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Also, see measures for fish habitat protection below. (FEMA July 30, 1996 <br />Memorandum in response to Region V.) <br />Maintaining the capacity over time. After altering a watercourse; the developer <br />has created an artificial situation and must assume responsibility for maintaining <br />the capacity of the modified channel. If maintenance is not required, this can result <br />in situations such as severe overgrowth or sediment deposition in channelized <br />streams, causing reduced conveyance and increased flood hazards. In other cases, <br />inadequate maintenance has resulted in erosion and scour problems within altered <br />watercourses, thereby increasing potential floodwater velocities and downstream <br />flood damages. Formal maintenance agreements, such as are required in other parts <br />of the NFIP regulations, like for levees, are not specified or required for alterations <br />of watercourses. Also, this requirement does not pertain to existing channels, <br />whether natural or man -altered, that pre -dated the NFIP requirements (Call for <br />Issues, June 2000, page II -3-29). <br />FEMA's only requirement is for appropriate assurances that maintenance will be <br />provided. These assurances should specify all maintenance activities, the frequency <br />of their performance and the community officials responsible for their performance. <br />Even in the case of bridges and culverts that may alter the watercourse, an <br />arrangement must be made to maintain the flood carrying capacity of the channel. <br />Such assurances can come in the form of a simple letter from a responsible <br />community official. Maintenance should consist of a program of periodic <br />inspections, routine channel clearing and other related functions (but see fish <br />measures below). This is necessary for FEMA to verify that maintenance will be <br />carried out in the event the community requests a map revision (Federal Register, <br />May 6, 1988, page 16273, and November 3, 1987, page 42119). <br />Oversize, and avoid the maintenance program. Some communities have design <br />criteria for watercourse alterations that include factors that account for regrowth of <br />vegetation, sediment deposition, etc., thus obviating the need for maintenance. This <br />is a much better course of action as it relates to fish habitat enhancement in the <br />Northwest, and is a practice recognized by FEMA in Section 65.6[a] [13] of the <br />regulations: <br />"...a community may submit, in lieu of the documentation specified in Section <br />65.6[a] [12] (the maintenance program), certification by a registered <br />professional engineer that the project has been designed to retain its flood <br />carrying capacity without periodic maintenance." <br />What's best for fish? Recognizing the need to enhance fish habitat in the <br />Northwest, there are several measures that communities can require relative to <br />alteration of watercourses (including bank stabilization projects) that would not <br />degrade fish habitat (some of the general standards in the preceding paragraphs, <br />while FEMA policy for the Nation, would not be in the best interests of preserving <br />fish habitat in this area): <br />• Bridges should be used instead of culverts wherever possible; <br />2016 PIDS Manual, Appendix, B-3 B-3-3 <br />