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HomeMy WebLinkAboutAgenda - 12-11-2007-6dORANGE COUNTY BOARD OF COMMISSIONERS INFORMATION ITEM ABSTRACT Meeting Date: December 11, 2007 Action Agenda Item No. ( - C SUBJECT: Report on the Consultant Services to Determine Topographic Elevation Data and Authorization to Proceed with a FEMA Grant Application DEPARTMENT: Planning and Inspections PUBLIC HEARING: (YIN) No ATTACHMENTS: Attachment 1 -Floodplain Management for the National Floodplain Insurance Program and Community Rating System Attachment 2 -Report of the Governmental Service Center Annex Elevation Certificate Attachment 3 -Outreach Fact Sheet Attachment 4 -Pre/Post FIRM Table INFORMATION CONTACT: Craig Benedict, 245 2592 Glenn Bowles, Certified Floodplain Manager, 245 2577 Pam Jones, 245 2650 PURPOSE: To review the results of the land surveying for the floodplain elevation certificates surveying project and to consider authorizing staff to proceed with a FEMA Hazard Mitigation Grant Program. BACKGROUND: On September 15, 2005, a letter was received from the Federal Emergency Management Agency (FEMA), outlining why Orange County could not receive approval to participate in the Community Rating System (CRS). CRS is a voluntary program for local government to encourage, enact, and enforce floodplain regulations. The CRS recognizes and encourages community floodplain management activities that exceed the minimum National Flood Insurance Plan (NFIP) requirements. As a result, flood insurance premium rates can be discounted to reflect the reduced flood risk resulting from the community actions meeting the three goals of the CRS: (1) reduce flood losses; (2) facilitate accurate insurance rating; and (3) promote the awareness of flood insurance. If the County can document floodplain elevations and the appropriate adjacent grade and first floor elevations for a good portion of the estimated number of residences and accessory buildings found in flood-prone areas, it may be eligible to participate and gain the benefit from the CRS program. With the BOCC acceptance of the new floodplain maps on January 23, 2007, which became effective on February 2, 2007, there are now some 76 residences and accessory buildings in flood-prone areas and 39 of those are due to the new mapping. The table in Attachment 4 (Pre- FIRM /Post-FIRM Conditions) summarizes impacts of the recently adopted new floodplain mapping program. Greenhorne & O'Mara, Inc. of Raleigh, the selected land surveyors for the program, submitted a bid of $26,660, based on 86 completed surveys. Staff could only get written or verbal permission to enter private properties for 78 surveys, including the Government Services Center Annex in Hillsborough. Forty-six structures, which were once within mapped floodplains, are now confirmed to be outside the floodplain. Four of the surveys indicated that the structure(s) is physically outside of the base flood elevation (BFE) elevation contour and will require a Letter of Map Amendment (COMA), which is an application for a single residential lot or structure amendment to the National Flood Insurance Program maps. Staff has prepared the documentation and the surveyor has signed and sealed the forms. From personal conversations with the participating residents, at least three owners were paying flood insurance premiums and now will not have to continue in the insurance program. Another situation the program revealed was that a request for "map maintenance" from the State Floodplain Mapping program is warranted. A recent improvement to a stream culvert under Brandywine Road in the Heritage Hills Subdivision may not have been taken into account when the new mapping was complete. To re-petition to become eligible for the CRS program, FEMA has requested that the County survey a significant number of structures formerly in a mapped floodplain. The County has attempted to comply with this request and will provide elevation certificates for all but one structure in newly mapped floodplain areas and for over forty structures built after 1981, which were erroneously placed within mapped floodplains. Such certificates can only be completed through collaboration between a professional, licensed Land Surveyor and the Orange County Certified Floodplain Manager (CFM). Just recently, staff received an invitation to apply for FEMA hazard mitigation grants. The timing for the grant request coincides perfectly with the completion of the elevation certificate survey work. Staff now has the technical documentation to prepare, with BOCC approval, a grant request to assist owners of flood-prone structures to retrofit and