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Dec. 18, 2020
Siting Standards For Critical Facilities
By Chad Berginnis, CFM, Executive Director, ASFPM The Insider
FEMA recently posted a fact sheet related to temporary critical facilities and floodplain considerations. Of course, we are all aware of the extraordinary steps that the local, state and federal governments are taking to battle the coronavirus, including the construction of temporary hospitals, mortuaries or recovery facilities for COVID-19 patients. Unfortunately – and this is especially true when you are in the heat of battle – we typically do not give enough consideration to potential site-related hazards such as flooding. I am really pleased to see FEMA release this fact sheet as a great reminder of a type of development that requires careful planning.
What are critical facilities/development/action? The simplest definition I have seen over the years is this:
A facility/development/action for which ANY threat of flooding is too great.
OK, so what exactly does that entail? Well, it could be a lot of things. That is why, instead of an exhaustive list of specific facility types, it is easier to define critical facilities by their impacts:
- Critical to the community’s public health and safety, especially during a flood event
- Essential to the orderly functioning of a community
- Storage or production of materials that are highly volatile, toxic or explosive
- Facilities where occupants may be insufficiently mobile to avoid loss of life or injury (this would encompass many of the COVID-19 related facilities)
- Facilities that, when flooded, would create an added dimension to a disaster
- Facilities that, when damaged, can impact the delivery of vital services
Examples of critical facilities include but are not limited to emergency service facilities (i.e., fire stations or emergency operations centers), hospitals, retirement homes/senior care facilities, major roads and bridges, critical utility sites (i.e., electrical substations, water/wastewater treatment facilities), hazardous storage facilities, and so forth.
What are appropriate standards for siting/protecting critical facilities? Where possible, critical facilities should simply not be sited where there is any risk of flooding. Now that is easier than it sounds because most community flood maps do not show all flood risks. And other communities may simply not have any sites that are not flood prone. So with that, there is a hierarchy that should be followed:
- Identify all flood hazards that may affect a proposed site for a critical facility. Start with your Flood Insurance Rate Map, but do not stop there. Is the site in a dam failure zone? Is it in an area protected by a levee? What is the protection level of the levee? Is there a small stream, drainage way, or conveyance of flood water in any proximity to the site? Is the site in a hurricane surge zone or tsunami zone that may not be on a FEMA flood map? Does the site have a history of flooding or standing water? What about high groundwater that could cause surface water flooding for long durations? It is very important that due diligence is exercised at this point. If any type of watercourse goes through or near the site, its flood hazard areas should be studied and mapped period.
- Do not place a critical facility on a site prone to flooding, ever. Ideally, this also means using the future conditions floodplains (not just the present condition 100- or 500-year floodplain). Future conditions are an especially important consideration in areas subject to sea level rise and significantly increasing storm intensity.
- If you must construct or improve a critical facility on a flood-prone site, at a minimum it should be protected/resilient to the 500-year level or flood of record, whichever is greater.
Other siting considerations include means of access to the facility – is there only one means of access to the facility or multiple? Is that means of access prone to flooding? Also, if the facility must be located in an area with some measure of flood risk, flood water velocity, debris, and erosion should all be considered.
If your community only relies on NFIP minimum standards for flood loss reduction, then your critical facilities are at high risk of flooding. You must have standards that go well beyond NFIP minimums specific to critical facilities to effectively protect them. If your community has adopted the most recent model building code that does not exclude flood standards, you will have a better level of protection for critical facilities. However, the best approach would be to have specific critical facility standards in your local floodplain management regulations, subdivision standards, and zoning. Your floodplain management code would handle building and siting requirements, subdivision standards can handle siting and access requirements, and zoning can handle specific prohibition of uses/facilities in certain areas. If you cannot change all three, then focus on your floodplain management regulations where you can address most, if not all, critical facility issues.
Where can I find out more?
There are several excellent resources on critical facilities. If you wanted to learn more about the origins of the concept of critical facilities then the two-page section on Critical Actions in the Further Advice on Executive Order 11988 publication produced by the Water Resources Council in the 1980s is a must read. FEMA has three detailed design publications that go in-depth on different aspects of critical facilities:
Each state and territory has a floodplain management office. Most of them have produced model floodplain management codes tailored to that state, commonwealth, or territory that may include a higher standard for critical facilities. If you don’t know who your state floodplain manager is you can find them here.
This article was reprinted with permission -Chad Berginnis, CFM, Executive Director, ASFPM “The Insider”
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Should I Sign This Letter Of Map Revision Based On Fill Community Acknowledgement Form? (Part 2)
The first part of this article on the Community Acknowledgement form can be found in the June 2020 issue of the Floodplain Management News. Since the questions continue to come into our office, we are offering the Community Acknowledgement Form, Part 2.
Who can complete the form?
- The community official responsible for floodplain management. Please consult with your local legal counsel on the community’s liability with signing the Community Acknowledgement Form.
Why is the form needed?
- The Community Acknowledgement Form is required prior to submitting a LOMR-F application to FEMA.
- Provides FEMA written assurance that the community is aware that the structure or property is located within the NFIP regulatory program and meets all community floodplain zoning requirements and federal requirements of the NFIP.
- It is important to read the Community Acknowledgment Form thoroughly, so that the Community fully understands what they are signing. There are sections on the form that request verification that previous fill was not brought on the property, etc.
What does a LOMR-F accomplish?
- It eliminates the property’s requirements for both flood insurance and floodplain zoning purposes, but only if all federal and community standards are met. It is very important to understand that FEMA has different minimum requirements than your community’s floodplain zoning ordinance. Keep in mind, the lender has the discretion to still choose to require flood insurance.
