Posted on Friday, February 16 2007 by Heather Brandon
At a Springfield City Council committee meeting yesterday at City Hall, the city’s flood protection system problem was discussed. Springfield Water and Sewer Commission executive director Joseph Superneau was there to say that the April 30 federal deadline for a plan is “reachable,” but “various obstacles could cause delays,” and no one seems to know who will pay for the upgrade. The city has until January 31, 2008 to make the required changes.
Last month, an article in the Boston Globe quoted Army Corps of Engineers regional spokesman Tim Dugan indicating that the recent round of dam inspections was prompted by the crisis in New Orleans. “After Katrina we had to take a hard look,” Dugan told reporter Kyle Cheney. “It’s really up to the communities to determine how they proceed with these projects.”
The same article quoted Chicopee Mayor Michael Bissonnette, “This sort of alarm, without the scientific or agricultural background or the engineering background to go with it, is unfortunate.”
What, the Army Corps of Engineers hasn’t done its homework? Does Mr. Bissonnette mean to indicate that these drastic required changes might have something to do with… paranoia?
A February 2 press release from the Corps shines a little light onto why this is happening now. From the release:
A levee is a man-made structure, usually an earthen embankment, designed and constructed in accordance with sound engineering practices to contain, control, or divert the flow of water so as to provide protection from temporary flooding. Levees were first built in the United States more than 150 years ago. Farmers, traditionally drawn to the rich soils of floodplain, put many of the earliest levees in place to protect agricultural areas from frequent flooding. The Corps’ Levee Safety Program emphasizes the role of levees in flood and storm damage reduction to reduce the risks to public safety.
The Corps of Engineers first became involved in flood damage reduction through the 1917 Flood Control Act, which authorized the Corps to have a significant role in flood activities nationwide. The Corps has long been active and concerned with the protection of life and property behind levees.
Most of these local protection projects in New England were built at the request of a local sponsor, either a city or state. Once construction was completed the projects were turned over to the city or state for operation and maintenance. The Corps provides periodic inspections.
Because of the cost to maintain these structures and the competing interests for money locally through the years, many lacked regular repairs or maintenance resulting in projects that today may no longer provide the expected level of protection against flooding that the projects were designed and constructed for.
The release adds, “To develop a program remediation plan, the city or sponsor which operates and maintains the project must conduct a comprehensive inspection of their project.”
The New England district of the Corps of Engineers sent along a “fact sheet,” dated November 20, to the Springfield Water and Sewer Commission detailing the changes that would need to be made along the city’s Connecticut River waterfront. At the time, an apparent misunderstanding left the city to believe that the changes were required almost immediately, leading to an urgent multi-mayor press conference sounding the alarm. But that was later clarified, and a follow-up January 31 letter was received outlining next steps. From that acronym-happy letter, signed by Colonel Curtis Thalken, Corps district engineer:
To afford you reasonable time to correct the noted deficiencies and establish the required maintenance program, the United States Army Corps of Engineers (USACE) is establishing a one-time only “maintenance deficiency correction period” (MDCP) of one year from the date of this letter. Failure to correct project maintenance deficiencies within a one-year period will result in the project being placed in an inactive status in the Rehabilitation and Inspection Program (RIP) and thus ineligible for Public Law (PL) 84-99 rehabilitation assistance. A summary of the observed deficiencies is provided below, and a copy of the inspection reports are enclosed for your reference.
Significant vegetation is present along the dikes and floodwalls creating insufficient vegetation buffers along the structures and insufficient vegetation controls on the structures. Approximately 200 linear feet of floodwall north of Broad Street have been removed by the abutting developer. General and routine maintenance is required on the pump station buildings and interior equipment. Numerous concrete repairs are required on the conduit, floodwalls, and buildings.
