Figure 2 shows the man-made levees totaling over 41 miles creating Natomas Basin. Some 20.6 miles of canals plus another 20.6 miles of the Sacramento and American Rivers encircle the Basin. Water marks its boundaries. The north boundary is the Natomas Cross Canal. The east boundary is made of the Pleasant Grove Creek Canal and the Natomas East Main Drainage Canal. The south boundary is made of the Sacramento River and American River joining south of Natomas. The west boundary is the Sacramento River.

To give the reader an understanding of what Natomas Basin looks like, Figure 3 is an aerial photograph of the area. The expansive agricultural and vacant land in the large northern portion can be contrasted with small urbanized development in the southeastern corner between Interstate 80 and the American River.

DEVELOPMENT IN NATOMAS BASIN

Created by constructing drainage canals and 41 miles of encircling levees, Natomas Basin was considered "protected" from the 100-year flood. Like elsewhere in America, urban development was proposed to replace farming in Sacramento's floodplain. When officials of Sacramento City and Sacramento County decided to approve urban development, it made sense at the time as Natomas Basin is flat land and a 15 to 30 minute drive to downtown Sacramento. Since the level of flood protection met the minimum Federal standards set by the Federal Emergency Management Agency (FEMA) under the National Flood Insurance Program (NFIP), urban development proceeded. By 1990 over 31,000 people called this area home. Over 13,730 homes, businesses, industries, and public buildings were built over 7,260 acres in Natomas Basin. These buildings and their contents have an estimated value exceeding $2.351 billion.5

In February 1986 a major Pacific Ocean storm brought record breaking rainfall to Northern California causing the Sacramento and American Rivers to reach new record high flows. The Natomas Basin levees held, but weaknesses were found. FEMA contracted with the Corps of Engineers to evaluate the Sacramento area flood control system. With new record river flows plus new FEMA safety standards for levees, Natomas Basin levees were downrated from 100-year flood protection to ranges of 40-year to 70-year protection.

Without going into the details, urban development stopped in Natomas Basin after the 1986 storm because the FEMA 100-year flood control standard was no longer met. Without 100-year flood control, FEMA would allow development to continue only if the first habitable floor is built one foot above the height of the 100year flood elevation. Because of the potential high flood depths of 8 to 23 feet in Natomas Basin, it was impractical and uneconomical for residential buildings to meet the one foot standard. Residential development stopped.

Projects supported by the Federal, California, and local governments have worked to strengthen the Sacramento River levees. Projects to strengthen other levees around Natomas Basin are progressing. Once the minimum FEMA 100-year flood control standard is restored or exceeded, urban development can continue on the 47,622 acres (75 square miles) of vacant and agricultural land in Natomas Basin. ACCOUNTABILITY FOR DEVELOPMENT CONSEQUENCES

Who will be held accountable for the consequences of further urban development in Natomas Basin? Who is responsible for promoting such urban development? Who is responsible for declaring Natomas Basin safe for development? In the minds of land speculators, developers, and the local government officials of Sacramento City, Sacramento County, and Sutter County, further urban development is the "Manifest Destiny" for Natomas Basin.

After 100-year flood protection is restored to Natomas Basin, FEMA will give its "seal of approval" and the requirement to build the first floor above the 100-year flood elevation will be removed. Development can continue. To local promoters and decision-makers, this means the flood risk has been determined by FEMA to be acceptable to the Federal Government. FEMA's acceptance allows the flood risk caused by approving further development to be shifted from land speculators, developers, and local government taxpayers to Federal taxpayers. The land speculators and developers make their $5 to $10 billion of profits and leave the disaster cleanup bills for others to pay. This is wrong. The consequences of local land use decisions should stay with those promoting and making the decisions.

The accountability for land use decisions promoted by land speculators and developers and approved by local government officials is lost because the consequences

"Corps Feasibility Report, Appendix C, Table III-3 on page C-14, Table III-5 on page C-18, Table III-6 on page C-19, and page C-29. Figures are existing conditions as defined on each table.

are shifted to the Federal Government. Accountability for decisions will only occur when institutions and individuals making decisions are held accountable for the resulting consequences. Without such ultimate accountability for their actions, land speculators and developers will pressure and encourage local government officials to allow further development in Natomas Basin. Continuing to shift the accountability for development consequences to the Federal Government, and ultimately Federal taxpayers, is bad public policy.

How can the accountability for local land use decisions be left with the decisionmakers? The answer is found in the Coastal Barrier Resources Act (COBRA) enacted in 1982. COBRA prohibits new development in designated coastal barrier areas from receiving flood insurance and other Federal financial assistance. By removing the Federal encouragement to development (i.e., flood insurance and other Federal financial assistance), land speculators, developers, and local government officials are held totally accountable for the consequences of their land use decisions. Development is still allowed in the floodplain, but the Federal Government does not provide financial assistance nor does it provide flood insurance. All the risks and profits remain with those land speculators, developers, and local government officials who are willing to invest their money in floodplain development. The buck stops at the local level, where it belongs.

