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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 02/08/2005 - REVIEW OF PROPOSED CITYWIDE FLOODPLAIN REGULATIONS DATE: February 8, 2005 STAFF: Jim Hibbard STUDY SESSION ITEM Bob Smith FORT COLLINS CITY COUNCIL Marsha Hilmes-Robinson SUBJECT FOR DISCUSSION Review of Proposed Citywide Floodplain Regulations (except for the Poudre River) On January 13, 2004 City Council held a study session on proposed floodplain regulation revisions. Council supported the proposed revisions. The process of revising City Code for formal consideration by Council grew into a total rewrite of Chapter 10. Since over a year has passed since the previous study session, this review was scheduled prior to final consideration in March. GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED • Does City Council still agree with the staff approach of balancing risk with regulation? • More restrictive in floodway, less restrictive in flood fringe • More restrictive for new development, less restrictive for existing development • More restrictive for residential, less restrictive for non-residential • Are there any specific regulations for which Council would like to see alternatives? • Is it still OK to have two regulations less than FEMA minimums and move to a Class 5 CRS rating? BACKGROUND The City of Fort Collins has participated in the National Flood Insurance Program since 1979, which enables property owners to purchase flood insurance through this federal program. Part of that participation includes the City's enforcement of floodplain regulations on existing and new development in the various floodplains across the city. Undeveloped properties located in a floodplain can develop as long as they comply with the floodplain regulations. The Fort Collins Utilities is charged with the administration of these regulations. The purpose of the enforcement of the regulations is to reduce the potential for loss of life and damage to properties located in or near these floodplains. Periodically the City has revised or updated these floodplain regulations. Floodplain regulations were first adopted in the City in the mid 1970's for the Poudre River. In 1979 the City of Fort Collins entered the National Flood Insurance Program with the adoption of floodplain regulations for the Poudre River, Spring Creek, and Dry Creek basins. Between 1979 and 2001 enforcement of floodplain regulations was expanded to other basins within the City when the master plan for that basin was adopted. February 8, 2005 Page 2 Several of the floodplains in the City have not been submitted to or approved by FEMA. In these floodplains the City has the option to establish floodplain criteria below the FEMA minimum. City basin floodplains are located in the Old Town, West Vine, McClellands/Mail Creek, Canal Importation, Foothills and Fossil Creek basins. FEMA basin floodplains are located in the Poudre River, Spring Creek, Dry Creek, Cooper Slough and Boxelder Creek basins. In the FEMA basins there are minimum standards set by FEMA that must be met in order to participate in the National Flood Insurance Program. However, FEMA encourages and supports communities that go beyond the minimum FEMA regulations in both FEMA and locally designated floodplains. After the 1997 flood, questions were raised concerning the adequacy of the City's floodplain regulations. City Council directed City staff to review the floodplains across the city and make recommendations on changes. In 2000, the floodplain regulations for the Poudre River were reviewed and changes to the regulations were adopted. Regulations for the other basins were to be reviewed as the City remapped the 100-year floodplains during the development of the basin master plans using the updated rainfall standard. In 2001, the Canal Importation Basin Master Plan and floodplain were adopted by City Council. Floodplain regulations were initially adopted for both existing and new development. However, several months later, City Council suspended regulations for platted and existing development on an interim basis until the citywide review could be completed. However, City Council determined that new development and critical facilities must continue to comply with the floodplain regulations as contained in city code. At that time, staff was instructed to review the City's floodplain regulations for all basins other than the Poudre River with the goal of balancing risk with regulation. In September of 2001, the Utilities General Manager was given the authority to remap the floodplains using the higher rainfall standard. The new mapping was completed in 2002 and 2003. On January 13, 2004 City Council held a study session on the proposed floodplain regulation revisions. Staff received the following input: • Council agreed with staff's approach of balancing risk with regulation. • Most did not have comments on specific regulations. There was one concern about allowing critical facilities in the moderate risk zone, i.e. 500-year floodplain or 100-year sheet flow areas of less than 1 foot in depth. • A majority thought it was ok to go from a class 4 CRS rating to a class 5. • Two members of council expressed concern about proposed regulations less than FEMA minimums, while others felt it was appropriate. During that discussion, City Council asked for the following additional information. • What impact do floodplain regulations have on property values? The City's Real Estate Services Department performed an audit of home sales in four areas of the city. That audit compared home sales outside of February 8, 2005 Page 3 the floodplain with comparable homes sold in the floodplain. The