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HomeMy WebLinkAbout0508.000I I G). . -": ;I' ,'--- .. ----- -- September 20, 1990 THE BONORASLE CI Tll COIJIiCrL palo Alto, callfGrni. rl221 Hazard RegulatipOs Status Report Members of the Council: Report in Brief This is an informational report on the status of flood hazard regulation related activities~ No council action is required. Background On June 11, 1990, council provided the following quidance to staff on outstandlnq flood hazard related issues: • 00 not request tbe santa clara Valley (District) to pursue a study of improvement Franclsqui to Creek. Water District opt.ions tor San • Do not pursue a levee improvement project vith the District. • Do not pursue an Army Corps of Engineers levee project 'Which meets Federal Emerqency Management Aqency {FEMA} criteria. CoUncil direeted staff to investiqate hiring a lobbyist to represent City Interests in Washington, D~C. on FEMA policies and regulations, and to report back on the cost{benefits of joining: the FEMA Community RatIng System Program. This program was described in CMR:346:0, dated June '. 1990. Disgussion At the June 11. 1990 meeting. Council indicated a desire to receive periodic reports on the status of flood hazard related issues4 The follOWing suaaarizes the actions which have occurred over the last fifteen weeks. 1. Legislative LobtIyist On September 10. 1990. Council authorized hirinq tbe firm of Rivkin, Radler, Bay!'!. Hart. , Kremer to assist the City in determininq what alternatives aight be appropriate to pursue~ The consultants' report is due within 45 days. - -1- CMR:508:0 • I ! I ~ i ~ I _ . . - .. \ <.­, ." , .-. l \ \ ." ~I,,~~" j "' j 1 1 j 1 - • \ / ______ -..,"ol. ...,~_,' __ .~_~ __ ".,..: ____ .. ;o""'''"'''~_ -=.!.._-~-:r<.lo.,~"'~~~~I_£iii!S~" 3. 4. o o Legislatiye Responses Attacbed are copIes Of letters from .rEMA which respond to Senators Cranston and Wilson and to Representative Campbell on issues raised by various Palo Alto citizens. In summary ... FEKA defends the accuracy of the flood maps and explains the differences 1n their flood criteria as opposed to that of the Army Corps of Engineers. }"EMA vould consider map changes if the City provided the proper elevation and hydrologic dataa However, staff bas already recommended to Council aqainst pursuing a challenge due to the expense and. low probability of success based on Foster city's recent experience (CMR:346:0). Community Assistance Visita On April 20 1 1990, FEMA regional staff conducted a co~unity assistance visit (audit) making a field survey of the specIal flood hazard areas to assess the numl::ler of substantially improved structures. FEKA also reviewed City files to obtain preliminary information on the City's documentation of building permits. staff received a Community AssIstance Visit Report on August 15 1 19-90a The report reque&ts that Palo Alto: • provide FEMA with a copy of all building permits issued on projects within .e. special flood hazard area since February 1'980 (the date of the City's entry into the National Flood Insurance Program]; • • • provide FEMA with a copy of all variances processed since February 1980: adopt a floodplain manaqement o·rdinance" which includes the latest Flood Insurance Rate Kap dated September 6 1 1989. The City's existing ordinance references an earlier map dated August 15, 1979; develoP procedures t.o be follo'Wed for processing a building permit application ... with respect to flood hazard requlatlons. The procedures should identify areas of responsibility, review processes l conditions for approval I record keeping and handling of variances and public requests for information. A final community assistance report. based on findings trom infonaation requested in the preliminary report. will be completed in fall 1990a Community Rating System program f~. The final community assistance report diSCUSSed above will indicate whether the City meets federal requirements for National Flood Insurance Program participationa If -deficient in meeting the requirements ... Palo Alto will not be permitted t.o participate in the CRS program. Therefore l staff viII postpone proceeding -2- CXR:~8:0 -. I l, f I f • I ." ". " \ - ~ \ " " , 1;, " , -" '-"'~o-":": --1~ . .,.,' '. • \ /' """.Le' ,~""-~~ ______ .. "_..,._, •.. _~.'""'_~. _"_~_""""-_""""~,-".;.>~~,:,,,.;:~".c..::il(~_t!,,.*_;~.,, 5, with a CRS application until receiving the tinal report and aaklng an assessment of any required corrective actions~ Worksbopt A workshop tor surveyors... enqineers and other interested partie.s entitled ·Surveying The Flood Zone-was held on July 16, 1990. city staff and representatives from FEMA explained survey requIrements and the information necessary to complete the FEKA Elevation Certificate and the City of Palo Alto Elevation Certificate For Special flood Ha%ard Areas. The Elevation Certificate is used by FEMA to deter.ine insurance rates and issue Let~ers of Map Amendment and Letters of Hap Revision {LOMAs and LOMRs}.. The Elevation Certificate for SpeCial Flood Hazard Areas is used by the city to admInister building applications for new and substantially I.proved structures within flood hazard areas in accordance with the FEKA regulations. city staff found it necessary to develop a separate form because FEKA f S form: did not request infonoatiOl'. needed to pre-qualify houses. The ~ity's Elevation Certificate enables homeowners in special flood hazard areas ~o pre-qualify their ~ses to future buyers if they conform to FEMA $tandards~ thus ensuring that any future substantial remodeling can be performed without baving to raise the e~isting floor or house. 6.. Levee Improvements. On June 1.9 .. 1990 .. a meeting was held between t.he Santa Clara Valley Water District ... the count}· of Santa Clara and cities within the County to discuss possible u·nified action on opposing the Army Corps of Engineers' negative pcsltion on federal funding of new South Bay levee systea construction. As none .of the participants in the lIIeetifl9 sbowed interest in opposing the Army corps' position .. the District has decided not to pursue this matter further~ 7. A letter regarding the City IS position 'Was sent: to the District on June 22. 