Thompson, Johnny-CS 890223 P.O. Box 478
Coppell, Texas 75019
The City With A Beautiful Future 214- 462- 0022
FILE COPY
MEMORANDUM
DATE: February 23, 1989
TO: Alan Ratliff, City Manager
FROM: Russell R.,~C~t¥ Engineer
RE: I~F-~ #1 OF THE FEBRUARY 19, 1989~OHNNY THOMPSON
L~R ENDORSED BY 3 COUNCILMEN
Item 1 of subject letter makes the statement about "the placement of Mr.
Thompson's entire property in the flood way by the City". That same
letter had five attachments referred to as Documentation. My eYaluation
of that letter and the accompanying documentation, is that some of the
documentation relates to item 1, some does not and some only speculates
about it from a distance'. That is, the documentation is inconclusive to
prove or disprove the specific statement of Item 1. But in an effort to
honor this request for City Council consideration and to prouide some
substantive information for their consideration, I provide the following.
First of all the "entire property" is not defined nor has it ever been
well defined in my conversations with Mr. Thompson. I am aware of two
tracts of land owned or brokered/represented by Mr. Thompson.
One tract contains warehouses that I belieue are east of the easterly city
limit line prior to the 1986 annexation and was annexed at that time. I
don't belieue I have seen a certified surue¥ (by a licensed public
surveyor) with the boundary of the tract, the buildings and the then
existing nor current city limit lines. Mr. Thompson has shown me, many
times, the drawing that was submftted in application for a water
extension to some of his properties. That drawing contained some spot
elevations and occasional contour in areas that is supposedly his property
but not "near" the proposed water main alignment and proposed easement for
the placement of the water main.
continued../2
-2-
I understand that that drawing was produced to represent the design and
possible construction of a water main extension not, as I understand was
it to show evidence in compliance with the regulation of our local flood
plain ordinance and the United States Federal Emergency Management
Administration (FEMA) regulations and requirements to exhibit that the
property in question is not in the floodway nor to prove it was ever in
the floodway.
I provide the above information to exhibit some of the efforts of Mr.
Thompson to prove that these properties are not in the floodway. If Mr.
Thompson would ever show by a survey and other information that the
information used by FEMA in their Flood Insurance study is in error and
that his property is not (or was ever in the floodway) then Mr. Thompson
could now, or anytime through either the FEMA appeals process as defined
in Mr. Thompson's documentation #2, "F.E.M.A. rules for the designation of
floodways"; or though the standard process of a Letter of Map Amendments
(LOMA) (such process furnished to Mr. Thompson by transmittal memo dated
January 24, 1989 copy attached). This transmittal was done after many many
conversations between Mr. Thompson and Shohre Daneshmand, Civil Engineer
and myself, both at separate and combined sessions.
Both the FEMA appeals process and the FEMA LOMA process requires much
documentation to be developed and submitted by a registered professional
Engineer or a licensed land surveyor for review and approval. Mr.
Thompson adamantly objects to do that because he must retain such a
professional to accomplish this work for him and his private property and,
in fact, expects the City Engineer for the City of Coppell to certify his
accusations for him to the City of Coppell and to FEMA using such items as
that proposed water main drawing and such other items as the boundary
survey partly copied as documentation No. 4 with his February 19, 1989
letter.
As that partial boundary survey exhibits, it is a survey for a 592.9838
acre tract of land of which it appears Mr. Thompson's property is outside
the boundary shown. Mr. Thompson expects that such a boundary survey
covers his property which is only contiguous (not within) to the property
for which the Boundary Survey was made.
continued..%/3
-3-
Mr. Thompson also expects the City Engineer to use the Riverchase
Floodplain study to prove that his property is not in the floodway. I
could discuss this further, but that is inappropriate, illegal and assumes
liability to use another engineer's information gathered for another
reason and to use it for something else. Likewise it is inappropriate
for the Coppell City Engineer to certify using "information of sorts" in
the interests of a "private individual" land owner. A City Engineer
should only act on projects authorized by the City Council and those will,
more than likely, be in the interest of the public at large and not for
one individual land owner.
While this explanation is somewhat lengthy, I must present it to exhibit
what has already been coLt~,unicated to Mr. Thompson on numerous occasion
and to exhibit a little (could provide a much more in depth explanation)
of the complexity of the situation both in what is needed to prove a tract
is not in the floodway and the difference in responsibilities between a
private practicing registered engineer (which Mr. Thompson refuses to
retain as required by City ordinances and F.E.M.A. regulations) and a
practicing public registered engineer employed by the City of Coppell to
practice in the interests of the public good as a whole and not to serve
in the sole interest of an individual land owner(s).It is a conflict of
interest for me to do engineering work for a private citizen in Coppell
and be the City Engineer.
