I'm not an expert on the proposed rules; however, I think the editor and DeFazio should recognize that the fundamental point is this: Federal flood insurance should not be subsidizing development in flood plains. Let the developers pay the market rate, as well as their fair proportion of any flood mitigation measures (e.g., dams), and the problem will mostly take care of itself.

I also understand, that NMFS has proposed one option which is local development regulations and other actions that result in "no net loss," _not_ a complete ban on development.

Right now, we have an excellent example of a development that would be partially in the flood plain -- the proposed Oakleigh Meadow Co-housing 29-unit condominiums. The proposal would dump tons and tons of rock and fill dirt in the flood plain and cover much of the current meadow with hardscape. The result wouldn't pass NMFS muster because of the impact on listed fish species. Nevertheless, our feckless Planning Division approved it.