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22-2123RESOLUTION NO. 22-2 123 A RESOLUTION OF THE CITY OF DENTON APPROVING THE CITY’ S REPETITIVE LOSSAREA ANALYSIS WHICH PROVIDES A MITIGATION PLAN FOR AREAS THAT HAVE OR ARE EXPECTED TO EXPERIENCE REPEATED LOSSES DUE TO FLOODING; ANDDECLAR[NG AN EFFECTIVE DATE. WHEREAS, the City of Denton seeks to identify and reduce the risk of repetitive flood damage; and WHEREAS, the City contracted with a floodplain management consultant to help prepare a Repetitive Loss Area Analysis (“RLAA”), which will help the City implement improved floodplain management practices particularly in areas of the City that are historically proven to be more likely to flood; and WHEREAS, the RLAA performed by consultant provides the City with flood risk reduction and flood damage mitigation measures that the City may implement as it deems feasible and in the best interest of its residents; and WHEREAS, the City seeks to reduce the cost of flood insurance policies for residents by participating in the Community Rating System incentive program; and WHEREAS, the adoption of a Repetitive Loss Area Analysis will increase the City’s score within the Community Rating System incentive program and thereby help reduce the cost of flood insurance premiums for residents through the National Flood Insurance Program; and WHEREAS, in furtherance of the goal of protecting public health, safety, and welfare City staff recommends the adoption of a Repetitive Loss Area Analysis; NOW THEREFORE, THE COUNCIL OF THE CITY OF DENTON HEREBY RESOLVES: SECTION 1. The recitals in the preamble of this resolution are true and correct and incorporated into the body of this resolution as if copied in their entirety. SECTION 2. The Repetitive Loss Area Analysis presented to the City Council appended to this resolution as Appendix "A'’ and incorporated herein, is hereby adopted by the City, and the City will implement the measures found therein to the extent deemed feasible and in the best interest of its residents. SECTION 3. This resolution shall become effective immediately upon its passage and approval. The motion to approve this resolution was made by hu\ h&k and seconded by :SQSS& OaI)1 S . The ) )roved by the following vote [2 - a : Aye 1/ IZ Ji IZ IZ / V/ Nay Abstain Absent Mayor Gerard Hudspeth: Vicki Byrd, District 1 : Brian Beck. District 2: Jesse Davis. District 3 : Alison Maguire. District 4 : Brandon Chase McGee, At Large Place 5 : Chris Watts, At Large Place 6 : PASSED AND APPROVED thi, th, \ g d,y ,f C)cAb&r . 2022 GERARD HUDSPETH, MAYOR RETARY-nos#eJ@5 SAI.AtA ATTEST: L\\\\\lllIJlff APPROVED AS TO LEGAL FORM: MACK REINWAND, CITY ATTORNEY By: Benjamin Samples BE%.r=====in;, H==-, September 2022 Sunset at Lake Ray Roberts State Park bENTON TABLE OF CONTENTS Section 1.0 – Introduction............................................................................................................................. 3 Section 2.0 – Identify Repetitive Loss Areas ................................................................................................. 5 Section 3.0 – Contact Property Owners........................................................................................................ 7 Section 4.0 – Collect Building Data ............................................................................................................... 8 Section 5.0 - Contact Other Agencies........................................................................................................... 8 Section 6.0 - Repetitive Loss Areas .............................................................................................................. 9 6.1 Repetitive Loss Area #l.................................................................................................................... 9 6.2 Repetitive Loss Area #2.................................................................................................................. 13 6.3 Repetitive Loss Area #3.................................................................................................................. 16 6.4 Repetitive Loss Area #4.................................................................................................................. 20 6.5 Repetitive Loss Area #5.................................................................................................................. 23 6.6 Repetitive Loss Area #6.................................................................................................................. 26 Section 7.0 – Conclusion ............................................................................................................................. 30 Section 8.0 – Resources .............................................................................................................................. 30 Appendix A: Letter to Property Owners..................................................................................................... 31 Appendix B: Flood Protection Questionnaire ............................................................................................ 33 Appendix C: Contacting Other Agencies .................................................................................................... 35 Appendix D: Draft Notice on Website........................................................................................................ 36 Appendix E: Building Data (omitted from public vers/onJ.......................................................................... 37 City of Denton Repetitive Loss Area Analysis Page 2 1.0 INTRODUCTION The city of Denton is the county seat of Denton County in the northern part ofTexas. The climate in Denton is similar to the rest of the state: hot and humid in the summer with mildly cold winters. Occasionally, the city experiences snow, but major winter events are rare. The city’s location in the northern part of the state means it is rarely affected by the coastal tropical storms that mostoften occur in late summer. Flash floods and severe thunderstorms in Denton occur most often in the spring. A levee, maintained by Denton County Levee Improvement District #1, and high hazard dams, maintained by the US Army Corps of Engineers, help protect the city from substantial flood events. FEMA issued Denton’s Flood Hazard Boundary Map in November of 1974. The first FEMA Flood Insurance Rate Map is dated August of 1979. The City of Denton (City) currently regulates under two effective FEMA FIRMs dated April 18, 2011 and June 19, 2020. Floodway almost entirely surrounds downtown Denton where the base flood elevation increases incrementally upstream ranging from 600 to 700 feet. aend Digital Data Available Unmapped NFHL Politial JurisdictionsB Profile Baselinos Coastal Transects Transect Baseline s Hood Hazard Boundaries – Limit Lines SFHA / Flood Zone Boundary Hood Hazard Zones 1%/Vrnual Chana Flood Hazard Regulatory Hood way Spedal Floodway Area of Undetermined Flood Hazard 0.2% Annual Chanoe Rood Hazard Future Conditions 1 % Annual Chana FlooHazard Area with Redued Risk Due to Levee rJ Area with Risk Due to Levee City of Denton Repetitive Loss Area Analysis Page 3 The city has numerous drainage channels and tributaries. There are also several lakes surrounding the city such as Tedrow Lake, Twin Lakes Number 1, and Evans Lake to the north; Rayzor Lake to the southwest; Unicorn Lake and Galbraith Lake to the southeast; and Lake Ray Roberts to the north. Cooper Creek, Hickory Creek, Pecan Creek and Clear Creek are the four main watersheds that convey water through Denton with parts ofCulp Branch and Denton Creek added through annexations. Stormwater ultimately drains out to Lake Lewisvilleto