Hillsborough County
Flood Plain Information

 

Recent Updates (with the most recent first).

Last updated on May 18, 2007.

Update #1:
Light at the end of the tunnel...

Finally, we're starting see our efforts pay off. Hillsborough County resurveyed our topography to an accuracy of about six inches. The computer model was updated and rerun. FEMA used the new data to draw better flood plain maps for us. The county analysed aerial photographs of our homes relative to the flood plain contour. The County and FEMA agreed to issue "Letters of Map Admendment - Out As Show" to about 700 Sun City Center properties now entering the flood plain. That means that the flood will touch part of your property but not your home. About 300 similar letters will be issued to properties that were considered in the flood plain, but now have just part of the property in the flood plain. Unfortunately, there are about 80 properties in which the flood plain still includes the home.

Here is the newest timeline for upcoming events:

Feb 28, 2007 was the end of the formal Protest/Appeal Period

The last completed appeal was submitted in early May 2007.

Between May and September 2007, the County will complete its recommendations to FEMA about our "Letters of Map Admendment - Out As Show." FEMA's map subcontractor (Dewberry) will update all modeling and boundary changes to be incorporated into the digital and hard-copy maps

September 2007 is the anticipated date for the issue of the “Letter of Final Determination.”

Between September 2007 and March 2008, the new LOMA’s and LOMA-Out As Shown will be processed for issue in March 2008. Press releases will encourage the purchase of PRP insurance to take advantage of granfathering. Developers will start to use the new floodway and SFHA delineations and associated FIS data.

March 2008 is the anticipated date that the new flood plain maps become effective.

After March 2008, mortgage lenders will be advised of any changes in your property's flood plain status. Insurance agents will start using the new maps to scare you into buying more insurance.

Update #2:
Kings Point concerns...

The list for Kings Point had to be generated manually, because the parcel records included large swaths of condominium land associated with many homes in KP. The computer cross-referencing of property lines and the flood plain was causing whole parcels, with their many homes, to be declared in the flood plain when, in fact, it was just a small area of land, often not even associated with a particular home, that was causing the computer to greatly overstate the affected properties.

Brian May of Sterling Management and Wayne Musholt, Chairman of the Federation developed an address list for Kings Point which identified ten duplexes that are touched by the flood plain. Sterling is arranging for the insurance purchase.
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Overview.

Recently, about 90,000 residents in Hillsborough County received a letter from the county's Flood Hazard Mitigation Department. About 1,100 of us here in Sun City Center and Kings Point received that letter. The letter advised us that our property is adjacent to or within the 100-year floodplain. This means that if we have a mortgage, reverse mortgage or a line of credit based on our home and any part of our home is in the flood plain area, we are required to have a federally-backed flood insurance policy for at least the value of the mortgage or line of credit.

The flood plain contour is drawn by the Federal Emergency Management Agency (FEMA) using the County's computer generated flood model data. The drawn contour is then applied against the County's database of property lines. If the two coincide in any manner, the property is tagged as being in the floodplain. In other words, if the computer thinks that the flood waters from the worst storm in a 100-year period will touch even one-square-inch of your property, you're in the flood plain. Officially your property is considered to have a Flood Zone Classification of "X" (formerly known as "C" or "X-500") which indicates an "area of minimal flood risk."

An A Zone is specifically the area that the water covers, like down near a sea wall. But if FEMA has drawn the flood plain contour line including any part of your home, including a garage or carport, then your home is in the dreaded "A" Zone which means you must buy flood insurance if you have a mortgage. Different parts of your lot can have different Zone Classifications. If you can show that the map is wrong, then you can get out of having to buy flood insurance. But you have to spend a lot of money to prove to FEMA that their maps are wrong. And even if you're right, they don't reimburse you for the outlay to show that they are incompetent! Even common criminals are presumed innocent until proven guilty - but not we folks in the flood plain! FEMA has benevolently provided a bureaucratic method to have your home removed from the "A" or "AE" classification. You have to come up with a certified site plan, with elevations, showing that your home is above the flood plain. A $urveyor will charge you between $400 and $700 for the survey because it has to include elevations. It is submitted to FEMA along with a 19-page form Form MT-1 or an 11-page Form MT-EZ form depending on the date of construction of your home and if it was constructed on fill dirt. The form is referred to as a Letter Of Map Amendment (LOMA).

For some unknown reason, the County does allow newer developments to have homes in the flood plain, although certain restrictions apply - like the electric box has to be above the flood plain or a garage below the flood plain has to have a sump pump. Because the home is "vertically" in the flood plain, flood insurance is required. The County uses Grading Plans to make decisions beneficial to the developer.

