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'APPENDIX D: MINORITY OPINIONS'
Pages 96-101

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From page 96...
... the purpose of the NFIP being to mitigate flood hazard for existing structures wherever possible, is best furthered by not discouraging the construction of engineered levees to provide whatever level of protection is economically justified. This opinion is based on the assumption that new buildings behind such levees would, as practiced and recommended by this committee, be required to meet the 100 year base elevation requirement.
From page 97...
... and the standards recommended by this committee add 3 feet of freeboard plus geotechnical considerations plus operation and maintenance requirements that will tend to upgrade the level of protection of "100-year levees." It is unreasonable to require communities to adopt higher levee standards and then add insurance requirements to the burden.
From page 98...
... On the Mississippi River and lower Illinois River in Illinois, the Illinois Department of Transportation (IDOT) has identified over 900 square miles of areas protected by substantial levees that will not be rated as 100-year levees according to the new criteria.
From page 99...
... Alternative proposal: The proposed rule makes sense in theory but cannot be defended where there are substantial levees protecting entire communities. This alternative proposal is an attempt to modify the extreme effects of the proposed rule in the areas which will be hardest hit.
From page 100...
... Annual costs = $282 to $506. It can be seen that in areas where buildings have to be elevated very high, but, where the levees provide a lot of protection, it will be much cheaper for the buildings to build at grade and pay the extra insurance premiums than to pay the lower insurance and additional mortgage costs.
From page 101...
... The new Corps levee system on the Pearl River at Jackson, Mississippi, for instance, failed to completely withstand a discharge of less than its design magnitude due to design defects (unplugged sewer pipe extending under levee from river side to "protected area" and low point where levee met interstate highway embankment)


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