This project is being built as part of a new combined cycle 300 MW gas fired power plant for the City of Austin, Texas. In order to prevent flooding of this site from Onion Creek a levee has been built. Existing floodplain maps do not show this levee. Upon request of the civil engineers on this project FEMA has issued a CLOMR (Conditional Letter of Map Revision) in which they state: "We have reviewed the submitted data and determined that the proposed project meets the minimum floodplain management criteria of the National Flood Insurance Program (NFIP). If the project is built as proposed, a revision to the Flood Insurance Study (FIS) and FIRM, for your community will be warranted...." In the case that the floodplain map is not updated before the project is complete, will we meet the floodplain requirement of SS Credit 1 if we provide a copy of this Conditional Letter of Map Revision (CLOMR)?
The intent of the flood component of the Site Credit 1 is to encourage building at least 5 feet above the 100 year floodplain. Doing so eliminates the need for levees which are generally distructive to the natural and built environment. For decades, the U.S. Army Corps of Engineers has encouraged the development of levees for flood control along major river systems. During high flow conditions, levees simply convey a flood surge to downstream communities. Levees channel a river into a narrower cross section that increases the velocity and flow which can scour natural and engineered systems. For example, this can cause soil erosion and bridge washouts. Levees also help eliminate wetlands, preventing water from flowing freely to flat areas adjacent to the river channel. These areas would otherwise serve as wetland habitat. It appears the project is not 5 feet above the elevation of the 100 year floodplain, and therefore the project would not comply with the requirements of this credit.