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At the July 18, 2013 Sacramento Area Flood Control Agency (SAFCA) Board meeting, flood agency staff and its consultants provided a status update on the Sacramento and American River levee systems.

In the aftermath of Hurricane Katrina, the U.S. Army Corps of Engineers (USACE) has developed more stringent levee standards and since then has said two things:

1) The current 100-year storm event certification for the lower Sacramento and American River levees expired on August 31, 2013.

2) In order for the USACE to re-certify, the levees would have to meet new, more stringent standards. As a result, SAFCA has retained a team of registered civil engineering firms to explore the option of certifying the levees under FEMA standards. This may mean additional upgrades on specific levee sections.

Toward that end, SAFCA and its consultant team have initiated an effort to review and collect more data regarding the levees in order to develop a design plan for upgrading any deficient levee sections and undertake certification efforts under FEMA standards.

The information contained on this page explains what certification means and the status of SAFCA's efforts.


History of Levee Certification


Currently, the City and County of Sacramento participate in the National Flood Insurance Program (NFIP). The NFIP is administered by the Federal Emergency Management Agency (FEMA). Cities and counties are required to participate in the program as a condition of maintaining their eligibility for Federal disaster relief in the event of a flood. Participating communities must enforce the rules and regulations of the NFIP by adopting appropriate local ordinances. Property owners in such communities are eligible to obtain Federally-backed flood insurance. Moreover, banks and mortgage companies are required to make sure that if loans secured by the Federal government are made to a property within a special flood hazard area (100-year floodplain); the property owner receiving such a loan is required to carry flood insurance.

When the City and County of Sacramento joined the NFIP in the late 1970's, they were required to identify floodplains and determine if area levees would be considered strong enough to protect against the 100-year flood. Levees that met the criteria were considered "certified" and the areas protected by the levees were deemed to be out of the 100-year floodplain. Since most of the levees in the Sacramento area are Federal "project levees", the U.S. Army Corps of Engineers (USACE) was retained by FEMA to perform the requisite levee evaluations. USACE provided FEMA with a letter indicating which levee systems were certifiable and in 1978 FEMA produced the first set of floodplain maps for the community.

The NFIP has a distinct set of engineering criteria for determining whether a levee is strong enough to protect against the 100-year flood. Levees that meet these criteria are eligible for "certification" although this term is fading from use as it implies that a levee is guaranteed not to fail. Today, the trend is to use the term "accreditation". Levees can become eligible for accreditation in two ways. One way is for a Federal agency such as the USACE, U.S. Geological Survey, or the Bureau of Reclamation, to accredit the levee system. This process entails the Federal agency in charge of flood control providing a letter to FEMA (through the local community) that the levee system can withstand a 100-year flood event. SAFCA and its member agencies have used this method on several occasions to secure accreditation of the majority of our levee system. The other alternative for a levee to be accredited is for a licensed civil engineer to follow the guidelines set out in Title 44 of the Code of Federal Regulations (CFR) Section 65.10 (44 CFR 65.10). This method involves the submittal by a local entity of numerous technical reports stamped by a licensed engineer. This process can be quite expensive and time consuming. SAFCA and the County recently used this method of accreditation on the Mayew levee.

Past accreditations in the Sacramento area reflecting both methods may be summarized as follows:

  • In 1989, the levee systems in Sacramento were recognized as not providing a 100-year level of flood protection. This change in the mapping status was a result of FEMA, with help from the USACE, updating the maps in response to the record flood of 1986. This remapping put Natomas, North Sacramento, and Downtown Sacramento, areas along both banks of the American River, Land Park, Pocket and Meadowview in the 100-year floodplain. Affected property owners were required to carry flood insurance but special legislation enacted by Congress allowed new development in these areas to continue in accordance with locally adopted general plans.
  • In 1998, as a result of work done by the USACE through their Sacramento Urban Levee Program and SAFCA's North Area Local Project, USACE produced a letter indicating that the levee system protecting the Natomas Basin and the North Sacramento Area could withstand a 100-year event. SAFCA worked with the City and County of Sacramento along with Sutter County to map Natomas and the north area streams out of the 100-year floodplain.
  • In December of 2004, the USACE again produced a letter stating that the American River levee system (right and left bank) and the Sacramento River levee system from the confluence of the American River down past the Little Pocket area could withstand a 100-year event. This letter was written as a result of the accomplishments of the American River Common Features Project and a long term agreement that was reached on the operation of Folsom Dam. SAFCA took the lead in developing an accreditation package that was submitted through the City and County. This allowed FEMA to redraw the maps and in February 2005, over 60,000 properties were mapped out of the floodplain, which resulted in insurance relief.
  • In January 2007, the USACE produced another letter stating that the Sacramento River levees from Little Pocket down past the town of Freeport (Cliff's Marina) along with the Beach Lake Levee could withstand a 100-year event. Once again, SAFCA had the lead in developing the mapping data; the City has the lead submitting the needed information to FEMA and the maps were redrawn in this area in February of 2007, resulting in insurance relief for the Pocket and Meadowview areas
  • In June of 2010, FEMA recognized a SAFCA local accreditation effort for the Mayhew levee along the south bank of the American River that also included a County levee along the Mayhew Drain. A USACE letter was included in the application but it was not a typical USACE accreditation letter. It merely indicated that the Mayhew levee along the south bank of the American River was built according to plan and met the standards as per 44 CFR 65.10. SAFCA, with the use of a registered civil engineering consultant, developed an accreditation package that was subsequently accepted by FEMA.