Older developments tend to have older residents, who have lived there for some time. The Grading Plans for these older developments have long since vanished. However, the County (thanks to our County Commissioner Ronda Storms) is going to provide the assistance to get Elevation Certificates for the homeowners in these older developments. (It would have been tragic if we older folks had to resort to eating dog food and foregoing needed medicines in order to pay for a LOMA survey for a home that is obviously above the flood plain anyway.)

The 2005 FEMA generated flood plain contour were the most atrocious mapping that I have ever seen. Thankfully, the Hillsborough Board of County Commissioners rejected FEMA's contour at that time. Now, the County has an accurate 1-foot contour, topographic map of our area which has been used to redraw the SCC/KP flood plain.

As of December 2006, the maps were redrawn and are now much more accurate for Sun City Center and Kings Point!

Several years ago I complained to Hillsborough County about the quality of the older flood plain maps as they related to Middle Lake. (I was president of the Middle Lake Association at the time.) Over a year ago, the County asked if I would provide citizen input on the introduction of the new flood plain maps. Other local communities, like Apollo Beach and the Alafia River area, also have citizen representatives.

Because of the TV interview and newspaper articles and talks that I've given to several groups, I have received a lot of feedback from residents with questions about the new flood plain definition. Here are the answers to some of those frequently asked questions...
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What Is The Timeline For All This Stuff?

See Updates #1 above for the most recent tentative timeline.
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Who Is Affected?

  • If you do not have a mortgage and do not live in the flood plain, you are not affected.

  • If you do have a mortgage but do not live in the flood plain, you are not affected.

  • If you do not have a mortgage but do live in the flood plain, you are not directly affected. However you may want to consider buying flood insurance, but you are not required to. But when you go to the Great Retirement Village In The Sky, your heirs will be required to tell prospective buyers that your home is in a flood plain which will cause it to fetch a lower price. However, if you can prove that the water will never reach your slab, you can get out of having your home in a flood plain - after jumping through bureaucratic hoops and paying fees!

  • If you do have a mortgage (or line of credit based on the home) and do live in the flood plain, you are affected and will no doubt be required to buy flood insurance! If flood waters barely touch your property, the whole property is declared to be in the flood plain. However, if you can prove that the water will never reach your slab, you can get out of having to buy the flood insurance - after jumping through bureaucratic hoops and paying fees!

    Both FEMA and the County's website emphatically state that "Flood Insurance is required..." Other times they try to weasel out of this statement by saying that technically, it will be your mortgage or Line Of Credit lender who decides if you are required to have flood insurance. But what they do has a big impact. When $urveyors prepare a site survey, they copy the flood plain contour as though it is gospel. And if FEMA and the County have erroneously put you into the flood plain, it's going to be pretty hard to argue with the bank that your home is safe from flooding. On the other hand, if your home isn't in the County's flood plain and the bank wants you to carry flood insurance, you should be able to truthfully argue that "FEMA and the County don't have me in a flood plain - why should you?" And if the County has "officially," but erroneously, put you into the flood plain and you're selling your house, what are you required to tell the potential buyers?

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Is Flood Insurance Required For A Line Of Credit Or A Reverse Mortgage?

If your home is in the flood plain, all "loans" that are secured by it are required to have flood insurance. This includes things like a mortgage, second mortgage, line of credit, home equity loan, home equity line of credit and a reverse mortgage. For example:

A line of credit is a fixed amount of money, with your home as collateral, that you can draw against from a lender. You apply for a line of credit with a lending institution just like applying for a loan. However, unlike a loan, the borrower only pays interest on the amount actually used. The interest rate is pretty close to the prime interest rate. You write a check or use a credit card to get the money. Then you pay off the lender in monthly installment payments. It is often used to buy big ticket items like a car. I understand that a number of Floridians got a Line Of Credit following last year's hurricanes so that they could immediately write a check to repair any damage, then and in the future, instead of having to wait on FEMA and/or insurance companies. As long as the roof is still on the house, the lender will honor the Line Of Credit. At one time a Line Of Credit was "free" except when you were using it. But now with yearly flood insurance premiums required, whether you use the money or not, it may require a rethink. Is it worth over $500 a year to maintain an unused $100,000 Line Of Credit?

A Reverse Mortgage is a special type of loan used to convert the equity in a home into cash. The money obtained through a reverse mortgage is usually used to provide seniors with financial security in their retirement years. A lender makes payments to the borrower. With a reverse mortgage, the borrower owns the home and holds title to it, without having to make any monthly mortgage payments. But when the borrower goes to the Big Retirement Village In The Sky, the lender gets the house. Because the home is the collateral, flood insurance is required so that the lender has something to fall back on if the home is damaged by rising water.

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Why Flood Insurance?

