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Bethel Rd Est 2-CS010703Kimley-Horn end Associates, Inc. July 3, 2001 Mr. Ken Griffin, P.E. Director of Engineering and Public Works City of Coppell P.O. Box 478 Coppell, TX 75019 Tributary G-1 of Grapevine Creek Coppell, Texas · Suite 1800 1270~ Park Central D~ive Dallas, Texas 75251 VIA FACSIMII,E 972.304.3673 HARD COPY VIA U.S. MAIL 4 pages total Dear Ken: Kimley-Hom and Associates, ~c. (KHA) has performed a review of the Floodplain Analysis Report for a Conditional Letter of Map Revision for a portion of Tributary G-1 of Grapevine Creek, prepared by JD Landes, Inc. (JDL), dated June 2001. The submitted report includes data to apply for a Federal Emergency Management Agency (FEMA) Conditional Letter of Map Revision (CLOMR). 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. KHA recommends that JDL address the following items: The Effective Flood Insurance Rate Map (FIRM) showing the project impact to the FEMA floodplain/floodway is not very readable in KtIA's report copy. Please provide readable copies of the exhibit. It is important to note here that JDL may be interpreting the FIRM incorrectly. There is not a 500-year floodplain associated with Tributary G-1 on the FIRM. The workmaps included in the submittal call out the · TEL 972 770 1300 FAX 972 239 3820 Kimley-Horn and Associates, Inc. City o f Coppell, July 3, 2001, Page 2 100-year and 500-year floodplain and 100-year floodway, but the modeling does not correspond to the floodplains delineated on the workmaps. JDL should provide clarification and/or and explanation. It is also unclear what hydrology the floodplain delineations are based on. A clarification of the linework on the workmaps is needed. The FEMA floodway should be shown on any workmaps showing the FEMA floodplain. 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. On Table 6A, slight increases (ranging from 0.01 to 0.02 feet) are occurring at 6 cross sections through the subject roach. These increases appear to be a result of the proposed fill. Article 4, Section C.5.a of the Coppell Floodplain Management Ordinance states that the proposed development "will not increase the water surface elevations of the design base flood (fully-urbanized watershed)." The design or modeling should be revised accordingly. Table 2 in the report calls out a "software anomaly" to account for the increase in water surface elevation between the current effective and duplicate effective models. JDL should reference the specific source that they believe is the source of this anomaly and why the reviewer should discount it. It is likely that the FEMA reviewing agency will ask for the same information. The production of the corrected effective model for the tributary shows that three homes on the north side of the tributary are now slightly in the "500-year floodplain" (or 100-year floodplain - to be determined by the design engineer under Comment 1) by overlay of the floodplain boundary. It is advised that the finished floor elevation of these structures be obtained and compared to the proper floodplain elevation to evaluate the potential flood hazard to these s~ructures. Note that homes may not be located in the 100-year floodplain (FEMA or City fully developed) by elevation or by overlay of the FIRM. A comparison of Table 4 to Table 6 shows negative surcharges in the 100-year floodway as a result of the proposed development. It is unlikely FEMA will accept these floodway modeling results while they include negative surcharges. It may be possible to adjust these values by attempting to optimize the floodway as outlined in Comment No. 8. Kimley-Horn and Associates, inc. 10. 11. 12. 13. 14. It is noted that the floodway modeling does not appear to have encroachments made from the floodplain to the floodway, attempting to optimize the floodway elevation 1'0" above the floodplain elevation. A comparison table is needed between the lO0-year floodplain and floodway elevations in the duplicate effective, existing (corrected effective), and proposed improved conditions to properly evaluate this effect. Once the floodway is set, no rise will be allowed by FEMA in the LOMR process. It is advisable to attempt to optimize the floodway using the encroachment model. It appears by evaluating the FIRM that this project will require adjustment of the FEMA floodway. There is not proper modeling in the submitted report that supports such an adjustment. Efforts to address comment No. 8 above should assist in addressing this comment. An encroachment model is not required for fully developed watershed conditions in existing or proposed hydraulic conditions. It is recommended that fully developed models be clearly separated from FEMA flow models for submittal as a CLOIVIR. It is acceptable to submit them to FEMA, but their reviewer will ignore the fully developed models in the submittal. Please have noted in the report and on the workmaps what cross section(s) the water surface elevations are taken from to compare to the finished floor elevations of the proposed lots. Any interpolation performed should be explained in the report. In producing a corrected effective model, it is advisable for the design engineer to reevaluate the Marming's "n" values in the tributary and its overbanks during a field visit. The "n" values remain consistent from the duplicate effective to the corrected effective and finally the proposed condition model. While the adjustment of these values should not affect the proposed encroachment, they may increase the base flood elevations through the reach of the project and affect the fill and wall design. Any adjustment is based on the design engineer's judgment with proper backup and research. It appears that the proposed condition - ultimate discharge HEC-2 model is missing from the Appendix. It should be included for comparison and review. Kimley-Hom and Associates, Inc. City of Coppell, July 3, 2001, Page 4 15. Forms required by FEMA to process a CLOMR are not included in the submittal. They must be reviewed and signed before submitting the CLOMR request to FEMA. Downloadable forms may be found at http://www, fema. gov/mit/t sd/DL MT-2.htm. 16. It is advisable that the City has the design engineer evaluate the proposed development for impact to valley storage. Coppell's Floodplain Management Ordinance requires a separate analysis for this condition through the project reach. The CLOMR report is currently not complete for submittal to FEMA. The comments listed should ha addressed before a submittal is made. Additional comments to the ones listed above may be generated as a result of the reply to the above comments. All responsibility for the adequacy of the design plans and models shall remain with the design engineer. In reviewing these plans and models, KHA must rely upon the adequacy of the work of the design engineer. With recent changes with the FEMA consultant reviewer, KHA would be happy to provide the City of Coppell with details of the updated process. There have also been recent developments with respect to the fully developed floodplain and FIRM mapping that KHA has become aware of. Let me know if you need to discuss this information. 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. Project Manager cc: Justin D. Landes - JD Landes, Inc. 1107 East 1't Street Fort Worth, TX 76102 VIA U.S. MAIL