FS0001-CS010320Kimley-H0rnand Associates, Inc. Z~ ~ ----/,-z) ~ ~'! '~ ~
~,..~ .~ V ¥~ Suite 1800
C~Jl X~"OODallas,12700ParkCentralgriVeTexas
L," ~1 ~J~ 75251
March 20, 2001 VIA FACSIMILE
972.304.3673
HARD COPY VIA U.S. MAIL
8 pages total
Mi'. Ken Griffin, P.E.
Dii'cctoi' of Engineering and ?ub]ic Woi'ks
City of Coppe]l
?.O. Box 478
Coppcll, 'TX 75019
Re: Resubmittal Review
CLOMR and CDC Application
Estates of Denton Creek
Coppeil, Texas
Dear Ken:
Kimley-Hom and Associates, Inc. (KHA) has performed a review of the
resubmittal of the Estates of Denton Creek FEMA CLOMR Request for the 32.09
acre Holmes Tract, prepared by Nathan D. Maier Consulting Engineers, Inc.
(NDM), dated January 2001. The resubmitted Corridor Development Certificate
(CDC) application was also reviewed. This letter is set up to show the KHA
comments from NDM's previous submittal that were addressed and any
additional comments by KHA.
The submitted report includes only data to apply for a Federal Emergency
Management Agency (FEMA) Conditional Letter of Map Revision (CLOMR).
NDM's report does not address some issues related to the City's Floodplain
Management Ordinance, such as fully developed flows. KHA reviewed the
document for adherence to FEMA criteria and has also noted instances where
City criteria may not have been met with respect to the City Floodplain
Management Ordinance or Subdivision Ordinance.
·
TEL 972 770 1300
FAX 972 239 3820
Kimley-Harn
and Associates, Inc. C,y of Coppell. March 20. 2001. Page 2
1. The Effective and Annotated Flood Insurance Rate Maps (FIRM)
showing the project impact to the FEMA floodplain/floodway are not
readable in KHA's report copy. Please provide readable copies of these
exhibits.
Comment cleared. Readable copies were included in the resubmittal.
2. On page one of the narrative report, it reads "The resultant water surface
elevations due to the proposed grading of the Estates of Denton
Creek...". This statement implies that there will be modifications to the
floodplain elevations, while the remainder of the report maintains that
the base flood elevations (BFE) for Elm Fork or Denton Creek will not
change. Please provide clarification in the narrative.
Comment cleared. The comment was removed from the narrative, but no
clarification was given.
3. The FEMA 100-year Floodplain reclamation proposed in this CLOMR
could be accomplished using a CLOMR - F (CLOMR based on fill).
Please explain the reasoning behind pursuing a CLOMR for this
proposed reclamation.
Comment cleared. This comment was not addressed, but it is at the option of
the engineer and the City to determine by what means the floodplain is reclaimed
via FEMA.
4. The included FEMA MT-1 Form 3 outlines criteria for fill compaction
and erosion control in the FEMA 100-year floodplain. It is suggested
that this information be required on the grading plan for the site.
Suggestion stands. The requirements outlined on the forms should be included
on the plans or in the construction specifications.
5. The Post-Project Conditions Work Map shows a portion of multiple lots
will be located in the FEMA floodplain. It is suggested that the engineer
be made aware of Subdivision Regulation Appendix C, Section 11.5 a/b
covering access to this floodplain area for maintenance and provide for
this access via easements or other means.
Suggestion stands. While this comment does not pertain to the CLOMR
submittal, it is important that the development plans and final plat allow for this
access.
Kimley-Horn
and Associates, Inc. City of Coppell, March 20, 2001, Page 3
6. The FEMA floodway should be shown on any workmaps showing the
FEMA floodplain.
Comment cleared. The FEMA floodway has been included on the enclosed
exhibits and workmaps.
7. On FEMA MT-2 Form 1 Section 5, it states that the community will be
responsible for performing maintenance on flood control structures
associated with this project. The submitted CDC forms indicate that the
owner will be responsible for maintenance. Clarification of this
responsibility should be provided.
Comment cleared. The CDC form now matches the FEMA CLOMR forms.
