. •
created to provide the community with
current, accllrate infol'1l'lation about
developments in flood control.. was
published in a -City Scape insert,· Which
was distributed with the ·Palo Alto
Weekly. II
April II. 1990 Staff attended a FEMA yorkshop in
Petaluma to obtain information regarding
the community Rating System (CRS}
Program.. The CRS program is discussed
later In this report.
April ~O. 1990 A community assistance visit was
conducted by FEMA representatives ~bo
audited the City's ~anaqement of the
National Flood Insurance program ..
Results of the audit are expected this
summer.
April 28, 1990 EEMA requlation info~atfon was
distributed to the public and m~n~
workshops were giv~n by staff at a Palo
Alto Real Estate fair.
May U90 The storm Dr-ainaqe Enterprise Fund was
designated as the focal point for ForA.
flood issues ..
June 1990 The second edition of -Floodwatch-was
published with -city Scape,· which is
distributed with the ·Palo Alto Weekly.-
Administratiye -CUrrent Actiyity
1. Pre-qual i fication Form. A new fOnl.. which will be
available next month, is being developed to enable
homeowners in special flood hazard areas to pre-qualify
their houses to future buyers. Based on survey
infonnatlon provided by the homeowner that verifies
compliance with FEMA requlations ... the fOrll would ensure
that any future substantial remodeling could be performed
without having to raise the existing floor or house. The
information would need to be certified by a surveyor as
being accurate. Staff does not recotmnend. t.hat the City
assume responsibility for providing this information .. as
surveying the ' .. OPO properties in speCial flood bazard
areas is too massive a project for in-bouse staff. Costs
are estimated to ranqe from $600,,0'0'0 to $81)0,00.0 if dor.e
by outside contract.
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.2.alJalnaxy S\lXYCy IDfonation. staff ~ill assist
homeowners Who are contemplating making substantial
improvements to their bomes in special flood hazard areas
by p~oviding eppro~imate elevations in the public right
of-way. This information will give homeowners an idea as
to the extent. if any, that the floor or bouse needs to
be. ra.ised to .. eet FEMA re.q\Jirements,. The bomeowne_:f" ~hen
can dec1de wnether t.o proceed with the improvements
'Without incurring the. expense of a surveyor. In the
event the homeowner undertaJces a remodeling project ..
he/she would need tD provide the city with exact
elevation data obtained by a surveyor or engineer to
certify co~pliance with rEMA regulations. very often,
this can be obtained from the designer who prepares the
remodeling plans. The City CAn assist by referring the
designer or surveyor to existing City survey bench marks.
Edueatlon/out"lIch. The Storm Drainage Enterprise Fund
will be the focal point for all futUre public awareness
programs and will continue to educate and inform the
public on FEHA issues.. An inforlllation video tape
explaining the FEMA flood program Is beinq developed by
staff and -Fioodwateb-will continue to be published on
a quarterly basis. Staff is in the process of organizing
a workshoP for surveyors" civil engineers and other
intereste~ parties in July. The workshop will cover the
survey information required for verifying compliance 'With
FEMA floed regulations (pre-qualification form) and for
removing a property froll the flood map (Letter of Map
AlIIendment).
Favorable InterpretatIon Of fEMA xaoulatious.. Staff is
continuing to meet with representatives of FEMA in an
effort to Identify FEKA regulations whIch can be
interpreted mor-e favorably for homeowners in special
flood hazard areas. Recent examples include second story
additions and 9arages~ Under certain circumstances, via
a variance, a homeowner vill be able to construct a
second story addition without having to raise the
existing house above the flood plain, even if the
addition is considered a SUbstantial impr-ovement~ under
certain circumstances, via a variance" a qarage or
storage area can be built below the flood plain level~
Staff also will assist homeowners by providing advice on
~akiD9 modest remodeling changes that could avoid
enacting the FEMA 50 percent rule.