the south. In an effort to protect the water sources and ecosystems within the watersheds, the City created the Residential Watershed Protection program and the Business Watershed Protection program administered through the Environmental Services Division. The programs focus on protecting the quality of stormwater runoff, and they encourage citizens to help by not dumping in the waterways. This effort directly affects the impact of flooding by allowing waterways to function at their highest capacity at any given time. of Denton Watersh Land tkBUBCiry LMsHI CasMeta tbCIWyCN4 Pb&nCIBd wah DaBaCIBd LeaRrill•bkc. Ella Fat (ii+inHbCh.ElnFat 1.1 The Flood Hazard During floods, average water velocities in streams in Denton will range from one to 16 miles per hour. When one cubic foot of water weighs over 62 pounds and the typical flow rate during a flood will be several thousand cubic feet of water each second, one can only imagine the immense force floodwaters will exert on anything in their path. Flood hazards include large volumes of fast-moving water and large debris moving with the flow. While streets are designed to be part of the drainage system, it can be somewhat unsettling for homeowners to see street flooding accumulating too quickly or for too long in their own neighborhoods. Over the life of a 30-year mortgage, there is a 26% chance that a property will experience a 100-year flood or storm. However, homeowners tend to dismiss their risk of flooding if they have never flooded before or if they are in a low-risk zone on the FEMAFIRM The major cause of flooding in Denton, in a general sense, is due to stormwater runoff and riverine flooding. Widespread flooding is not common to this area; however, one major event occurred in 2007. Rain gauges scattered across the city yielded precipitation totals upwards of seven to eight inches. After the 2007 flood, the City encouraged property owners to report the kind of damage they incurred such as the depth of water in their structures. The City captured data from 156 citizens. Only four percent (4%) of the respondents reported having flood insurance at the time of the event. The damage from the 2007 flood motivated the City to take a more proactive approach towards implementing higher standards in the Outside Emily Fowler Central Library, 2007 City of Denton Repetitive Loss Area Analysis Page 4 ordinance and Storm Water Design Criteria Manual, as well as encouraging more citizens to purchase andmaintain flood insurance on their structures. 1.2 Flood Insurance Coverage City staff work hard to educate the public on the importance of flood insurance, and to ensure that citizens understand that flood damage is not covered by regular homeowner’s insurance. Given the varying topography of the area, the purchase and maintenance of a flood insurance policy is strongly encouraged for every resident and business owner in the city. The table below is a breakdown of flood insurance data in Denton based on the effective FIRM flood zones (data current as of June 2, 2022). # of Policies 148All A Zone 221X/Shaded X Zone TOTAL 369 P$38M $108,182 $411,972 I $67,890,800 $104, 117,800 The City is committed to making flood insurance more affordable for its residents. The recent rollout of FEMA’s Risk Rating 2.0 initiative put a spotlight on the importance of flood insurance since each policy is based on the structure’s actuarial risk as opposed to location relative to the floodplain. Since structures outside the FEMA-mapped floodplain may now be eligible for the discount available through the NFIP’s Community Rating System (CRS), the City has prioritized its efforts in community outreach to encourage an increase in flood insurance policies and coverage. 2.0 IDENTIFY REPETITIVE LOSS AREAS The City’s goal to ease the financial burden of flood insurance for its citizens has been a strong motivator towards improving their class rating in the CRS program. Previously, the City’s participation in the CRS as a class eight had given eligible policyholders located in the floodplain a 10% discount on their annual flood insurance premiums; however, citizens stand to gain an even greater discount with the additional higher standards the City has implemented. In May of 2022, the City commissioned its engineering consultant, Freese & Nichols, Inc., as well as a subconsultant, Cahoon Consulting, to assist in the preparation of the City’s CRS five-year cycle visit that would also include activities to qualify for advancement to the next class. Part of the City’s plan to improve the CRS rating involved the development of this Repetitive Loss Area Analysis (RLAA). An RLAA is a report that identifies repetitive loss areas (RLAs) and recommends alternatives to mitigate the effects of future flooding. A property is classified as repetitive loss if it has had two or more claims of more than $1,000 that have been paid by the National Flood Insurance Program (NFIP) within any 10-year period since 1978. Repetitive loss properties have been a drain on the NFIP for over 40 years, counting for a fourth of all NFIP payments since 1978. FEMA maintains a list of repetitive loss properties, and makes it available to anyCRS community by request. The list includes property specifics, loss dates, and claims information. (Due to the sensitivity of the data, it is protected by the Privacy Act of 1974 and cannot be shared with the general public.) Repetitive loss properties remain on FEMA’s list for the life of the structure, and are City of Denton Repetitive Loss Area Analysis Page 5 classified as either mitigated or unmitigated. A mitigated property means the structure has been protected against future flood damage through elevation, acquisition, demolition, structural control project, or another form of resolution. In preparation for the CRS visit, and for the purpose of developing this RLAA, the City tasked the Engineering Department, with assistance from consultants (hereafter known as the “Team”), to investigate the problem of unmitigated repetitive loss properties and to consider mitigation alternatives that may alleviate the flood hazard. The Team submitted a Data Sharing Agreement to FEMA Region VI and obtained the latest repetitive loss list in August of 2022 that showed seven (7) unmitigated repetitive loss properties. One property was located outside the city limits; consequently, the Team prepared an NFIP Flood Loss Update Worksheet with accompanying documentation and sent it to NFIP Underwriting to remove the address from Denton’s list. The Team examined the remaining six (6) properties on FEMA’s list on a GIS map that revealed the repetitive loss properties spanned the entirety of metropolitan Denton. Based on location and similar flooding causes, the Team delineated RLAs consisting of repetitive loss properties from FEMA’s list plus adjacent or nearby properties that may be susceptible to the same cause of flooding. It may be that nearby structures have never flooded in the past, but are at a higher risk based on their proximity to channels, drainage system features, age and foundation of the structure, or other factors. Another reason to include some properties in the RLAs that are not on FEMA’s list is that they may have flooded in the past, but the homeowners did not have flood insurance or did not file for disaster assistance. These properties may be one loss away from ending up on FEMA’s repetitive loss list. FEMA’s data of losses and claims history, as well as flood insurance policy statistics, were also examined. All of the above factors were deemed reasonable enough to group particular properties into RLAs. Below is a summary of each RLA and its corresponding number of properties with a map on the following page (RLAs noted in red). City of Denton Repetitive Loss Area Analysis Page 6 Repetitive Loss Areas Overview \\ \\m The Team followed the scope in the 2017 CRS Coordinator’s Manual and the “Developing a Repetitive Loss Area Analysis” supplemental guidance to develop this RLAA. The following sections explain the process of developing the RLAA such as contacting property owners, contacting entities that may have projects affecting the RLAs, and collecting data on each of the 28 structures (omitted from the public version) , 3.0 CONTACT PROPERTY OWNERS On July 22, 2022, the City mailed 28 letters to the property owners whose addresses were identified in the six (6) RLAs. The letter explained the purpose of the RLAA and what kinds of information would be used in the report including permit records, appraisal district records, field data, and photographs taken at the site. The letter also notified property owners that the draft report would be posted on the City’s website for comments (see Appendix D), and included a link to an online, 10-question Flood Protection Survey regarding individual flood damage history and property protection options. (A copy of the letter, City of Denton Repetitive Loss Area Analysis Page 7 questions from the Flood Protection Survey, and a summary of the responses are included in Appendix A and Appendix B.) 4.0 COLLECT BUILDING DATA An essential part of the RLAA process involved assessing the flood risk each building faced based, in part, on the specific characteristics of that structure. Each structure was researched using two resources: the Denton County Appraisal District and observations noted in the field. 4.1 Denton County Appraisal District The Team procured the majority of building data from the Denton County Appraisal District website (www.dentoncad.com). The information in the Appraisal District database included year of construction and foundation type. The building data helped determine the level of risk for each structure such as identifying how a common source of flooding might affect a house built in 1940 compared to a house built in 1990. The data from the appraisal district was combined with the data available on FEMA’s repetitive loss list to form a comprehensive view of each structure at risk in these areas. (Specific data per address is located in Appendix E, and is not available to the public per the Privacy Act of 1974.) Older homes, such as pre-FIRM structures, were not required to meet the same higher standards the City is currently enforcing such as freeboard above the base flood elevation. This extra level of protection has helped diminish the flooding risk to newer structures or structures that have been substantially damaged. A substantially damaged building is one where the cost of repairing the structure to its pre-flood condition is greater than 50% of the market value of the structure. When a structure has been declared substantially damaged, it is required that the structure be brought into current code and regulations. Most often, the regulations require elevation as a means to compliance. 4.2 Field Data In addition to data from the Denton County Appraisal District, the Team observed the properties in the field. City staff canvassed the RLAs and took photographs from the street orsidewalkthat captured ground elevation differences, drainage patterns, and nearby drainage features such as inlets, culverts, or storm drains. This data helped in understanding where and how each property drained, and whether or not water collecting in the lot or drainage from nearby structures may have contributed to the cause of flooding. The Team also conducted observations of the natural channels and drainage systems to see how vegetation or other obstructions may be affecting the channel’s ability to function optimally. (Specific data per address is located in Appendix E, and is not available to the public per the Privacy Act of 1974.) 5.0 CONTACTOTHER AGENCIES Before determining the best mitigation alternative for the RLA properties, the Team wanted to find out what studies and projects were in the process or planned for the areas by other entities and organizations. The City’s Engineering Division contacted three entities via email on August 12, 2002 to request this information. (A copy of the email is included in Appendix C.) City of Denton Repetitive loss Area Analysis Page 8 5.1 US Army Corps of Engineers The City received an email response from Matthew Lepinski, a hydraulic engineer with the Water Resources Branch of the US Army Corps of Engineers (USACE) in the Fort Worth District. The following is language copied from Mr. Lepinski’s email response: “[The USACE are working] on a relevant planning project we are kicking off with funding from the Texas General Land Office (GLO) that intends to proactively vs reactively address flooding in North Central Texas while integrating (where appropriate) transportation and environmental considerations." The project is known as the “Integration of Transportation and Stormwater Management in developing North Dallas/Fort Worth" and the timeline of the project is 2022 to 2027. Funding will be obtained from the Texas GLO, and the cost of the project isroughly $4 million. According to Mr. Lepinski, the purpose of the project is to “increase flood risk awareness and resiliency...through innovative planning-level analysis and integration...of transportation, environmental, and stormwater planning.” 5.2 Texas Department of Transportation The City received an email response from Travis Campbell, a Project Delivery Supervisor for the Texas Department of Transportation (TxDOT) in the Dallas district. Mr. Campbell explained that all TxDOT projects must adhere to guidelines that result in zero rise at the new or existing right of way. Since the TxDOT projects do not reroute or detain any flows in the right of way, they will not have an impact (positive or negative) on the flood risk in the Denton RLAs. 5.3 Denton County The City did not receive a response to their request for information from Denton County regarding any projects that may impact the repetitive loss problem in Denton. 6.0 REPETITIVE LOSS AREAS Section 6.0 of this report describes each RLA, presents the cause(s) of flooding, demonstrates the RLA on a GIS map, explores the six (6) FEMA mitigation categories, and recommends one or more mitigation alternatives that would be appropriate for that particular RLA. Mitigation Categories Preventative Natural Resource Protection Structural Projects Property Protection 6.1 Repetitive Loss Area # 1 6.1.1 Cause of Flooding City of Denton Repetitive Loss Area Analysis Page 9 There are three (3) properties located in RLA #1 and all of the homes were built in the mid-1970s. FEMA did not issue a Flood Hazard Boundary Map until 1975; consequently, there were very few, if any, regulations on development in the floodplain or floodway. Properties in this neighborhood between US 380 and Lariat Road are located in the floodway and/or floodplain of Hickory Creek Stream DF-2 and are subject to flooding during storm events. The culvert crossing just to the south of RLA #1 restricts flow and causes water to back upon the north side of US 380 and flood the area. epetitive Loss Area 1R EaRqpHbveLDnAFn = RqDlabryFbQdHW – CetTeTtne 1% AIIIng CIIne FRxx! Hazard nParDM D2%AnmnlanrnFbodHum AIn wIll Reduced Ria Due to Leno Future Caxlltkxt91%Annud Glutsee Fkxxl Hazard 6.1.