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Rick Griffin,Project Manager Page 2 August 6, 2019 An example would be where there is such a unique physical condition of the site that no other alternatives are possible. For example, a residential structure on a narrow lot with a setback requirement,where the structure must have an elevated lowest floor: in such a situation a variance may be issued to provide relief from the required elevation. However,the relief provided must be the minimum necessary(my emphasis)to provide relief and an elevated floor is still required. Variances may be issued for new construction and substantial improvements to be erected on a lot of one-half acre or less in size, in conformance with the conditions and technical findings that are outlined in your county's flood damage prevention ordinance(San Joaquin County Code 9- 484). As the lot size increases the rationale for the variance decreases and the requirements and justification for the variance become more restrictive. In this request,the structure is not residential,therefore elevation is not the only method of flood damage avoidance; structures can also be floodproofed. Additionally, the property is zoned AG- 80, with lot sizes of 80-acre minimum. Economic considerations are not a hardship. It would be difficult to argue that a variance for this application, without adhering to the minimum NFIP design criteria would be a prudent and safe way for development on the site. San Joaquin County participates in the Community Rating System(CRS)and is currently a Class 7 community. San Joaquin County residents enjoy a 15%discount on their flood insurance premiums precisely because the County has adopted building requirements and floodplain management practices which are more restrictive than the minimum federal standards. Entertaining this variance request runs counter to the nature,reason,and administration of the NFIP in general and the CRS program in particular. Therefore,this office's review and comment on variance application PA-1900158 (FVR) is that it should not be approved and the project should comply with the County's Flood Hazard ordinance. Please review the current effective Flood Insurance Rate Maps (F1RMs)for the County of San Joaquin (Community Number 060299), Maps revised October 20, 2016. A partial summary of NFIP floodplain management building requirements are as follows: As previously addressed in this letter, San Joaquin County has more restrictive standards than the minimum NFIP requirements. Elevation standards for lowest floor may be more restrictive. • All buildings constructed within a riverine floodplain, (i.e.,Flood Zones A, A0,AH,AE, and Al through A30 as delineated on the FIRM),must be elevated so that the lowest floor is at or above the Base Flood Elevation level in accordance with the effective Flood Insurance Rate Map. ww%vlema.gov