AdministrAtiye -Pending Issues
1. o:;elf-Insuraoce. Staff has looked into the option of
providing self-insurance and 'WithdraWing from the
National Flood Insurance Program. Congr-ess adopted the
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Flood Disaster Protection Act of 1913 requiring the
purchase of flood insurance as a condition for receiving
any torm of federal or federal-related tinancial
assistance wIthin an ident.ified special flood hazard
area~ The Act also requires that no such federal
financial assistance be provided within a special flood
bazard area unless the community i5 participating in the
program. All federally assisted loans secured by
property in special flood bazard areas Blust be protected
by flood insurance., which is also required by most
lenders. Without federal underwritinq, insurance
companies will not provide flood insurance coverage and
due to the magnitude of the risk, underwriting for self
insurance is not possible.. Withdrawing from FEMA would
effectIvely elim.inate all financing for building
construction and remodelinq or resale of property in
special flood hazard areas. Not only would flood
insurance be affected by withdrawal from the National
Flood Insurance Program, but other federal aid within the
flood plain, such as Community Development Block Grant
funds and loans from the Federal Housing Administration,
the Veteran's Administration end t.be Small Business
Administration 'Would be cut off. Also ... other federal
disaster assistance for reconstruction of damage~
buildings would not be available in special flood hazard
areas. The loss of fede.ral funds could severely hurt the
local community. For these reasons, staff does not
recoamend that t.he City 'Withdraw from the. National Flood
Insurance Program and self-insure.
Community Bat.ing System program. To reduce flood
insurance premiums, FEMA is implementinq a community
Rating System (CRS) Program. Insurance premiums for
citizens would be lowered based on the City's involvement
in up to 18 community activit.ies organized under-four
cateqaries (public information: mapping and regulations:
flood damage reduction; and flood preparedness). A
credit voula be 9i~en for each ~ctivity dependinq upon
how veIl it is performed and documented~ Some of the 18
activities are already being: performed by staff and would
receiVe credit immediately .. if documented properly.
It is recommended that council have staff evaluate the
costs and benefits of joining the CRS Proqram. staff
would review-the. list of oomniunity activities, and return
to Council vith a pr~sal tor City involvement in the
Program. Some activities may not be cost effective due
to the level of city effort versus credit received.
Also, temporary or contract assistance will be required
to administer this new program so as not to adversely
affect other storm Drainage Enterprise Fund activities,
such as the expanded Capital Improvement Program.
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Legal -fending ISBues
CMR:346:0
HydrOlogic study.. council requested that staff look into
the possibility of challenging the hy~rologic study used
as iii basi. for FEMA flood maps in order to reduce or
ell.1nate the 10~-year special flood hazard area
boundaries in palo Alto. This would require performi~~
a hy:!rologlc study of the entire SOuth Bay Area. It
should be noted that San Francisco Bay, and its shoreline
bave been the subject of numerous studies which confirm
the tact that there Is a siqnificant threat of flood
damage in Palo Alto due to high tides.
A FEMA stUdy performed in 1978 and update~ in 1987 was
used to establish the flood zone maps. The study,
per~oraed by George Nolte and AssocIates and updatea by
OKA Consulting Engineers" Inc." uses extensive tidal -data
provided by the Corps to establish saltwater flood
elevations~ The study examined exIsting and preQicted
sea level changes and their. effects on ann·ual maximum
tides measured in San Francisco Bay, taking into account
aite-specific wind conditions. The COrps study on the
San Franci&co Bay Shoreline co~pleted this ye~r confirms
tIdal ~ata contained in the FEHA st~y.
It should be noted that both FEMA and the Corps use the
same tidal hydrologIcal data to create their flood zone
maps~ The reason the FEMA maps shol.' oS larqer floodplain
is d·ue not to hydroloqic data, but to differing policies
concerning the levee system. The Corps' ·San Francisco
Bay Shoreline Study Public Notice-states" -the economic
and environmental principals and guidelines for water and
related la.nd resources implementatIon studies require
that the formulation and evaluation o~ alternative plans
be based on the most likely condition-(emphasis a~ed).
The corps' policy Is to lIap the flood plains according to
the most likely condition" which is overtopping of the
levee system~ FEMA's policy. on the other hand, is to
Ilap the flood plain under the worst case conditiO-D~ FEMA
assumes that a levee system is substandard and subject to
complete failure if it has less than two feet of
freeboard and is not engineered or maintainetl by a public
agency. FEMA takes this more conservative approach in
order to minimize the insurance liability inherent with
their responsibility to protect against threats to the
health and safety of people and property during-a flOOd ..