1990. stating that the city or Palo Alto could not join 'With the District in a study of San Franclsquit.o creek .. propose improvements to the outboard levee system ... or oppose the position of the Army corps of Engineers on federal financing of the levee system. The letter indicated that t.he city 'Would continue to work 'With the District to complete existing rlood cootrol projects on Matadero and Adobe Creeks and erosIon control projects on San Francisqulto creek .. and would like to continue to be infonr.ed by the District on future District actions with the Army Corps of Engineers and FEMA. l1eighborh004 Meeting.. On June 27. 19"90 .. City staff and Council Members Levy and Fazzino met with residents of walter Hays Drive and the surrounding area to address concerns reqarding SUbstantial improvements in the Special Flood Hazard Area adjacent to San Francisquito Creek. FEMA requlations and -)- CKR:~08:0 ...1: o o their effect on buying. sellinq and constructing bomes in the Special Flood Hazard Area also were discussed. 8. Future fJ'Ka Study. In a meeting on Auqust 16, 1990" ataft was advised by FEHA repres.entatives tJ:r.at the agency vill be conducting a restudy of the fresh water flood zone in tbe South Bay area including Palo Alto.. The restudy will llse more conservative levee criteria" which viII affect the boundaries of the "flood zones.. It is es1:imated t.hat new 'Jlaps based on a restudy will be available tor public comment in approxi~ately nine ll""tII.. staff will bring this item to council'. attention wben this inforeatton becomes available. Staff will provide the information requested in FEMA's preli.inary ComtIiunity Assistance Report and viii return to Council in fall 1990 with the final Report findings o!lOO their effect on participation in the CRS program. At the same time.. an updated flood plain management ordinance vill be recommended for Council action. ~~ Assistant Director of PUblic Works DAVID G. ADAMS Director of Public Works ~~~~ City Manager cc: Janet K. Dolan, Menlo Park city Man~ger Attachments: FEMA res~ses to Senator Wilson, Senator Cranston and Representa~ive Campbe11 Related: Reports: CMR: 346: 0 CMR:SOB:O • • " ~ ... . ' , - . ~ o Federal Emergency Management Agency wa.s!iington. D.C. 20472 The Honorable Tom Campbe11 House of Representatives washington, D.C. 20515 Dear Mr. Campbell: This is in response to yc~r concern regarding the identification of tbe area landward of the existing levee as flood-prone on the Flood Insurance Rate Map (FIRM) for the City of Palo Al to.,. CaliforlliaJ' dated September 6, 1989. You submitted newspaper articles to,at discuss the dilemma tb.e city faces regarding whether the bay front levee system should be considered to protect against flood events. The articles also mention that the U.S. Army Corps of Engineers (COE) has detennined the flood-prcne area to be smaller than that identified by the Federal Emergency Management Agency (FEMA} on the FIRM, We share yoar concern and certainly appreciate that local residents and city o~ficials are confused by these conflicting flood-prone area ~e.si9nations~ Un.fortu·nately. we see no simple solution. FEMA is charged with identifying flood-prone areas throughout the United state.s. In order to remove a flood hazard oesignation from a FIR...'"'! .. we m~st be provided" with either 1) technical data indicating that the .freeboard .. structural stability. ~el'"ation .. and :maint.enance requirements .. as detailed in section 65.10 of the National Flood Insurance Program (NFIP) regulations (copy enclosed). have been met. or 2) certification from a Federal agency with responsibility for levee design l such as the COE.. that a levee has been adequately designed and constructed to provide protection against a 10'O-year .flood event. Because 'we bave not received such information, "'e cannot remo"-e t.he flood hazard designation from the area in question. The bay.front levee system in Palo Alto "Would be overtopped during a 10c-year flood event. A levee system designed ~or a fl.ood -.:.ore .frequent than the 10'O-year event cannot be. credited on a FIRM because the potential for levee failure "Would be much qreater ~hen overtopping occurs and it is Qoubtful that a cOmJIlunity 'Will always be able to prevent. a levee failure by making repairs durinq the event. Because of the sense of security that a levee can create among the owners and potential purcha5ers of property. development often occurs in the area the levee is intended to protect~ As a re5ult .. a large number of ho~es ~ay be at risk it the levee fails. Also .. the flooding that results from a levee failure is more like t.he instantaneous flooding-from a dambreak than the flooding ~aused by a qradual rise of ~aters in unprotected floodplain areas. Therefore, We consider the flooding from a failed levee to be po·tentially catastropbic. • ., • " > ";'~~'~, \ \ t , , . . ~ . . " \ : "-," ~~.~ ,-'-... ' .. ' ;:~~~. , , , I , , r I , < - ....... . , o o 2 The COF-, on the other hand, considers the flood protection levels afforded by existing levees in the estimates of potential flood damage it uses to eva!uate an exis~ing levee system for possible upgrading. Wben the estimated .flood. damage is annualized an.d compared with the estimated project cost annualized over the life of the project, the COE may often find that the necessary cost-to-benefit ratio_ is not Obtainable l and the project is declared to be economically unjustified. The COE levee evaluation criteria differ from our criteria because tbe agencies have different missions. One of our missions is to accurately map :flood hazards throU9hout the United states b~sed on a urliforlll lO'O-year standard for flood insurance and floodplain management purposes.. While the :floodplain management standards of the NFIP are dJrected primarily at ne~ construction l the COE is oriented toward the design and construction of eccnomically