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #1. Considerations were given to the location of the nearest channel, the flood zone, age and condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #1. Preventative The City regulates residential and commercial development through its Development Code, Stormwater Design Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.cityofdenton.com. City Council adopted a revised Flood City of Denton Repetitive Loss Area Ana/ysB Page 20 Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500- year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches of freeboa rd to the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. This extra level of flood protection may be a contributing factor to why there are so few repetitive loss properties in Denton. The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for the stormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will beidentified. The final RLAA will be an integral contributor to the Storrnwater Master Plan’s initial activities. Property Protection The City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Floodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas City of Denton Repetitive Loss Area Analysis Page 11 (http://gis.cityofdenton.com/mapviewer/) throughout Denton, identified through the best information available from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #1 and would have not a positive or negative impact on the floodingrisk in this area. Emergency Services The City has developed a flood warning system for properties in floodplains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergencY management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural Projects Channel improvements constructed by the City along Pecan Creek Tributary 4 (PEC-4) have reduced the regulatory floodplain elevation in parts of downtown Denton. The area within the 100-year floodplain was also reduced significantly along Pecan Creek from approximately Ruddell Street upstream to Oakland Street. Another mitigation project for RLA #1 would include (1) a drainage study and HEC-RAS Model of Hickory Creek Stream DF-2 to ensure all drainage areas feeding into the creek are accounted for and to ensure the improved flows from the proposed drainage improvements can discharge into the creek without negatively impacting downstream neighborhoods along Hickory Creek; and (2) increasing the capacity of the culvert crossing U.S. 380 and possible elevating the roadway. TxDOT cooperation would be required as U.S. 380 is within TxDOT right of way. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. The City also maintains a comprehensive Flood Protection Information page on its website with a directory of various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maIntenance. City of Denton Repetitive Loss Area Analysis Page 12 One recent video (https://www.youtube.com/watch?v;dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sediment and debris. RLA #1 Recommended Mitigation Alternative Preventative Responsibility L Timeline Ongoing Funding CIP Mitigation grant Operating budget Dependent on funding Ongoing 6.2 Repetitive Loss Area #2 6.2.1 Cause of Flooding There are seven (7) properties located in RLA #1 and all of the homes were built in the mid-1970s. Although properties along this section of Bell Avenue are not in the floodplain and a City of Denton storm drain system does exist, a large area (approximately 130 acres) drains through this neighborhood and local flooding can happen when lots have not been graded to allow water to drain into the street or toward neighborhood drainage ditches. The downstream channel, Copper Creek Tributary 13, is also undersized. Repetitive Loss Area 2 EaRqpeHveL-BAIn A Reg-&bryFbH-VCetredne 1%Artttud Ctraroe Flcxxl Hazard[3 ParDeb Fame Caxlitkxt$ 1%AnrHd Clunu Fkxxl Hazard CHISHOIM TRL CORDOVA aR CORONADO DR City of Denton Repetitive Loss Area Analysis Page 13 6.2.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #2 condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #2. Preventative The City regulates residential and commercial development through its Development Code, Stormwater Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.citvofdenton.com. City Council adopted a revised Flood Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500-year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches offreeboard to the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for the stormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will be identified. The final RLAA will be an integral contributor to the Stormwater Master Plan’s initial activities. Property ProtectionThe City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. City of Denton Repetitive Loss Area Analysis Page 14 Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Ftoodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas (http://Ris.citvofdenton.com/map\Newer/) throughout Denton, identified through the best information available from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #1 and would have not a positive or negative impact on the flooding risk in this area. Emergency Services The City has developed a flood warning system for properties in floodplains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergency management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural ProjectsAfter this area experienced flooding in 2007, the City constructed a regional detention pond approximately 500 feet upstream from the RLA. near the Strickland MiddleSchool. There have been no flood claims in RLA #2 since the pond was constructed. The City plans to assembledocumentation to that effect and forward it to FEMA to update Denton’s repetitive loss list. The drainage could be further improved by (1) a drainage study and HEC-RAS Model of Cooper Creek Tributary 13 to ensure all drainage areas feeding into the creek are accounted for and to ensure the improved flows from the proposed drainage improvements can discharge into the creek without City of Denton Repetitive Loss Area Analysis Page 15 negatively impacting downstream neighborhoods along Cooper Creek; and (2) making channel modifications to increasing the capacity of Cooper Creek downstream of RLA #2. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. The City also maintains a comprehensive Flood Protection Information page on its website with a directoryof various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maintenance.One recent video (https://www.youtube.com/watch?v=dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sediment and debris. RLA #2 Recommended Mitigation Alternative r 1 Projects !sponsibility Public Works TimelineMM 6.3 Repetitive Loss Area #3 6.3.1 Cause of Flooding There are six (6) properties located in RLA #3 and all of the homes were built in the 1940s and 1950s. FEMA did not issue a Flood Hazard Boundary Map until 1975; consequently, there were very few, if any, regulations on development in the floodplain or floodway at the time of construction. Properties in this neighborhood between McKinney and Congress Streets and Carroll Boulevard and Locust Street are located in the floodway and/or floodplain of Pecan Creek and are subject to flooding during storm events. Pecan Creek transitions from an open channel to underground box culverts which run west-to-east underneath W. Parkway Street between N. Carroll Boulevard and Austin Street. This culvert is undersized (may accommodate the 2–5-year storm) and causes the flow to back up on the west end, flooding the surrounding area in larger storm events. City of Denton Repetitive Loss Area Analysis Page 16 Repetitive Loss Area 3 Ea RBp€tdtve banAna n RBgula+Dry Ft,adway 1%Annud Chnn Flexia Ha7nrdCenterlne f""""]I Paralb 02% Annwl Chance Fkxxl Hazard Area with Reduced Risk CAre b Levee Fubn CordborBl%Arwd CtBnoe Fbod Hazard InI to sc41£ 6.3.