Challenging the hydrology of the SOuth Bay ... ould be
extremely costly and ~ould not address the fundamental
difference between the Corps and FEMA, which involves
policy, not enqineerlnq. Foster City decided to perform
an hydrology study challenging the FO!A flood maps in its
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jurisdiction because the maps did not take into account
an existing protective levee system. Foster Ci~y spent
over $200,000 on the st.udy. 'Which concluded. that the
existill9 levee was adequate based on its past performance
In storms over the last >century and based. on such factors
as expected wind Intensities and tidal actions in their
ar~a. FEMA still would not recognize the existence of
their levee system, which FEMA considered. too low ... having
a freeboard less than the nationally applied minimum
criteria of two teet. FEMA 414 indicate acceptance of
the levees if they were certified by the Corps as being
qeotechnically sound. Foster City looked into this
option 'With the Corps and fou·nd that the geotechnical
study alone would cost nearly $400,000" vith rIO quarantee
of certification. In fact... the results of the study
could lead the Corps to requIre e~tensive levee
improvements before certification vas possible. Due to
this" Foster City has decided to i~prove and raise its
levees to meet FEMA requirements. Based on the Foster
City experience... staff believes that a hydrologic
challertge should not be pursued. Furthermore,
reeoqnizinq that Palo Alto's southern levee located
adjacent to the flood basin is an engineered levee .. staff
does not recommend pursuing Its certification due to the
cost of the study and Possible resulting improvements.
Topographic Study. Staff looked Into the possibility of
cballenging the topographic studies used as a basis for
:rEMA flOOd maps in order to reduce or eliDInate the 100-
year special flood hazard area boundaries. Elevation
information liould have to be obtained for approximately
one-third of the city and is estimated t.o cost from
$600,,000 to $800,000. A topographIc challenge, like the
hydrologic challenge" liould most probably confirm
existing data and result In very few changes. In fact,
in areas where pumping of groundwater has caused the land
to subside sInce FEMA's maps were established.. a
topographIc challenge may actually result in increasing
the special flood hazard area boundaries.
Staff recommends against this action as the costjbenefit
ratIo of a topographic challenge is very low and may
actually increase the speCial flood hazard area.. It
should be noted that any challenge to the F~A program
Would ultimately bave to be approved and accepted by FEMA
it.self~ <"tlrrently. tber-e is no other administrative
authority to apply for eKemptions or a relaxation In FEMA
requlations, othlll?!r than by the authority of congress.
For thIs reason... staff believes that the legislative
option is more viable.
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~slatiy@ -10Ft Actions
February 1990 council Members
and Conqressman
Washinqton to
requlo!ltions~
lIIet with FEMA administrators
Tom Campbell during a trip to
discuss FEMA rules and
March 8, 1990 A letter vas Bent to the administrator of the
National Flood Insurance Program requesting
re-lief from federal requirements.. including
increasing the 50 percent t.hreshold for a
substantial improvement to 7S percent.. and
excluding interior remodeling/second story
additions from t.he definition of a substantial
improvement.. Staff bas not yet received a
response to this letter.
Legislativfl -CUrrent Actiyity
1.. pIfference in rEMA/corps Policleg~ The City Manager's
office is preparing a letter to FEMA and Congressman
,~ll asltinq that FEMA adopt the Corps' policy for
"J!;appinq the lCO-year special flood hazard area
. boundaries. As the Corps recoqnizes the existence of a
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City levee system, the flood. map boundaries would be
substantially reduced.
LegislatiYe Lobbyist. The City Manager's office is
exploring the possibility of hirinq a lobbyist to
represent the City in Washington, D.C~ on future
legislative chanqes to FEMA regulations.
