committee pains of S. 1405 does attempt to alleviate some of the impact by imposing a cap on premium increases of 10% peryear. However, the use of simple compound interest shows that it will not take long for the impact of these rates to be felt on the average American in a coastal or riverine community.

As a result of this additional information, the NATIONAL ASSOCIATION OF REALTORS® no longer fock that it can support S. 1405 without significant changes to the bill We support amendments which would postpone the mapping and/or the implementation of erosion bazard zones until an economic impact statement is prepared. We feel that before the federal government spends $25 million of policyholder premiums on mapping, that we should know the answers to some basic questions such as how many properties will be affected by this bill and what the impact of crosion zones will be on property values, community tax revenues, employment, cconomic development and future premiums for existing structures.

As you know, the passage of flood insuranos legislation has been tied up for a number of years because of misunderstanding and misinformation on this issue. In good faith, the NATIONAL ASSOCIATION OF REALTORS® sought to help break the stalemate on this bill, by our prior endorsement. We no longer feel that we can support S. 1405 without some sort of assurance that this bill will not devastate the economies of coastal and, eventually, riverine communities. Once, and for all, let us remove the confusion that surrounds this issue, and get some clear, unequivocal data, before we act. We urge your support for the amendments to the erosion sections of the bill which call for the suspension of mapping, and/or the implementation of erosion hazards zones, until the completion of an economic impact study.

Attachment

feal
Stephen D. Drickar

Scalor Vice President and Chief Lobbyist

you are considering buying waterfront property or building there you should know the hazards! fore purchase or construction you should ask these questions:

FIGURE 6-1

Example of the variation of the rate of erosion as a function of

the duration of the period of observation, 1920 to 1940.

In furtherance to our conversation this date I am pleased to support the efforts in opposition to this Bill.

I am a Professional Engineer, licensed in nine coastal states on both coasts. I have lived and worked near the coast all of my life (50 years), and have been professionally involved in Marine and Coastal construction and restoration projects for the past twenty years. This has included the entire East Coast from Northern Maine to the Caribbean, and the West Coast From Neah Bay, Washington to Central California. This has included coastal protection, as well as beach nourishment and coastal construction projects.

I have reviewed your comments on this program's proposed methodology for
determining and measuring coastal erosion areas. As I understand it, the proposed
methodology for making these determination will be based on a generic formula which
relates to the elevation of the shoreline, and so-called historic data, and is based on survey
data dating back to the turn of the century. What I have seen of this plan appears seriously
flawed from a realistic viewpoint, since it fails to take into account the physical
characteristics of individual shorelines. Typically these programs also attempt to apply the
same formulae to all areas, regardless of location, and assume the same conditions apply
from the outer banks of Cape Hatteras to the Rocky Coast of Northern Maine. Proper
studies of coastal geology should include soils data, the offshore topography, the realistic
wave and shoreline drift climate, proper physical earth models as well as accurate historic
data. It appears that the proposed bill plans very little of this in its studies.

This is evident from the proposed budget to perform the studies, which I am told is
in the range of $25,000,000 to analyze 84,000 miles of shoreline, that little, if any, actual
field investigation or detailed analysis is intended. In the past FEMA has evaluated coastal
conditions using typical shoreline cross sections (Transects) that range from 1000' to 3000'
apart. Based on my experience evaluating these flood maps on a detailed basis, this results
in a rate of error in determining actual coastal flood conditions on a site specific basis, in
the range of 20 to 40%. Some of these errors are quite significant. Assuming that an
erosion study would also follow these guidelines, and that the average transect spacing
would be 2000 feet, this would require 222,000 transects that have been budgeted at
$112.00 each to perform. Assuming, hat these studies would be handled on a contract

Civil/Structural/Marine Engineering 811 Airport Road • Monterey, CA 93940 (408) 649-1712 FAX (408) 649-1772

Doris Crary,

Page 2

Re: Senate Bill 1405

Establishment of Erosion Flood Zones

November 4, 1993

consultant basis (as they have in the past), at an average rate of $65.00 per hour, this means that 1.75 manhours would be spent evaluating cach transcct condition. Based on my experience, the time required to properly, and accurately evaluate shoreline erosion potential characteristics would be about 10 to 30 times the cost budgeted.

It appears that if this program intends to stay within budget, only a very crude study will be performed, that will result in a rate or erosion map that will be largely unreliable, inaccurate, unfair, and would be continually challenged. Such an inaccurate study would prove nothing, and would be a complete waste of taxpayer money.

We also spoke of the maps that Coastal Zone Management has published, that purport to be an accurate representation of the coastal erosion process, dating back to the turn of the century. I have been involved in coastal surveys and mapping as it related to my work for over 20 years, in that time I have found most of the coastal data predating 1945 to be highly unreliable. In fact much of the available data between 1945 and 1965 has also proven only marginally usable, except in cases of substantial shoreline movement. My opinion is that any data that predates the 1927 Geodetic Survey is purely unsubstantiated conjecture.

I hope I can be of some help in your opposition to, what appears to be, yet another unfair tax on people that happen to like living near the water.

Very truly yours,

A

John A. DeRugeris, P.E.
President,

Coast Line Engineering Inc.