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #3. Considerations were given to the location of the nearest channel, the flood zone, age and condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #3. Preventative The City regulates residential and commercial development through its Development Code, Stormwater Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.citvofdenton.com. City Council adopted a revised Flood Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500-year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches offreeboard to the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. City of Denton Repetitive Loss Area /Ina/ya Page 17 The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for thestormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will be identified. The final RLAA will be an integral contributor to the Stormwater Master Plan’s initial activities. Property ProtectionThe City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Floodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas (http://gis.citvofdenton.com/mapviewer/) throughout Denton, identified through the best information available from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #3 and would have not a positive or negative impact on the floodingrisk in this area. Emergency Services The City has developed a flood warning system for properties in floodplains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The City of Denton Repetitive Loss Area Analysis Page 18 system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergency management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural Projects Channel improvements constructed by the City of Denton along Pecan Creek Tributary 4 (PEC-4) have reduced the regulatory floodplain elevation in parts of downtown Denton. The area within the 100-year floodplain was also reduced significantly along Pecan Creek from approximately Ruddell Street upstream to Oakland Street. A mitigation project for RLA3 # would include (1) a drainage study and HEC-RAS Model of Pecan Creek to ensure all drainage areas feeding into the creek are accounted for and to ensure the improved flows from the proposed drainage improvements can discharge into the creek without negatively impacting downstream neighborhoods along Pecan Creek; and (2) modifying the Pecan Creek channel to accommodate larger flowers and increasing the capacity of the culvert running under W. Parkway Street. Adding reginal detention upstream would also reduce the severity of flooding seen in RLA #3. The City is currently working to secure funding for storm drainage improvements on N. Elm Street which would capture runoff from a portion of the drainage area contributing to RLA #3. This additional storm sewer will help alleviate flooding in the area. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. The City also maintains a comprehensive Flood Protection Information page on its website with a directory of various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maintenance. One recent video (https://www.youtube.com/watch?v=dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sediment and debris. RLA #3 Recommended Mitigation Alternative Responsibill' Public Works Public Affairs Timeline Depme n fundin I Ongoi Funding Mitigation grant Operating budget City of Denton Repetitive Loss Area Analysis Page 19 6.4 Repetitive Loss Area #4 6.4.1 Cause of Flooding There are four (4) properties located in RLA #4 and all of the homes were built in the mid-19705. Although properties along this side of Angelina Bend are not in the floodplain, local flooding problems can still occur. Flooding may happen when lots have not been graded adequately to allow water to drain into adjacent streets or toward neighborhood drainage ditches or when multiple higher properties drain through a lower adjacent lot. The area to the west of RLA #4 does not have any underground storm sewer drainage. The western upstream area is also steeply graded toward RLA #4 at approximately a 7% slope. These steep grades, combined with a lack of curb-and-gutter storm drains, could allow upstream flow to overtop curbs or rundown driveways and cause flood damage to properties downstream. epetitive Loss Area 4R eaRqpdweLaHA'HB M RqIMUyFbadHV CetTlerSIn 1%Artrwal CtImae Fkxxl HazardE] Pareeb 02%Annwl Ch8nee mnd Hum Ana well Reducwl Risk Chr8 b Levw Future CaHitixt81%Anrud CtwIae Fkxxl Hazard – FOX-HOUOW Sl City of Denton Repetitive Loss Area Analysis Page 20 6.4.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #4. Considerations were given to the location of the nearest channel, the flood zone, age and condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #4. Preventative The City regulates residential and commercial development through its Development Code, Stormwater Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.cityofdenton.com. City Council adopted a revised Flood Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500-year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches offreeboard to the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for the stormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will be identified. The final RLAA will be an integral contributor to the Stormwater Master Plan’s initial activities. Property Protection The City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. City of Denton Repetitive Loss Area Analysis Page 21 Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Floodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas (http://gis.citvofdenton.com/mapviewer/) throughout Denton, identified through the best information available from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #4 and would have not a positive or negative impact on the flooding risk in this area. Emergency Services The City has developed a flood warning system for properties in floodplains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergency management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural Projects A mitigation project for RLA #4 would include surveying the upstream street, Sandy Creek Drive, and driveways. Any driveways with profiles which allow water to flow from the street gutter towards downhill properties would be replaced with profiles which contain flow in the street. Another mitigation project could extend the existing storm sewer system on Angelina Bend to the west along Sandy Creek Drive. This would allow the runoff to be transported downstream without traveling across the properties in RLA #4. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. City of Denton Repetitive Loss Area Analysis Page 22 The City also maintains a comprehensive Flood Protection Information page on its website with a directory of various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maintenance.One recent video (https://www.youtube.com/watch?v=dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sediment and debris. RLA #4 Recommended Mitigation Alternative Preventative Structural Projects Public Information TimelineResponsibil Funding PubjEMH[!1111Ha!!Ongoing CIP ePublic Works Public Affairs Operating budgetOngoing 6.5 Repetitive Loss Area #5 6.5.1 Cause of Flooding There are five (5) properties located in RLA #5 and all of the homes were built in the mid-1970s. Although properties along this side of Tennyson Trail are not in the floodplain, local flooding problems can still occur. Flooding may happen when lots have not been graded adequately to allow water to drain into adjacent streets or toward neighborhood drainage ditches or when multiple higher properties drain through a lower adjacent lot. The area to the northwest of RLA #5 does not have any underground storm sewer drainage. The northwestern upstream area is also steeply graded toward RLA #5 at approximately a five percent slope. These steep grades, combined with a lack of curb-and-gutter storm drains, could allow upstream floW to overtop curbs or rundown driveways and cause flood damage to propertiesdownstream. City of Denton Repetitive Loss Area Analysis Page 23 Repetitive Loss Area 5 aa RepethuB LoiB Area = ©aabryFbodvBy1%AnnudCh8nuFlmd Hazard 1HHHHHHHHHHH] IF)1B nEI1:1bIII D2%Artnbnl Chanw FbOd Head AreawKh Reduced Risk Due to Levee Futrn Caxlition5 1% Anrud Ctnnoe Fkxxl Hazard 6.5.