It should be noted that the work of the engineering team is not totally complete. The team needs to finalize the criteria it will use to identify an unacceptable encroachment and a hazardous tree that must be addressed as part of the NFIP accreditation effort. In addition, the adequacy of the levees with respect to the State's 200-year Urban Levee Design standards remains to be determined. Nevertheless, in light of the team's findings to date, it is clear that corrective actions need to be taken.

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Current Status


When the Consolidated Capital Assessment District (CCAD) was formed in 2007, the levee system around the Natomas Basin was known to be losing its accreditation status. However, it was assumed that the remainder of the accreditations outside of Natomas would remain in full force and effect. Meanwhile, USACE was in the process of standardizing their levee accreditation efforts across the country. As part of this process, USACE discovered that methods used for levee accreditation varied greatly through the various districts. To bring consistency to the accreditation process, as well as to fully implement their Risk and Uncertainty procedures, USACE developed an Engineering Circular (EC) 1110-2-6067 that sets forth the procedure for a levee to meet USACE standards for accreditation. While some of the information in the EC has been around for a while, other elements are new and reflect the evolution of USACE policy on urban levee design.

Under the provisions of the EC, all previous USACE accreditations must be periodically renewed. In 2011 the City and County were notified of this change which affected all of the accreditations outside Natomas. In lieu of requesting USACE to undertake the required renewals using their new criteria, the City and County agreed that it would make sense for SAFCA to engage a civil design engineering team to reevaluate the affected levee systems using FEMA's 44 CFR65.10 Standards, which allow more engineering judgment than the USACE criteria. Accordingly, in February 2012, SAFCA retained a civil engineering team to determine whether the levees protecting Sacramento along the Lower American River and Sacramento River and their tributaries (outside the Natomas Basin) are adequate to meet established NFIP requirements for 100-year flood protection. A secondary objective was to determine whether the levees meet the State of California's Urban Levee Design Criteria for the 200-year flood.

SAFCA's engineering team has completed their evaluation with respect to the NFIP requirements with the following conclusions:

  • Embankment and foundation stability problems affecting up to 8 miles of the Sacramento River east levee, including the Pocket and Little Pocket area, need to be addressed to allow accreditation of this segment of the levee system;
  • Embankment and foundation stability problems affecting up to 3.7 miles of the levees along the north and south banks of Arcade Creek need to be addressed to allow accreditation of these levee segments in the North Sacramento area;
  • Accreditation of the Sacramento River East levee segment will require erosion repairs and monitoring at several sites totaling up to 2,500 feet in length;
  • Other issues affecting all of the levee segments outside Natomas to varying degrees need to be addressed to allow accreditation of these levee segments. These include unacceptable encroachments, which in some cases may be hazardous trees; and
  • Along the American River there are a few remaining gaps in the slurrywall that was constructed in the levee in the early 2000's. The USACA will close those gaps in the new few years.

It should be noted that the work of the engineering team is not totally complete. The team needs to finalize the criteria it will use to identify an unacceptable encroachment and a hazardous tree that must be addressed as part of the NFIP accreditation effort. Additionally, the adequacy of the levees with respect to the State's 200-year Urban Levee Design standard remains to be determined. Nevertheless, in light of the team's findings to date, it is clear that corrective actions need to be taken.

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Possible Future Actions


There are a couple of ways to approach the needed corrective actions. Currently, SAFCA and the State are working with USACE to complete a General Reevaluation Report (GRR) as part of the American River Common Features (ARCF) Project. The scope of the GRR covers the levee segments that have been identified as not meeting the NFIP's 100-year accreditation requirements.