A couple of comments regarding the statement in item 1. To address
specific occurrences as to when Mr. Thompson "entire property" was
"placed" in the floodway may take much research and resources and may even
be indeterminate especially to the satisfaction of all parties. Suffice
it to say that per the attached excerpt (too voluminous to attach here)
from The Texas Water Commission response letter to Mayor Lou Duggan dated
January 6, 1988 on the TWC's Come, unity Assistance visit= On November 17,
1988, the City of Coppell entered the Emergency National Flood Inusurance
Program on 6-11-85 and converted to the regular National Flood Insurance
Program on August 10, 1988.
continued.../4
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The August 1, 1980 Flood Boundary and Floodway map shows that the entire
area in and around Mr. Thompson's property was in the floodway from the
initiation of the Flood Insurance Program. Engineering hydraulics and
physical requirements produce the Floodway. By definition in the City's
Floodplain Management Ordinance, "Regulatory Floodway" is the channel of a
river or other watercourse and the adjacent land areas that must be
reserved (not be filled in or built upon) in order to discharge (convey or
carry) the base flood. The Base Flood is the flood or water surface
caused by a one hundred year runoff event produced by a 100 year rainfall.
Therefore, the City nor FEMAplaced the Johnny Thomson property in the
floodway. It has been in the floodway since it was identified (flooding)
in 1980 and probably for time immemorial. When one buys floodway property,
that's what one owns unless, or until one, by definition, takes action to
remove it from the floodway. Chances are that floodway land or tracts are
not sold or bought at developable prices because a prudent buyer will
realize what is the cost to remove property from the floodway to allow
development.
It appears that the water level for a 100 year event could have increased
since 1980, thereby Thompson's property is maybe deeper water but appears
to have always been in the floodway.
One last com~ent, the City Attorney is better qualified to provide an
opinion on the news article attached as documentation; but, the court only
gave warning not to go too far and that is true in any part of life.
I believe the onus is on Mr. Thompson to show by facts, verified by a
licensed Engineer, that his property was not or is not in the floodway
or some one placed it in the Floodway. I am sure such court cases occurred
in the mid to late seventies and Larry Jackson can best provide advice to
the City Council in Executive sessions because it deals with possible
litigation.
My memory and recall estimates that I alone have spent more than 25 hours
on Mr. Thompson's problem(s), and in the seven months I have been here the
time is greater than that. Ms. Daneshmand and our secretaries have spent
much time with him and in researching information in response to his
requests.
aD/kg/
xc: Shohre Daneshmand, Civil Engineer
C/JOhNNY
Entered Emergency Program - 06/11/75
Conversion to Regular Program - 08/10/80
SUMMARY OF INSURANCE COVERAGEANDCLAI~S
/ Number of NFIP - Direct Policies in Force - 7
Number of WYO - Policies in Force - 17
Total Policies in Force 2~
Amount of NFIP - Direct Coverage -$ 584,100
Amount of WYO Coverage - 2,0200400
Total Coverage $2,604,500
Number of Claims Paid - -0-
Amount Paid -$ -0-
A driving tour of the City's floodplains was conducted on Novem-
ber 16, 1988, using the new Preliminary Flood Insurance Rate Map
(FIRM) dated 09/22,88. The tour was to identify any new develop-
ment in the redefined floodplain, and to review problems identi-
fied in the Community Assistance Visit (CAV) performed by
Maryetta Cunningham (FEMA) in June 1987. The following
observations of development in the Special Flood Hazard Areas
(SFHA) were noted:
~. 1. Cottonwood Branch at Sandy Lake Road is overgrown with
vegetation.
2. All houses along east side of Winding Hollow Lane are
i~..9~ ~ on lots that extend into floodway. Determine if
building sites are out of floodway.
3. Mobile home park on south side of Denton Creek at U.S.
~ Highway 121 has several units located in floodplain and
' floodway. (June 1987 CAV)
4. Junk yard on north side of Denton Creek at U.S. Highway
~ 121 has structures and junk in floodplain and floodway.
~C~,,.~ (June 1987 CAV)
~ ·
5. 348 Parkview Place is a new home bordering the Denton
~-) Creek floodplain. Check SFHA determination and lowest
floor elevation.
6. City Service Center on Deforest Road appears to be
? w-~,'=~ located in floodplain of Denton Creek. (June 1987 CAV)
~)w. 7. Multiple piles of fill material located on east side of
om.~L Allen Road just south of dead-end.