Three technical issues impacted the benefit/cost ratio for the project:
• The area protected by the project;
• The effective life of the project; and,
• Amount of historical road damage in the area.
Upon the request for reconsideration, FEMA decision was made to to assume the following regarding the above technical issues:
• The area protected by the project is 5,100 acres;
• The effective life of the project is 10 years; and
• Historical road damage data is representative of losses that could be expected in the area protected by the project and these data, on a per acre basis, will be used to estimate expected benefits from the project.
The resulting benefit/cost ratio under these assumptions resulted in a beneficial ratio of 1.2. Assumptions on conservative side, not using these assumptions, had resulted in the benefit/cost ratio of 0.5. Based on the additional analyses and the 1.2 benefit/cost ratio, FEMA approved the proposed mitigation project under the following provisions:
1. The approval is provided based on the assumption that the applicant will assume all responsibility of repair and maintenance of the structure, even in the event of a major flood on the Elkhorn River.
2. The original project required that FEMA perform an Environmental Assessment (EA) to be in compliance with the National Environmental Policy Act (NEPA). The EA resulted in a Finding of No Significant Impact (FONSI) from the project. The project design has been modified to include jetties that extend into the Elkhorn River. This modification to the original design will require that FEMA prepare an addendum to the EA to be compliant with NEPA and to address any possible impacts associated with the revised design. The approval of this project is subject to the addendum to the EA still resulting in a FONSI for the project. I do not envision this to be a problem and I assure you that FEM.A will complete this environmental evaluation in a timely manner to ensure that the construction of the project is not unnecessarily delayed.
3. Applicant must notify the public that the structure provides very limited protection against frequent but very low flow flood events and that applicant ensure stringent enforcement of floodplain management.