improve the structures to comply with the Flood Damage Prevention Ordinance. Most retrofitting would involve installing hydrostatic vents in the crawl space walls, elevating central air units, and/or moving or deconstructing accessory buildings. The grant could also be used to make improvements to the Government Services Building Annex on Cameron Street. FINANCIAL IMPACT: The consultant has been paid just over $17,000, of the $26,660 budgeted for the program. The work, as contracted, is essentially complete, and the County is awaiting the final invoice. Seventy-nine (79) elevation certificates are complete. There will be approximately $2,110 unencumbered from the awarded contract. It is initially estimated that approximately $40,000 total is needed to address all situations in Orange County. The FEMA Hazard Mitigation Grant Program requires atwenty-five (25%) percent local match. A portion of the local match could be re-allocated from the unencumbered elevation certificate program funds. RECOMMENDATION: The Manager recommends that the Board receive the report and direct staff to pursue the FEMA Hazard Mitigation Grant and finalize all documentation prior to the January 11, 2008 FEMA a-Grant deadline for the Manager's signature. Attachment 1 Floodplain Management for the National Floodplain Insurance Program and the Community Rating System Orange County has developed a series of regulations to prevent building activity in its flood- prone areas, as well as to preserve the environmental attributes. Even though Orange County has been a leader in floodplain management through its work in planning, erosion and sedimentation control, Lands Legacy, and building inspection divisions, the County has not availed itself of federal programs that would financially recognize efforts through insurance rate rebates and other grant opportunities. Providing elevation certificates would allow the County to proceed into the qualifying phase of the Community Rating System (CRS) program. The County's interest in the proper management of floodplain areas has fostered an interest in the Federal Emergency Management Administration's (FEMA) CRS through the National Flood Insurance Program (NFIP), which provides federally flood insurance backing to private property owners. Benefits that communities can expect from participation in the CRS program may include the following: 1. Reduced privately held flood insurance premiums, 2. Enhanced public safety, 3. Reduction in damage to property and public infrastructure, 4. Avoidance of economic disruption and human suffering, 5. More comprehensive environmental protection, 6. Orange County can evaluate the effectiveness of its flood program against national benchmarks, 7. Added incentive to maintain other watershed protections, 8. Enhanced quality of life, and 9. Qualification for certain federal assistance programs. On December 14, 2004, letters, under the County Manager's signature, were sent to the Region IV FEMA Community Mitigation Program and to the North Carolina Division of Emergency Management, Floodplain Management Branch to, "Initiate the formal process to participate in the NFIP's CRS." In response to our initiative, FEMA responded with a letter to confirm a Community Assistance Visit (CAV) during the week of February 21, 2005. Our last CAV was on June 21, 1995. Orange County joined the National Flood Insurance Program in 1975, and entered the regular program in 1981 when it enacted the original flood damage prevention ordinance. The ordinance was first amended in 1995 and again in 2005. The County adopted its original soil erosion and sedimentation control standards in 1975 and its Neuse River Basin storm water regulations in 2001 and stream buffer use restrictions in 1994. In short, Orange County has a long, documented history of comprehensive land development regulations focused on our water resources and stream corridors. The CRS documents past and present county regulatory history and would elevate our efforts to a higher level or compliance and awareness. A summary of the February 2004 CAV recommendations include the following items: 4 1. Orange County should adopt the revised flood damage prevention ordinance. (The State of North Carolina has drafted a model ordinance, which would re-enact and continue the existing law. (The BOCC adopted a new Flood Damage Prevention Ordinance in October 2005 and adopted the new FIRMS, effective February 2, 2007 on January 23, 2007.) 