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #5. Considerations were given to the location of the nearest channel, the flood zone, age and condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #5. Preventative The City regulates residential and commercial development through its Development Code, Stormwater Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.citvofdenton.com. City Council adopted a revised Flood Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500-year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches offreeboard to City of Denton Repetitive Loss Area Analysis Page 24 the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for the stormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will be identified. The final RLAA will be an integral contributor to the Stormwater Master Plan’s initial activities. Property Protection The City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Floodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas (http://gis.citvofdenton.com/mapviewer/) throughout Denton, identified through the best informationavailable from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #1 and would have not a positive or negative impact on the floodingrisk in this area. City of Denton Repetitive Loss Area Analysis Page 25 Emergency Services The City has developed a flood warning system for properties in floodplains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergency management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural Projects A mitigation project for RLA #5 would include surveying the upstream street, Pennsylvania Drive, and driveways. Any driveways with profiles which allow water to flow from the street gutter towards downhil properties would be replaced with profiles which contain flow in the street. Another mitigation project could be constructing underground storm sewer drainage on Pennsylvania Drive. This would allow the runoff to be transported to downstream without traveling across the properties in RLA #5. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. The City also maintains a comprehensive Flood Protection Information page on its website with a directoryof various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maintenance.One recent video (https://www.youtube.com/watch?v=dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sedIment and debris. RLA #5 Recommended Mitigation Alternative Preventative Structural Projects Public Information TimelinehonsibilRlPLMHHOngoingleeri ng Dependent on fundiPublic Works Public Affairs Ongoi Funding CIP Mitigation grant Operating budget City of Denton Repetitive Loss Area Analysis Page 26 6.6 Repetitive Loss Area #6 6.6.1 Cause of Flooding There are three (3) properties located in RLA #6 and all of the homes were built in the mid-1960s. Although properties along this side of Mill Pond Road are not in the floodplain, local flooding problems can stilloccur. Flooding may happen when lots have not been graded adequately to altow water to drain into adjacent streets. This area has very little slope, making lot grading particularly important in avoiding water damage during rain events. With poorly graded lots, water may easily travel down a driveway and cause ponding and damage to structures. Repetitive Loss Area 6 EZnodnBLonAnB n R+gUdDryFbodHBy 1% Annual Ch#loeFload HazardCen&t&leLJ Pareeb 02% Annml Ch8nee Fbaa Hund Area wM Rodund Ri8k Un tO Levee FRI 2418Fr£un Caxldions 1% Ant&Id Cturne Fbcxl Hazard HI BROKEN BOW ST– ! POND RD 6.6.2 Mitigation Alternatives The Team evaluated several mitigation options to determine what would have the greatest impact on RLA #6. Considerations were given to the location of the nearest channel, the flood zone, age and condition of the homes, cost effectiveness, feasibility, and potential to reduce future flood risk. Below is a summary of mitigation alternatives considered and recommended for RLA #6. City of Denton Repetitive Loss Area Analysis Page 27 Preventative The City regulates residential and commercial development through its Development Code, Stormwater Criteria Manual, and Flood Prevention and Protection ordinance (Chapter 30), all of which are accessible via the City’s website at www.cityofdenton.com. City Council adopted a revised Flood Prevention and Protection Ordinance in August of 2020 that included higher standards for new and substantially improved structures in the floodplain, as well as new structures built within 200 feet of the floodplain. The Capital Projects and Engineering department is also recommending that City Council revise the ordinance again to adopt increased protection of critical facilities within the 0.2% flood zone (aka 500-year floodplain). The ordinance requires that minimum finished floor elevations for new or substantially improved residential buildings (or floodproofed elevation for nonresidential buildings) within the floodway fringe and within 200 feet of the floodplain boundary shall be determined by adding 18 inches of freeboard to the base flood elevation based on fully developed conditions or 30 inches above the base flood elevation as indicated in the effective Flood Insurance Study. The City’s Stormwater Design Criteria Manual, adopted in December 2021, requires that all stormwater management facilities be designed for the 100-year event. As some communities only design for smaller scale events, the City is proactive and aggressive in requiring a higher level of protection against major events. Other mitigation options under the umbrella of preventative activities include the City’s adoption of the most current (2021) building codes, as well as dedicated staff performing routine maintenance on the city’s drainage system to prevent clogs caused by obstructions. Recently, the City has contracted with a consultant engineering firm to begin initial activities for a Stormwater Master Plan. The purpose of these activities is to prepare a strategic direction for the stormwater utility that includes inventory and condition assessment of stormwater infrastructure, hydrologic and hydraulic modeling of watersheds, capital project identification and prioritization, funding levels and budget allocation, and a review of maintenance and development practices. More specifically, these activities include a flooding hotspot analysis and watershed prioritization that will include flood risk indicators such as drainage complaints, NFIP policies, repetitive loss areas, existence of prior studies/capital projects, infrastructure condition needs, development trends, and other relevant factors. The most vulnerable areas subject to flood risk due to anticipated future development activity will be identified. The final RLAA will be an integral contributor to the Stormwater Master Plan’s initial activities. Property Protection The City promotes the purchase and maintenance of flood insurance via an annual targeted outreach project (explained further in Public Information) . Since the rollout of FEMA’s Risk Rating 2.0 wherein flood insurance premiums are based on actuarial rates rather than location to the floodplain, the City suspects more property owners will take steps to mitigate their individual flood risk such as elevating or retrofitting their structures. Through the City’s outreach, citizens are encouraged