Flood insurance is different from Homeowner's insurance. For example, Homeowners covers you if your roof blows off and water comes down and damages your rug. Flood insurance only covers flood damage from "rising water" including lakes, streams and sewers. So if that same water comes in through your front door, because the water backed up from the street, and damages the rug, then it is covered by Flood Insurance. The company that holds your mortgage or Letter Of Credit wants to make sure that if you get rising water damage, their investment is insured. Because all "loans" can be traced back to the government (like Fannie Maes, Freddie Macs, Ginnie Maes, etc.), federal rules require homeowners with mortgages or Letters Of Credit to buy flood insurance. Unfortunately, the way the rules work has the stench of insurance industry lobbyists and government bureaucrats all over it!
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What's It Going To Cost Me?

The first option is that if you can prove that the water will never reach your slab, you can get out of having to buy the flood insurance - after jumping through bureaucratic hoops and paying fees! You will need an official $urvey of your lot and slab with elevations which will cost somewhere between $400 to $700 (because of the elevations). And then you or your lawyer$ need to complete a Letter Of Map Amendment (LOMA). And even then, the mortgage lender may still require flood insurance, particularly if his brother happens to be an in$urance $alesman. It is also possible to file these documents for large areas, like home-owners associations - maybe even the Community Association. I'm still trying to find my way through the bureaucratic morass to determine exactly what would need to be done.

At the moment, I am having a great deal of trouble getting through the FEMA bureaucracy to get a straight answer on typical Sun City Center premiums. Since the rates have been pre-set for all, it should be a simple matter to figure it out. After all, it ain't rocket science! However, FEMA always wants you to go to an in$urance $alesman - who will obviously try to mislead you and sell you more insurance than you want or need. Hopefully these communications problems about the premiums can be resolved within the next few weeks.

In the meantime, here is what I think the yearly premium situation is:

If the water is going to touch your slab and you do have a mortgage, then you are doomed to buy insurance. The Flood Insurance premiums are established by the Federal Government and your rate will be the same from any insurer. The mortgage lender should only require you to buy "building" insurance to cover the unpaid portion of your mortgage. If you want your own extra building coverage for flood or insurance on the contents, it is up to you. Note that it is cheaper to buy the "Building and Contents" package if you want to cover both.

The premium that you're going to pay depends on the official date that your house was built. This date is referred to as the DOC (Date Of Construction). I have no idea how to find this out but I have a query into the County about it. The precise date only matters if your house was built in the summer of 1980. In that case you need to determine if its DOC was before or after July 1, 1980. Before that date is referred to as "pre-FIRM." After that date is "post-FIRM."

For a typical Sun City Center home built before July of 1980 (single family, one floor with a standard $1,000 deductible) that is in the flood plain, the yearly premium will be:

ZONES A, AE, A1-A30, AO, AH - PRE-FIRM (STANDARD $1,000 DEDUCTIBLE)
i.e., Yearly Premiums For A Typical SCC Flood Plain Home Built Before July 1980
Building Only Contents Only Building & Contents
CoveragePremium CoveragePremium CoveragePremium
$ 35,000
50,000
75,000
100,000
125,000
150,000
250,000
$ 303
394
462
530
598
666
926
$ 10,000
15,000
20,000
30,000
40,000
50,000
100,000
$ 107
145
184
232
280
328
568
$ 5,000/10,000
50,000/15,000
75,000/20,000
100,000/30,000
125,000/40,000
150,000/50,000
250,000/100,000
$ 380
509
616
732
848
964
1464

For a typical Sun City Center home built after July of 1980 (single family, one floor with a standard $500 deductible) that is in the flood plain, the yearly premium will be:

ZONES A1-A30, AE - POST-FIRM + 1 FOOT ABOVE BFE (STANDARD $500 DEDUCTIBLE)
i.e., Yearly Premiums For A Typical SCC Flood Plain Home Built After July 1980
Building Only Contents Only Building & Contents
CoveragePremium CoveragePremium CoveragePremium
$ 35,000
50,000
75,000
100,000
125,000
150,000
250,000
$ 200
271
287
303
319
335
397
$ 10,000
15,000
20,000
30,000
40,000
50,000
100,000
$ 77
101
124
134
144
153
201
$ 5,000/10,000
50,000/15,000
75,000/20,000
100,000/30,000
125,000/40,000
150,000/50,000
250,000/100,000
$ 248
342
381
407
432
458
568

If your home is not located in the floodplain, but you want to buy flood insurance anyway, you can buy a Preferred Risk Policy (PRP) with has lower premiums. In that case, for a typical Sun City Center home (single family, one floor) that is not in the flood plain, the yearly premium will be:

PRP 1-4 FAMILY RESIDENTIAL BUILDINGS AND CONTENTS COVERAGE COMBINATIONS
i.e., Yearly Premiums For A Typical SCC Home That Is Not In The Flood Plain
BuildingContents Premium
$ 20,000
30,000
50,000
75,000
100,000
125,000
150,000
200,000
250,000
$ 8,000
12,000
20,000
30,000
40,000
50,000
60,000
80,000
100,000
$ 112
138
180
207
233
249
264
296
317

Because Hillsborough County is a willing participant in the program, everybody gets some sort of discount on their flood insurance (provided they buy it before April 25, 2006). If you are in the flood plain, you get a 20% discount. I already applied these discounts to the above tables of premiums.