2. Within the basic flood zone, county zoning and building inspectors should require base flood elevation (BFE) and lowest floor elevation (~FE) data for each new structure and repair and expansion of existing buildings, and require a surveyed plot plan to establish building improvement locations and elevations, if floodplains are involved, and 3. Develop specific administrative procedures to deal directly with substantial damage to flood-prone structures and to complement the existing procedures described in the flood damage prevention ordinance. (Staff has adapted administrative guidelines from the revised ordinance.) Over the years, county planners have been reasonably successful in discouraging new development within mapped floodplain areas. Portions of 3,545 Orange County parcels contain some floodplain areas. Around 135 parcels now contain or have contained some 180 residences or accessory buildings. The new FIRM contains just 33 residences and 38 accessory buildings. Just four of those accessory building and no residences have been built within the effective floodplain area since the original effective date of the Flood Damage Prevention Ordinance. Twenty-two of the 33 residences and 17 of the 38 accessory buildings now found within the floodplain areas are the direct result of the new flood mapping extending beyond the 1981 boundaries. Through its attempt to become accredited through the CRS process, staff has initiated several small projects to improve the county's ability to administer its regulations and educate the public regarding floodplain regulations. These actions include the following: 1. Within the Orange County website, under Current Planning, flood elevation certificates are available, as well as, instructions to complete the document and the county flood damage prevention ordinance. 2. Staff now logs in all floodplain information inquiries. 3. ,Forms to respond to formal floodplain data requests. 4. A floodplain insurance data form for hand out to any interested citizen. 5. The Neuse, Cape Fear, and Roanoke Basin floodplain maps for Orange County are now a layer in the Planning Department GIS and are available for viewing in the Planning Department's map room. 6. All parcels with structures located within flood prone areas now have a notice placed on them within the Building Inspection permit system, so that no improvements or addition are allowed unless base flood elevations, lowest adjacent grades, and first floor elevation data are determined. 7. Staff hosted a November 2006 open house/informational meeting for all property owners with structures in mapped floodplains. 8. Both the Planning Department and County libraries have books, pamphlets, and brochures on the NFIP and flood proofing buildings. ATTACHMENT 2 Report on the Government Service Center Annex Elevation Certificate Attached is a copy of an elevation certificate for the building. This elevation certificate is an official document that a licensed land surveyor and the Orange County Floodplain Manager prepared for the property. The elevation certificate is also an important administrative tool of the National Flood Insurance Program. It is used to provide elevation information necessary to ensure compliance with the County's Flood Damage Prevention Ordinance, and is required to properly rate buildings constructed after the Flood Insurance Rate Maps (FIRMs) became effective. The certificate is not required for buildings constructed before the Orange County FIRM originally became effective on March 16, 1981, unless the owner wishes to be rated for flood insurance purposes. The certificate indicates annex is in a special flood hazard area (floodplain). If you presently do not carry flood insurance on the structures, you may wish to use the certificate to apply for a preferred flood insurance rating. The base flood elevation (BFE) for the Governmental Service Center Annex is 506.8 feet above mean sea level, which is 3.5 feet above the top of the basement floor elevation and 1.4 feet above the base of the central air unit. The main floor of the building is nearly 5.4' above the BFE. Because the Orange County Flood Damage Prevention Ordinance requires a two (2') foot freeboard above the BFE and to minimize potential flood damage, staff would recommend that the central air unit be elevated 3.4 feet. Since the building houses anon-residential use, the building can be retrofitted with flood-resistant entry doors into the basement areas. Any other utilities in the basement should be either elevated or walled off from intruding . floodwaters. Any stored materials should be elevated at least five (5') above the basement floor. No cost estimates for such flood damage retrofitting have been prepared. U.S. DEPARTMENT OF HOMELAND SECURITY ELEVATION CERTIFICATE OMB No. 1660-0008 Federal Emergency Management Agency Expires February 28. 