The City of Coppell has been deemed responsible for maintenance on flood
control structures associated with this project.
8. The HEC-2 model for Denton Creek and HEC-RAS model for the Elm
Fork of the Trinity River are provided as supporting documentation to
this report. The HEC-2 model includes existing condition geometry with
fully developed condition flows. This model results in water surface
elevations through the project reach that may inundate the site during a
large storm event. This is evident comparing the resultant water surface
elevations from the HEC-2 model to the grading shown on the Post-
Project Conditions Work Map. It is also important to note that this
model would not typically be included in a FEMA CLOMR submittal,
rather the FEMA effective model for Denton Creek would be included.
The narrative report states that the site falls within the ineffective flow
area of the Sandy Lake Road Bridge over Elm Fork. For this reason, the
narrative concludes that the effects of Denton Creek should not govern
this floodplain. It is suggested that the engineer provide the FEMA
effective model for Denton Creek with any necessary geometry
modifications (if proposed) and address the concern stated above
regarding the fully developed floodplain. The FEMA effective model for
Denton Creek will need to be evaluated to see if those water surface
elevations pose a flooding hazard to the proposed development, or an
alternate explanation provided.
and Associates, Inc. City of Coppell, March 20, 2001, Page 4
Comment open. It is unclear in the submittal if the HEC-2 model for Denton
Creek is the FEMA Effective model. Please provide documentation or a
comparison to the FIS to clarify. FEMA could ask for this clarification as part of
their comments.
The HEC-2 model resubmitted for Denton Creek contains two profiles. The first
profile is existing condition FEMA discharges. The second profile is the 2-year
fully developed profile. NDM dropped the 10-year and 100-year fully developed
profiles from that model, but did not drop the 2-year profile. FEMA will likely
ignore the profile, but may return the submittal for clarification.
NDM has addressed the final comment under No. 8 above. An explanation is
provided in Section 5.0 of the narrative showing how the 100-year water surface
elevations in the Elm Fork of the Trinity River control the Denton Creek 100-
year floodplain.
While not necessary for a FEMA submittal, there is still concern regarding the
100-year fully developed flows in Denton Creek. According to the original
HEC-2 model submitted by NDM, water surface elevations through the project
reach still may inundate the site during a large storm event. This is evident
comparing the resultant water surface elevations from the HEC-2 model to the
spot elevations shown on the Post-Project Conditions Work Map. This concern
should be addressed by NDM at some point in the development plan process.
9. Digital models have not been included with the CLOMR submittal. It
would be helpful in review if these models could be provided. FEMA
typically will request digital copies of the models used.
Comment cleared. Digital models were included in the resubmittal.
10. The Post-Project Conditions Work Map includes topographic contours to
show the elevation of the site out of the 100-year FEMA floodplain. The
narrative report states that the fill will be 2 feet above the BFE. At the
northern end of the project, the BFE varies from 447.07 feet to 447.44
feet. The contours for the proposed fill in this area show 449 feet. Spot
shots showing the proposed fill 2 feet or greater above the BFE should be
shown on both the Work Map and reflected on the site grading plan.
Comment cleared. Grading spot elevations are now shown on the Post-Project
Conditions Work Map. The Work Map now matches the narrative.
Kimley-Horn
and Associates, Inc.
City of Coppell, March 20, 2001, Page 5
The CLOMR report is substantially complete for submittal to FEMA. Comment
No. 8 from the previous submittal remains open. That comment should be
addressed by NDM at some point in the development plan process as determined
by the City. It is not required by FEMA that the fully developed flows be
addressed.
The follow/ng comments pertain to the CDC application included with the
resubmittal package. The format is the same as the previous CLOMR submittal
comments.
1. A detailed Site Plan needs to be provided for adequate review of the
CDC application. This site plan should include the items outlined on the
application.
Comment cleared. A detailed site plan was included in the resubmittal.
2. The hydrologic and hydraulic information included on Part 2 of the CDC
form does not correspond to the FEMA regulatory information provided
in the CLOMR report or the profiles and cross sections provided as
attachments to the CDC application. Digital copies of the models should
also be included. Please have the engineer provide the proper backup
information for the forms.