to contact City staff for advice or to request a one-on-one site visit to explore property protection options. Following a flooding event in 2015, several homeowners initiated property measures by installing gutters and making grading improvements that seem to have made a huge different and no flood claims have been filed in RLA #6 since that time. Natural Resource Protection Many undisturbed creeks and wetlands provide a wide range of benefits to human and natural systems. They provide flood storage and conveyance and reduce flood velocities and flood peaks. Water quality is improved because creeks and wetlands filter nutrients and impurities from runoff and process organic wastes. Local creeks and wetlands provide breeding and feeding grounds for fish and wildlife, create and enhance waterfowl habitat, and serve as habitats for rare and endangered species. The City has City of Denton Repetitive Loss Area Analysis Page 28 designated many creeks, wetlands, and floodplains as Environmentally Sensitive Areas (ESAs) and protects them through regulations, thereby, preserving vital water related resources. The City has identified four distinct types of ecological habitats - Floodplains, Riparian Buffers, Water-Related Habitat, and Cross Timbers Upland Habitat - that provide for the community in many ways and are environmentally sensitive. The City has also adopted an Official ESA Map of Environmentally Sensitive Areas (http://gis.cityofdenton.com/mapviewer/) throughout Denton, identified through the best informationavailable from aerial photographs and records such as a soil survey from the Natural Resource Conservation Service (NRCS) and FEMA FIRMs. Upon further inspection of these ESAs, the City concluded that they are not located near RLA #1 and would have not a positive or negative impact on the floodingrisk in this area. Emergency Services The City has developed a flood warning system for properties in floodptains and susceptible to the flood hazard. Severe weather alerts and flood warnings will be issued by radio (KNTU FM 88.1), local TV Channel 26, all cable TV stations in Denton (audio override and bulletin board) and on NOAA weather radios. The system, which is operated manually by the National Weather Service and Emergency Management trained SKYWARN volunteers, can provide one-hour advanced warning of a flood hazard. Battery operated NOAA weather radios may be purchased to receive warnings during power and telephone outages. The City has also implemented a two-way radio and paging system (911 Dispatch) that can be used by emergency management personnel to activate warning sirens throughout the City as needed. In September 2022, the City developed a Flood Response Preparations plan that details efforts the City will undertake before, during, and after a storm event. Activities range from posting door hangers on homes of suspected flood damage with response and recovery information to posts on social media. The City also uses the Alert Denton emergency notification system to relay flood warnings and flood safety tips to citizens who have registered for the service. All of the above-described emergency services activities are ongoing and applicable to all six (6) repetitive loss areas. Structural Projects Due to the relatively flat topography around RLA #6, storm water velocities are lower in the streets and more prone to ponding and overflowing the curb. A mitigation project for RLA #6 would include surveying the upstream street, Emerson Lane, and driveways. Any driveways with profiles which allow water to flow from the street gutter towards downhill properties would be replaced with profiles which contain flow in the street. Another mitigation project could be constructing underground storm sewer drainage on Emerson Lane. This would allow the runoff to be transported to downstream without traveling across the properties in RLA #6. Public Information Part of the City’s extensive public outreach involves a targeted, annual mailing in May/June to each of the 28 properties in the RLAs. The RLA mailing is similar to outreach slated for the general public which includes information on flood insurance, development regulations, and drainage system maintenance. However, RLA outreach letters also include information on property protection and sources of financial assistance such as mitigation grants. The City also maintains a comprehensive Flood Protection Information page on its website with a directory of various topics such as flood insurance, flood warning system, property protection, natural and beneficial functions, and flood safety measures. Recently, City staff engaged with local real estate agents to provide handouts to perspective clients encouraging them to check the flood hazard before they buy City of Denton Repetitive Loss Area Analysis Page 29 property in Denton. Lastly, the City has its own channel on YouTube, and staff regularly post videos highlighting various departments and services the city provides such as drainage system maintenance. One recent video (https://www.youtube.com/watch?v=dNhNpu3EU I) demonstrated the path of stormwater and explained the importance of keeping channels clear of sediment and debris. RLA #6 Recommended Mitigation Alternative Preventative Responsibility Public Works/Engineering Timeline Ongoing Completed Ongoin.Operating budget Homeowners Public Affairs 7.0 CONCLUSION The devastation of the 2007 flood, and the knowledge that stormwater runoff could be a problem during any event, has kept the issue of flooding on the minds of citizens. The City strives to alleviate the flooding hazard through structural modifications, continued drainage maintenance, implementation of higher standards in ordinances and criteria manuals, comprehensive outreach campaigns, and programs that focus on protecting the city’s waterways. As a result, more citizens are doing their part to protect themselves and their properties such as purchasing and maintaining flood insurance, keeping storm drains clear of debris, and other forms of property protection. The City is also proactive in heading off potential events through its strict policies on developing in the floodplain in both current and future conditions. . All of these efforts combined contribute to why there are so few repetitive loss properties in Denton. Through its outreach and mitigation measures, the City remains confident it can reduce future flood damage for the benefit of their citizens. 8.0 RESOURCES •FEMA Flood Map Service Center: https://msc.fema.gov/portal/home • FEMA’s National Flood Hazard Layer (NFHL) Viewer: https://hazards- fema.maps.arcgis.com/apps/webappviewe r/index. html?id=8bOadb51996444d4879338b5529aa9cd &extent=-97.46386642578075,33.072943140075935,-96.79919357421915,33.360168477285534 • City of Denton Storm Water Criteria Manual: https ://www.citvofdenton.com/DocumentCente r/View/4425/Stormwate r-Criteria-Manualpdf • City of Denton Development Code: https://www.cityofdenton.com/DocumentCenter/View/427/Denton-Development-Code-PDF • Denton 2040 Comprehensive Plan: https://dentontxgis.maps.arcgis.com/apps/MapSeries/index. html?appid;836c9bOc19f946f8b319af6043e2b388 City of Denton Repetitive Loss Area Analysis Page 30 APPENDIX A Below is a screenshot of the letter the City of Denton mailed to 28 property owners on July 22, 2022. En$hlnriag Dep•rtrntnt al N, Eh„ Sa,,t„ Dantc„,, TX 762CI • (940) B9-8942 July 22, 2022 Mktrad HcmpW 19€X3 N La,id Rd lkatQn TX 762a7.3242 Subjoca 1900NLuiBtRnBd Dear Midud Hcmphill The City of Denton parddpates in the Nadanal Flood Insurance Program's Community Rating SFsnm (CRS), avahrntnry, hd•ral program that rewards cammuni6es far en6ardng higher standards in uchange fa• discount on flood Insurance