ASFPM – May 24, 2012
CASE STUDY – 408 PERMITTING AND LEVEE ACCREDITATION FOR
WATERLOO, NEBRASKA
ASFPM MAY 24, 2012
Presented byRandy Behm, PE, CFMLalit Jha, PE, D.WRE, CFM
ASFPM – May 24, 2012
OVERVIEW
• Levee History and Background• Regulatory Comparison• Project Approach • Problems and Challenges • Lessons Learned
ASFPM – May 24, 2012
• Just West of Omaha• West Bank of Elkhorn River• Population 728• Levee Constructed in 1967 by USACE• Entire Village is in Protected Area
LEVEE HISTORY AND BACKGROUND
ASFPM – May 24, 2012
• Enrolled in USACE PL 84-99 Program • Accredited Levee Since Early 1980’s• PAL Agreement entered on Jan 15, 2008• Evaluation, Design and Permitting(2008-2010)• Construction Started November 2010• Construction Completed October 2011• Accreditation Packet Submitted on April 2012
LEVEE HISTORY AND BACKGROUND
ASFPM – May 24, 2012
PAL PROCESS
• FEMA and Community Enter PAL Agreement• Levee is Shown as PAL and Allowed to Continue to Show Protection on
Flood Map• Provides Two Years to Submit Documentation Meeting 44 CFR 65.10
Requirements• After PAL Expires, FEMA Must Take a Minimum of 18 Months for Follow-
Up Mapping Processes (but still initiates levee de-accreditation process)
Recent Non-Accredited Levee Mapping Guidance -DRAFT process for mapping non-accredited levees, still being finalized
ASFPM – May 24, 2012
FEMA CRITERIA* (44 CFR 65.10)
• Freeboard• Closures• Embankment Protection• Embankment and Foundation Stability• Settlement Analysis• Interior Drainage• Operation Plan• Maintenance Plan
*CRITERIA PUBLISHED IN 1986
ASFPM – May 24, 2012
LEVEE DE-ACCREDITATION IMPLICATIONS
• Mandatory Purchase of Flood Insurance– Federally Backed Loan = Mandatory Flood Insurance
• Development Restrictions• Property Value/Re-Sale Concerns• Economic Development Concerns
Note: implications may be revised by new non-accredited levee mapping approach
ASFPM – May 24, 2012
USACE PL 84-99 PROGRAM
• Authorized through ER 500-1-1 (Civil Emergency Management Program)• Levees systems participating in PL84-99 must meet O&M RRR criteria• PL84-99 is not directly associated with FEMA levee certification• Levee section (crown, side slopes, r-o-w, seepage berms) remain intact
ASFPM – May 24, 2012
USACE PL 84-99 PROGRAM
• USACE Reviews– Modifications Related to O&M (Minor 408 Permitting)
• Approval at District Level
– System Changes to Levee Protection Level (Major 408 Permitting)• Approval at HQ level
ASFPM – May 24, 2012
Sec – 408 Modifications (Major) Assessment• Modifications requiring Chief of Engineers approval:
o degrading (lowering) projecto raisingo realignment
• Analyses required for major modificationo full range of loading (8 profiles)
upstream, downstream, adjacent too system performance (levee and structures)o risk analysis
USACE PL 84-99 PROGRAM
ASFPM – May 24, 2012
Sec – 408 Modifications (Major) Review• Iterative process:
o USACE district (initial, 60%, 90%, DrChecks) o agency technical reviewo type II Independent External Peer Reviewo USACE Division o HQUSACE
USACE PL 84-99 PROGRAM
ASFPM – May 24, 2012
PROJECT APPROACH
• Phased Approach – Preliminary Evaluation– Detailed Evaluation– Design/Permitting and Construction– Accreditation
ASFPM – May 24, 2012
PHASE 1 – PRELIMINARY EVALUATION
Levee Background Information
Field Investigations
Preliminary Hydrology & Hydraulics
Preliminary Freeboard Assessment
Levee Infrastructure Audit
Preliminary Economic Impact
ASFPM – May 24, 2012
PHASE 2 – DETAILED INVESTIGATIONS
Detailed Geotechnical Investigation
Detailed Hydrologic and Hydraulics- Internal Drainage Evaluation- Risk & Reliability Analysis- Pump Station evaluation
Alternatives Analysis
Drainage Structure Evaluation
ASFPM – May 24, 2012
Any improvement of levee will need U.S. Army Corps of Engineers approval.
Design Plans & Specifications
Permitting & Coordination
Post Construction
ConstructionImplementation
PHASE 3 – DESIGN AND CONSTRUCTION
ASFPM – May 24, 2012
PHASE 4 - ACCREDITATION
• Post-Construction– Verification of As-Built Condition and Meeting Project Intent– USACE O&M Manual Updates
• Accreditation Package– FEMA PM 63– FEMA Tabbed Submittal– Bringing it All Together
ASFPM – May 24, 2012
DESIGN AND PERMITTING
• Design of Improvements– Increase in Levee Height– Riverside Gatewell Improvements– Addition of Toe Drain– Accounting for O&M Deficiencies – Vegetation
• Permitting– 408 Permit– 404 Permit– Railroad– Department of Road– Floodplain – Others
ASFPM – May 24, 2012
CONSTRUCTION
• Construction– Contractor Coordination and Observation– Geotechnical Oversight– Phasing for NEPA– Vegetation Removal– Emergency Action Plan (EAP)
• Available/Designated Materials and Staff
ASFPM – May 24, 2012
LEVEE IN ACTION
• Flooding Elkhorn River– Ice Jam Downstream (Feb 2011)
• EAP Implemented
ASFPM – May 24, 2012
PROBLEMS AND CHALLENGES
• Freeboard• Geotechnical• Interior Drainage• Flood Warning Procedures
ASFPM – May 24, 2012
PROBLEMS AND CHALLENGES
• Time• FEMA vs. USACE Regulatory Requirements• An Acceptable Corps Inspection Rating, Alone, Does NOT
Equate to an Accredited Levee for the NFIP
ASFPM – May 24, 2012
PROBLEMS AND CHALLENGES
• Funding– Little if Any Funding is Available at the National or State Levels– FEMA Mitigation Programs Specifically Exclude These Types of Projects– Communities Must Fund Improvements Themselves
ASFPM – May 24, 2012
CONCLUSIONS AND LESSONS LEARNED
• Evaluate Early• Provide Routine Public Information• Timeline for PAL Insufficient for Significant Improvements• Coordinate with USACE Early • Evaluation Criteria of FEMA and USACE Are NOT the Same• Quality Geotechnical Evaluation• Construction Operations Sequencing/Scheduling• Vegetation Removals and Management• Emergency Action Plan and Preparedness
ASFPM – May 24, 2012
NATIONAL POLICY CHALLENGES AND EMERGING ISSUES
• Higher Standards for Levees (500-Year/0.2% Annual Chance Flood)
• FEMA Non-accredited Levee Mapping Approach• Mandatory Flood Insurance Behind Levees?• Railroad Highway Embankment Issues• Funding (or lack thereof)
USEFUL WEBSITES
National Committee on Levee Safety – www.iwr.usace.army.mil/nclsNational Flood Risk Management Program – www.iwr.usace.army.mil/nfrmp