justifiable civil vorks projects to protect existir.g construction and not necessarily tied to an'y specific frequency event. Although 'We cannot revise the flood hazard designation at this ~ime. please be advised tbat FEMA has recently created a community Ratinq System (CRS) to provide a new incentive for activities that reduee flood losses and support the sale of flood insurance.. Any community participating in the NFIP may apply for CRS classification in order to obt.ain floOd insurance premium rate credits for its residents~ The community must demonstrate that it is implementing floodplain management and public information act.ivitie.s that exceecS the minimum. requirements of the NFIP.. One o~ the activities tor which the CRS provides credit involves levee ~aintenance and the development of a levee emergency response plan for areas protected by levees designed for Ilore frequent than lO~-year ~vents. However, to be eligible fo~ credit under this actIvity. the levee system must provide protection from at least a 25-year flood and be certified by a registered professional engineer as meeting all of the requirements specified in Section 65.10 of the NFIP regulations except for Paragraph (b) (l) ...... hieh establishes the .inimum design £reeboard~ Additional information concerning eRS may be obtained by contacting our F.egional Office in San Francisco# California l at (415J 923-7177 .. L • ! . ':::; ""1~~ """'" ' '. 1-~"c I I I l ] , L -- c 3 A.' V ; / o I trust tb~ i~formation provided bere ~ill be helpful. alth¢U9h I understand it does not solve the city's dilem:na. Please be assured that we will ~o everythi.ng 1ie can , within thE limits of the regulat.ions by "'hicll 'We ]Dust abide ... to assist the city in achieving its objective. Xf you require further assistahCe~ please have a zember of your $taff contact our Office of Con9ressional Affairs at (202) 646-4SO¢. Enclosure CC; FEHA Central FIXA. }{eading Acting' DIR Cole itegic..nal Dir. RS Ce.ntral File Case File Duryee Waters Kolu:- Co.ncurrence: ll-AA-RS !:IOlIR IA-R.l.-RS KAT'UCKS Sincerely, Harold T. Dut:Yee Ad.minilStrator Federal Insurance A~inistration Mai~ Room l!a il ROO11l EX-CA NTHD -Reg. 9 IA-~-:RS TEe -KBJ IA IA-M IA-~-:RS II' ROSE CR 2- .~ = ~-. ~ '" ,- .-J ~~-- ~?;: ~ v. ,- 0.;:> (,> <11 !'''! "f ... . ' ';-~:-'"~~ -:' "0 .! "l , • i ,-' " .. :.. . ~ .... _., . :: '--' ~--- . ~'. ,--. ::~ --+'~--:-:':-.. '.:-::' ~-:-. . - 11f' --:-i.-::: - " .. : . .:.: :-; ... .-"'-' .. . '- '_." , ," o : Tom Cempbea Member-or COflsreu / o • "' .. ---" t ~' ! t" 1 ; . -.. 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':'.~'.:.-" y~",-~,,_;:,-~}~~.!,,;::~:-~~,~'.:'_!t • o MEMORA."IDUM FOR: FROM: SUBJECT: F.e4 -------- CHAEl !AKERo JR. 1'1<:' RECEIVED AUxANDR ...... YIRGINL&, DEPUTY REGIONAL DiRECTOR . -/k OUe~ Natural & TechnologiaJ Hazards Division hsues Tlial Collld Arise Dl1ring the FEMA Direclor's Confirmation Hearings This responds to the req~st from Headquarters to address any issll-es that could be brought up by Senator Pete Wilson during tbe confirmation bearings. The Palo Alto City CollDcil .toted tha!tbey intended to' go congressional' will! • · complaimt tbat the 100 year floodplain designated by the Corps Ilf Engineers . · (COB) f« thi< COS! benelit study differed greatly Crom the 100 year fIoodplaill designated by FEMA under tbe Flood Insurance. Study, During tbe Coundl . meeting ou May 7. FEMA, COE and the County Water District staff attempted · to explain the difference in the purpose and ultimate results of tbe two stU<lies. The Counell Hstened politely. but stated tba! when FEM .... tells tbem that they .have • large floodplain tIlat should be p<operly managed at the sawe time Illat Ille COE tells them that !bey llave a sm.all floodplain and can't qualify for COE assistance \0 improve the levees, something is wrong. " The basis for tbe differen~e is tb~ purpose eacb ·agency bas for doing its flood study. The statutOI)' focus of tbe FEMA slndy is on the floodplain created by the 100 year flood. based on existius ~ondjtions. If an existing levee does nO! meet our 5taooards or is not <:ertifi-cd as adeqllate by the COE .. we must assume Chat the levee ,.011 fail during the 100 year flood event. The results of the study are used as the basis for cbarging actuarial insurance rates and establishing minimum floodproofing requirements for new construction and substantial impr""eme nlS of existins builamgs. The f""u, oflbe COE .tudy is on the economic benefit derived by funding flood !,<otection for !he flooding that is "most h"kely to occur", This means tbat a gre.t part of the economic ben.e:fil is obaine(! by evaluating <Iii-mage: caused by less severe flooding that o<:cun 'With ~reater frequeccy SOdl as 10.20-1 an-d 50 year flood ev~nt~ They an also take into account future conditions, wbkh in some ~ases enlarge. Ibeir fioodplaia Over FEMAo .. but in this case which is based OD Udal flooding, had no effect on the result. Tbe COE guidelines for !e"ee. allow them to aSSDme that if • levee lias cot failed in tbe past, it Wllt not fail in tbe future even tl10ugh it doc, no! meet the COE safety standards and would not be , . • \ ., "' ,,/~ --.,.-. ,~!~~t-. ~:;--. '. \ \ . \" \-1\ ." • ---- - " ;.,"" ::' " .", ,/ o : -2-. certifi<:d b~ tile COB. As a result oCthe two different meilwdoicig~:the study assumes tIlat the Palo Alto levees arc over-lopped but most probably woDld hold lip onder tbe 100 year flood, ",bile FEMA must assome that they WI and produce moch grealer Dooding In this ease. . . The problem pr:senled by tbe si,nitieant differe~oe between the 100 year floodplains genua ted by FEMA and the COE has been raised before in other commonities Bnd Regions. It has been recently discussed at the congressional level with DO resolution. The two agencies agreed to disagree. The result is that Ibe public appearance ~oDtiDues 10 be given that the Federal government can't decide wh.( a 100 year Doodplain is and both agencies <actinue to be a target for c!i:sgruntled local officials who reel they cmmol get 3 straight answer. «: . Record File: RIX NTII.D/fJPR Reading File a.ron File J. FEMA/RIXjNJHD/FIPB/JEklridge/l" _. 