premiums for eligible policyboldenp As part of the CRS, the Building Sah8y Divirian is waluzting properties that have ex}nrienued repetitive flood damage. This analysis will include the reviPW af all previous flood data and studies conducted in specific locations Development of the Repedave Lass Area Analysis involves the collection of the following property level data D Building permit records (ia£hrdtng •ppb£ztiaa and associate ruuds) U Strrulurearul ate ebIqbal infmmatiaa (dantion urLi£icate, if a\aRable)D TalIDanalatmdpartduEarIb U BuilrlinBpu}buty\nhreanrecord (assessed value, rqlaowwt value, or bath) Age aIdQ a Bmldin€ codu/£lm©bindesxkilnrbwt n£alatiow aceedinE nhimw starBlaIdsa Histczi£rI £oodrvuain&mahan(when ennIs occurled, amaM ofdzauEeto lrrqerty, etc.) In addidaa, City of Den80n st•am•y visit several properties to survey dIe Road risk and take photographs, Fra#nrty gwaers are encouraged to provide any relevant flooding hrformatioa. Ttr• survey crews will be laakinr at the type and collaihoII of the £oundadan, drainage patterns on the lot, and whether outside mechAnical equIpment is elevated. The Repe6aw Lass Area Analysis will also include a r•view afaUtiBa6an zheruHw appraadh•s for property proucdon measures or drainage impruvement3, where feasible, You can b•lp the City OUR CORE VALUES hrngriry • FixrIRzqmrsRIihtIF • Irrchrsiaa • Ttxrwnzacr • Chrt=txlUliIrg Canaw£rSeni£e City of Denton Repetitive Loss Area Analysis Page 31 of Denton perform this analysis by campledag a Flood Protetdon Survey by Aug. 19, 202Z. Th• survey can be accessed at www3urveynonkey=om/r/2S6P92Ra A drIft of the RepeUhv• Lass Area Analysis wiII be posted to the City’s Flood Prabecdon laformzaan websin (https://www.cityafdeaton,coa/Flood-Protection), md wiII be •vzilzble for public comment Once the analysis is complete and has been adapted by City Council a copy of the report will be posted to the same website. Sincerely, Michael nadu, PE Engineering Department C940) 349-8942 MicbaeLLinder@cityofdentobcom Under, KEW'Michael E.p'm=::‘an]a:IJrJ] thatIrana City of Denton Repetitive Loss Area Analysis Page 32 APPENDIX B In its introductory letter on July 22, 2022 to the 28 property owners, the City included a link to an online survey via Survey Monkey. Of the 28 property owners, four (4) of them completed the survey. Below are the questions and summary responses from the City of Denton Flood Protection Survey. City of Denton Flood Protection SUIvey I What b your stI;;t8ddrus? I HowmanyyunhHeyouhedhheMI IHhrB at thIs addru? [] 1 to 5 Years [ jeto nVean[ ]Uto20yean []21 to 30 years []31 years or more Half of the resFxrndents have lived in their home for 1 1-20 years. q. Eb you rent orawnthb home/buldhB? []Own []Rent []Other (please SWfY) All respondents own their homes It What@ dhuMatbn dOH+Ie home/hUN have? []Slab []Crawlspdce []Pier and beam[ ]Notsure [ ]Ottnr (please specfY) All respondents’ homes have a slabfoundation q. lsthe home/buBdhg h the FEMA IMyear$oodphh7 []Yes, tIle hone/building is hated in FEMA ltD.w3rfboddah. [ ]No, the home/txliHin8 is not located in the FEMA lm,year floodplain.[ IFmnotsure. []I am not famithr with the FEMA la3-yearfbodPtah, []Other (please specify) Half of the respondents are not located in the FEMA 100-year floodplain, One respondent was not sure. The other respondent is located in the FEMA 100-year floodplain (AE zone) City of Denton Repetitive Loss Area Analysis Page 33 -C lb31hbh01 !/b4undfn8orpnlmty eye been flooded? Three quarters of the respondents have not flooded. One respondent A noted his/her garage had flooded multiple times.[] Not surE [] if A pkgbe URIah, (IIEne War, mme al £bmb anne, depth of water, athe aRab etc.) If the hnne/buHHhl tas flooded h the past, what do you lelbve wls the e8use7 Check all that affected yOUr hOtWruhlh& [ ]Slarm£cwerbadup [ ]s3naary sewn b9cLup [ ]Law lyN area []sura@ water text to MubeMHdiq LIJDnhap korn rnaItV paWns InIJhbnw pauMub in crawbpu waRs [J Ovubink flood@ horn rna@ CIa/bapu [] H>mdbdHir€ tHS IUt fbaded [] CRIer (pLan SHcHy) Three quarters of the respondents have not flooded. One respondent said the cause of flooding vms drainage burnnearby properlies. &Have anY !hal poteakrn nna9rrtu been hIS:Zlbd arl the paISleytV? Check aH that appIY, []Sump pump []Watepaated the out£kk wa b []Re4nM yard []Mnd thitV aut al bwer Ina alarunue []Bagkt# power £ptnnV#lnnbr [ ]nMb%d[ ]Vabr+atyelwatbn[ ]None [ ] HomdbdHh€ tUb not fbaded[""""1 DtM [phan 4nciq) None of the respondents have installed any f3cod prnte<Hon measures on their properties. gO Eb you have a fU# InsuranCe RoRy ur you ham•/btdHtnB? One quarter of the respondents h3ve flood insurance n 1 at ba I let tIe policy l3p£ [ ] 1 dan'tIIBrE I Feed nDad ifBurrBEe DaIRy tHrrH/bdHiT4. LIJ atta:r iplease WEnT) tO. Wh•tnthru do YoU thhrb the CIty, State, or Fedual annrunent Utm bIke to reduce the effects alncnHllrq7 - Su SectIon 3.0 of the RLAA for le5pondents' mmments. City of Denton Repetitive Loss Area Analysis Page 34 APPENDIX C On August 12, 2022, the City reached out via email to three entities – US Army Corps of Engineers, Texas Department of Transportation, and Denton County – for feedback on any planned or current projects that might affect the RLAs. Their responses are included in Section 5.0 of this RLAA. Below is the content ofeach email. The City of Denton is in the process of developing a Repetitive Loss Area Analysis to examine the causes of repetitive flooding and consider appropriate mitigation efforts. As such, the City is looking for any planned or current projects or drainage studies administered by neighboring communities or entities that may have an impact on the flooding problem in Denton Please advise if you are aware of any such projects and, if so, please provide the followinginformation : 0 0 0 0 0 Project name Goal of the project Funding sourceTimeline and current status A link of the project (if available) Thank you for your time and consideration. If you have any questions, please do not hesitateto contact me. Thank you, Michael Linden P.E. City of Denton Engineering 401 N Elm Street, Denton, Texas 76201 (P) 940-349-8942 City of Denton Repetitive Loss Area Analysis Page 35 APPENDIX D Repetitive Loss Area Analysis post on the City’s website: https://www.citvofdenton.com/436/Flood-Protection-Information How DBusinessDepartments!esidents Govern rnent Flood Protection Information Flood InformatIon Flood Information The City of Denton has adopted the latest Flood Insurance Rate Maps (FIRMs I effective April 18, 2(nl as issued by FEMA. For general information about FEMA’s Flood Insurance Rate Maps please call BOO-358-9616 or viSit FEMA's websFte. City of Denton floodplain areas can also be dtsplayed using the alya Denton Interac„tive MaB Floodplain maps are also available for reference in the Capital Projects Department at the City Service Center located at SOI-A Texas Street and at any Denton Public Library. Elevation certificatu of all propertis irr ailable and on file intMMojects Department, and coPiu are availaMBq£quest. Flood Insurance Flood ProtectionAssistance Flood Hazard Areas The Flood Hazard Repetitive Loss Analysis Draft Report The following is a draft report of the City's Repetitive Loss Area Analysis made avallable on #25/2022 through 9/01/2022 for public comrnent Piease direct all cornments to Michael Under at Michael.Under@ityQfderltan.com. Flooding & FliFlooding Flood Warnin8\System Repetitive LQ ss Anajysjs – Draft Rena£t City of Denton Repetitive Loss Area Analysis Page 36 APPENDIX E In accordance with the Privacy Act of 1974, Appendix E containing sensitive and site-specific data per address will not be shared with the public. City of Denton Repetitive Loss Area Analysis Page 37