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FRANKLIN COUNTY

EMERGENCY MANAGEMENT

33 Commerce Street

Apalachicola, Florida 32320

(850) 653-8977, Fax (850) 653-3643

July 9, 2002

TO: Alan Pierce

FROM: James Turner

RE: Proposed Amendments to Franklin County Comprehensive Plan as pertaining to Summer Camp Development

This letter is to advise you and the Commissioners of some concerns I have with the Summer Camp Development Project I understand Amendments to the Comprehensive Plan will be voted on at the public meeting on July 16, 2002.

Emergency Management has not been included in planning on this project and it should have been. It is my responsibility as Emergency Manager to advise the county on issues that affect Emergency Management operations and that is the purpose of this letter. I have a number of concerns about compliance with the Comprehensive Emergency Management Plan, Local Mitigation Plan and the Coastal Conservation Comprehensive Plan that relate to the Summer Camp Development.

Concern 1:

There seems to be an effort to re-define what a coastal high hazard area is. This attempt is deceptive on the part of Arvida and the definition is very clear in 24CFR55.2 as well as Florida Administrative Code 9J-5.003(19). 24CFR55.2 defines a coastal high hazard area as an area subject to high velocity waters including but not limited to hurricane, wave wash, or tsunamis. According to the national Flood Insurance Rate Map a coastal high hazard area is indicated as a V-Zone as Vl-30, VE, or V on the national Flood Insurance Rate Map. The Florida Administrative Code 9J 5.003 (19) describes a coastal high hazard area as an evacuation zone for a Category 1 hurricane.

The Florida Hurricane Surge Atlas is the official map created by the National Oceanic and Atmospheric Administration (NOAA) and the U. S. Geologic Survey. This is the recognized guideline that was used to create the Apalachee Bay Regional Hurricane Evacuation Study. This atlas clearly indicates that more than 50% of the Summer Camp Development that is south of Hwy. 98 is in a tropical storm or Category 1 hurricane surge zone. The map that Arvida is attempting to use from the Apalachee Bay Regional Hurricane Evacuation Study on plate 3-1 is incomplete and in error. We need to refer to the official Florida Hurricane Surge Atlas. The text of the Apalachee Bay Regional hurricane Evacuation Study on page 3-2 emphasizes that evacuation zones should include all populated areas that have serious risk of being flooded or being cut off by flood prone areas.

The national Flood Insurance Rate Maps #12088 0515B and 0555B indicate that the majority of the eastern portion of this development would be located in a V-zone or the 1 00-year flood plain. This includes the area designated for commercial development. Much of the western portion of the Summer Camp Development is outside the limits of the detailed study and no clear details can be determined without further studies.

This development by all definitions is clearly in a coastal high hazard area. A 499 home plus commercial development in this area would place lives, property, and services at unnecessary risk and could cause severe economic and environmental harm to Franklin County.

Concern 2:

Building a community in a coastal high hazard area is contrary to the principles outlined by the Franklin County Local Mitigation Strategy, Comprehensive Emergency Management Plan, and the Coastal Conservation Comprehensive Plan. Our Board of County Commissioners approved these documents. The Summer Camp Development violates objectives 1, 2, 4, 5, 7, 10, 16, and 18 of the Franklin County Local Mitigation Strategy.

Placing a 499 home development in a coastal high hazard area and placing lives and property at risk violates Local Mitigation Strategy Objective 1.

Local Mitigation Strategy Objectives 2 & 5 are violated by placing homes in an area that would receive damage to infrastructure, i.e. electricity, water, sewer, telephone etc., in event of a hurricane.

Local Mitigation Strategy Objective 3 is violated by building in an area that will certainly have an adverse effect on the water quality of the estuarine areas due to run off of fertilizers, pesticides, chemicals, and petroleum products etc. The buildup over time of phosphates can also increase the frequency and duration of Red Tide in Apalachicola Bay. This would cause tremendous economic injury to the fishing industry.

Building in an area that will cause destruction to wetlands violates Local Mitigation Strategy Objective 10.

Local Mitigation Strategy Objectives 7, 16, & 18 are violated by relocating a section of scenic highway and denying public access to this area by building a private gated community.

Concern 3:

The types of soils found in this area are not suitable for residential, commercial, or recreational development. According to the U. S. Department of Agriculture Soil Survey for Franklin County, this area was found to be poorly drained, a poor filter for sanitary systems, to have severe flooding problems and to be overall too wet and sandy to support development.

Concern 4:

Under its Community Rating System, the National Flood Insurance Program could change the county's rating or even drop Franklin County from the program if this type of development is allowed. A change in rating could substantially raise the insurance premiums for all homeowners. If FEMA determines that our county is no longer an acceptable risk and drops us from the program this would affect residents' ability to secure a mortgage and cause even greater economic harm. This should be carefully considered.

Arvida has a number of areas in our county that could potentially be developed with little or no environmental or economic harm. Allowing the Summer Camp Project will set a precedent that will eventually cause great harm to our county. If the Commissioners approve this project it appears it will place the county as well as the Commissioners in a position of legal liability.

I hope you will do the right thing and continue to support the Local Mitigation Strategy, the Emergency Management Plan, and the coastal Conservation Comprehensive Plan.