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A Wf'IIen'atlYo eP.tn'u ! ...... _'dilld _ 900 Inl.ant.t;. tol , ; ttflll too hot. " 'friend to get out. .' ' l!,IgM CIte lind, "We ,u.rt braUm.!. 'nlQ gu ta~ iI t'n bl,lrsUng Into the engin. bflck tbll!l"8o 'I'her.t wu r. kchlldml. • " 'I11(! develop"'lPTlt reo • used lu rWuce ur~' Sec C:rtdJ to do but W'Ilt.ch It butn IUld·waU for y ret.a1l. the pro~· 'Utili depal'l.menl.," 1Ietl'tI'It., 1IAId. "ll wu, )11 It 18 wOt'king on C(Nl'-:ed _ tolaJOO!": ' llnl,.a\n Ulli OOtn~· The lJerrol .. Jolnoo a'gfowlng nwnbtor ~ ___ .'" .• 'I. ;'f';~ _ '=-','" _ ",. 1,1,' . If recall n~ of Ylel'O ownen WllO han Jeer) Ulelr two.'. i' '''''1i."it'-,,,,,' " \ 'J" . ~ ~ aIId the coV1!m~ teBleta go oul_ UtcrBUy -In". bhua of'~, i ... .:A:-Ir'~q.:~:. '".,;,.:\i' \ ' ..... ,,' _"":~h"'-...•. : .... ',' I ,'. ,1'1 ,II,.' .• ' ...' ,'1 .' ' .. , '. ~, oj Irone.,. "glory.1'b1' in~d~t,CanI.l!r fl'lr,!,wo',. "_ '_I .' _,' _,,_ '. ., _ _ •• • Of.,. 22.y ...... 'd Wety In WMhln""''' D,c.; ""d tl,~""""~<:,i'iP()ntiac';i'kr6s'have a weakness lor bur.tong onto (Jame " , , , , \ \1111 .porl! Car'll of at IM,lt 3'10, Iln'!J involving 1084 Fleroa"~~ ',.: '. ",', ,j ,',' J'l~ ,"', ••• 1,·""1 f.o\" 'j ",':t. " , . ': ' , ". . ': ,,' Regents weIgl Inside 1.11 bllJterlng ICt.'UI. and anol))et !IS Involvlng Idtet mode-lK. ' " ... \ ~~. I ", ~ ,.' f ,>I.",,, ... ~ _. (1 " • i. ~'{I': ,"j I 'w'" >._., '" ! .,' I I '.', 'j,.. ' 0, H. and • Irtood AbouI34~.OOO .cUt • ..,.."en! """, •••• i;., b~!~'J1r."1 t::;.'» J~'i' :'~"r-'-' /' ('" '\'L~!be' _-'-'. . "-I' rC ~ ' .. John Nuck."s. dit""", J in hlI dad'. 1984 _ btotw~ ]98,3 And )988. but 18.1e& decllnr!tt~;\ .. : .lD .",'~ \'b/' petluon I&IUW~ i.be ;Natiooal:' &Crt.......,. ·rruru RI'I a I'M ..... ,'" nos .,,' L~ t..,pbon.tory, BAld h. """nod ..... ily .rlo! 198. and tho model ,"US', ,HigbwaJ"TnUIlOSa!<llJ'MmInIairaUon "' .. ",/rom a <ltadll oomblnaUon o! '." dol .... '.'toolimon bel_ Con. .~-,,-~ In I •• a. .' ... -n f'" '/ ,\" I ,I, luwsCl-'''' the fire iePOl'ta. Cbo C8ltor de.. .' " . \ S~t FIJ!:Jl.O PDQr'4]J Y ¥R\. .. 'm,LI1~ ,.,. .,'.-..-.... • 'K'-;.!;. -.: ' "J i "grt!n8SR'gL"lltsoftlxo '. I . :~., Urilvonity ... OIliI ...... .J> .A. hires, 19hb "·"··~JlfC;:,iW~a~:!~hiougIi :fl~d,'rule's,:::" :~te,.,"';'~t1~. , ,"In "~";)' /.",\ 't<, t·: .'1 .. ' I,.''' .:.<,", •.• '",-" i " .'.' d .... :"""_ .... ::J: By ~I" wpln . I ~:./ -, ,',' ::i'~;,:" j .'/,'OOaIMd!e tor 'n!isldeata'an OQeofOtItlb or tbe 'abQou.ooo PalD Alto htnDol '" vulnrTabht, ~ ve alicsdy Ii' . Menul)'''',," lIuff W",,,-[ ", ,\' I: , : ... 1',\ -( "·'i:city. '''41.~1! -"1' 1 :",'i!. _. .~.'.:.':' ,,_, 'I " -I " I 1n .'l(Jo.')'"all" llOOtJ. -!' ,', ,.1,. '" cd to 1~ {un4!l • I'al(l Alto', poUUct&na •. wou'd.,rv.ther k}·--~~·~.bait lM!la:}'edd~ ", Coancl1 DXlmben JllJd ~y hope t.h.al'a,', rrow-t'\Inning the: LaW] ~I right U<ao gi •• 1n ",roder>l,llaQdJa'" !bal', oldlng,"bolhot,," all'eugthoU s..,.Fraoru....,~ C<I>aUlIMI'WU1 belp them nnd "'me lug ... ' roQn' RlId Los_ .' I "'ron;, ,UJ cJllm are rh:.Uculoua arid ouUandl&h, ~~ ("co. na1~ .. 1lhd wJdea San I~to .,.1.11.1.1\ .. 'Qr' regulatory tolution. 'l"IIey 5ald' lab;ntories 'QTl "nwnic ~ ", v"e . City cOuncil dootdro :unanlmomly .• Cttd\::.DotJ),wwld-be apemtve .. ud env. t •..• ,'thfy hopo tJ\at!iOl1'H!OlWl vrtu cbailengo,llIB: ~ , •. r,7-'. , ' . late M~tI.t1y to h1nt. Waab.lnglon Jobby1at. 'roomenl&Jly ~ but t..bet AteI tIM! QJl]t '_, 'Fed.etal Emergtllf • .,. Ma.Q8g«m:at~g~. '~ . \ . to help wade t~. bW'IM.ucratkqua.g. I :&ppcm!I:lc..wa" to,"OUrnlDQ\e,fNeralllood', ';' •. -':,' 1..'1 S "'FI',no p 3B' 6UQ ~ . &EI' 0 ~ vf Jlood,ruleI,th&"hu ('l't".Q\ed a .maps'doolgnat.1onoCananatb.lt1Dcl1Jdea .,J ':,." L (P(P,rI.AlV J. pae. l' a::ze: --. . ~ . , ,J' :~t 'r" • , J't;' ·h.\; .Jj"""'~' . '~'''';:si.;;-.~ " , .. _ .. 1_. , ''' .. "''~'-' , ... ~ :~~~~.~ ~ i"' 1 ... ' ,,"'. ' ,,1.. _ _.... ~ ..•• ... , , i >j. , " --1 ',-'-:,; ':: "",-.. , ...... , .,' ,-~-- =: :m: 1 '. • , -~~ .~. --1 -" ~ i I I , ] 1 t .. o o Federal Emergency Management Agency W ... hingtan, D.C. 20472 The Honorable Pete wilson united States Senate Washington~ D.C. 20510 Dear Senator wilson: ..ll 3! 199) This is in response. to your letter dated July 9.. 1990 .. 'Which enclosed a letter dated April 25 .. 19"90, from Mr. and .Mrs. Lyle Bartz and Hr. and Krs~ Fater Kittell, wb-o o;"m property in Palo Alto, and MS. Maureen Moravick, Chairman" West Baysbore Property Owners Associaticn. You req\lested that we co,nsider the e.nclosure, which you referred to as case 0190070'0'02. Your constituents are concerned that more. than 5" 0-0'0 bomes and businesses in Palo Alto have been designated to be within a Special Flood Haz;ard Area (SFHA). The April 25 letter raises several issues about 1) the sources used to prepare the effective Flood Insurance Study (FIS) report and Flood Insurance Rate Hap {FIRM) for the City ~f Palo Alto, 2) flood insurance requirements, and 3) the processes by which SFHA designations bay be revised a The initial FIRM for the City ~f Palo Alto was issued on February 15, 1980. The FIRM was subsequently revised on September 6, 1989_ to incluoe updated flood risk aata for Matadero Creek and to revise the base {lOa-year) flood eleVation {BFE) for san Francisco Bay .from elevation 7 a.c.9 feet to 7. 7 f02-e.t~ For reference, the BFEs on the FIRM are rounded to the nearest Whole foot; bowever, the actual BFEs are given in the FrS repor~a The source of the San Francisco Bay BFE presented on the effective FIRtIf was a 1984 report prepared by the U.s. Army Corps of E.ngirleers (COE). Although the SFE for san Francisco Bay .. as ppdated .. the extent of the SFRA affected by flooding from the Bay remained the same as that sbown on the 1980 FIRM because the increase in elevaticn and the cha1lge to tile SFHA boundary "'ere minimal. To ensure teat the FIS report and FIRM are as accurate as possible, we E1eet with cOI!UI'\unity officials to discuss the preliminary result.s before the :final FIS report and FIRM are published. The final community coordination ~eeting for the effective FIS report and FIRM for the city of Palo Alto was held on August 4, 198,8. After the com:munity coordination :lJ.eeting, ,.,-e published a public notice in t.he ~insula Times Tribune.,. on September 9 and September 16, 1988, to inform cOlIl1llunity residents of the proposed BFEs. 