INCREASING THE RISK TO PUBLIC HEALTH AND SAFETY

Let's explore the possible consequences from further urban development in Natomas Basin. In the Corps of Engineers report on Sacramento flood hazards, the Corps identified THE flaw in all the flood control alternatives examined for protecting Sacramento: All flood control alternatives increase the risk to public health and safety. Why? Because the number of people and buildings exposed to flooding will increase due to urban development in floodplains. The Corps states:

"Finally, under existing local and Federal floodplain management regulations, all of the alternatives carried forward in this report would provide a sufficient level of protection to permit development to proceed in Natomas and elsewhere in the floodplain. This development would significantly increase the number of people and the amount of property exposed to flooding and would increase the losses produced by an uncontrolled event."7

The most disturbing results from Natomas Basin flooding are the potential for significant loss of life, the massive disruption of peoples' lives, and the massive destruction of buildings and their contents. Over 31,000 people call this area home.

"8

"Loss of life could be significant depending on the warning time given to residents to evacuate the basin. Advance warning would be essential because the breach would be proximately located to the urbanized portion of the basin. Floodwaters would thus reach vital transportation corridors relatively quickly, and eventually render the affected freeway and local roadway segments impassable." Proposed urban development plans by local governments would add over 170,000 people and over $13 billion of new buildings and their contents in Natomas Basin. The total population would exceed 200,000 and property value exceed $15 billion. Where do 200,000 people who lived in 93,000 homes find housing during and after the flood? What magnitude of human and economic disaster will befall the Sacramento area when a flood inundates a fully urbanized Natomas Basin? To answer this question let's compare the Great Flood of 1993 to a future flood in Natomas Basin with 200,000 people and over $15 billion worth of structures and contents. Table A shows the comparison:

"Federal Emergency Management Agency, Mandatory Purchase of Flood Insurance Guidelines, FEMA 186, Effective on July 13, 1989, page 24.

Corps Feasibility Report, EIS/EIR, page EIS 1-8.

Sacramento Area Flood Control Agency, Revised Draft Environmental Impact Report for the Revised Natomas Area Flood Control Improvement Project, (Sacramento, Mar. 1993), page 5.3

1.

Table A

Comparison of Great Flood of 1993 to Future Flood of Urbanized Natomas Basin9

The comparison is striking. In the Midwest the flood damage and destruction is spread over 31,250 square miles beside rivers stretching hundreds of miles. In Natomas Basin the destruction is concentrated in 86 square miles. It is ironic to compare the Midwest flood damage to that of a fully developed Natomas Basin. Crop damage is half of the Midwest damages because flooding occurred during the growing and planting season. Property damage is the entire source of damages in Natomas Basin.

The estimated property and crop damage, as of August 6, produced by the Great Flood is $12 to $15 billion spread over 31,250 square miles compared to an estimated $8 to $10 billion of property damage over just 86 square miles in Natomas Basin. Twice as many homes would be damaged in Natomas Basin (93,000) compared to the Midwest (45,000 as of August 6). Why would we knowingly create a potential catastrophe of this magnitude?

SEVERITY OF FLOOD DAMAGE

Why does flooding in Natomas Basin cause so much destruction? The answer is found in its physical features:

1. During flood events, river levels are higher than the ground level inside the Basin.

2. Rivers or canals surround the Basin on all sides.

3. Levees surround Natomas Basin on all sides.

4. Levees are 15 to 20 feet higher than the inside land area.

5. Natomas Basin has no drain.

6. Low lying lands inside the Basin are lower than surrounding land.

7. Flood waters fill the Basin whenever levees fail.

Together these physical features make Natomas Basin a disaster waiting to happen. Whenever a levee breaks, flood water could fill the Basin. Why? Natomas Basin is a 55,000-acre bathtub and swimming pool combined, but it has no drain! The 15 to 20 feet high levees form the "bathtub" walls. The land inside is the "bathtub" bottom, but the bottom is not flat. The bottom is like a swimming pool with the deep end located in the middle. From the deep center the pool gets shallower as one moves toward the levees.

In Figure 4 the land area shown as white (over 23 feet) is the lowest part of Natomas Basin. The next lowest land elevation is the land area marked 18 to 23 feet. Once flood waters get inside, it cannot get out until the river level goes down allowing some water to drain out the break in the levee. In these two low lying areas, water will remain until pumped out or it evaporates. These two areas are 5 to 10 feet lower than the land around them and would form a 17,700 acre (27.6 square mile) pond. It would cover 32 percent of the land area.

Figure 4 shows the land area covered by the estimated potential flood depths for Natomas Basin. The flood depths are based upon a flood elevation of 33 feet derived from the Flood Insurance Study and Flood Insurance Rate Map (FIRM) issued by the Federal Emergency Management Agency (FEMA) in March 1993. Figure 5 shows the estimated flood depths, the number of acres and square miles by flood depth, and the percentage of land area covered by flood depth.

See Appendix B for sources.