Thank you,

James Turner

Director

cc: Franklin County Commissioners

Steven Siebert, DCA

Chris Floyd, American Red Cross

Becky Jackson, City of Carrabelle



	FRANKLIN COUNTY EMERGENCY MANAGEMENT 33 Commerce Street Apalachicola, Florida 32320 (850) 653-8977, Fax (850) 653-3643 July 9, 2002 TO: Alan Pierce FROM: James Turner RE: Proposed Amendments to Franklin County Comprehensive Plan as pertaining to Summer Camp Development This letter is to advise you and the Commissioners of some concerns I have with the Summer Camp Development Project I understand Amendments to the Comprehensive Plan will be voted on at the public meeting on July 16, 2002. Emergency Management has not been included in planning on this project and it should have been. It is my responsibility as Emergency Manager to advise the county on issues that affect Emergency Management operations and that is the purpose of this letter. I have a number of concerns about compliance with the Comprehensive Emergency Management Plan, Local Mitigation Plan and the Coastal Conservation Comprehensive Plan that relate to the Summer Camp Development. Concern 1: There seems to be an effort to re-define what a coastal high hazard area is. This attempt is deceptive on the part of Arvida and the definition is very clear in 24CFR55.2 as well as Florida Administrative Code 9J-5.003(19). 24CFR55.2 defines a coastal high hazard area as an area subject to high velocity waters including but not limited to hurricane, wave wash, or tsunamis. According to the national Flood Insurance Rate Map a coastal high hazard area is indicated as a V-Zone as Vl-30, VE, or V on the national Flood Insurance Rate Map. The Florida Administrative Code 9J 5.003 (19) describes a coastal high hazard area as an evacuation zone for a Category 1 hurricane. The Florida Hurricane Surge Atlas is the official map created by the National Oceanic and Atmospheric Administration (NOAA) and the U. S. Geologic Survey. This is the recognized guideline that was used to create the Apalachee Bay Regional Hurricane Evacuation Study. This atlas clearly indicates that more than 50% of the Summer Camp Development that is south of Hwy. 98 is in a tropical storm or Category 1 hurricane surge zone. The map that Arvida is attempting to use from the Apalachee Bay Regional Hurricane Evacuation Study on plate 3-1 is incomplete and in error. We need to refer to the official Florida Hurricane Surge Atlas. The text of the Apalachee Bay Regional hurricane Evacuation Study on page 3-2 emphasizes that evacuation zones should include all populated areas that have serious risk of being flooded or being cut off by flood prone areas. The national Flood Insurance Rate Maps #12088 0515B and 0555B indicate that the majority of the eastern portion of this development would be located in a V-zone or the 1 00-year flood plain. This includes the area designated for commercial development. Much of the western portion of the Summer Camp Development is outside the limits of the detailed study and no clear details can be determined without further studies. This development by all definitions is clearly in a coastal high hazard area. A 499 home plus commercial development in this area would place lives, property, and services at unnecessary risk and could cause severe economic and environmental harm to Franklin County. Concern 2: Building a community in a coastal high hazard area is contrary to the principles outlined by the Franklin County Local Mitigation Strategy, Comprehensive Emergency Management Plan, and the Coastal Conservation Comprehensive Plan. Our Board of County Commissioners approved these documents. The Summer Camp Development violates objectives 1, 2, 4, 5, 7, 10, 16, and 18 of the Franklin County Local Mitigation Strategy. Placing a 499 home development in a coastal high hazard area and placing lives and property at risk violates Local Mitigation Strategy Objective 1. Local Mitigation Strategy Objectives 2 & 5 are violated by placing homes in an area that would receive damage to infrastructure, i.e. electricity, water, sewer, telephone etc., in event of a hurricane. Local Mitigation Strategy Objective 3 is violated by building in an area that will certainly have an adverse effect on the water quality of the estuarine areas due to run off of fertilizers, pesticides, chemicals, and petroleum products etc. The buildup over time of phosphates can also increase the frequency and duration of Red Tide in Apalachicola Bay. This would cause tremendous economic injury to the fishing industry. Building in an area that will cause destruction to wetlands violates Local Mitigation Strategy Objective 10. Local Mitigation Strategy Objectives 7, 16, & 18 are violated by relocating a section of scenic highway and denying public access to this area by building a private gated community. Concern 3: The types of soils found in this area are not suitable for residential, commercial, or recreational development. According to the U. S. Department of Agriculture Soil Survey for Franklin County, this area was found to be poorly drained, a poor filter for sanitary systems, to have severe flooding problems and to be overall too wet and sandy to support development. Concern 4: Under its Community Rating System, the National Flood Insurance Program could change the county's rating or even drop Franklin County from the program if this type of development is allowed. A change in rating could substantially raise the insurance premiums for all homeowners. If FEMA determines that our county is no longer an acceptable risk and drops us from the program this would affect residents' ability to secure a mortgage and cause even greater economic harm. This should be carefully considered. Arvida has a number of areas in our county that could potentially be developed with little or no environmental or economic harm. Allowing the Summer Camp Project will set a precedent that will eventually cause great harm to our county. If the Commissioners approve this project it appears it will place the county as well as the Commissioners in a position of legal liability. I hope you will do the right thing and continue to support the Local Mitigation Strategy, the Emergency Management Plan, and the coastal Conservation Comprehensive Plan. Thank you, James Turner Director cc: Franklin County Commissioners Steven Siebert, DCA Chris Floyd, American Red Cross Becky Jackson, City of Carrabelle