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November 2007

The below questions/comments were submitted by Mt. Vernon resident, Ted Cook:  A/C response in blue.

Just came across the August entry, Dr. Dr. Dr., I mean, that's got to trump anything...  Now Slade says that FEMA doesn't actually have to listen to an appeal if they choose not to.  Funny, because they've been so open to suggestion up to this point.

I agree, anybody that would put PhD after his or her name 3 times has to have an ego the size of Texas.  However, he did present some pretty good statistical data which when I get the time to update the Stewart Whitepaper again I will quote his data liberally.

FEMA is absolutely in charge and Senator Gordon was right on point.  FEMA is running the whole show and after reviewing all the work that has been done to show why the Stewart figures are not realistic, can say something like; “Thank you for your input but we have decided that it would be prudent and in the best interest of the American taxpayer (that is who they work for which may or may not be in the best interest of local government) to go with what we’ve got and not proceed with your recommendations or findings.”  Or they could say lets put this issue to bed once and for all and submit to a 3-5 scientist dominated “independent review” of the County’s work vs. FEMA/Corps/USGS work.  We just have to sort of wait and see how they respond to the County request based on newly gathered scientific evidence if they want to do that or not.  We have all seen how the federal agencies define “independent review”.  The Corps submitted their hydrology report to their office in Davis California without identifying any of the problems with the Stewart data.  USGS, submitted their request for an “independent review” from their office in Colorado that determined Stewart’s figures were within an acceptable 20-25% error factor although Stewarts methods were unacceptable to today’s standards.  And FEMA, well they just told their consultant the Michael Baker Corporation, not to do anything although they had promised me personally that they were going to ask them to do a complete “independent review”.  A truly independent review is all Skagit County has ever asked for.  And it is the one thing we never were given.  We can only hope that Senator Gordon and his law firm can be successful in bringing this about.

On floodways, I'd be curious if there is any intelligent opinion out there, perhaps from PIE or the corps hydrologist.  Are they applicable in an alluvial fan, or only in a river valley?  Dames and Moore said in 1982, conventional floodways are not appropriate for the complex flow of the Skagit river delta.  As far as any manmade structure that raises the BFE, there is the railroad and the interstate, two continuous pieces of raised fill.  Not to mention every raised road bed across the delta and the dykes at the sound.  Do the buildings have any impact on hydraulics?  I'm guessing no.  They're just there to get wet.  Any potential application of the floodway concept is now obsolete since so many roadbeds were built forty or fifty years ago.  Basically, the concept is good, but the damage is done.  The only thing that could raise the BFE more would be building a new roadbed or raising an existing road bed which is high and continuous.

One thing that is being lost in this whole floodplain/floodway argument is that the Skagit Delta is not just an “alluvial fan delta”.  The Skagit is a volcanic floodplain and anytime the two volcanoes (Mt. Baker and Glacier Peak) decide to reclaim Mother Nature’s park, all bets with the exception of one will be off.  That “one” is that the main channel of the river will move back again North to either Padilla or Samish Bay where the mouth of the channel used to be 5,000 to 10,000 years ago.  No matter what we do as mankind is going to stop that from happening.  So keeping areas open for serious flood events or channel changes due to volcanic eruption would seem to be a good idea.

While I can’t speak for PIE or the Corps, the delta because of the acts of man, has created floodways although to a larger degree Mother Nature created them first.  As you know, the delta is anything but flat.  From Sedro-Woolley to the Bay, we lose 42-46 feet in elevation.  Gages Slough, which begins in Sedro-Woolley (and the argument could be made all the way to Lyman) known as Beatty Slough, which runs into Harts Slough, which runs into Gages Slough, which cuts across Highway 20 at the intersection of Highway 20 and Holtcamp Road, is the old channel of the Skagit when its mouth used to be at Padilla Bay 1,500-1,700 years ago.  Once the water breaks the banks and goes overland above Burlington the only place it has to cross the freeway is from Gages Slough adjacent to the Cascade Mall north to the Target Store.  Then again from the High School to Cook Road.  Both could/would/should be designated as floodways (areas of fast moving, deep water, anything over three feet from ground elevation moving at 3 feet per second will take the legs out from under a 6 foot 240 pound man).  This is why I have argued for seemingly an eternity now that the key to flood control in the lower valley is to widen the 3 bridge corridor, get the water past Burlington, past I-5 and get rid of it onto the floodplain before it gets to Mt. Vernon.  As I have stated in previous editorials, if we had today’s system of storage and levees in place we would only have had to dump the water once in the last 84 years.  Whether we do that by lowering the levees or installing some sort of a series of flood gates/spillways is up to the engineers to figure out.  Not only do you provide safety for the urban areas you also get rid of the floodway issue for the urban areas and in turn lower the Base Flood Elevations (BFE’s).  Why this is so hard for the powers that be to understand is way beyond my comprehension. 

With respect to your comment concerning the impacts of the buildings, I could not disagree with you more.  Although to a certain degree you are right.  It’s not the buildings that create the problem, but the landfill that was brought in to build them on.  Landfill that was never properly analyzed under SEPA for their cumulative impacts, all in violation of CFR 60.3(c)(10) in accordance with the NFIP and the local ordinances supposedly enforcing it (See the following documents for discussion on CFR 60.3(c)(10).


FEMA letter to Port Commissioner

FEMA investigating Burlington sewer project.  Letter addresses 1 ft rise requirement in Burlington.  City must adhere to requirements of CFR 60.3(c)(10).


MFR re Final Coordination Meeting (1 foot rise part of NFIP)

Only 16 people attended the public meeting  CFR Section 60.3(c)(10) or cumulative impact=1 foot rise regulation clearly was part of local flood ordinances.  Bud Norris was the Chairman of the Board of County Commissioners.


1981-1984 FEMA-BFE Flood Research

Compilation of articles describing the FEMA flood insurance base flood elevation and floodway determination made by FEMA in 1984.


FEMA letter re floodway designation of Gages Slough

This letter discusses why FEMA felt it could not designate Gages Slough as a floodway. Cascade Mall hydraulic study could not be supported by any scientific or technical data. Section 60.3c would be part of local ordinances which would require hydraulic analysis of fill in the Burlington area.


FEMA letter re development restrictions

FEMA informs Dept of Ecology that since a regulatory floodway had not been designated that 60.3(c)(10) would have to be enforced before local or state permits could be issued for building permits.

Are there any requirements which prohibit buildings in high velocity water flow zones?  Certainly anywhere near a levee or in a channel would be dangerous.  This is a different issue than the "floodway" concept, right?

Yes and no.  There are several definitions of floodways (See Black October Editorial under nhc Presentation).  Any areas where the velocities and depths could be high should be designated as floodways.  There should be a 1,000 foot from the levee building prohibition.  Anything within that 1,000 feet should be a floodway.  As stated above the Gages Slough and any other low-lying channel and 500 feet on either side of those should also be designated as floodways as well.  In reading the historical articles contained on this web page (over 1,000 now) one can determine that the most destructive areas were the areas adjacent to Gages Slough and the levees.

I hope this addresses your concerns.  As always your comments are welcomed and appreciated.


May your fields be ripe and budding and your rivers full and flooding (because its the only time people pay attention). 

 The Angry Citizen

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