results of this analysis found that there was no discernable difference in sale price compared to those in the floodplain and those outside the floodplain. However, in some cases those in the floodplain did have a higher sales price than those outside of the floodplain. • What is the probability of a 500-year event over the life of a 30-year mortgage? There is a 5.8% chance that there will be a 500 year flood over a 30 year mortgage on a home. For a 100 year event over that same period, there is a 26%chance of being flooded. • Provide an example of a typical 500-year floodplain map. See the attached map. Floodplain Maps and Property Statistics A map of the revised citywide floodplains is attached. The floodplains on this map are the maximum extent of the existing (FEMA) mapping and the new City mapping. The 100-year floodways (areas of greatest risk with high depths and velocities) are shown in dark blue. The 100-year flood fringe is shown in light blue. The moderate risk areas, shown in green, are either the existing FEMA 500-year floodplain in the Poudre River basin or areas of sheet flow in the 100-year floodplain in the other basins. The 500-year floodplain will not be mapped in basins other than the Poudre River. Citywide statistics for the 100-year floodplain are shown in the following table. Floodplain Statistics Floodway Flood Frin e Moderate Risk Area acres 1900 1,200 500 Number of Structures 700 1500 900 Revised mapping has been submitted to FEMA for the basins that have FEMA basin floodplains, except for Dry Creek, which will be submitted after the completion of the Dry Creek Flood Control Project. This will result in only one regulatory map per basin. Floodplain maps are also revised after each capital improvement project to reflect areas that are no longer in a mapped floodplain. Since 1997, over 900 structures were removed from the floodplain in the Old Town basin due to the construction of stormwater capital projects. February 8, 2005 Page 4 Proposed Floodplain Regulations As staff began review of the floodplain regulations, the purpose of floodplain regulations as contained in Chapter 10 of the City Code was reviewed and paraphrased into the following statement of purpose. "Strive to promote public safety, raise awareness of flooding risks, and reduce public and private losses from floods through enforcement of floodplain criteria that balance risk with regulation." To carry out this purpose, three underlying themes were identified: 1. Floodway vs. Flood Fringe Map a floodway (areas of greatest depths and highest velocity) in all of the City's floodplains where practical. This allows the higher risk areas to be distinguished from the floodplain areas of lower risk. Staff is recommending stricter regulations in the higher risk floodway areas and less restrictive regulations in the remaining 100-year floodplain. 2. New Development vs. Existing Development It is important that we not create future problems that will place more people at risk and require those who come after us to spend money fixing new problems. On the other hand, there are many existing homes and businesses currently in floodplains where owners have normal expectations of being able to remodel, repair and add to their structures. Staff is recommending stricter regulations for new development and less strict regulations for existing structures. 3. Residential Development vs. Non-Residential Development From a health and human safety perspective, residential structures represent a higher risk than commercial structures. Staff is recommending stricter regulations for residential development and less strict regulations for commercial development. Compared to the City's current regulations, some of the proposed regulations are more restrictive, while others are less restrictive. The attached floodplain regulation matrix identifies the proposed regulation changes. It is color coded to show which changes are more restrictive, less restrictive, or remain the same when compared to existing regulations. This matrix also compares the proposed regulations to the FEMA minimum requirements. To help illustrate these regulations with less complexity, the attached "Proposed Floodplain Regulations Quick Guide" was prepared. February 8, 2005 Page 5 Key Changes to Floodway Areas More Restrictive than Current Regulations • New residential structures would not be allowed. Currently they are allowed if they show no-rise. • New residential additions would not be allowed. Currently they are allowed if they show no-rise. • Basements in non-residential new structures and additions would not be allowed. Currently they are allowed if floodproofed. Less Restrictive than Current Regulations • Substantial Improvement time period changed from the life of the structure to 1-year. • Freeboard requirement changed from 18-inches to 6-inches on substantial improvements and non-residential additions. • Utilities General Manager can waive floodplain regulations in a City basin floodplain if a capital project is under construction. Currently, completion of the project is required. • Sub-grade crawl spaces would be allowed per new FEMA guidelines. Currently sub- grade crawl spaces are not allowed. Key Changes to Floodplain Fringe Areas More Restrictive than Current Regulations • New mobile homes or modular offices would not be allowed except in existing parks or as a replacement for an existing mobile home or modular office. Currently the development of new mobile home and modular offices parks are allowed. Less Restrictive than Current Regulations • Substantial Improvement time period changed from the life of the structure to 1-year. • Improvements on a floor above