'l'he notice stated 'that the preliminary FIS report. and FIRM vere on display at the Palo Alto City Hall, Public Works De~rtment, and that the second publication of the notice would initiate a 90-day appeal period durinq ~hich prop~rty owners could appeal the BFEs, including the revised Bay elevation, hased on scientific or t.echnical data. All concerns raised by the community during the appeal period ~ere resolved. • \ " I' I f ") '. :,;.,.; -. .t:t~. , \ I . I. I t - --' .-~ ."' , - 0-o 2 In response to your constituents· concern that the lO-foot contour line. is veIl 'Within the SFHA, 'We plotted the contour from tlIe u.s. Geologic~l Survey (USGS) quadrangle maps for Pale Alto and M~ntain View on the September 6" 1989, FIRM. We .found that, except .for an area south of Ross Road" east of Lema Verde Avenue, and vest of San Antonio Road, the lO-foot contour is not within the SFRA. Ho~ever, tor the area where the 10-foot contour is within the SFHA, we reviewed an aerial map entitled ·San Francisco Bay Shoreline Levee.s: San Mateo and Santa Clara Counties, California,­ prepared by the caE. AI thoogh this map does not depict ground contours, it does present spot elevations and is more detailed than the USGS quadrangle that covers the same area. The extent of the flooding depicted on the FIRM: is consistent with the more .accurate spot elevations on the COE mapa For your information, the Flood Disaster p.rotection Act of 1973 mandates the purchase of flood insurance as a condition of receipt of Federal or federally related financial assistar.ce for acquisition or construction of buildings in SFHAs. The Act prohibit.s Federal agencies from making or guaranteeing a loan secured by a building in an SFHA unless flood insurance has been purchased a The prohibition of the Act applies to lending institutions regulated, or whose deposits are insured by, a Federal instrumentalitYa A lending institution may also require the borrower to purchase flood insurance in a .greater amount than required by statute or for a building outside an SFHA. Pl~ase not.e that revising the FIRM to remove the SFHA. designation from a property does not automatically waive the flood insurance requirement., as the lending institution reserves the right to require the purchase of flood insurance. The April 25-letter states that. the CQE believes that we have overstated the flood risk and that the flood that has a l-percent chance of occurrence (lO'O-year flood} would net af.fect property 'West of Bayshore, Highway lOI~ The COE's evaluation considered the flood prot.ection levels af.forded by existing levees~ This is performed as part of the estimate of potential flood damage used in a cost-to-benefit ratio to evaluate possible upgrades to the levee system. The COE criteria differ from our criteria because the agencies have different missions. One of our missions is to lIlap :flood hazards throughout t.he C·nited States accurl!lltely based on a uniform lOil-year standard for flood insurance and .floodplain management purposes. While the floodplain ~anagement standards of the National Flood Insurance Program (NFIP) are directed primarily at neW' construction, the COE is oriented toward the design and construction of e<::onomically justifiable civil "'orks projects to protect existing constru~tion ar~ not tied to any specific frequency event. We are unable to a.:ljust the SFHA to reflect the exist.ence of levees unless _ ",e receive either 1) technical data indicatill9 that. the freeboard, structural stability, operation .. and :l1.aintel'1ance requirements, as detailed in Section 65.10 cf the NFIP regulations (copy enclosed}, have been ~et or 2) certification from ~ .. • r I t ~ I • \ \ \ , , .. .-\ ... -, ... i 1 ; 'j 1 1 , , , -, o o 3 a Federal agency, such as the COE# that the existing levee system or improved levee has been ~~equately designed and ccnstructed to provide protectIon from the 100-year event. The April 25 letter mentions that several manmade improvements have been ~ompleted since the map was published. The NFIP regulations provide proceaures by which a property or structure may be removed froIl. a designated SFHA 'When technically justified. One such proced·ure involves a :map revision based on manmade changes ~ including improvements-to an existing levee system. If the City of Palo Alto or individual property ovners -wish to pursue a revision to the floodplain boundary delineations sholJn on the effective FIRM, they may do so under the applicable provisions of Part 65 of the NFIP regulations. Part 65 descr-ibes the map revision procedures and the requir-ed supp¢rting data. Depending on the basis o~ the requested revision I the supporting technical data that the requester would be required to submit might consist primarily of elevation information but could also include hydrQI09ic and hydraulic calculations.. If ~ after revielJing the requester's supporting data~ ve find that a revision is warranted~ we can re .... ~ise and reprint the: FIRM cr issue. a Letter -of Map Revision .. Another procedure involves a map amendment based on property being inadvertently included in the -SFHA on an effective FIRM. Property owners may submit certain property and elevation information and request ~ap amendments under the provisions of Part 70 of the NFIP regulations. The map amendment procedure mi'ly be useful for property O\o7Do!;rs in the area where the Ie-foot contour is within the. SFHA. :I.f we determine that a property has been incorrectly incltlded in the SFHA, 'We can amend the FIR-Ii by issuing a Lette.r of Map Amendment that oEticial1y removes the property from the SFHA. We have enclosed a copy of our ·Conditions and criteria for Letters of Map Amendment (LOMAs}l-which further describes the amendment procedures. We regret that l without additional information I we cannot consider a revision to the efEective FIRM for the City of Falo Alto. SholJ!d the City or individual property owners wish to pursue a revision or amendment~ 'We will be pleased to ~ork 'With the~ to ensure tbat the request is fully considered. -" \ ) • I r ~~;~,.