2009 National Flood Insurance Program Important: Read the instructions on pages 1-8. r'o SECTION A -PROPERTY INFORMATION For Insurance Company Use: A1. Building Owner's Name Governmental Services Annex PoUcy Number A2. Building Street Address (including Apt., Unit, Suite, and/or Bldg. No.) or P.O. Route and Box No. I Company NAIC Number I Cameron Street City Hillsborough State NC ZIP Code 27278 A3. Property Description (Lot and Block Numbers, Tax Parcel Number, Legal Description, etc.) south side of East Margaret Lane A4. Building Use (e.g., Residential, Non-Residential, Addition, Accessory, etc.) open public market A5. Latitude/Longitude: Lat. Long. Horizontal Datum: ^ NAD 1927 ®NAD 1983 A6. Attach at least 2 photographs of the building if the Certificate is being used to obtain flood insurance. A7. Building Diagram Number 7 A8. For a building with a crawl space or enclosure(s), provide A9. For a building with an attached garage, provide: a) Square footage of crawl space or enclosure(s) 7.745 sq ft a) Square footage of attached garage na sq ft b) No. of permanent flood openings in the crawl space or b) No. of permanent flood openings in the attached garage enclosure(s) walls within 1.0 foot above adjacent grade walls within 1.0 foot above adjacent grade c) Total net area of flood openings in A8.b 0 sq in c) Total net area of flood openings in A9.b 0 sq in SECTION B -FLOOD INSURANCE RATE MAP (FIRM) INFORMATION 61. NFIP Community Name & Community Number B2. County Name B3. State Orange County -- 370342 Orange County North Carolina B4. Map/Panel Number B5. Suffix B6. FIRM Index B7. FIRM Panel B8. Flood 69. Base Flood Elevation(s) (Zone Date Effective/Revised Date Zone(s) AO, use base flood depth) 9874 J 02/02/2007 02/02(2007 AE 506.8 B10. Indicate the source of the Base Flood Elevation (BFE) data or base flood depth entered in Item B9. ® FIS Profile ^ FIRM ^ Community Determined ^ Other (Describe) B11. Indicate elevation datum used for BFE in Item B9: ^ NGVD 1929 ®NAVD 1988 ^ Other (Describe) 812. Is the building located in a Coastal Barrier Resources System (CBRS) area or Otherwise Protected Area (OPA)? ^Yes ®No Designation Date ^CBRS ^ OPA -- SECTION C -BUILDING ELEVATION INFORMATION (SURVEY REQUIRED) C1. Building elevations are based on: ^ Construction Drawings* ^ Building Under Construction* ®Finsshed Construction *A new Elevation Certificate will be required when construction of the building is complete. C2. Elevations-Zones Al-A30, AE, AH, A (with BFE), VE, V1-V30, V (with BFE), AR, AR/A, AR/AE, AR/A1-A30, AR/AH, AR/AO. Complete Items C2.a-g below according to the building diagram specified in Item A7. Benchmark Utilized Vertical Datum Conversion/Comments Check the measurement used. a) Top of bottom floor (including basement, crawl space, or enclosure floor)_ ^ feet ^ meters (Puerto Rico only) b) Top of the next higher floor ^ feet ^ meters (Puerto Rico only) c) Bottom of the lowest horizontal structural member (V Zones only) ^ feet ^ meters (Puerto Rico only) d) Attached garage (top of slab) ^ feet ^ meters (Puerto Rico only) e) Lowest elevation of machinery or equipment servicing the building ^ feet ^ meters (Puerto Rico only) (Describe type of equipment in Comments) f) Lowest adjacent (finished) grade (LAG) ^ feet ^ meters (Puerto Rico only) g) Highest adjacent (finished) grade (HAG) ^ feet ^ meters (Puerto Rico only) SECTION D -SURVEYOR, ENGINEER, OR ARCHITECT CERTIFICATION This certification is to be signed and sealed by a land surveyor, engineer, or architect authorized by law to certify elevation information. l certify that the information on this Certiticate represents my best efforts to interpret the data available. r 1 understand that any false statement maybe punishable by fine or imprisonment under 18 U. S. Code, Section 1001. ^ Check here if comments are provided on back of form. Certifler's Name License Number Title Company Name Address City State ZIP Code Signature Date Telephone i,.x Fi S..ga E,» a~~^S E ~}t3.... i-IEI'~~. FEMA Form 81-31, February 2006 See reverse side for continuation. Replaces all previous editions IMPORTANT: In these spaces, copy the corresponding information from Section A. For Insurance Company User Building Street Address (including Apt., Unit, Suite, and/or Bldg. No.) or P.O. Route and Box No. Policy Number --' Cameron Street City Hillsborough State NC ZIP Code 27278 '.Company NAIC Number _.. SECTION D -SURVEYOR, ENGINEER, OR ARCHITECT CERTIFICATION (CONTINUED) Copy both sides of this Elevation Certificate for (1) community official, (2) insurance agent/company, and (3) building owner. Signature Date ^ Check here if