Staff warns FEMA biological-opinion model code could make floodplain work impractical

Oct 22, 2025

Planning staff told the commission that the FEMA Biological Opinion (BiOp) and proposed model code add stringent habitat and fill-replacement rules that may be unattainable for many Prineville properties; staff submitted comments and expects wider jurisdictional pushback.

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Staff presented concerns about a FEMA Biological Opinion (BiOp) tied to floodplain mapping and a corresponding model code. The director said the BiOp "is taking our floodplain layers" and described proposed rules that would require habitat creation, no-net-fill, and mandated ratios for tree replacement — measures staff said are difficult to apply in locations where habitat does not currently exist.

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