~. "'- '-~1~l '"~'" " ,'1:;-. to . , ", , \ \ , 3'; I I I • . . :-.:-':.-_ -'--_:::....:. ____ __''''-" .. ..,...,l..,..,., ;-.d-,~ ___ ~<_.,_...:-~ __ -_ ..... :-.,,..,...~,...~ "'l!':':~"1;.~"'f:,i\!!"· __ 4.~ ~ o o I trust 'that the information presented in .this letter-will be useful to you and to your constituents.. 'We bave returned the April 2S letter. as you requested. If you require further assistance I please have a member o~ your staff call our Office of congressional A~falrs at 646~'SOO. Enclosures Sincerely, SIGNED Harold T~ Duryee Administrator Federal Insurance Administration Incoming correspondence cc: FEMA Central FEMA P.eading Acting Cole Regional. Oir. ~ central File Case File Duryee Waters Croxdale Hail Room lola il Room DIR EX-CA IITHD -Reg ° 9 IA-RA-RS TEe -KBJ IA lA-FA ll-RA-R$ IA:RA:RS:CROXDALE:hs -07}24/90 -FEMA control ,1146-90 Du~ Date concurrence: IA:RA:RS CROXDALE COOE:IBM:SCOTTS 07/31/90 IA:RA:RS KATTICKS lA-RA MRAZIK IA CR ROSE c --,'" r. !~ ---,-,- §~ <0 "_0 ~ = <-~ W ~ W '" c , '----~ i ! • , ; --l J , .::; .. • .- C'C_'1'1"lJ!5 o o ..... U1 n.w 1C!5 ,o.(l'011:".a."U"e.. .... ~.,',CI ..... "" .o_uu. Cll_OO1:~ SCbf"C!: ~ " .... ~~ •• _ ""~I"" (C ...... :-tf-! 000 o.c:,..c July 9. 1990 Director Federal Emergency Management J..gen.cy 50,0 C Street .. S.W. Washio~t~~ D.C. 20472 Oea:o ni recto-r: .,010'''' IC-Q,o,Q ... ,c r;t' ..... "'~ I nave en.closed a copy of a letter which I received from several constituents of Palo Alto .. Califoccia regardiog FE~A·s designation of more than 5,0'00 bomes and businesses in Palo Alto as beio'9 in a salt water flood zone. I would appreciate it very much if you would bring this letter to the attention of the a~~iate i~dividuals within your agency for consideration and respond to ~e at your earliest conveo ience .. Flease return with your reDly the corresoondence which 1 have enclosed referring to cas~ ~l90070002A Thank you vet'"j' l[luch for your assistance in this matter. Sincerely. PETE WILSON PW':dw Ene losure o o April 25. 1990 'Ihe l'.cnxable Pete Wilson thited States Senate 720 s..nate Hart Office lUllding Washlngtcn D. C. 20520 Dear Senator Wilson: Z am 10Iri ting to ask your support for the efforts of the City of Palo Alto and Mayor Cd:>b in partkular to resolve the prol:llems an->ected Yith J'EMA's designation of D>Xe t!lan 5000 ha1les and OOslnesses in Palo Alto. as being in a salt Water flood 2Cne. NE:I~ MEE"l'Il.t:;S -= WH1\T WE HAVE LEARNU> Real r:inancial Hardship Peed Real Estate Market ffi? I S .Map We have !learl frao in:tividual owners s.lffoOring financial ~p in ttyW:J to sell their haDes, of omers and real estate agents I:>eing sued for ·n:rdisclosure-of 1:h.in;s they 'Were l.lIia"waIe of~ of lowsuits I:>eing prepared against Palo Alto, .. ince the"e is sane. evidence t:hat certa1n persons in t:he city administratiOfl .-.ere awa.re~ stat.istics anr:3 sales rates vera pt."eSe1'ited loohtch s."":lai.7 haTe sal ... have d..~ dramatically for ~~ within the -flood zone 8 , offers have been ~led and banJ<s are trying to =nTI'ELY reqllre flood ~.. '!he drop is in addition t..o ncx-:rra.l. rr.arket "'softe.'"li.r:g" an::! there are dL>-ect 1 inJ..:",=, tc tM pmlicity an:::! con:fusiOi-. cannec""~ ",'ith this ~Je:n. FEM1Vs !rap is not believable. USGS Tcpolo;:ical maps for the Palo JJ. to arrl M::mltain View qu.adrarl;les s.."1t::7... 10 foot. cx:nt.our lines well t..i. thin ~'s 1 foot flood bc:>lndaries. In additicn the u.s. "Anrrf CO<ps of Eng-ineers !las stated in a l'Jblic meet ing that they believe ~ has overstated the floc:d rLCik an::3 a. ·~OO ~-aar flood" l'C:>lld nolo affect prq>erty -st of Bayshot"e, hi<jhway 101. We uroerstan1 that J'EMA's map is basEd on a pri~te survey done by a San .Jose firm. • .'\ . ..... - \ . \ -' . :".\. . • .' -:~."'" .' .;~~~~i=,/' , ' .. ~:. • '~.'. . - .. ' . o o Sane ~ the information d>tained fiaIl the city, and f=m FE». has !>=yen ~ or ..as later c:artxadicta:!. 1oiIIA!I' an yoo ro o Assist the city ~ Palo Alto in eliminating the exnfUsicn 0<>II1n3 f:ran FE».. o FersU>de nw. that it ""'-lld be better i~ it used "generally acoept.oble" sources foe its hydrological =rveys and :tt a private contra= worJdng for: nM1<. o Assist in getting the area restttVe'jed if neoes" ry since there are a mmber ~ w.N-MAOC ~ts that have bee.'l <XIftllet.ed since 'the mp '\.'as ~...ruct.ed.a o Assist in 00tal.n1rq ~ on a list of ad:titionaJ. izrproo.-enents, if req.llred, "rum \IO:>lJ.d rem:;M; the banes am bls:inesses fran the flo::xi zane designation. Rer.E!lbe.r, there are two flood zones in Palo Alto .. the fresh. water danger f:ra:n the IISe'Ve.I'al c:reeks, and the salt wter danger fran a -100 year H:.gh Tide·. '!he salt .... ter dan3er ""'" affects the most _Ie by far. S!noe.rely. ';?!f"o ~ &7 'f~ ~ ~~KU l¥le and =1 Bartz Peter and l<Ory Elle.'l Xi ttell 32ll stoc:kton PI. 3132 Korris Dt:. p-~o Alto .. Ca. !l43¢3 Palo Alto ca. 94303 • .' . i , . / o Federal Emergency Management Agency Washington, D.C. 20472 The Honorable Alan Cranston United States Senate Washinqton.-D~ C ~ :2 0 51 Ct Dear Senator Cranston: J.t ,,4 199') This is in response to your letter dated June 29" 1990-., which forwarded a letter dated April 25" 19'90 .. from Mr. and Krs .. Lyle Bartt and Mr .. and Mrs. Peter Kittell, ~bo own property in Palo Alto l and Ms. Maureen Horavick, Chairman, West Bayshore Property Owners Association~ You requested that we consider your constituents I concern regarding the more than 5,000 homes and bosinesses in Palo Alto that have been designated to be within a Special Flood Hazard Area (SFHA). The April 2S letter raises several issues about 1J the sources used to prepare the effective Flood Insurance Study {FIS} report and Flood Insurance Rate Map (FIRM) for the city of -Palo Alto, 2) flood insurance.requirements, and 3) the processes by which SFHA designaticns may be revised. The initia1 FIRM for the City of Palo Alto vas issued on February 15. 