The above yearly premiums for a typical home should be accurate within $10 or overstated. The number of feet your slab is above the flood plain affects the premium. If your insurance agent quotes you a grossly different rate, be cautious!

If you want to check my work, go to www.floodsmart.gov and click on the appropriate table. For a flood plain home's premium, deduct the $30 fee, multiply by 0.8 and then add the $30 fee back in. I'm trying to get confirmation from FEMA that I did this right. If you think I made a mistake, please let me know pronto!
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What About Condominiums?

The law mandates flood plain insurance if the water touches your home and you have a mortgage or Line Of Credit based on the home. I'm trying to find out what happens when you only own the house to the "paint" or out just a few feet. I know that there is a condo situation over on Augusta Drive where the property line for one house extends out about five feet from the walls and the association owns the land between the house and the lake - and that lot is not in the flood plain because the flood waters will not touch their limited lot area. On the other hand, the person right next door owns the land down to the lake and that lot is in the flood plain. Based on that precedent, I wonder if any of the limited lot size condominium homes in Sun City Center or Kings Point would be tagged incorrectly. There are special provisions in the law for condominiums. I am pursuing exactly how they will apply to us and will update this information when I find out. Of course, having to buy insurance is suppose to be based on the flood plain's going through the house, not if it touches the property. It would be interesting to know if a banker would treat the two properties differently, since one gets tagged by the County and the other one doesn't.
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Why Now?

The official maps which show the location of the flood plain are called FIRMs (Flood Insurance Rate Map). This is the map that a loan officer would pull out of a drawer and look at to decide if flood insurance is required for your mortgage package. The current map that is used for Sun City Center was drawn in 1980 and only has some of the residents around South, Middle and North Lakes in the flood plain. The old map is out-of-date and has a number of errors. The new maps will give in$urance $alesmen a bigger customer base to scam.
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Why Hillsborough County?

A few years ago the County decided to update their flood-control maps so that they could get a handle on the infrastructure needed to prevent all the flooding that takes place in residential areas after a modest rain storm. They were able to use the same data to update the flood plain maps. This whole process allows (1) the County to manage flooding better, (2) all residents who buy flood insurance to automatically get a 10 to 20% discount on their premiums, and (3) everyone within the County to be eligible to receive disaster assistance following a catastrophic event. I need to find out if the disaster assistance would come anyway. I find it hard to believe that a Governor or President would deny disaster assistance to a county's residents.
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How Is A Flood Plain Determined?

The first step is to determine how many inches of rain will fall during a 24-hour period for the worst storm that will occur in the next 100 years. Using Weather bureau records, rainfall estimates are mapped as contour lines on a regional map with Hillsborough County and all of the surrounding counties that are "upstream" from us. This map's official name is: "Twenty-Four Hour One-Hundred Year Return Period Rainfall Map" and was prepared by SWFWMD (Southwest Florida Water Management District).

There were actually seven maps to choose from: 2, 2.33, 5, 10, 25, 50 and 100 years. Obviously, the longer the time period, the better the chance for a really big storm, and the more people that will have to buy insurance. The 100-year map was used! So, can you start to smell the insurance industry lobbyists yet?

Here is the 100-year map that was used, which shows that Hillsborough County will receive between 10 to 12 inches of rain and that Sun City Center is predicted to receive about 11 inches of rain in that storm.

The second step is to develop a computer model of the topography, vegetation, soil types, man-made structures (like culverts) etc. that affect water flow. Very small areas (sometimes less than an acre) with a particular characteristic are defined.

The third step is that the rainfall contours from step one are combined with the computer model from step two. The result is a map of the flooding as it will appear at the end of the 24-hour period. The elevation of the flooding is called the BFE (Base Flood Elevation). For example, the normal elevation for Middle Lake is 34.90' above sea level. After the 100-year, 24-hour rain event, the model predicts that the water level will rise to 37.33', which is the BFE. The BFE differs for each small area defined in the computer model. There are three types of flooding. Coastal (like along the beach), riverine (along rivers) and inland (Sun City Center).

