Item J13 J.13
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CountCounty ��Monroe. ,y, ? "tr, BOARD OF COUNTY COMMISSIONERS
y M T� \�1a� Mayor Michelle Coldiron,District 2
�1 1 nff `_ll Mayor Pro Tem David Rice,District 4
-Ile Florida.Keys Craig Cates,District 1
Eddie Martinez,District 3
w Mike Forster,District 5
County Commission Meeting
June 16, 2021
Agenda Item Number: J.13
Agenda Item Summary #3303
BULK ITEM: No DEPARTMENT: Building
TIME APPROXIMATE: STAFF CONTACT: Karl Bursa(305) 453-8759
11:30 AM
AGENDA ITEM WORDING: A Presentation of Monroe County's Appeal of the updated FEMA
Flood Insurance Rate Maps (FIRMS)by County Staff and Woods Hole Group.
ITEM BACKGROUND: Monroe County currently participates in the National Flood Insurance
Program. As part of the Federal Emergency Management Agency's (FEMA) Risk MAP study for
South Florida, PRELIMINARY Flood Insurance Rate Maps (FIRMS) for Monroe County were
released on December 27, 2019. These maps show FEMA's preliminary data on Flood Zones and
required Base Flood Elevations for Monroe County which will replace the effective 2005 maps once
they are finalized and adopted by the County.
Generally the following changes are proposed by FEMA:
• The existing maps are outdated (County's surge analysis is 40 years old).
• There are 4 Current County Flood Zones:
o Zone AE: An area inundated by 1% annual chance flooding, for which BFEs have
been determined.
o Zone VE: An area inundated by 1% annual chance flooding with velocity hazard
(wave action) for which BFEs have been determined.
o Shaded X Zone: An area of moderate flood hazard between the limits of the base
flood and the 0.2% annual chance flood.
o Unshaded X Zone: An area of minimal flood hazard outside the SFHA and higher
than the elevation of 0.2% annual chance flood.
• The New FIRMS will include a new boundary (Limit of Moderate Wave Action [LiMWA]),
which will be shown on the maps and if a property is within this boundary, it will be required
to be built to VE Zone construction standards
• There is a datum change from NGVD29 to NAVD88, which means there is now
approximately a 1.4' difference in existing elevation
• Required structure elevations throughout all areas of the County, including cities have
changed
During the week of January 27, 2020, FEMA held Preliminary Map Open House Meetings where
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the public was invited to meet with FEMA representatives and staff members from the various
municipalities to discuss the Preliminary Maps and how the changes would impact property owners.
Last year, in anticipation of the new maps, the Monroe County BOCC approved a contract for
Woods Hole Group (WHG), Inc. to provide assistance to Monroe County to review and comment on
the updated FIRMS. Representatives of WHG have been working side by side with staff to analyze
the maps and the data used to create them for any discrepancies, inconsistencies, or errors in
methodology.
On May 4, 2020, some of this analysis was submitted to FEMA requesting that FEMA reconsider
the Preliminary Maps in advance of the start of the required notice in the Code of Federal Register
(CFR) and the appeal period. It was hoped that early coordination with FEMA regarding Woods
Hole Group's findings could help to limit the need for an appeal of the Preliminary FIRMS, while
still maintaining the County's ability to appeal, if issues remain with the methods utilized by FEMA
to develop the maps. On June 11, 2020 FEMA responded, addressing each of the 21 comments
submitted on the Preliminary Maps. In each case, FEMA respectfully declined to make any
adjustments or changes to the Preliminary Maps and analysis as it is currently presented.
On June 17, 2020, WHG presented their findings to the Board, which indicated potential
inconsistencies with standard practices in modeling on key components of the Risk MAP study and
with available data used to support FEMA's study. While further review of these issues is ongoing,
the scale of impacts to the Preliminary FIRMS ranges from the entire County to individual
neighborhoods. WHG noted inconsistencies both in method of risk modeling and in areas identified
below that need additional adjustment, including:
■ Storm selection
■ Statistical analysis of storm sets
■ Wave model validation
■ ADCIRC+SWAN model mesh resolution
■ ADCIRC+SWAN modeling of reefs
■ Overland modeling of mangroves
■ Transect spacing & location for overland modeling
■ Topography
The County Commission concurred and requested WHG work to develop appeal materials.
On December 22, 2020, FEMA published notice to open comments and appeals of the proposed
updates to Monroe County's FIRMS in the Federal Register. FEMA is required to publish two (2)
notices regarding the appeal period in the local newspapers of record. FEMA published the second
required publication on March 18, 2021. At the time of the second local public notice, Monroe
County's Comment and Appeal Period for the Preliminary Map update began and is running for
ninety (90) days, concluding on JUNE 17, 2021. During this time, all interested parties were
encouraged to submit comments or appeals to the proposed changes to the FIRMS. All private
comments and appeals were required to be submitted June 3, 2021. All remaining comments and
appeals are required to be submitted by the conclusion of the appeal period or the appeals will be not
be considered by FEMA.
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WHG will be submitting the Appeal by the deadline.
In the event Monroe County's appeals are not successful, the final procedural step available for an
applicant who has found inconsistencies or potential errors with the updated Preliminary FIRMS is to
request review of the Scientific Resolution Panel (SRP).