It should be understood that the USACE inspections provide a snapshot of the general condition of the flood protection project and highlight readily observable deficiencies. Our inspections do not detect all discrepancies nor do they relieve you of your duties and responsibilities under applicable federal law. It is incumbent upon you, in accordance with Title 33, Code of Federal Regulations, Section 208.10 (33 CFR 208.10) and the project Operation and Maintenance Manual, to insure the project is continuously maintained and operated to obtain the maximum benefits and ensure serviceability. By law you are required to perform a thorough inspection in accordance with 33 CFR 208.10 and the requirements identified in the O&M Manual to determine if there are other project deficiencies.
You are required to submit a plan for the correction of the project deficiencies within three (3) months from the date of this letter. The plan must include as a minimum: a schedule for correcting the noted deficiencies within the one-year period; a summary of the interim actions, which include an evacuation plan, that will be implemented to reduce the flood risk created by the deficiencies; and an outreach plan to notify the public of the deficiencies and planned correction process. If the correction plan is approved by the District Engineer and you adhere to the terms, conditions, and schedules established in the approved plan, your project shall maintain an active status in the RIP during the MDCP. If the correction plan is not approved, or the District Engineer determines the work outlined in your plan cannot reasonably be completed within one year, or at any time the plan is not fully implemented as approved, your project status shall be changed to “inactive.” Projects in an “inactive” status are ineligible for PL 84-99 rehabilitation assistance.
I just want to pause here to note that the letterhead on which this letter is printed says, “Department of the Army,” and not “Office of God,” for any who may have been wondering. Continuing:
Concurrent with the USACE’s inventory and assessment initiative, the US Department of Homeland Security’s Federal Emergency Management Agency (FEMA) has embarked on a nationwide flood plain mapping program—the Map Modernization (MapMod) Program. FEMA is responsible for administering the National Flood Insurance Program (NFIP), and develops Flood Insurance Rate Maps (FIRMs) to identify areas at risk of flooding, to determine flood insurance rates, and for flood plain management activities. Through the MapMod Program, FEMA will provide the nation with digital flood hazard data and maps that are more reliable, easy to use, and readily available. As part of this process, FEMA is working with other federal, state, and local agencies to ensure that the most up-to-date information possible is incorporated into this new digital project.
FEMA recognizes that many levees may have changed considerably or deteriorated since the current effective maps were published. As part of the remapping process, FEMA is verifying that all levees recognized as providing protection from the base flood meet the requirements outlined in Title 44 of the Code of Federal Regulations, Section 65.10 (44 CFR 65.10). Deficiencies noted in the USACE inspection could prevent this levee from meeting the operation and maintenance requirements of CFR 65.10 for certification under the NFIP.
We have provided a copy of this letter to your Congressional Delegates, the Governor, FEMA Region I, and the Massachusetts Executive Office of Environmental Affairs, as required by our regulations (ER1130-2-530, paragraph 3-3.g; or ER 500-1-1, paragraph 5-5.c).
Be assured that the USACE is committed to working closely with each state, local municipality, and project sponsor to ensure that levee projects protecting their communities are properly maintained. …This letter of notification only addresses the project’s eligibility for USACE rehabilitation assistance under the RIP, as associated with PL 84-99. Correcting the maintenance deficiencies within the MDCP does not imply the levee meets certification requirements for FEMA’s National Flood Insurance Program (NFIP) or meets eligibility for FEMA’s Provisionally Accredited Levee (PAL) Program. FEMA will make the final determinations for these programs.
Not the perkiest letter. But how cool that FEMA is digitizing its flood plain mapping system!
FEMA’s Map Service Center offers the ability to browse maps of Springfield’s flood control system online. Of the maps, Shaun Hayes, Cartographic Section Manager at the Pioneer Valley Planning Commission, said, “These maps portray special flood hazard areas inundated by ’100-Year Flood, 500-Year Flood,’ and various benchmarks relating to flood elevation. Although the flood control system is represented on the map, there are no attributes describing the system.”
Perhaps before long we’ll see a series of bake sales for the Water and Sewer Commission.