Campgrounds & Mobile Homes in Flood Zones Letter 1985

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TO: District Directors - September 9, 1985 2. This question actually addresses two distinct parts; one dealing with the placement of the units and the other addressing the development of the facility. While the code is silent on campgrounds in the floodfringe, we believe that their use in the floodfringe is more restrictive than the use in the floodway allowed by the code, and thus could be approvable if such ordinance provisions were developed. Therefore, it is our contention that campgrounds uses allowed in NR 116.13(2)(c) are permissible in either a floodway or floodfringe providing they are capable of meeting the development criteria established in s. NR 116.13(2)(c), without having to meet the fill standard in s. NR 116.14(2). Where it is not possible to meet the criteria in s. NR 116.13(2)(c) the residential development standards in s. NR 116.14(2) must be adhered to. NOTE: The Code should be changed at the next opportunity to reflect this interpretation. 2. Is it necessary to place fill in mobile home parks 1 foot above regional flood? This question was included within this PMMS response as a result of-a—recent decision rendered in Shiocton concerning a proposed mobile home park. ) NR 116 requires that all new residential development in the floodfringe areas must be placed on fill and have dryland access before development can occur. The question is whether it is necessary to place the pads on fill so that they are 1 foot above the regional flood elevation. The major goal in the rule is to protect the structure from flooding by requiring the first floor of the mobile home to be elevated 2 feet above regional flood. The requirement to place fill 1 ft. above the regional flood elevation becomes superfluous since that fill is not needed to protect the pad from infiltration, uplift or hydrostatic forces of flood waters as it is with a basement or building foundation. Under the Code, crawl spaces and basements of homes can be built at the regional flood elevation providing the dwelling's first floor is elevated to the flood protection elevation. For all of these reasons we believe we would not be in a position to enforce the one foot of fill requirement if the slab is at or above regional flood, dryland access is available and the first floor is at or above the flood protection elevation. They must also meet the FEMA tie down requirement and it would be necessary that all utilities are placed above or floodproofed to the flood protection elevation. Under these conditions, the primary criteria for protecting the structure has been met. NOTE: Mobile Home Parks are considered a "unit" according to an Attorney General ' s opinion and thus, we can only require full compliance with codes where the park is new, or where improvements are greater than 50% of the value of the unit." (Emphasis added. )