Comment open. The hydrologic and hydraulic information included in Part 2 of
the CDC application still does not match the information in the CLOMR request.
KHA reviewed the electronic models provided by NDM and noted multiple
slight discrepancies between the two models. It is suspected that two base
models may have been used by NDM to create the submittals, one from the U.S.
Army Corps of Engineers, and one adapted by NDM. NDM should provide
clarification for the discrepancies and correct the submittal if necessary. Profile
outputs from the CDC and CLOMR HEC-RAS models are included as an
attachment to this letter.
Standard CDC Form Part 2 does not correctly reflect the upstream boundary for
the project in the 100-year flood event. The upstream boundary of the project is
HEC-RAS cross section 97919 as evidenced by the data in the table. The
velocity shown for the channel at the upstream boundary is from the next cross
section downstream of 97919. The form should be adjusted to match the correct
HEC-RAS model as determined from addressing the comment in the above
paragraph.
Kimley-Horn
and Associates, Inc.
City of Coppell, March 20, 2001, Page 6
3. Design and calculations for the valley storage mitigation swale should be
included with the CDC applications. They currently are not included.
Comment cleared. Valley storage calculations were included in the resubmittal.
4. (New Comment) Exhibits 4A, 4B, 5, 6A,and 6B call out the East Fork
of the Trinity River as the subject reach for the site. This site falls on the
Elm Fork of the Trinity. This should be corrected on the exhibits before
submittal. No formal response to this comment is necessary.
The CDC application is substantially complete for submittal. The submittal
could require further review, based on NDM's response to open comment No. 2
above. Review of NDM's reply by KHA is at the discretion of the City
Engineer, and can be performed on an hourly basis per our agreement.
Additional comments to the ones listed above may be generated as a result of the
reply to the above comment.
The City should evaluate the proposed development for impact to and influence
from the Denton Creek fully developed floodplain. The City should also
coordinate the application for the CDC with the U.S. Army Corps of Engineers
and be copied on transmittals from NDM to the Corps, TNRCC, etc. to see that
the City's requirements are met in this regard.
Please feel free to contact me if you have any questions or concerns, or need
clarification of the comments.
Sincerely,
Kimley-Horn and Associates, Inc.
Dan F. Grant, E.I.
Project Manager
/dfg
Attachments - CLOMR Submittal HEC-RAS Profile Table
CDC Submittal HEC-RAS Profile Table
G:~IYDROyrojects\63124004\CorrespXLetO2Cty. doc
cc: Mike Boyd, P.E. - Nathan D. Maier Consulting Engineers, Inc. - Via Facsimile & Mail
Plan: 10,50, & 100 River: Elm Fork Reach: ef3
~ t~:~ 31600.00 422.71 449.26 446.00 449.34 0.000210 2.02 20151.63 4218.30 0.11
31600.00 420.20 448.98 441.75 449.08 0.000384 3.78 20393.68 5700.01 0.16
i:i; 31600.00 418.75 448.79 442.24 448.85 0.000286 3.19 24006.11 5727.22 0.14
;,: ,,, ~ 31600.00 419.00 448.45 445.79 448.55 0.00054~ 4.43 19861.67 5255.84 0.18