attachments SECTION E -BUILDING ELEVATION INFORMATION (SURVEY NOT REQUIRED) FOR ZONE AO AND ZONE A (WITHOUT BFE) For Zones AO and A (without BFE), complete Items E1-E5. If the Certificate is intended to support a LOMA or LOMR-F request, complete Sections A, B, and C. For Items E1-E4, use natural grade, if available. Check the measurement used. In Puerto Rico only, enter meters. E1. Provide elevation information for the following and check the appropriate boxes to show whether the elevation is above or below the highest adjacent grade (HAG) and the lowest adjacent grade (LAG). a) Top of bottom floor (including basement, crawl space, or enclosure) is ^ feet ^ meters ^ above or ^ below the HAG. b) Top of bottom floor (including basement, crawl space, or enclosure) is ^ feet ^ meters ^ above or ^ below the LAG. E2. For Building Diagrams 6-8 with permanent flood openings provided in Section A Items 8 and/or 9 (see page 8 of Instructions), the next higher floor (elevation C2.b in the diagrams) of the building is ^ feet ^ meters ^ above or ^ below the HAG. E3. Attached garage (top of slab) is ^ feet ^ meters ^ above or ^ below the HAG. E4. Top of platform of machinery and/or equipment servicing the building is ^ feet ^ meters ^ above or ^ below the HAG. E5. Zone AO only: If no flood depth number is available, is the top of the bottom floor elevated in accordance with the community's floodplain management ordinance? ^ Yes ^ No ^ Unknown. The local official must certify this information in Section G. SECTION F -PROPERTY OWNER (OR OWNER'S REPRESENTATIVE) CERTIFICATION The property owner or owner's authorized representative who completes Sections A, B, and E for Zone A (without aFEMA-issued orcommunity-issued BFE) or Zone AO must sign here. The statements in Sections A, B, and E are correct to the best of my knowledge. Property Owner's or Owner's Authorized Representative's Name Governmental Services Annex Address Cameron Street Gity Hillsborough State NC ZIP Code 27278 Signature Date Telephone Comments ^ Check here if attachments SECTION G -COMMUNITY INFORMATION (OPTIONAL) The local ofFcial who is authorized by law or ordinance to administer the community's floodplain management ordinance can complete Sections A, B, C (or E), and G of this Elevation Certificate. Complete the applicable item(s) and sign below. Check the measurement used in Items G8. and G9. G1. ® The information in Section C was taken from other documentation that has been signed and sealed by a licensed surveyor, engineer, or architect who is authorized by law to certify elevation information. (Indicate the source and date of the elevation data in the Comments area below.) G2. ^ A community official completed Section E for a building located in Zone A (without aFEMA-issued orcommunity-issued BFE) or Zone AO. G3. ® The following information (Items G4.-G9.) is provided for community floodplain management purposes. G4. Permit Number G5. Date Permit Issued G6. Date Certificate Of Compliance/Occupancy Issued FPD07-0079 10/02/07 10/02/07 G7. This permit has been issued for: ^ New Construction ^ Substantial Improvement G8. Elevation of as-built lowest floor (including basement) of the building: 503.30 _® feet ^ meters (PR) Datum 1988 G9. BFE or (in Zone AO) depth of flooding at the building site: 506.8 ®feet ^ meters (PR) Datum 1988 Local Official's Name Glenn R. Bowles, jr. Title Fooodplain Manager Community Name Orange County Telephone 919 245 2577 Signature Date 10/02/07 Comments ® Check here if attachments FEMA Form 81-31, February 2006 Replaces all previous editions Building Photographs See Instructions for Item A6. For Insurance Company Use Building Street Address (including Apt., Unit, Suite, and/or Bldg. No.) or P.O. Route and Box No. Policy Number Cameron Street Clt 1-IillsborougF State NC ZIP COde 2727.8 Company NAIC Number If using the Elevation Certificate to obtain NFIP flood insurance, affix at least two building photographs below according to the instructions for Item A6. Identify all photographs with: date taken; "Front View" and "Rear View", and, if required, "Right Side View" and "Left Side View." If submitting more photographs than will fit on this page, use the Continuation Page, followin . Front -Right View Rear -Right View ~~o ~, ~ I ;..gym.--~ ~~ '~~ '~° ~~ : ~~ l , ,.,., ,~~,~,,,,,,."~ '' ~r Equipment ~." .~„~' ' ~ ~ ~A levation = 505.4' ~~.~~;~~~>pm ~ ~„~, 1 ``"~ Top of Bottom ~~~ a~o~~,~~~~ r ~~~ ~ d~~~.