19BO. The FI~{ was subsequently revised on Septembe~ 6. 1989. to include updated flood risk data for Matadero Creek and to revise the base (IOO-year) flood elevation (BFEJ for san Francisco Bay from elevation 7.49 feet to 7.7 feet. For reference. the BFEs on the FIRM are rounded to the nea~est whole ~oot; boweverl"the actual BFEs are 9iven in the FIS report. The source of the San Francisco Bay BFE presented on the effective FI&~ vas a 19B' report prepared by the U.S. Army Corps of Engineers {COE}. Altbo1J.gh the BFE for San Francisco Bay .. as updated l the extent of the SFHA affected by flooainq from the Bay remained the same as that shown on the 1980 FIRM because the increase in elevation and the change to the SFHA boundary ~ere mini~al. To ensure that the FIS report and FIRM are as accurate as possib1.e .. we meet with co~unity officj~ls to discuss the preliminary ~-esults before the final FIS report and FIP.H. are published. The final community coordination meeting for the effective FIS report and FIRK Cor the City of Palo Alto was held on August " 1988. After the community coordination meeting, ~e ~blished a public notice in t.he Peninsula Times Tribune on september 9 and September 16~ 19B8, to inform community residents of the proposed BFEs. The notice stated that the Preliminary FIS report and FIRM were on display at the Palo Alto city Hall .. PUblic ~orks Department.. and that the second publication of the notice ~ould initiate a SO-day appeal period during which property owners could appeal the BFEs, includinq the revised Bay elevation... based on scientific or technical data. All concerns raised by the community during the appeal period were resolved. L • k , , r. '/ , \ • .""'T\ ..... . ~>":c -I-~·~ .-:~~-,- ,;~, , .. - . o o 2 In response to your constituents I concern that the lO-foot contour line is 'Well 'Within the SFHA t we plotted the contour from the c. s .. Geological Sunrey (USGS) quadrangle :maps for Palo Alto and Mountain View on the September 6. 1989 .. FIRM. We found that,. except tor an area south of Ross Road,. east of Loma Verde Avenue .. and west of San Antonio Road .. the lO-foot contour is not 'Within 'tha SFHA. Hoveve~1 for the area wbere the lo-toot contour is within the SFHA .. 'We. reviewed an aerial map entitled -San Francisco Bay Sh~reline Levees: ~n Mateo and Santa Clara counties .. California,.­ prepared by the COE. ~thou9h this map ooes not depict ground contours .. it does present spot elevations and is more detailed than the USGS quadrangle that covers the same area. The extent of the flooding depicted on the FIRM is consistent with the more accurate spot elevations on the COE map. For your information, the Flood Disaster Protection Act of 197) mandates the purchase of flood insurance as a condition of receipt of Federal or federally related .financial assistance for acquisition or construction of buildings in SFHAs. 'l'b.e Act prohibits Federal agencies from making or guaranteeing a loan secured by a building in an SFHA unless flood insurance has been purchased. The prohibition of the Act applies to lending institutions regulated, or ~hoSe deposits are insured by, a Federal instrumentality. A 1ending institution may also require the borrower to purchase "flood insurance in a greater amount than required by statute or for a buildir~ outsiee an SFHA. Please note t.hat revising the FIRM to remove the SFRA designation "from a property does not automatically Y~ive the flood insurance requirement, as the lending institution reserves the right to require the purchase of flood insurance. The April 25 lett.e.r states that the caE bel ieves that woe have overstated the flood risk and that the flood that has a l-percent chance of occurrence (10'O-year flood) 'Would not affect property 'West of Baysoore, Highway 101. The COE's evaluation considered the flood protection levels affort!ed by existing levees. 'This is performed as part of the estimate of potential flood damage used in a cost-to-benefit ratio to evaluate possible upgrades to the levee system. The COE criteria differ from our criteria because the agencies have different ~issicns. One of cur missions is to map flood hazards throughout t,he United States accurately based on a uniform tOO-year standard for flood insurance and floodplain management purposes. While tbe floodplain management star~ards of the National Flood Insurance Frogram (NFIP) are directed primarily at new construction.. the COE is oriented to\o,ard the design and construction of economically justifiable civil ~orks projects to protect existing construction and n¢t tied to any specific frequency event. We are unable to adjust the SFHA to reflect the existence of levees unless . "We receive either 1) technical dat<:!.. indicating that the .freeboard .. structural stability. operation l and ~aintenance requirements, as detailed in Section 65.10 of the NFIP • \ I I' "11':"; ~ . .;.,.,,' \ , , ", \ , \ \ ~ ., .-, , " "7""10 00" " "0 '"""' '. ~" J"~: ,., '",,",- ! ~.·.c. ~, . - ... o o 3 requlations (copy enclosed) r have been met or 2) certification from a Feaeral agency~ 5UC.