Just because an area is downstream from you doesn't mean that its BFE is going to be the same or more than in your area. For example, there might be intervening culverts or vegetation that impede the water flow and/or maybe the stream bed drops more after it leaves your area, which would cause the water to empty out faster, instead of backing up and flooding downsteam from you. Setting flood plain levels is based on very, very local conditions - like the size of the storm drain culvert in front of your house - or a berm in your backyard. The fact that your home's slab is forty or fifty feet above sea-level has absolutely nothing to do with an inland flood plain. Inland flood plains are based on very local conditions!

An example of this is the bridge on North Pebble Beach at Cherry Hills Drive. On the golf course side of the bridge, the flood plain elevation is 42.85". On the North Lake side of the bridge, it is 38.72". This is because the abutments for the bridge cause the water to backup on the golf course side. And indeed, when we had that "New Year's Eve Storm" a couple of years ago, the backup of water caused a little bit of it to run over the bridge, but North Lake's level stayed about four feet lower.

The fourth step is that the Base Flood Elevations (BFEs) are given to FEMA who draws the elevations as contours on a map. This map then becomes the new FIRM (Flood Insurance Rate Map) that a banker will use to decide if you need flood insurance with your mortgage. The 2005 proposed maps were dreadful! What happened is that the BFEs should have followed the known topographical contours within each little area of the model - but they sure didn't. Consequently, the maps show things like water running uphill and adjacent homes being treated differently!

Bearing in mind that there are some errors, here is the 2005 map of the flooding (cross-hatched area) that will occur in the Sun City Center area. The December 2006 map will be posted as soon as it becomes available.

Click on the map for a higher-resolution version...  

The fifth step is that the flood plain contours file is automatically compared with the County's database of our property lines, property by property. And if the computer sees that the flood plain line touches any part of your property, the whole property is tagged as being partly in Flood Zone X (minimal flood risk) and Flood Zone A (where the water covers). Even if you owned 1,000 acres and the flood plain touched just one square inch of it, your whole property will be divided into Flood Zones A and X! And you will then get your letter from the County , saying something like "you live or own property adjacent to or within the 100-year floodplain. Although your property may be within the 100-year floodplain, your structure may not be. But if it is, you will be required to buy flood insurance." And if you get a survey done of your land, it will say "Per the Federal Insurance Administration Flood Hazard Boundary Map Community No. ___ Panel No. ___, dated ___, the Property shown and described hereon appears to be in Zone A+X, with a base elevation of ___."

The official draft map for Sun City Center is available at http://www.hillsboroughcounty.org/pgm/resources/publications/floodmap/suncitycenterupdatedmap.pdf

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How Bad Were the 2005 Flood Plain Contours?

The phrase "Close enough for government work" implies that we unfortunately don't always get the best and the brightest in government service. Absolute proof of that is in the way that FEMA drew the flood plain contour lines for Hillsborough County. Get ready to shake your head in disbelief!

The South West Florida Water Management District (SWFWMD) has a set of 1-foot contour maps for Hillsborough County drawn a few years ago. The contours look very accurate when compared with the actual lay of the land. From them, I built a 3-D model of Middle and North Lakes. Each layer of foam-board, which is about 1/4" thick, represents 1 foot of elevation. Middle Lake is 34.9' above sea-level and the computer estimated its flood plain height at 37.33'. North Lake is 35.35' above sea-level and the computer estimated its flood plain height at 38.72'. The dark blue is the lake surface. The green are the lawns that go from the edge of the lake up to the back of the homes. The white lines are the computer model's flood plain height estimates for the two lakes, which the County gave to FEMA to generate the Flood Insurance Rate Maps.

Then I used red tape to put on FEMA's resulting flood plain contours translated downward to the map. If FEMA had correctly transferred the computer's vertical heights to their flood plain drawings, the red contour should have exactly coincided with the white contour for the estimated water height after the 100-year storm. Instead, note how FEMA's flood plain height, indicated by the red tape, cavorts all over the place and is often one-, two- or more feet above the estimated height which is indicated by the white line. It may come as a shock to FEMA, but water doesn't flow uphill. This exercise of laying FEMA's contours onto a 3-D map and comparing them to the known height established by the computer model is sorta like when you compare your check-book balance against the bank's balance. They should match exactly, or else someone screwed-up! When I showed the finished product to my wife, her first comment was "How can a flood plain do that?" Fortunately, the County Commissioners asked the same question, came to the conclusion that FEMA's work was seriously flawed and demanded a redraw.

An interesting feature of FEMA's lines are the scallop shapes at the end of cul-de-sacs. This was cause by FEMA's drawing straight lines instead of curves. And when these straight lines were projected downward onto the slopes of the lawns around the end of a cul-de-sac, they produced a scalloped-shaped flood plain.

