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Villages C P3&4-CS 950818 Federal Emergency Management Agency Washington, D.C. 20472 0._ f.... .-~ ~-e'~ A U G 18 1995 Mr. Steven W. Smith 977 Parker Drive CoppeR, Texas 75019 Dear Mr. Smith: This responds to your letter ~ted July 24, 1995. In your letter you asked for clarification of issues discussed in our June 26, 1995, letter to you, regarding a September 8, 1992, Conditional Letter of Map Revision (CLOMR) for Case Number 92-06-037R. Each of your questions is reiterated below, and followed by our response. 1. How COuld a LOMR now be issued by FEMA, which would remove strucn~es from the floodplain, 'if the elevations and locations of building foundations are identified and fill compaction for the foundations are provided,' when the September 8 CLOMR clearly states that a certification of compaction is required on all areas where fill was placed on the then currently effective floodplain ? The intent of the compaction requirement of the National Flood Insurance Program (NFl?) is to prevent struc~es elevated to or above the base (1-percent annual chance) flood elevation (BFE) from settling below the BFE. This requirement, spewed in Paragraph 65.5(a)(6) of the NFIP regulations, applies to fill pads prepared for residential or commercial stmcaa-e foundations and does not apply to filled areas intended for other uses. As stated in our June 26 letter, the site plan submitted to support the September 8 CLOMR did not identify the location of the fill pads; therefore, the compaction requirement identified in the September 8 CLOMR was for all areas proposed to be removed from the floodplain. 2. Since FEMA never received the as-builts and compaction reports as mentioned above, why does the F1RM (Community Panel Number 480170 0010 E, Map Revised April 15, 1994) suggest that the subject land development (Denton Creek/Villages of Coppell, Phase 3 & 4; Case No. 92-06-037R) no longer lie within the 100 year floodpha'n. Since the September 8 CLOMR was issued, the Flood Insurance Rate Map (FIRM) for the City of Coppell has been revised. A preliminary FIRM was issued to the community on December 18, 1991. During the review process of the preliminary FIRM, the City of Coppell submitted additional information, including the 'as-built' plans for the Villages of Coppell, Phases 3 & 4 project. This information was incorporated on the FIRM before the maps _boa___me effective on April 15, 1994. No compaction information was submitted during the review process of the pre'~ FIRM; however, "as-built" plans show the elevations of the lowest floors and lowest adjacent grades 2 of the homes on sheet 12, entitled "Lot Grading Plan, Villages of Coppell, Phase m' (copy enclosed), are at least two feet above the BFE. As stated previously, compaction requirements of Section 65.5 of the NFIP regulations are intended to prevent structures from settling below the BFE. Since it is unlikely, in this situation, that structures placed two feet above the BFE will settle below the BIZ"E, these areas can be removed from the floodplain without compaction information. 3. Since a LOMR was never issued by FEMA for the subject land development as mentioned above, does this mean that the homes within this development still lie within the 100 year floodplain? As stated above, the most recent FIRM for the City of Coppell dated April 15, 1994, includes as-built conditions within Villages of Coppell. The FIRM indicates that the new homes do not lie within the floodplain; therefore, a LOMR will not be necessary to show this. If you have any other questions regarding this matter, please contact Mr. Alan Johnson of my staff in Washington, DC, either by telephone at (202) 646-3403 or by facsimile at (202) 6464596. Sincerely, L~'\~ Michael K. Bu,~y', P.E., Chief /il' Fla,ard Idenfi/~mtl'~n Branch [/ Mitigation ~e~ate Enclosure / cc: ~/Mr. Kenneth Griffin, P.E. City Engineer City of Coppell Mr. Richard Hovas, P.E. Tipton Engineering, Inc.