A Draft GRR could be completed as early as December 2014. Following USACE Civil Works review, a Chief's Report could be transmitted to Congress sometime thereafter. Congress would then need to include the recommended improvements in the next Water Resources Development Act (WRDA) so that USACE could receive appropriations for project construction. However, this path to achieving levee certification raises three significant challenges:

  • The USACE planning process has been streamlined to complete studies within a three year time period for a total cost of $3.0 million. While the streamlined process will greatly benefit most communities, it is problematic for communities like Sacramento that are faced with complex legacy levee issues that cannot be satisfactorily addressed through a series of simple assumptions and solutions. For example, simply transposing the USACE vegetation, encroachment and landside access requirements onto the community's existing levee systems under the assumption that the details will be worked out later will likely lengthen rather than shorten the project review process due to the reaction this approach could generate among property owners and agencies responsible for the environmental protections;
  • While Congress has set a goal of passing a WRDA every other year, only two WRDA bills have been enacted in the last 13 years and;
  • Federal appropriations for the Sacramento Area have been in the range of $75 million per year over the past five years. With the Folsom Dam Joint Federal Project and Folsom Raise Project already authorized, the Natomas Project pending authorization, and the West Sacramento Project not far behind, it will take many years to complete the improvements covered by the GRR without a dramatic increase in the Federal dollars targeted to the Sacramento area.

As SAFCA's experience in Natomas has demonstrated, there are options within the USACE planning process that could address these challenges. These options require more proactive efforts by the non-Federal sponsors. In this instance, the starting point for the State and SAFCA would be to develop a Locally Preferred Plan (LPP) for the GRR that would focus on the actions needed to correct the deficiencies outlined above including the actions needed to meet minimum NFIP and State vegetation and encroachment standards. Depending on USACE's willingness to accept the LPP as the core of the federally recommended plan, it would be possible for the State and SAFCA to proceed with design and construction of the key improvements without waiting for Congressional authorization. As in Natomas, the Federal share of the cost of any such non-Federal sponsor expenditures would be creditable against the non-Federal share of the cost of later phases of the GRR. In effect, this approach would allow the State and SAFCA to apply their share of the total project cost to the first phase of the overall project, thereby expediting completion of the project elements that generate the greatest flood risk reduction and avoiding the most severe consequences of falling out of compliance with the NFIP.

Next Steps

SAFCA has retained design consultants to develop plans to address the deficiencies found in the levee evaluation effort. SAFCA anticipates having enough information pertaining to the type of improvements needed, estimated cost and schedule in order to make a recommendation to its Board in early 2014. The Board will then decide whether or not to proceed with "early implementation" work. This will be based in part on the financial feasibility of constructing improvements ahead of the USACE, absent Federal funding.

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Project Documents, Notices and Permits (chronologically listed by date)
 
2015.07.13

FINAL ENVIRONMENTAL IMPACT REPORT NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICAN RIVER, AND RELATED FLOOD IMPROVEMENT PROJECTS

MITIGATION MONITORING AND REPORTING PROGRAM FOR THE NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICAN RIVER, AND RELATED FLOOD IMPROVEMENTS PROJECT

FINDINGS OF FACTS AND STATEMENT OF OVERRIDING CONSIDERATIONS

NOTICE OF PUBLIC HEARING TO CONSIDER CERTIFICATION OF THE ABOVE-REFERENCED PROJECTS

2015.06.05

FINAL ENVIRONMENTAL IMPACT REPORT NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICAN RIVER, AND RELATED FLOOD IMPROVEMENT PROJECTS

MITIGATION MONITORING AND REPORTING PROGRAM FOR THE NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICAN RIVER, AND RELATED FLOOD IMPROVEMENTS PROJECT

NOTICE OF PUBLIC HEARING TO CONSIDER CERTIFICATION OF THE ABOVE-REFERENCED PROJECTS

2015.03.17

DRAFT ENVIRONMENTAL IMPACT REPORT NORTH AREA STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICIAN RIVER, AND RELATED FLOOD IMPROVEMENTS PROJECT

PUBLIC MEETING EXHIBITS: Click on each link below for expanded view of graphics

Exhibit 1: General   Exhibit :
Sac River
  Exhibit 3:
North Sac
  Exhibit 4: High-Hazard
Vegetation & Encroachments

Exhibit 1 pic         Exhibit 2 link        Exhibit 3 link          Exhibit 4 link

2014.05.15

NOTICE OF PREPARATION OF A COMBINED PROGRAM ENVIRONMENTAL IMPACT REPORT AND PROJECT ENVIRONMENTAL IMPACT REPORT FOR THE NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, LOWER AMERICAN RIVER AND RELATED FLOOD IMPROVEMENTS PROJECT AND NOTICE OF PUBLIC SCOPING MEETING AT SACRAMENTO COUNTY BOARD OF SUPERVISORS

2014.05.15

Public Notice Posted in the Sacramento Bee

NOTICE OF PREPARATION (NOP) OF AN ENVIRONMENTAL IMPACT REPORT FOR THE NORTH SACRAMENTO STREAMS, SACRAMENTO RIVER EAST LEVEE, AND RELATED FLOOD IMPROVEMENTS PROJECT & ANNOUNCEMENT OF PUBLIC SCOPING MEETING

   
   

Levee Certification Timeline Graphic

      
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