The County can request a Scientific Resolution Panel if:
• A Letter of Final Determination (LFD) has not yet been issued by FEMA, and
• Scientific and technical data submitted during the 90-day appeal period shows changes to the
Preliminary maps and the County has been consulting with FEMA on the appeal for at least
60 days (but not more than 120 days)
The Scientific Resolution Panel (SRP) can also be requested by the County if FEMA issues a
resolution letter to the appeal. In this situation, the County has 30 days to request the SRP if the
County finds issues with the resolution letter.
Attached are detailed projected timelines for the mapping appeal:
APPEAL PROCESS MAP
TIMELINE ADOPTION
(a ., Vo hll ed)
May April December
APPEAL 2021 2022 2022
(Starts) (Ends)
SRP PROCESS MAP
U� TIMELINE
z ( ADOPTION
June May
` SRP 2022 2023 January
m' 2024
(Starts): (Ends)
In addition to the Appeal information, County Staff have worked with Woods Hole Group to create a
comparison tool to show county residents how they would be impacted by the Preliminary FIRMS
and how they would be impacted in the event the County's Appeal was successful. Staff has made
this tool available on the Monroe County Floodplain Management Website for the public to view
and use.
This link can be found at:
h 1/Prelim FEMA Coin are.htiul
The results of Woods Hole Group's review of the maps has resulted in findings that would be
positive for Monroe County, showing reduced Base Flood Elevation (BFE's)in most areas and
changes in Flood Zones and the location of the LiMWA line that will benefit the overwhelming
majority of Monroe County property owners. While there are isolated areas that would be
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negatively impacted by the Appeal should it be adopted, it is Staff s belief that WHG's Appeal Data
more accurately depicts the flood risk to Monroe County.
PREVIOUS RELEVANT BOCC ACTION: On August 21, 2019, the Monroe County BOCC
approved a contract for Woods Hole Group, Inc. to provide assistance to Monroe County Staff to
review and comment on the FEMA Draft Flood Maps for Monroe County.
On September 18, 2019, Monroe County Floodplain Management Staff delivered a review of the
Draft Maps, proposed changes, and initial reactions/findings of Staff at the monthly meeting of the
Board of County Commissioners.
On January 22, 2020, Monroe County Floodplain Management Staff delivered an update on the
Preliminary Flood Insurance Rate Maps and the Consultation Coordination Officer (CCO) and
Public Open House Meetings.
On April 20, 2020, the Monroe County BOCC, through Chief of Floodplain Regulatory Operations
Karl Bursa, sent a letter to FEMA requesting an 18-month delay to the start of the Appeal Period for
the Preliminary Flood Insurance Rate Maps.
On May 4, 2020, Monroe County, through Assistant County Administrator Christine Hurley, sent a
letter to FEMA documenting the preliminary findings of Woods Hole Group, illustrating areas where
portions of the Preliminary Flood Insurance Rate Maps and the accompanying analysis contained
potential errors or inconsistencies.
On June 1, 2020, FEMA sent a letter declining the Monroe County BOCC's request for delay of start
of the Appeal Period. In this communication, FEMA also provided the County with an updated
timetable showing the approximate beginning of the Appeal Period in September of 2020 following
the conclusion of Pre-Appeal activities.
On June 11, 2020, FEMA sent a letter addressing Monroe County's letter regarding potential errors
or inconsistencies with the Preliminary Flood Insurance Rate Maps. FEMA's response
acknowledged the County's concerns; however, FEMA declined to make any changes to the maps or
the underlying analysis, stating that they stand by their data as presented.
On June 17, 2020, the Monroe County BOCC directed Staff and representatives of Woods Hole
Group to begin preparation in anticipation of an Appeal of the FEMA Preliminary Flood Insurance
Rate Maps.
On February 17, 2021, County Staff delivered an update to the Monroe County BOCC regarding the
FEMA Preliminary Flood Insurance Rate Maps, their adoption timeline, and Woods Hole Group's
appeal data.
CONTRACT/AGREEMENT CHANGES:
n/a
STAFF RECOMMENDATION: N/A
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DOCUMENTATION:
FINANCIAL IMPACT:
Effective Date: N/A
Expiration Date: N/A
Total Dollar Value of Contract: N/A
Total Cost to County: N/A
Current Year Portion: N/A
Budgeted: N/A
Source of Funds: N/A
CPI: N/A
Indirect Costs: N/A
Estimated Ongoing Costs Not Included in above dollar amounts: N/A
Revenue Producing: N/A If yes, amount:
Grant: N/A
County Match: N/A
Insurance Required: N/A
Additional Details: N/A
N/A
REVIEWED BY:
Rick Griffin Completed 05/24/2021 12:06 PM
Assistant County Administrator Christine Hurley Completed
05/28/2021 8:53 AM
Paunece Scull Completed 05/28/2021 9:51 AM
Purchasing Completed 05/28/2021 9:59 AM
Budget and Finance Completed 05/28/2021 10:00 AM
Maria Slavik Completed 05/28/2021 1:47 PM
Liz Yongue Completed 06/01/2021 10:36 AM
Board of County Commissioners Pending 06/16/2021 9:00 AM
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