County of Sacramento California*

SAFCA has proposed increasing protection for the entire Sacramento flood risk area. Its goal is 100-year protection by 2008 and 200-year protection by 2021. Even though these levels of protection are less than what has been achieved at similar flood prone areas in the nation, they seem reasonable and achievable for Sacramento. SAFCA Response to Finding #1: Concur SAFCA concurs with Finding # 1, while noting that with our current understanding, we recognize that the Natomas Basin is likely to lose its 100-year certification through a FEMA map revision in 2008. An important part of SAFCA's work program is to expedite the work required to restore that 100-year certification by 2010, while making the improvements needed to achieve 200-year flood protection by 2012. SAFCA staff concurs that its goals are reasonable and achievable for Sacramento. Sacramento County MSA & ED Response to Finding #1: Concur

Both the City of Sacramento and the County of Sacramento are allowing building to continue in areas that do not have 100-year flood protection. This is especially true in North Natomas that was found to have less than 100-year protection in 2006. Potential flood depths of greater than 15 feet in that area place immense risk to both lives and property. Sacramento County MSA & ED Response to Finding #2: Concur in Principle The Natomas basin is a deep floodplain by virtue of the surrounding levees and is currently vulnerable to potential flood damage and loss of life. In 1986, the United States Army Corps of Engineers (the Corps) evaluated the Sacramento flood control system and determined the system inadequate to meet the minimum 100-year level of flood protection required by the National Flood Insurance Program managed by the Federal Emergency Management Agency (FEMA). The Corps estimated that flood depths likely to result from a 100-year flood would range from two feet to in excess of fifteen feet in the Natomas basin. In 1989, FEMA created a special A99 flood zone for this area to designate that the area was dependent on levees that were under construction but which did not yet meet the 100-year standard. Flood zones are defined by FEMA and describe land area in terms of its risk of flooding. These zones are depicted on a community's Flood Hazard Boundary Map or a Flood Insurance Rate Map. Each zone reflects anticipated severity of flooding in the area, and generally includes regulations concerning building in the zone. In February 1990, the City and County adopted building restrictions in Natomas that imposed a de facto moratorium on residential development and imposed conditions that all non-residential building permits must meet certain criteria to minimize risks due to flood. The Congress passed legislation in 1992 directing FEMA to create a new "AR" flood zone designation applicable to communities such as Sacramento. The rationale was that a previously certified 100-year flood protection system had been decertified due to updated hydrologic data. FEMA was prohibited from requiring elevation of improvements to existing structures. In 1998, the Corps certified that levee work in the North Natomas area had raised the flood protection level to the 100-year standard. While the residential moratorium was lifted in the City, the County adopted General Plan policy in 1996 that requires 200-year protection be provided if residential development is to be allowed in floodplain areas reclaimed by levee construction. As a result of the high water event in 2005 which exposed some levee weakness, and in view of Hurricane Katrina, The Sacramento Area Flood Control Agency (SAFCA) requested that the North Natomas flood control system be re-evaluated. Based on this evaluation, and the new application of a levee design standard, the Corps found that it 6 could no longer stand behind its prior certification of the Natomas levees. As a result FEMA has indicated that the area will be re-mapped to reflect the newly identified risk.