- It removes property from the floodplain. For the purposes of a LOMR-F, for a portion of a property to be considered out of the floodplain:
- It must be on fill at least two feet above the regional or base flood elevation (Flood Protection Elevation)
- The fill must be contiguous to land outside the floodplain
Please review the standards of your community’s floodplain ordinance to ensure the proper provisions are met, prior to signing the Community Acknowledgement Form.
The details about the federal requirements for a LOMR-F are in 44 CFR 65.5
Before signing the form, what documentation and analyses should we request?
- Verify if the land or structure to be removed is in the floodway or floodfringe zoning district.
- If the proposed development/fill is placed within an administrative floodway, the community may need to request a hydrologic and hydraulic analysis to verify that the development does not impact the regional or base flood elevation.
- A survey that confirms the lowest adjacent grade (LAG) – the lowest place that the ground touches the building. Remember to remove land from the floodplain, fill must be placed at least two feet above the regional flood elevation and be contiguous to land outside the floodplain. Keep in mind, a waiver from the local emergency services, cannot be used in lieu of contiguous dry land access for the purposes of a LOMR-F.
- That the land or structure removed is “reasonably safe from flooding” as defined in 44CFR 65.2(c). Under the requirements of federal Section 60.3 there must be written assurance that they have complied with the appropriate minimum floodplain management requirements. This section says that the community is assuring that any existing or future building will be “reasonably safe from flooding,” and all necessary permits were issued. Since “reasonably safe from flooding” is not defined in the code of federal regulations, the community must reference FEMA Technical Bulletin 10-01 “Ensuring that Structures Built on Fill In or Near Special Flood Hazard Areas are Reasonably Safe From Flooding (2001).
- Verify that the standards of your community’s floodplain ordinance are met, prior to signing the Community Acknowledgement Form.
- Verify that the federal requirements for a LOMR-F are met. The details about the Federal requirements are in 44 CFR 65.5
*Reminder* When a property receives a LOMR-F this does not mean the flood risk is eliminated, it just has been reduced. Landowners are highly encouraged to purchase flood insurance to protect their investment. With the LOMR-F, flood insurance policies may be available at a reduced cost.
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Flood-Frequency Of Wisconsin Streams Update
The U.S. Geological Survey (USGS) document, “Flood-Frequency of Wisconsin Streams” was updated in April 2020. This document contains regression equations frequently used for hydrologic stream flow calculations. The April 2020 publication revises some aspects of the 2017 update. The equations are mostly the same as the 2017 version with some clarifications of certain variables.
Since this 2020 publication supersedes the previous publications, the DNR will not accept new hydrology for floodplain analyses that uses a previous iteration of the USGS regression equations prior to April 2020. Similarly, the previous versions of these equations may not be used as the Chapter NR 116, Wis. Admin. Code required a second method for a new hydrologic analysis.
Questions? Please contact your regional DNR floodplain engineer.
Meet Our New Floodplain Staff
The DNR Dam Safety/Floodplain Management Program is pleased to announce Brian Cunningham as the new DNR Floodplain Management Policy Coordinator, working out of the DNR Dodgeville Service Center. Brian started with the Department on Oct. 26 and has the statewide responsibility of managing Wisconsin’s floodplain program by serving as the primary floodplain zoning policy and enforcement specialist for the DNR.
Brian will be the State’s National Flood Insurance Program (NFIP) Coordinator for administration of the NFIP in Wisconsin and the Community Rating System (CRS).
A greeting from Brian: “I am very excited to be a part of the DNR team as the new Floodplain Management Program Coordinator! Before migrating to the DNR, I worked for Sauk County’s Land Resources and Environment Department for over 20 years as a Land Use/Sanitation Specialist, Assistant Zoning Administrator and Deputy Director. Prior to that, I worked in Middleton for Resource Engineering Associates (REA, Inc.) as a hydrogeologist. I started my natural resources career at UW-Stevens Point where I received my B.S. degree in Water Resources-Hydrogeology. I currently live in Sauk County and enjoy spending most of my time backpacking, hiking, fishing and hunting with my wonderful family. In September, I was fortunate enough to have the opportunity to bow hunt in the White River National Forest in Colorado with some of my family and friends. This is a picture of the bull I harvested. Looking forward to getting to know you all.”
You can contact Brian by email at Brian.Cunningham@wisconsin.gov or cell phone at 608-220-5633
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About The Wisconsin Floodplain Management Program
The program's goals are to protect life, health and property; to minimize costs for flood control projects; to reduce tax dollars spent for rescue, relief and repair of flood damage; to shorten business interruptions caused by flooding; to prevent future flood blight areas; to discourage victimization of unwary land and home buyers; and to prevent increased flood levels caused by unwise floodplain development.
Contact Us
Floodplain: Brian Cunningham, 608-220-5633, Brian.Cunningham@Wisconsin.gov
Shoreland: Kay Lutze, 920-360-0472, Kay.Lutze@Wisconsin.gov
Dam Safety: Tanya Lourigan, 608-444-2089, Tanya.Lourigan@Wisconsin.gov
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Floodplain and Shoreland Management Notes is published by the Wisconsin Department of Natural Resources' Waterways Bureau. The purpose of the newsletter is to inform local zoning officials and others concerned about state and federal floodplain management, flood insurance, shoreland and wetland management, and dam safety issues. Comments or contributions are welcome. Please send comments to DNRFloodplain@Wisconsin.gov.
This newsletter is supported by funding through the FEMA Cooperative Agreement as part of the Community Assistance Program-State Support Services Element of the National Flood Insurance Program. The contents do not necessarily reflect the views and policies of the federal government.
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