HomeMy WebLinkAboutDepartment of EcologyD EGEI E
MAY 3 2017
CTTY CF PORT ANGELE S
CLEBK
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Apil24,2017
The Honorable Patrick Downie
City of Port Angeles
P.O. Box 1150
Port Angeles, W A 98362-0217
RE: National Flood Insurance Program (NFIP) Community Assistance Visit
Dear Mayor Downie:
I appreciated the oppornrnity to work with Nathan West on April 17,2017, to discuss
Port Angeles's participation in the NFIP. The conversation was a follow up to the Community
Assistance Visit (CAV) conducted by Donovan Gray on August 9,2012.
A primary purpose of our visit was to assure the City's implementation of Chapter 15.12, Flood
Hazard Protection Regulations, in the Port Angeles Municipal Code. Continued enforcement of
these provisions enables FEMA to continue to allow the sale offlood insurance in the City.
Other purposes ofthese visits are to provide you with the most current information on the NFIP
and state regulations and to give your staff aa opportunity to discuss issues conceming the City's
fl oodplain management program.
Correspondence dated August 22,2013, from Mr. Gray identified a number of outstanding
issues. I will address these issues in tum.
1. FloodplainManagementOrdinance
Minor updates to the City's Flood Damage Prevention Ordinance were requested and have been
completed. This matter is resolved.
2. Administrative and Enforcement Procedures
2a- Permittins
Mr. Gray noted that floodplain development includes activities that may be exempted from
building permit requirements under the Intemational Building Code (IBC). The City's
administrative processes must address the situation where floodplain development requires a city
Gt,
STATE OF WASHINCTON
DEPARTMENT OF ECOLOGY
The Honorable Patrick Downie
Apm24,2011
Page 2
permit but is exempt from the IBC permit requirements. Small storage structures are a corrmon
example of this situation. While this matter will not keep the CAV open, city staff must be aware
of the need to permit floodplain development even when the activity is exempt from building
permit requirements.
2b. Material and Dment Storase
Mr. Gray correctly noted storage of material and equipment in the floodplain meets the definition
of floodplain development and must be permitted. As discussed in item two, above, such storage
of materials does require a flood permit even if the activity is exempt from the IBC permitti:rg
rcqutements. As above, this is a technical assistance discussion item rather than a CAV
enforcement item.
2c. Res toration Proiects
While no enforcement issue has been identified, this item serves as a reminder that restoration
Fojects that change the aerial extent of the 100-year floodplain need to comply with FEMA's
iequirements for Letters of Map Change. A project that is only for ecological restoration may be
exempt from the requirement to prepare a habitat assessment. If such a project is proposed, I
recommend discussing the matter with FEMA or Ecology staff.
2d. s MSlOnS
While no enforcement issue has been identified, this item serves as a reminder to review for
floodplain management standards when reviewing subdivision applications, including
compliance with the Puget Sound Biological Opinion.
2d. Biotoei cal Opinion Requirements
As a Door 3 community implementing the Puget Sound Biological Opinion for the NFIP, Port
Angeles must require or prepare habitats assessments for all but a very narrow group of
floodplain development projects. I have attached a draft habitat assessment checklist prepared by
FEMA. Although still a draft; this docurnent previded useful guidance in reviewing and
preparing habitat assessments. ln this case, this is an ongoing training and assistance issue rather
than a CAV compliance issue.
This issue related to the proper flood permitting for construction trailers. Temporary uses require
flood permits. Nathan West's Apil14,2017, email indicates the trailers have been removed.
Thus, this case is closed.
3, Potential Violations
3a. Nippon Paper lndustries
The Honorable Patrick Downie
April24,2017
Page 3
3b. Ediz Hook and Port Angeles Haven
This matter was previously closed.
3c. Sand Gradine at Hollywood Beach
This matter was previously closed.
Training
I emphasize the importance of adequate training for those staff members engaged in
implementation of the NFIP. It is important that staff members responsible for the review of
floodplain development have a strong background in floodplain review standards, flood permit
record keeping, and Biological Opinion requirements. I ask that you allow staff members with
floodplain management responsibilities the opportunity to take advantage of NFIP and Habitat
Assessment training as it becomes available.
Conclusion
There are no remaining issues from our August 9, 2012, CAV. This closes the CAV for the City
ofPort Angeles. Our conclusion is that the City is effectively regulating development in its flood
hazard areas and is fully compliant with the NFIP. By copy of this letter, we are notiffing FEMA
of this certification.
Sincerely,
David Radabaugh
NFIP State Coordinator
Shorelands and Environmental Assistance Program
Nathan West, Port Angeles
Karen Wood-McGuiness, FEMA
Charles Kline, FEMA
Jeffree Stewart, Ecology
If any questions should arise in frrther implementation of your floodplain management program,
please feel free to contact Jeffree Stewart, Ecology's Southwest Regional Floodplain
Management Specialist, at (360) 407 -6521 or ieff.stewart@ecy.wa.sov, or myself at (425) 649-
4260 or david.radabaugh@ecy.wz. gov.
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