~ as the COE 1 that the existing levee system cr improved levee bas been adequately designed and constructed to provide protection from the lOO-year event. The April 25 letter mentions that several manmade improvements have been completed since the map was published. The NFIP regulaticns provide procedures by which a property or structure lnay be removed from. a designated SFHA when technicaliy justified. One su-ch procedure involves a map revision based on manmade changes, including improvements to an existing levee system. If the City of Palo Alto or individual property owners wish to pursue a revision to the floodplain boundary delineations shoW'll on the effective FIRM. they may do so under the applicable provisions of Part 155 of the NFIP regulations. Part 155 describes the map revision procedures and the required supporting data. Depending on the basis of the requested revision, the supporting technical data that the requester would be required to submit might consist primarily of elevativn information but could also include hydrologic and hydraulic calcula:tions.. If, after revie..,ing the -requesterfs suppOrting data, \Ie find that a revision is warranted; we can revise and reprint the FIRM or-issue a Letter of l"!ap Revision. Another procedure involves a map .amendment based en property being inadvertently included "in the SFHA on an effective FIRM.. Property owners za~ submit certain property and elevation information and request map amendments ur~er the provisions of Part 70 of the NFIP regulations. The map amend!!le.nt procedure may be. useful .for property owners in the area 10Ibere the lO-foot contour is within the SFHA. If \Ie determine that a property has been incorrectly included in the SFHA, we can amend the FIRM by issuing a Letter of Map Ame~ent that officially removes the property from the SFHA. We have enclosed a copy of our ·Conditions and Criteria for Letters of Map Amendment (LOMAs),· which further describes the amendment procedures. We regret that, without agditional info~ation, we cannot consider III revision to the effective FIRM for the City of Palo Alto. Should the City or individual property owners \lish to pursue a revision or a~enQment, we will be pleased to work with them to ensure th2t the request is fully considered. • I- t '. • I I ' I 1 j I : / o o 4 1. trust that the. infontation presented in this letter will be usetul to you and to your constituents. We have returned the Apl':'il 25-le.tter.. .s you requested.. If you require further assistance, please have a member of your staff call our office of Congressional Affairs at 646-4500. .•.. : Sincerely .. SU!r+€D Harold T. Durye~ Administrat.or Fede.ral Insurance Administratiot'l. Enclosures I.ncoming corr,espondence cc: FEKA central FEMA Readill9 Acting OrR Cole. Regional Dir. RB Central File Case File Duryee Wat.ers Mohr Mail. .Room Hail Room EX-CA NTHD -Reg. 9 IA-RA-RS TEe -MBJ IA IA-RA IA-RA-RS XA-RA-RS:Mohr:hs: 07/17/90 -FEMA Control :1084-9Q code : lBM: PALO Concurrence: IA-RA-RS MOHR IA-RA-RS MATTICKS IA-RA MRA2IK IA ROSE _._-"-~ CR DUe Pate D7/20/90 "" _. .. ,. , ! 1 , To: / o o 1anital ~tatts ~rna£[ WASHJHGTO",,-DC JO!l10 June 29, 19.90 Con~re5sional Liaison Federal Emergency Management Agency 500 C Street~ SW Washiagto.n, DC 20472 Enclosure From: He: :Mr a and Mrs. Lyle Bartz 3211 Stockton PI. Falo Altos CA 94303 Please address the concerns raised by Mr. and Mrs. Bartz regarding FE.MA"'s designatio-n of more than 5,.00'0 homes and businesses in Palo Alto as being in a Salt Water flood zo-ne. I forward tbe attacbed for your coosideratioc. Your report .. in duplicate~ along with toe return of the e~closure "'i 11 be appreci at ed . ~;'DCetelY ~n~ Please ad~ress envelope to: Senator Alan Cranston Senate Office Building Wasbicgton. D.C. 20510 Att: Marco Frazier 4 202/22(-3553 • '. o 10iXU 25. 1990 'Ille Sono<a!:>le Alan cranston onit.ed states serate 1.12 Senate !!art Office B.li.Jding Washin;ton D. C. 20510 Z am IoIritirq to ask )'<lUI: suppo>:t foc tile ~!forts of the City of Palo Alto ~ Y.ayor 0Jbb in particular to resolve the pcobl=s comecte:l with F'EM1l.' s designa:tion eX 110Ce than 5000 bares an:i bJs:inesses in Palo Alto as I:>eirq in a saltwater Flood zane. " NEIG!iOCilHXO MEE:'l'lN;S -I!ND >IHAT ~ HAVE IEAllNED Real Financial Rard$ip ~'s Man We have beard fran inlividual. c.me..""S SIlffe.ri.ng financial hardship in ~ to sell their hanes., of """"'"" ard real estate agents being sued for -Ia"disclosure." of th:"",..]5 they 'Were ~'are -of, ard cf lawsuits bei.Tq prepared against Palo Alto... sino:! the....""'e is sane evidence that. certain persons in the city adm:inistratian -were aware. statistics an::! sales rates 'ioo'ere prese.~ .... him s.~ haDe sales have ~ dra!t;oUcally for p.:opa.'"\:y 'Within the -flood zor.e"" ... offers hav-e be'2..., canc:elle:i a.rd banks are tryi.ng to R....~C1'IVU.Y require flocd insurance. "D1e drq:l is in a&Ution to noI:'!!lC!.l 1!'..:rY.2t -s0fteni.n:.3'" ar'd the:::'e are dire:::t. lir.ks t.o the ~licity am confusion co~ with this p<cllle:;l. ~'s map is not. belie\P....ble. USGS Topological traps foc the Palo Alto a.ro. l"!oontain Vie. quadrangles $hCI.; 10 foot. cont.Q.Ir lines lo'e'll vithin FE'1A's J foot. floo:J bo.nlari"". In addi tien the u. s. ~ Corps of Engineers has stated in a p.Jblic zreet3n3 that t..lJey bel.ieve :FE-9!. has ovastated tl'-.e flccd risk arO a. -100 year flocxl" '-""lld not affect prq:erty .. _t of Bayshore .. rugtl'"way 101. we un5.erstarrl that ~ ts map .is based: on a private survey done by a San .1csa tirm~ • \ .... .: -" , o o R~ Ct!nfusim SaIIO of the infoanation obtained ft= the city. an:! frau nMA has proven wr=g or was later c:ontrad.icted. l<aM CAN YOO to o Assist the City of Palo Alto in e1.ilninatin3 the o:>nfusia'l cxming fran FD9... <> Persuade F»!A that. it ""'-lld be better if it use::! ~ly acceptabl.e" sources f= its by<lrolcqical SUIVe)'S an:! rrt a private contractor ~ for n>o\. o Assist in 9"ttin;J the area resurveyed if T>eoesS?'Y since there are a t1U!IDer of Mm-lWE ~ that have bee, oa!plet.e:l since the map .as <XTlSt:ruct:erl. o Assist. in d:>taining agrea>ent on a list. of ..&:litionaJ. ~. if ~. ohld>. \oIC>.lld rarcve the haDes ard businesses = the need zone designation. _ P.eme:nber¥ the-""e-are. two floo::1 ZCCleS in Palo }.ltc, the frEs.."L wter darJ:1er fran the several creeJr.s., and the salt 'Water dan3er fran a -100 year High Tide". '!be salt "",ter dang€r nc<J affects the llD6t people by hr. 'lhank you for your tine an;j ef.forts to help resolve this prd:llem... l¥le am Carol Bartz 32ll stockton PI. Palo .Alto*' Ca.. 94303 Mauree..'1 M.xavkk., O'la:i.rnan le~~~~~ 3132 Morris Dt'". Falo Alto Ca.. 94303 . " .- West aa~ Property o.mers ;'ssoci.tion :n.25 Stockton Pl. . Palo Alto ca. 94)03 • •