Computer Aided Drawing (CAD) programs have a tool called CURVE. After you invoke this tool and click along, the program draws in a curve that aligns with your individual points. Apparently, the "artist" for the maps was unfamiliar with the concept of CURVE. Note how the flood plain contours that should curve around the ends of a cul-de-sac are actually a series of straight lines!

Another observation is that at least two different people worked on the drawings. Miss Tiny Clicks would do tiny little click distances that weren't lined up very well, and then Mr. Straight Line would take over and go around the ends. But he didn't use the NEAREST POINT tool to start his lines so he didn't hook-up with Miss Tiny Click's line. Their offsets have been circled on the various drawings.

CAD programs also have a tool called FILL. You click within the boundaries of a shape and the shape will be filled with a color - in this case yellow. But the FILL command requires a shape that is totally enclosed. There can't be any gaps or the color will "leak out" and fill the whole drawing. It looks like there were gaps. So somebody went back and connected the end of Miss Tiny Click's line with the start of Mr. Straight Line's line which accounts for the five to ten-foot jags which are circled. My guess is that this was done after it was discovered that the yellow fill color was "leaking" out into the rest of the drawing because of gaps between the ends of Mr. Straight Line's and Miss Tiny Click's lines.

In the left-hand picture, observe the difference in the distance between the sea wall and flood plain on one side of the cul-de-sac compared to the other side. In reality, both sides are identical.

Another wonder to behold is how the flood plain went up through the homes that are adjacent to the east and west weirs on North Lake. It would be interesting to find out what the FEMA people were tracing over as a contour guide. Actually, it would probably be more interesting to find out what the FEMA people were smoking at the time.

This is the flood plain adjacent to the east weir. Note how the flood plain is near the lake at the bottom left - but by the time it rounds the corner, the water has flowed uphill and goes through houses.

And here's a photograph of that same area. Obviously the lawns' slopes are uniform and there is no reason for FEMA to have drawn the water's going uphill.

And here's the flood plain adjacent to the west weir. Again, the flood plain is near the lake at the right - but by the time it has moved down ten houses, it up into the homes.

And here's a photograph looking down the sea wall at the same area. Obviously FEMA doesn't know what they're doing.

Here's a part of North Lake that shows all three problems: The flood plain rounds the corner close to the sea wall, but by the time it gets to the third house, FEMA has the flood plain rising halfway up the yard. And the flood plain contour is straight and then takes a big jag which is followed by increments of 6.5 foot (2 meter) jags.

And here's a photograph of the same area that shows that FEMA doesn't have a clue.



I have recently come upon something most curious and somewhat disturbing! Dr. Su, who is responsible for the flood plain computer model, gave me a map of North Lake with the two-foot topographic contours and flood plain contour. He marked the 38' contour in blue. North Lake's flood elevation is 38.72'. I think he wanted to prove to me that FEMA's flood plain had been drawn between the 38' and 40' contours. Here is that map with my notations in red...

Since this is a two-foot contour map and since Dr. Su marked Contour 3 as 38', that means that Contour 2 is 36' and Contour 1 is 34'. But wait, North Lake has a normal height of 35.12'. And since the sea walls are about one foot high, more or less, one would expect the 36-foot contour to coincide with or be within inches of the lake edge Contour 1, because they would all line up vertically.

Here's a graphic to demonstrate the relationships:

When I discovered this, I wrote to Dr. Su:
"For North Lake you have three contours stepped up from the lake. On the maps that you gave me you made the third line up be blue and you noted that it was the 38-foot contour. Since these lines are from the two-foot data, that implies that the next line down will be 36 feet. And the bottom line appears to follow the sea walls or the edge of the lake. You consider the lake's normal height to be 35.12' Given that the sea walls are about a foot high - more or less, one would expect the 36-foot contour to coincide with or be within inches of the 35.12' contour. So whether that bottom line represents both the 35.12' lake edge and 36' sea wall edge or only the 36' sea wall edge directly above the 35.12' lake edge, that would make the second line up be 38' and the third line up be 40'.

"I suspect that the bottom line is actually a 36' contour in that you generally have the three contour lines evenly spaced as they run around the lake, which would indicate the same slope, i.e., 36', 38' and 40' - not 35.12', 36' and 38'. Since your model has set the flood elevation for North Lake at 38.72', it looks like the flood plain should be constrained between the second (38') and third lines (40') up, instead of between the third and fourth - which would make FEMA's flood plain off vertically by two feet. And if they got it wrong for North Lake (and Middle Lake also has the same mistake), I wonder if that applies to all of Sun City Center and perhaps to all of the County?"

