FIRM Case#92-06-110P-921029G c �4 aye 0S48;t1 2
Federal Emergency Management Agency
Region VI
40 Federal Regional Center
890 North Loop 288
Denton, TX 76201 -3698
NTH !-14 a
!, Mstober 28, 1992
Billy E. E and Sheila F.� 1
1 Irvin �jv
1336 Sandy Lake Road
6
Coppell TX 75019
Dear Mr. and Mrs. Irvin: C1 I Y ANAf,PD
Your recent letter raises several questions regarding property
located within the floodplain in the city of Coppell and the
application by the City of local floodplain management requirements
for permitting purposes. The City of Coppell, in order to
participate in the National Flood Insurance Program (NFIP), was
required to adopt and enforce performance standards for new and
substantially damaged structures within the floodplains of the City
as identified on the Flood Insurance Rate Map prepared for the
City. In return, the Federal Emergency Management Agency through
the NFIP, has made low cost flood insurance available throughout
the community.
Communities are required to adopt and enforce local ordinances
which meet or exceed the minimum requirements of the NFIP. The
program encourages communities to adopt more restrictive ordinances
and the more restrictive requirements take precedence over the
minimum established by the NFIP. Within the past two years, FEMA
has offered a new program for such communities which results in
reductions in flood insurance rates. In the case of Coppell, their
ordinance is more restrictive in terms of elevation requirements
than the minimum. NFIP only requires that for new or substantially
damaged structures that the lowest floor of the structure must be
elevated to or above the base flood elevation. As you are aware,
those base flood elevations are determined utilizing hydrologic and
hydraulic methodology and are reflected on the maps produced by the
Agency. Many communities require the lowest floor to be elevated
one to two feet above the base flood elevation. Communities also
recalculate the floodplain using "fully developed" conditions. The
FEMA flood maps are all based on "existing" conditions in
calculating the base flood elevation. Coppell's ordinance requires
two feet of elevation in the FEMA defined 100 -year floodplain and
one foot in the Coppell version of the floodplain, calculated on
"fully developed" conditions. In addition, the City requires
engineering calculations to demonstrate that the development will
not cause any increase in water surface elevations during the
discharge of the design 100 -year or base flood.
The NFIP regulations and the City of Coppell's ordinance both
provide variance procedures. However, there are several points
contained in the variance procedures and all of those criteria must
MAYOR AND C 3 4-j L', cU -1 J
DATE: io - 30 - 9 ,�-
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214 393 0948;11 3
Billy E. and Sheila F. Irvin page 2
be met before a variance could be granted. The responsibility for
reviewing the basis tor a variance and granting or denying lies
solely with the City of Coppell.
Permitting, as with -the variance, is the responsibility of the
local community. As long as a community is enforcing the
requirements of their local ordinance and the minimum requirements
of the NFIP, this office has no authority to intervene in the
community's permit process. If a community were found to be not
enforcing the requirements of their ordinance, corrective action
would be impose on the community ranging from probation to
suspension. The problems you have encountered in obtaining a
permit can only be resolved by working with the community and
complying with the requirements of the local ordinance.
If additional information or clarification is needed, please let
me know.
Sincerely,
Bill Kuno, Senior Natural Hazards
Program Specialist