~~ ~ ~ ©~~ ~~~,~~ ~ a ~~~: _ Floor = 503.3 r~~'~ ~ :08.31 .2007 A9:35 , 0 For Insurance Company Use Building Street Address (including Apt., Unit, Suite, and/or Bldg. No.) or P.O. Route and Box No. Policy Number ;Z8d1 Gartter Road Ci Hillsborough State Nc ZIP Code X7278 Company NAIC Number If using the Elevation Certificate to obtain NFIP flood insurance, affix at least two building photographs below according to the instructions for Item A6. Identify all photographs with: date taken; "Front View" and "Rear View", and, if required, "Right Side View" and "Left Side View." If submitting more photographs than will fit on this page, use the Continuation Page, followin . ear -Left View to Attachment 3 NCEM Hazard Mitigation Section FY 2008 Hazard Mitigation Grant Programs lii~~erecnn~ Overview The Federal Emergency Management Agency (FEMA) has announced that funding is now available for three non- disaster based Hazard Mitigation Grant Programs for funding in FY 2008. Eligibility for ALL Grant Programs (PDM, FMA & RFC) Require: AFEMA-approved, locally-adopted Hazard Mitigation Plan Project must be Cost Effective (at least 1:1 Benefit Cost Ratio) Activities must meet conditions of the with National Environmental Policy Act (NEPA), including a State Historic Preservation Office (SHPO) review Application is submitted to FEMA via NCEM through the e-Grants system -Contact NCEM for technical assistance. PDM: Pre-DlSaster Mltlgatlon (http://www.fema.gov/government/grant/pdm/index.shtm) 75% Federal Funding; 25% Non-Federal Match required Nationally Competitive Must be feasible, cost effective, and consistent with the FEMA-approved, locally-adopted Hazard Mitigation Plan Eligible Projects: o Planning activities that develop or update State, Indian tribal, local, and university hazard mitigation plans o Voluntary acquisition of real property (for open space conversion) o Relocation of public or private structures o Elevation of existing public or private structures (to avoid flooding) o Structural retrofitting and non-structural retrofitting (i.e. impact-resistant windows) o Construction of safe rooms (i.e. tornado and severe wind shelters) o Vegetation management o Protective measures for utilities o Stormwater management projects o Localized flood control projects that are designed specifically to protect critical facilities Application due to NCEM in e-Grants: January 11, 2008 FMA: FIOOd Mltlg1t1011 ASSIStatlCe (http://www.fema.gov/government/grant/fma/index.shtm) 75% Federal Funding; 25% Non-Federal match required Applicant must a participant be in good standing with the National Flood Insurance Program (NFIP) Must be feasible, cost effective, and consistent with the FEMA-approved, locally-adopted Hazard Mitigation Plan Eligible Projects: o Elevating structures in high-risk flood areas o Acquiring buildings in high-risk flood areas and returning the property to open space (100% voluntary; Property owners are never forced to sell their property) o Demolition of NFIP-insured structures on acquired or restricted real property o Dry Flood proofing of non-residential structures o Minor Localized Flood Control Projects o Beach Nourishment Activities Application due to NCEM in e-Grants: March 14, 2008 RFC: Repetitive Flood Claims (http://www.fema.gov/government/grant/rfc/index.shtm) 100% Federal Funding; No match required Applicant must be a participant in good standing with the National Flood Insurance Program (NFIP) Applicant must demonstrate that either: o The State and the community are not able to meet the 25% non-Federal match that would otherwise make the activity eligible under FMA; or o The State or community does not have the capacity to manage the activities under the FMA program. Requires that the full data Benefit Cost Analysis module be used - Eligible Projects: o Acquisition/demolition of insured properties that have one or more claim payments for flood damages and demolish or relocate structures, with conversion of property to deed- restricted open-space use o Elevations (must maintain flood insurance for life of structure) o Dry Flood proofing of non-residential structures o Minor Localized Flood Control Projects (funding limited to $1 M per project) that protect insured structures Applications due to NCEM in e-Grants: January 11, 2008 ~a Attachment 4 Pre-FIRM /Post-FIRM Conditions STRUCTURES Pre-FIRM 1981 Post-FIRM TOTAL 128* 71 199 Houses Accesso Houses Accessory Houses Accesso 1981 2007 67 61 35 36 102 97 +~,., SST ,i ~ _ -}~ ~~ I:=~. 1 ( ~J,u i®i~ 6 • In NOut ,k,.; ,`'44 23/3 ;~ 26 27/3 70 50/6 120/6 * Includes 7 removed structures and 4 structures with elevation certificates prepared after 1981 Houses, Businesses, and Accessory Buildings still Subject to Floodplain Regulations (32 houses and 41 accessory buildings). Of the 76 structures, 39 are the result of the new FIRMs (effective February 2, 2007).