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<br />(NFIP). The NFIP requires that any modifications that cause a rise in the Base Flood Elevations <br />(BFEs, which corresponds to water surface elevations associated with the 100-year flood event) <br />must be approved by FEMA. The no-rise condition is also a requirement of ODOT for any bridge <br />replacement project. <br /> <br />Consistent with C.31, both Eugene and Springfield have adopted ordinances regulating construction <br />within floodplains and floodways; City of Eugene FEMA "no-rise" certification for any <br />construction or structures within floodways/special flood hazard areas; and City of Springfield Type <br />I permit to allow any construction in the floodplains or floodways within Springfield. Comments <br />from the Eugene Floodplain Manager note that a FEMA no-rise certificate would only be required <br />through the City of Eugene for construction (fill) or structures within the floodway or floodplain <br />that are outside of the right-of-way. The proposal includes temporary staging areas outside of the <br />ODOT right-of-way; portions of the Whilamut Natural Area and Eastgate Woodlands, and ODOT <br />and Lane County property both located southeast of 1-5 and the Willamette River. For these areas, <br />prior to any fill or other development within the regulatory floodway, ODOT will be required to <br />obtain a "no-rise" certification stating that the development will not impact the pre-project (before <br />the temporary bridge) base flood elevation elevations, floodway elevations and floodway data <br />widths. This certification must be signed by a professional engineer and supported by technical data <br />consistent with current FEMA standards. <br /> <br />Based on the preliminary modeling, the proposed pier location options would result in the <br />following; Option A would result in an increase of 0.02 feet over existing conditions for the 100- <br />year flood event and, Option B would result in a decrease of 0.54 feet for the 100- year flood event. <br />Option B, including a decrease in base flood elevation, is consistent with the no-rise and Policies <br />C.30 and C.31. Option A's preliminary analysis shows an increase of 0.02 base flood elevation, <br />which does not meet the no-rise requirement. However, a detailed no-rise analysis has not been <br />submitted and the modeling will be run again to meet the no-rise requirement when the design is <br />refined for the permitting process. Furthermore, ODOT requires its bridges to meet the no-rise <br />requirement. Therefore, in the context of a plan amendment, these policies are met. Specific <br />construction and operational details will be appropriately addressed during local and state <br />permitting processes, subject to applicable approval criteria and related standards. <br /> <br />Regarding Policy C.32, as noted under Goal 7, portions of the project area proposed for temporary <br />staging areas are identified as moderate hazard risk areas on the map identifying Relative Slope <br />Instability Hazards in Eugene. However, while this information may guide the City in adopting <br />code revisions, it does not apply directly to land use applications as it is not adopted as refinement <br />plan or as codified land use criteria. Additionally, based on the earthquake hazard, geotechnical <br />investigations can be completed prior to construction to determine the best method to seat <br />foundations, piers, and bents to reduce effects related to earthquakes (e.g., lateral spread, <br />liquefaction). In addition, slopes can be constructed in a manner that reduces the potential for <br />erosion or small landslides. <br /> <br />Based on the findings above, in the context of a plan amendment, the proposed plan amendments <br />are consistent with these policies. <br /> <br />D. Willamette River Greenway. River Corridors. and Waterways Element <br /> <br />Exhibit A ~ Findings <br />Page 27 <br />