Legislative -Pending lssuc
The Santa Clara Valley Water DistrIct (District) has recently
received a letter froD the Corps wbich confirms the Corps 1
positi~n on federal financing of improvements to the City 's
levee systeD. The Corps 15 recommending to congress that a
levee improvement project not bE federally fu~ed due to a lov
costfbenefit. zati.o~ Representatives .from the District (along
with other affected South Bay cIties) have requested the
City's sUPPQrt In seeking a reversal of t.his position.
Council has indicated significant concerns about the
environmental effects of improving the levee system~ For this
reason .. staff requests q'..lidance froD Council as to whether the
City should join with the District in opposing the Corps'
recommendation.
If Council wishes to support pursuing federal funding, staff
would meet with representatives of the District to formulate
an opposition strateqy.. This would include seeki1l9 a more
favorable Interpretation of the Corps' costjbenefit ratio so
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as to make the levee project economically justifia~le. Statf
also 'Would ensure that any federally fUnQed levE'e project
'Would Beet FEKA criteria. In the absence of such approval~ it
is unlikely that sUfficient funding 'Would be available from
the City and the District to pursue future levee imprcvements
(estImated t-:> cost more t.han $S~ 0'0,0" 0<1<1) .. Physical
improvazents to the levee system are discussed in more detail
in the followinq section.
Physical -Pending Jssu£s
1. freshwater flooding. since 1985" the District has been
making improvements on Matadero. Barron and Adobe Creeks.
These projects have already been revie'Wed by FEMA and
have received a conditional Letter of Hap Revision. When
construction 15 completed in 1994, FEMA ~ill revise its
~aps to eliminate the special flood hazard areas in the
vicinity of the creeks. Map revisions typically take
approximately one--snd-one-balf years. Properties in
these areas 'Would t.hen be removed frOom FEMA flood
insurance requirements.
Special flood hazard areas subject to flooding from San
Francisquito creek will remain under FEMA requirements
until ~n improvement program~ agreeable ~o the city cf
Palo Alto, the City of Menlo Park~ the county of San
)fateo and the santa Cl~ra valley Water District, is
completed. If requested and supported by Council, the
District would give such a study and subsequent project
the hiqhest priority in the District's Northwest Flood
Control Zone d'ue to the Creek's damage potential of $10'0
million. The District would conduct a detailed
investiqation of San Franclsquito Creek and present all
possible alternative solutions. This ~ould take
approximately two-and-one-balf years and cost up to
$.l~o<)O.OO'o-with District funding.. As an alternate" the
Oistrict may be able to approach the Corps on performing
a reconnaissance study 91ving a cursory review of its
1969 study. It would take approximately one y8ar~ cost
less and be funded by the Corps.
There are a finite number of basic improvement Qp,tie>ns
available to red,uce or elIminate t.he lOO-year specIal
flood hazard areas caused by San Francisqult.o Creek
flooding. Tbese have been identified in previous studies
of San Francisquito Creek and include diverting the flood
water from the Creek, constructing upstream retention or
detention basins for containing the flood water" and
constructing flood walls/raising bridqe crossings along
the Creek to accommodate the flood ~ater.. There are m.any
variations on these basic opt.ions. Diversion of the
creek flood waters, for €xample, has been recommended in
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the. pa.st. using a large conduit system throuqh Menlo.
Parks and upstream retention or detentiGn of the flood
water has been recommended at the Ladera site
investiqatecS by the Corps. Also, these basic options can
be utilized in combination.
Alternate .oluti~s bave been recommended for San
Francisqulto Creek in the past. However, due to local
environmental concerns and the expressed feelinqs of the
surrounding communitIes who perceive little flood danger
from the Creek ... no neW' flood protection studies have been
made since 1972. The re fore I it Is recommended that
Council provide quldance to staff on whether to request
that the District pursue a study of improvement options
for San Franclsquito creek. If Council wishes to support
a study, .taft would meet with the District and Corps to
identify the best approach and return to Council for its
approval~
2. Saltwater flooding. Staff has looked into the physical
options available to reduce or eli.minate the l.OO-year
of :0 .apecial flood bazard areas in Palo Al to created by
salt .... ater flooding. The SaOl Fr~ncisco Bay Shoreline
study recently completed by the Corps indicates that the
existing levee system needs to be raised to 11~5 feet
above sea level to ~eet FEMA criteria. FEKA requires
that a J foot. freeboard and a 6-inch wave run-up factor
(at locations exposed to tidal action) be added to the
base flood elevation of 8.0 feet. The project is
estimated to cost up to $5 .illion. Total cost including
any land purchase a:\d mitigation could approach $15
million.. Based on past experience 'With other
environmentally sensit.ive projects, the levee
improvements could take several decades to complete.
