June 24, 2002

Reference: FEMA CLOMR Case No. 01-09-393R
Matt Miller, P.E., Chief
Hazards Study Branch
Federal Insurance and Mitigation Administration
Federal Emergency Management Agency
500 C Street SW
Washington, DC  20472

Dear Chief Miller,

I am writing in regards to FEMA CLOMR Case No. 01-09-393R which was recently issued for the city of Huntington Beach, California, in response to the proposed Shea Homes Parkside Estates development.  As far as I can tell from the EIR and associated FEMA submittal materials that are publicly available, it appears that a key technical detail has not been considered which calls into question the conclusions of this CLOMR.

The proposed development calls for various flood control improvements including the addition of two 147-cubic-feet-per-second pumps to the Slater Pump Station.  What the developer has consistently neglected to mention is that when the construction permits for these pumps are obtained, the County of Orange will impose automatic throttle-back limits to prevent these pumps from causing the East Garden Grove-Wintersburg (EGGW) Channel to overflow.

I have confirmed with Huntington Beach Public Works Water Operations personnel that the County of Orange imposes throttle-back limits for all significant new pumps that are connected to the EGGW Channel.  Recent city improvements in upstream areas of the EGGW Channel were subject to these limits, and the city fully expects similar limits to be imposed on the new Shea pumps at the Slater Pump Station.

If there is enough water in the Slater Channel to activate these new pumps, then the EGGW Channel will likely also be running quite high -- perhaps even high enough during a combination high tide / El Nino storm event to prevent the new Shea pumps from even starting.  Therefore, if the Shea pumps cannot operate at the specified 147-cfs assumed by this CLOMR, its conclusions that depend on a 147-cfs flow are invalid.

Lastly, this CLOMR doesn’t mention the impact on several areas adjacent to the proposed development:

• The small triangular area bounded on the east by Graham Street, on the south by the Slater Channel, and on the northwest by the southern bank of the EGGW Channel.  This is where I live.
• The area bounded on the east by Springdale Street, on the south by the Slater Channel, on the west by Graham Street, and on the north by Warner Avenue.
• The area bounded on the east by Graham Street, on the south by Kenilworth Drive, on the west by Bolsa Chica Street, and on the north by Warner Avenue.

The base flood WSEL changes (if any) for these areas should have been mentioned in the CLOMR in the interest of full community disclosure.

Sincerely,

Mark D. Bixby
17451 Hillgate Ln
Huntington Beach, CA  92649-4707
voice: 714-625-0876

cc:

The Honorable Debbie Cook Mayor City of Huntington Beach Mr. David Webb City Engineer City of Huntington Beach, Department of Public Works Mr. Scott Hess Planner City of Huntington Beach, Planning Department The Honorable Cynthia P. Coad Chairperson Orange County Board of Supervisors Mr. Sara Bavan Manager County of Orange Flood Control Planning Mr. Neil M. Jordan, P.E. Senior Engineer Exponent Failure Analysis Associates Mr. Ronald C. Metzler Vice President, Planning and Development Shea Homes