And that's the scary part! I know for certain that they drew the flood plains two feet too high for North and Middle Lakes. Did they do that for all of Sun City Center? Did they do that for all of Hillsborough County?

To find out, I downloaded the contour maps from the County's website for the six official lakes in Sun City Center: Middle, North, Simmons, South, Swan and Wedgewood. All six lakes are surrounded by sea walls one foot or more in height. Part of the download data is the elevation of each contour. I already had the "Normal" and "Flood" elevations for these six lakes. (I've been trying to get the Normal and Flood elevations for all the bodies of water in Sun City Center and all of Hillsborough County for the better part of two months, but the County has been stonewalling.) Then I captured the map data and added what data I had in red.

I sent the following comments to Dr. Su accompanied by the six images...

I used your GIS contours and the Normal and BFE elevations that you gave me for the six official lakes in Sun City Center to draw the attached images. All six lakes have sea walls. Wedgwood has a combination of sea walls and a bank of a similar height.

As you can see, you got the elevations wrong, and thus the flood plain contours, for five of the six. The only one that you got right was Swan, assuming a conservative sea wall height of just one-foot. But for the rest, your GIS contours are off by 1.5 to 3.9 feet, which, of course, would affect the choice of contours used to constrain the flood plain or, in the case of Wedgewood, where within the constraining contours the flood plain contour was drawn.

Let me know if you disagree with my analysis.

I'm looking forward to getting the Junction Point maps and data from you (or their URLs) so that I can do other lakes in other parts of Hillsborough County to see if this sort of error is pervasive throughout the County.

Note in the following images how the actual "Normal" elevations of the lakes is always higher than the contours which enclosed the lakes. This is not good because it inflates the height of the flood plain contours and forces us to buy unnecessary flood insurance.

If I found this many errors within just a thousand of so feet of my home, the maps for all of Hillsborough County must surely contain many thousands, or even tens of thousands, of errors. They've been fixed for the Sun City Center/Kings Point area, but I wonder if FEMA fixed the maps for the rest of the county.
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Is The Accuracy Of The Flood Plain Contours Important?

Absolutely! Here are five of the many reasons for wanting the flood plain contours to be accurate.

First is that once the flood plain becomes official, you can build additions or structures in it, but you have to meet a number of additional requirements. The map will be put on the Hillsborough County Property Appraiser's site. If you go to get a Building Permit, the first thing the clerk will do is look up the map of your property to see if it's in the flood plain. If it is, be prepared for a lot of extra paperwork!

For example, here is the County's map of my property which is in red. The 1980 flood plain contour is in blue. The 1980 flood plain contour was even worse then the proposed one. Note how it goes from lake level (35 feet), up through my lot, across the road in front of my house (40 feet) and back down to the lake. If I wanted to put an addition on the north-east corner of my home, I would have to do a lot of extra paperwork. Once the flood plain contour is set, you are forever locked into having to abide by it - no matter how bad it is!

Second is that if you ever hire a $urveyor to survey your land, he will copy onto your survey exactly what the County has set as the flood plain contour. For example, neighbors who live around the corner had a mortgage and were required to pay about $800 a year for flood insurance. Here is the 1980 flood plain map for their property. Again, the 1980 map was really bad. See how the flood plain goes from lake level (35 feet) up to the road in front of their house (42 feet) and back down to the lake.

The $urveyor copied the flood plain contour precisely as it was on the County's map. The upper left oval contains the delineation between the "C Zone / A Zone." An "A Zone" for the house means you must buy flood insurance. The text in the lower-right oval says "The Property shown and described hereon appears to be in Zone A+C, with a base elevation of 42+N/A." The 42 is the elevation of the crown of the road that the goofy flood plain contour crossed! Once the flood plain contour is set, you are forever locked into having to abide by it - no matter how bad it is!

Third is that if you ever plan to file a Letter Of Map Amendment because the contour has been set and passes through your home, the burden of proof will be on you to prove that the map's flood plain contour is wrong. Once the flood plain contour is set, you are forever locked into having to abide by it - no matter how bad it is!

Fourth is that when you sell your home, you're going to get a much lower price for it if is in the flood plain. Once the flood plain contour is set, you are forever locked into having to abide by it - no matter how bad it is!

Fifth is that these contours set the mandatory evacuation areas. It will be a nightmare as 100,000 or more vehicles attempt to merge with those from the south onto Interstate 75. It is just as wrong to overstate the potential hazard as to understate it. Whereas the road system may be able to barely handle the traffic of those who truly need to evacuate, it is wrong to clog the interstate with those who don't. Needlessly forcing residents onto highways to run out of gas, food and medicine and forcing them to weather a hurricane in their cars isn't the brightest of plans. My guess is that the maps are as skewed for the rest of the County as for Sun City Center. Our County's Administrator, Commissioners and Emergency Planners need to recognize that it's the quality of the evacuation, not the size, that matters.

