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Deer Creek residents urge city to clarify floodplain "substantial damage" letters; FEMA, state guidance cited

May 03, 2025 | O'Fallon City, St. Clair County, Illinois


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Deer Creek residents urge city to clarify floodplain "substantial damage" letters; FEMA, state guidance cited
Dozens of residents from the Deer Creek subdivision told the O'Fallon City Public Works Committee on May 5 that a city letter about "substantial damage" assessments after the March storm has caused confusion and concern about when repairs require elevation or other floodplain mitigation.

Residents said the letter, signed by Chad Trueran and dated April 9, 2025, asked property owners in mapped floodplain areas to submit damage estimates so the city could determine whether repair costs meet the National Flood Insurance Program threshold for "substantial damage." Rod Thompson, who read a prepared statement to the committee, said the city's instructions conflicted with FEMA and Illinois guidance and asked the city to rescind the letter: "The city should rescind their letter dated 04/29/2025 and focus on damage related to flooding as FEMA and the state of Illinois FEMA offices have done," Thompson said.

Why this matters: If a structure in a mapped floodplain is determined to be "substantially damaged"—commonly defined by FEMA and state guidance as repairs exceeding 50% of the structure's pre-damage value—owners can be required to bring the building into compliance with current floodplain regulations, which can include elevating the structure or other costly measures.

At the meeting residents repeated specific questions: whether hail damage must be reported under the city's substantial-damage process, whether cumulative repairs are counted toward the 50% threshold, and whether community development staff or the city's floodplain official would provide one-on-one explanations. Karen Pfeiffer told the committee she had sought roof repairs following hail and that city staff told her "if the total cost of all repairs, cumulative, the flood or any other disaster, if it exceeds 50% of the assessed value of your property, you have to have your house elevated."

City staff said the item is administered through the Community Development Department and that Chad Trueran is the city's floodplain/building code official. A city staff member asked residents to contact Community Development or meet the department at its next scheduled meeting; staff also said the city is required to collect and report certain damage-assessment information to remain in the National Flood Insurance Program. "That was the information that he relayed to me," a staff member said of the city's floodplain official.

Residents asked for clearer written guidance and raised broader concerns about creek erosion, exposed sewer infrastructure and the adequacy of upstream stormwater work. Multiple speakers described repeated backyard erosion and tree loss along Engle/Deer Creek and said debris and narrowing culverts were making flooding worse.

The committee did not take formal regulatory action at the meeting. Staff committed to refer detailed technical questions to Community Development and the floodplain official and to provide residents with contact information and next steps; Community Development's next meeting was identified as May 12, 2025.

The transcript contains inconsistent date references to the city's letter (both April 9 and April 29 are mentioned by speakers); residents noted the discrepancy and asked the city to clarify the correct letter date and to explain why hail damage had been included in the city's mailing.

Ending: Committee members encouraged residents to contact Community Development directly and to attend the May 12 meeting for address-specific guidance; staff said they would follow up with the floodplain official and check FEMA/state guidance and report back.

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