The Dalles Planning Commission voted June 5 to recommend that City Council adopt amendments to the comprehensive plan and Title 10 of the The Dalles Municipal Code to comply with FEMA’s 2024 Pre‑Implementation Compliance Measures (PICM) and updated floodplain development standards.

The change would update local floodplain regulation, including a “no‑net‑loss” habitat mitigation requirement drawn from FEMA’s 2024 model ordinance, and introduces new permitting, mitigation-plan and elevation documentation requirements. Joshua Chandler, Community Development Department, told the commission the goal is "to ensure continued participation in the National Flood Insurance Program" and that communities must meet PICM obligations by July 31, 2025.

Why it matters: FEMA’s PICM links floodplain development rules to endangered‑species protections; failure to adopt implementing measures could jeopardize a community’s eligibility to participate in the National Flood Insurance Program (NFIP). Chandler said The Dalles currently must rely on 1984 Flood Insurance Rate Maps until new maps are finalized and cautioned the city is navigating a compressed federal timeline while new FIRMs are not expected to be final until 2026.

What was proposed and the city’s approach: Staff described three PICM implementation paths FEMA outlined — a model ordinance, a permit‑by‑permit habitat review, or a prohibition on development in mapped floodplain — and said City Council chose the model ordinance path. To reduce the city’s administrative and legal exposure while attempting to remain consistent with Oregon land‑use law, staff and outside counsel proposed an Option 2 approach that shifts the technical compliance burden to applicants. Under this approach, property owners would hire qualified professionals to produce habitat assessments and mitigation plans; the city would verify submission rather than perform the full environmental analysis itself.

Commissioners and speakers pressed staff on practical effects and costs. Chandler said the work will increase the length and detail of the flood code, replace the term “100‑year floodplain” with “special hazard flood area,” add new variance and elevation‑certificate standards, and require a mitigation plan "conducted by a qualified professional for all development within a floodplain." He estimated that letters of map amendment (LOMAs) or similar technical updates commonly cost several thousand dollars and that habitat assessments would add additional expense for applicants.

Legal risk and NFIP consequences: Josh Soper, attorney with Barry Elsner, told the commission there is litigation nationally challenging some aspects of FEMA’s implementation, but that the immediate risk is the agency’s July 31 PICM timeline. "The threat from FEMA is that failure to meet the July 31 deadline will result in evaluation and possible revocation of eligibility to participate in the National Flood Insurance Program," Soper said. He and staff emphasized FEMA has not formally approved the city’s Option 2 submission and the agency’s Pick'em (PICM) staff resource constraints have limited federal responses.

Public testimony and local concerns: Property owners and residents raised questions about how the requirements would affect existing homes, commercial uses and vacant lots — especially in the Lone Pine neighborhood — and asked whether previously developed sites or interior renovations would trigger the mitigation requirement. Anne Anderson, a civil and structural engineer and local property owner, asked for clarification on why FEMA tied endangered‑species assessments to flood insurance rules. Tom Peters, a building owner and developer with HUD experience, said similar rules applied to HUD‑financed multifamily projects have added hundreds of thousands of dollars to large projects.

Next steps: Staff recommended the commission forward a recommendation to City Council. The commission passed a motion (resolution PC629‑25) to recommend adoption of Comprehensive Plan Amendment 56‑25 and Zoning Ordinance Amendment 110‑25 as presented; recorded voting indicated the motion passed and staff will present the matter to City Council at a hearing currently scheduled for July 14, 2025 (with a July 28 backup date). Chandler noted the city will continue outreach and prepare "how‑to" materials for applicants.

What remains unresolved: Staff and counsel told the commission they have not received formal approval from FEMA or DLCD on the Option 2 path and warned that federal rulemaking or litigation could require further local code changes in 2027. Several commissioners and public commenters urged additional clarity on which parcels will be affected once the updated FIRMs are final and on options to reduce applicant cost burdens; staff said it can return information and include public comments in the City Council record.

For now the commission’s action is a recommendation; any code changes become effective only if City Council adopts amendments to the comprehensive plan and Title 10.