If the County is going to participate in FEMA's program, I believe it has an obligation to the citizenry to insure that the flood plain contours are drawn absolutely accurately for the whole County. This can only occur several years from now when the county-wide 1-foot contour mapping project is finally completed.
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Can I Build In The Flood Plain?

Yes, although there will be more paperwork and certain restrictions apply. For example, the mechanical work (electric box, hot water heater, A/C, etc.) has to be above the flood plain and a garage below the flood plain has to have a sump pump. Because the home is "vertically" in the flood plain, flood insurance is required.
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How Can The System Be Improved?

If the County thinks that the 100-year storm criteria is so important, they should fix the infrastructure to handle a 100-year storm. Since the county has failed to provide adequate drainage, they should impose a lower standard. And if you really think about it, flood plains are a frank admission on the part of the County that they haven't done a very good job over the years. And it provides an excuse to not do a very good job in the future. After all, why bother to improve an area's drainage if everybody there has mandated flood insurance?

Also, I object to the bureaucratic hoops that FEMA makes us jump through to get our home declared out of the flood plain. When they say "property owners are required to submit adequate supporting data", that means that we have to go out and hire a certified $urveyer who will draw a fancy map (for $400 to $700) with the Base Flood Elevation (BFE) contour line and our house slab showing that the water won't reach our home. Awwwwwg! You can tell that the money to pay the $urveyer isn't coming out of the pockets of the bureaucrats that wrote the rule!

One has to use the 19-page Form MT-1 package or the 11-page Form MT-EZ depending on the date of construction and whether the home was built on fill. There seems to be some confusion between what the forms say and what bureaucrats have told me as to which form to use. And I'm sure this will be one of the many topics at the meeting to be held in our Community Hall on December 12, 10am to noon, by Hillsborough County and FEMA.
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Implementing Legislation.

The implementing legislation for flood insurance is Title 44 of the Code Of Federal Regulations - specifically 44 CFR 59 to 78. The LOMA legislation is at 44 CFR 70.3(b).

There is also a document called the "Community's Floodplain Management Ordinance" which I haven't located yet.

The Florida law which gives you access to all of the Hillsborough County Hazard Mitigation Program, Planning and Growth Management Department's certified survey records of your property is the "Public Records Law," Chapter 119 of the Florida Statutes. This law provides that any records made or received by any public agency in the course of its official business are available for inspection.

Florida's Sunshine Law can be found in Chapter 286 of the Florida Statutes. It establishes a basic right of access to most meetings of boards, commissions and other governing bodies of state and local governmental agencies or authorities.

The federal statute which prohibits FEMA from releasing false flood plain data is Title 18 of the United States Code. The specific sections are 18 USC 1001(a)(1), 18 USC 1001(a)(2),18 USC 1001(a)(3) and 18 USC 1018.

Section 839.13 of the Florida Statutes is related to falsifying records - it's not allowed.

You can view all of Florida's Statutes, Laws and Constitution online at www.leg.state.fl.us

The County has put up a website about the Flood Plain implementation which you may find helpful to get the big picture. It is www.hillsboroughcounty.org/pgm/hazardmit/firm.cfm

The County's spatial information is available at www-gis.hillsboroughcounty.org
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FEMA - Arrogant And Incompetent!

I have a very poor opinion of FEMA. This opinion is based on how they have treated me and how they treated other Floridians (particularly senior citizens) after last year's hurricanes. Opinions do not belong on this particular page which is devoted to facts about the proposed Hillsborough County flood plain. However, I have created a separate page which details a few examples of just how arrogant and incompetent FEMA really is. Click here to access that page.
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This Site Is Always Under Construction!

If you know of something that should be added to this page or have any questions that weren't answered here, please give me a call at 634-6048 and I'll try to answer them or get the answer for you. If you're tempted to call just to find out if you're going to be in the flood plain, please wait until after December 1(?) and view your property on the County's website. If that doesn't work, after December 12, the maps will be in the Sun City Center Information Center where they can be viewed from 10am to 3pm, Monday through Friday - 642-2047.

And bear in mind that I'm just a messenger and that my only interest in this whole project is to make sure that Hillsborough County and FEMA get it right, this time. I neither advocate nor oppose mandated flood insurance. Actually, I do oppose the government's mandating anything. It is essential that we defy authority! But I do want the new maps to be absolutely correct on behalf of all Sun City Center/Kings Point residents - and maybe get FEMA to change their bureaucratic ways! That last thing will happen when pigs fly, if that soon!
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