~J 42900.00 419.80 448.03 444.01 448.07 0.000120 1.81 31534.77 6843.29 0.09
i~ 42900.00 418.90 447.9! 443.92 447.98 0.000132 2.12 32304.51 7301.67 0.09
~i~ ~t 42900.00 417.60 447.81 444.10 447.84 0.000145 2.41 33607.97 7704.08 0.10
~ 42900.00 416.90 447.66 444.12 447.70 0.000183 2.88 33011.64 6627.43 0.12
!!~ ~'~i';~ 42900.00 416.20 447.44 443.92 447.48 0.000325 3.07 33162.39 9125.75 0.14
42900.00 416.50 447.07 444.90 447.18 0.000600 4.36 25205.72 5250.00 0.19
~ 43500.00 417.30 444.66 441.64 445.20 0.001411 7.56 11215.89 2220.00 0.31
~;f~ ~ ~ 43500.00 417.50 443.67 438.18 444.32 0.001541 7.50 7235.27 1060.34 0.32
~ 43500.00 417.50 443.49 439.47 444.24 0.000654 8.99 7839.55 1019.43 0.35
~?;~ ~ ~ Bridge
~~ 43500.00 417.50 443.47 439.19 444.07 0.001383 7.84 7827.60 1019.37 0.31
~ 43500.00 417.50 443.50 438.50 444.03 0.001346 7.17 8034.56 1000.00 0.30
~ 43500.00 433.70 442.31 441.44 443.92 0.002712 15.01 5380.45 1000.00 0.93
~ 43500.00 433.70 442.25 441.44 443.90 0.002803 15.18 5317.44 1000.00 0.95
~ ~ 43500.00 410.20 443.04 431.60 443.56 0.000977 6.89 9247.99 1068.50 0.26
~ 43500.00 410.20 442.98 431.60 443.51 0.000994 6.94 9176.98 1067.78 0.26
~?i~ 43500.00 410.20 442.86 434.20 442.96 0.000089 2.04 17350.60 1319.75 0.08
~ ~!~ 43500.00 410.20 442.83 432.01 442.89 0.000050 1.37 22905.10 1896.06 0.06
43500.00 409.00 442.63 431.99 442.80 0.000341 3.89 14220.44 2477,79 0.15
43500.00 408.00 442.44 436.53 442.53 0.000262 3.32 19236.12 2584.95 0.13
Plan: UTCDCl-100 River:Elm Fork Reach: ef3
35600.00 422.71 449.84 446.00 449.91 0.000241 2.24 22577.53 4223.89 0.12
~~ 35600.00 420.20 449.53 442.46 449.63 0.000382 3.65 23518.39 5709.68 0.16
35600.00 418.75! 449.35 446.80 449.40 0,000276 3.20 27236.05 5817.79 0.13
35600.00 419.00 449.00 446.45 449.10 0,000549 4.52 22827.94 5415.65 0.18
49600.00 419.80 448,80 444,01 448.83 0.000110 1.80 36863.75 7079.53 0.08
49600.00 418.90 448.72 444.11 448,75 0.000118 2.06 38531.78 8133.72 0.09
~,~ ~iii~ ~. 49600.00 417.60 448.60 444.32 448,63 0.000128 2.33 39961.33 8162.77 0.09
49600.00 416,90 448,47 ~ 444,36 448.51 0.000160 2.77 38430.39 6755,73 0.11
49600.00 416.20 448.28 444.24 448,32 0.000277 2.94 40878.13 9233.62 0.13
49600.00 416.50 447.98 444,90 448.06 0.000477 4.03 31588.54 8750.00 0,17
51500.00 417.30 445.82 442.55 446,33 0.001338 7.67 13774.16 2220.00 0.31
51500,00 417.50 444.77 440,81 445.45 0.001550 7.84 8455.44 1150,00 0,32
51500.00 417.50 444.51 - 440.48 445.37 0.000729 9.81 8885.08 1024,55 0,38
Bridge
51500.00 417,50 444.53 440.11 445.20 0.001510 8,48 8910,32 1024,67 0.33
51500.00 417.50 444.56 439.56 445.16 0.001465 7,77 9094.56 1000.00 0.31
51500.00 433,70 443,04 442.59 445.02 0.003028 16.81 6114,40 1000,00 1.00
51500.00 433.70 442.70 442.59 444.97 0.003638 17.94 5770.53 1000,00 1.09
51500.00 410,20 443.84 433.49 444.47 0.001146 7,65 10112.42 1078.43 0.28
51500,00 410.20 443.77 433.49 444.41 0.001168 7.71 10028,30 1077.58 0.29
51500.00 410.20 443.94 434.21 444.07 0.000102 2.27 18814.01 1466.42 0.09
51500.00 410.20 443.92 432.01 443.99 0.000064 1.62 25041.44 2044.14 0.07
51500.00 409,00 443.68 433.64 443.85 0.000357 4.12 16873.93 2538.69 0.16
51500.00 408.00 443.48 437.54 443.58 0.000282 3.57 21939.57 2613.95 0.14