the flood elevation would not count toward the substantial improvement amount (50% of current market value) for structures in a City basin floodplain. Currently all improvements in the structure count toward the substantial improvement amount. • Freeboard requirement would be changed from 18-inches to 6-inches on substantial improvements and additions. • Utilities General Manager would be able to waive floodplain regulations in a City basin floodplain if a capital project is under construction. Currently, completion of the project is required. • Sub-grade crawl spaces would be allowed per new FEMA guidelines. Currently sub- grade crawl spaces are not allowed. February 8, 2005 Page 6 Key Changes to Moderate Risk Floodplain Areas Less Restrictive than Current Regulations • Allow new critical facilities in the 500-year floodplain and in the 100-year sheet flow areas of less than 1-foot. Currently new critical facilities are not allowed in the moderate risk areas. • New structures or additions in the 100-year sheet flow areas do not have to be elevated or floodproofed. Currently they are required to be protected. Code Language Changes in Erosion Buffer Zones Erosion buffer zones, identified in the Stormwater Master Plan, are areas along certain streams that need regulation due to the tendency of the stream to change its alignment. Previously requirements for erosion buffer zones were administered with the basin master plan. To consolidate like regulations into a common area, the regulations for erosion buffer zones are being added to the floodplain code section. The majority of erosion buffer zones are along Fossil Creek and Boxelder Creek. Other Changes There are some minor"housekeeping" items that are included in the proposed code. These items are needed to enable city code to be compatible with current FEMA terminology and interpretations. To make the city code more user friendly and easier to understand, Chapter 10 of the City Code was rewritten and more language was added to clarify specific types of development activities in the floodplain and their applicable floodplain requirements. The Poudre River floodplain regulations were rewritten in order to provide a consistent format and make the code easier to understand and use. There are no policy or regulatory changes to the provisions of the Poudre River floodplain regulations. Proposed Regulations Below FEMA Minimums In the past, the City basin designated floodplains have been regulated the same as the FEMA basin floodplains with some criteria above the FEMA minimum. However, in the proposed regulations for the City basin floodplains, two of the criteria are less restrictive than the FEMA minimum. These are: • Improvements on a floor above the flood elevation would not count toward the substantial improvement amount (50% of current market value). • The Utilities General Manager would be able to waive floodplain regulations once a stormwater capital project is under construction that will remove the structure from the floodplain. February 8, 2005 Page 7 Effectively, this means that City basin floodplains would be regulated at a lower level than FEMA floodplains on the above two criteria. Community Rating System and Flood Insurance Considerations Fort Collins currently has one of the highest rated stormwater management programs in the country based on the FEMA Community Rating System (CRS). The CRS is a voluntary incentive program that encourages communities to go beyond FEMA minimum requirements for floodplain management. Based on a rating of numerous stormwater management activities (public outreach, higher regulatory standards, drainage system maintenance, flood warning, etc.) residents and businesses of a community receive a discount on their flood insurance premiums. Fort Collins currently has a Class 4 rating (on a scale of 1 to 10 with 1 being the best) which results in a 30% discount on flood insurance premiums. All structures in Fort Collins are eligible for flood insurance regardless of whether they are located in a floodplain or not. Lenders must require flood insurance for any structure in a FEMA basin floodplain. Lenders may require flood insurance for structures in City basin floodplains or areas not even mapped in a floodplain, although this is not a common practice. The cost of flood insurance depends on many variables including amount of coverage, deductibles, type of structure, and how high the structure is elevated above the flood level. As of November 2004, there are 356 flood insurance policies in Fort Collins. Of the 356 policies, 72% are residential and 28% are non-residential. Changes in regulations as proposed would result in Fort Collins moving from Class 4 to Class 5. This will result in the City's discount rate dropping to 25%. The impact of this change is shown in the following table. Impact of CRS Class Change on Annual Flood Insurance Premiums Average Annual Average Annual Community Wide Premium Before Percent Premium After Annual Premium CRS Class Discount Discount Discount Cost 5(proposed) 548 25% 407 $144,892 4 current 548 30% 381 $135,636 Difference 5% 26 $9,256 Fort Collins obtained the Class 4 rating in 2000, having had a Class 6 rating since 1995. As of October 2004, there were 1,006 communities nationwide participating in the CRS program. The following graph shows the distribution of communities by CRS class: February 8, 2005 Page 8 National Flood Insurance Program CRS Communities by Class 500 460 407 d 400 350 321 1,006 Communites E 300 66%of NFIP Polices u 250 196 0 200 160 E 100 53 e 50 26 2 1 0 Class 9 Class 8 Class 7 Class 6 Class 5 Class 4 Class 2 The City recently received a$2.7 million Pre-Disaster Mitigation (PDM) grant from FEMA for capital projects on Spring Creek. Although our CRS rating was not used as a rating factor in this application, staff has learned a community's CRS rating will be used as a factor in evaluating future PDM grant applications. How much weight is given the CRS rating and effect of the proposed CRS class change on future grant applications is unknown. There are two specific regulations staff is proposing to become less restrictive that will effectively result in Fort Collins moving to a Class 5. If Council wants to maintain the Class 4 rating, the following regulations would have to be adopted in lieu of the staff recommendation: • require no new critical facilities in the moderate risk areas, and • require the time period for calculation of substantial improvement be cumulative for 10 years in the FEMA floodplains. Public Outreach The process of informing property owners in the City's 12 stormwater basins of upcoming changes to both the master plan and floodplain regulations began in early 2002 and continued until late 2003. A variety of communication tools such as customer mailings, web pages, press releases and media interviews, public meetings and open houses, and outreach to both internal and external groups potentially affected were used. In 2002, customers most affected by floodplain boundaries and proposed regulations were identified as the primary focus of initial outreach. Because a significant number of those within the mapped floodplains are Larimer County residents, City and County staff collaborated on public outreach. February 8, 2005 Page 9 These customers received a packet that included comprehensive information about: • floodplain mapping, • the review process for floodplain regulations, and • the impacts on property mapped within the floodplains. Each property owner/renter also received: • an individualized floodplain map showing their property relative to the floodplain, • a flood history for their basin, and • property protection information. Eight public open houses were held to provide an opportunity for customers and staff to discuss the information included in the mailings as well as the master planning process. Customers received mailed invitations and open houses were advertised in the Fort Collins Coloradoan and North Forty News. At the same time, web pages were developed on the Utilities Web site to provide additional information. Over 4,000 packets were mailed, and 250 people attended the 8 open houses held during the year. In 2003, public outreach was expanded to include all property owners and renters in the City's stormwater drainage basins, not just those within the mapped floodplains. At a kickoff open house held in February, property owners and renters were invited to learn more about the City's stormwater drainage basins, floodplains and regulations, safety and flood protections, and the regional weather patterns that can result in flash flooding. Following the kickoff, nine additional public open houses were held. Information presented at the open houses consisted of basin-specific information as well as information about the citywide planning process, including: • flooding histories for each basin, • maps showing identified basin problems, • maps showing proposed solutions, • proposed floodplain regulations, • stormwater project funding, and • the process for adoption of master planning and floodplain regulations. Over 62,000 pieces of mail were sent, including informational packets, basin-wide kickoff invitations, open house invitations and letters to 24 community organizations. Publicity for the outreach campaign included media releases and briefings, and advertising in local media. The nine open houses were attended by 470 people. Of the 24 community organizations contacted, seven asked for presentations or more information. Presentations were made to six City Boards and Commissions, including the Water Board, the Natural Resources Advisory Board, the Planning and Zoning Board, the Affordable Housing Board, Landmark Preservation Board and Parks and Recreation Board. The Water Board and the Planning and Zoning Board recommend adoption of the recommended changes. The consensus of the Affordable Housing Board was that the approach was reasonable and agreed February 8, 2005 Page 10 with the proposed changes. The Natural Resources Advisory Board, the Parks and Recreation Board and the Landmark Preservation Commission elected not to provide a formal recommendation. Their comments were included in the summary of comments however. Comment forms were available at the open houses and on the Utilities Web site. Thirty-three comment forms were submitted. Although most of those who attended open houses did not comment formally on either the proposed master plan or floodplain regulations, almost everyone got a chance to express their views to staff. Comments received on floodplain issues can generally be summarized as follows: • questions about the rainfall standard, never seen that much water, even in 1997, • agreed with the themes used to balance risk with regulation, • questions about the accuracy of the mapping, offered data for review, • regulations have a financial impact on property owners, • regulations are too strict, • regulations are not strict enough, • would like different regulations in each basin, • properties in floodplains pay for flood insurance in addition to stormwater rates, and • benefited from remapping, would like City to submit to FEMA soon. ATTACHMENTS 1. City of Fort Collins Flood Risk Map 2. Floodplain Regulation Review Table (Matrix) 3. Proposed Floodplain Regulations Quick Guide 4. 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