If the corps does not proceed with such a project due to
a low costjbenefit ratio" improvements to the levees
would be left to the City and ~he District. In order to
proceed on a joint project with the District, a funding
agreement, feasibility study. environmental impact report
and desic;n would be required. As Council has voiced
significant concerns aboUt the environmental effects of
levee improvements in the past, staff requests council
quidance on whether the City should pursue such a
project. If Council 'Wishes to proceed" staff ~ould meet
with the Oistrict to prolnOte a Corps project as indicated
In the legislatIve section of this report. The project
would Involve improving the entire levee system in order
to meet F£MA. criteria. Failing that, staff would discuss
a joint project with the DistrIct and return to Council
tor its endorsement.. The joint project would include
examining possible alternate construction methods for
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improving the e¥iating levee system, as well as
constructIng III ne'~ levee in locations which reduce
environmehtal impacts.. The joint project also coul.:S look
at the viability of other opttons~ including using the
free~ay BOUnd walls or medians as flood barriers.
Staff will continue to meet with local representatives of FEMA to
identify flood requlat!ons which can be interpreted more favorably
for bomeowners in special flood hazard areas; look into the
possibility of hiring III lobbyist to represent the City in
Wasbington, D .. C .. and work with Congressman Campbell on legislative
changes to FDlA pollcie.s and requlatio-ns; assist homeowners in
special flood hazard areas by providing appro¥imate elevations in
the public riqbt of way and pre-qualification torms: and educate
and inform th~ public on all FEKA issues through workshops, video
tapes and the -Flood'Watch.-
It is recommended that staff evaluate the community Rating system
Program and report back .to Council on the degree of City
-. involvement based on costs 'and benefits. Staff asks for Council
-quidance on pursuinq a study of improvement options for San
Francisquito Creek. A)so, Council quidance is requested on salt
water flooding Issues Including improvement of the existing levee
system and evaluatIon of alternate levee locations and protectIve
~easures~ such as using existIng freeway sound walls or medians as
flood barriers.
Staft recommends against self-insurance and withdrawing from the
National Flood Insurance Program. since underwritIng for self
insurance is not possible, and withdrawing from FEMA would
effectively eliainate all financing for building construction,
remodeling and federal disaster assistance in special flood hazard
sreas. Staff recommends against pursuing hydrologic or topogra~ic
challenges to FEMA studies due to the expense and low probability
of Success based on Foster City's recent experience. A
certification study of the southern levee also is not recommended
because of the hIgh cost and possibility of discoverinq
deficiencies Which require extensive repairs.
Re£2Prnendatfong
It is recommended that Council:
1. Direct staff to evaluate the Community Rating System Program
and report back on a proposal for City involvement based on
the costs and benefits involved.
2. Provide guidance to staff on the following issues:
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wh*ther to request the santa Clara Valley water
to pur.ua a study of improvement optlor.s
Franclsqul~o Creek~
District
for San
b. wether to join with tbe Santa Clara Valley Water
District In opposing the Army Corps of Engineers·
position on Cederal financing of improvements to the Palo
Alto levee .. ystea and t.o pursue a Corps project that
meets FEKA crIteria.
c. whether to pursue a leve6 Improv.m~nt project including
alternate construction methods and levee locations with
the santa Clara Valley Water District in the absence oE
a Corps project that meets FEMA ~riteria.
Respectfully submitted,
-~~~
Assistant Director of Pub11c Works
DAVID G. ADAMS
Director of Public Works
w~ ci~r'":naqer
oc: Janet K. Dolan, Menlo Park City Manager
O.S. Army Corps ot Engineers
Federal Emergency Management Agency
Santa Clara Valley Water District
County of San Mateo
-12-
CHR:3C6:0
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