Floodplain Exhibit Pressure Before a Rezoning Hearing
A GIS analyst at a consulting firm is preparing a floodplain exhibit for a rezoning hearing. The analyst's preliminary HEC-RAS run places 14 parcels inside the 100-year floodplain. The developer asks the analyst to shift the boundary about 40 m downstream to exclude six parcels, arguing the model is 'conservative.' The firm has 80 billable hours left on a fixed-fee contract; the hearing is in nine days. The developer suggests deleting the model run notes and using an older FEMA effective map instead. The analyst is not a licensed surveyor or engineer in the state, and the firm's QA manager is on leave. The county planning staff have not seen the preliminary exhibit. The developer says the revised exhibit is 'just a graphic' and will not be submitted as engineering.
1. Identify the ethical and professional issues in this request. Distinguish legitimate client advocacy from misrepresentation.
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Ethical issues: The request contains several distinct problems. First, shifting a floodplain boundary by 40 m without a technical basis is not advocacy; it is altering a technical conclusion to produce a preferred outcome. Second, deleting model run notes is destruction of the documentation that supports the exhibit and prevents independent review; that is falsification of the record, not a formatting choice. Third, using an older FEMA effective map may be legitimate if it is clearly identified as the effective regulatory map, but substituting it to hide a more recent preliminary run is misleading. Fourth, the analyst is not licensed as an engineer or surveyor, so the analyst must not imply engineering certification or seal the exhibit.
Legitimate client advocacy would be: reviewing model assumptions with a qualified engineer, testing a defensible alternative boundary condition, disclosing the preliminary nature of the run, and presenting the uncertainty to the county. Misrepresentation would be: moving the boundary to reach a parcel count, removing run notes, or calling the exhibit 'just a graphic' while using it to influence a regulatory decision.
Conclusion: The analyst should not comply with the request as framed. The analyst should escalate to a principal or QA manager, seek engineering review, and document the client's request and the analyst's response.
2. What options does the analyst have, and what should the analyst actually do next?
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Options:
- Refuse the alteration and explain why. State in writing that the boundary cannot be shifted without a technical basis and that run notes cannot be deleted. Offer to present the preliminary result with its assumptions and uncertainty.
- Obtain qualified review. Ask the firm's principal or another licensed engineer to review the HEC-RAS run and determine whether a defensible sensitivity case exists. If it does, document the changed assumption and show both results.
- Use the effective FEMA map transparently. If the regulatory exhibit should use the effective map, label it clearly as the effective map and disclose that a preliminary updated run exists. Do not present the older map as if it supersedes the preliminary run without explanation.
- Escalate internally. Notify the QA manager's supervisor or firm principal in writing. Fixed-fee pressure and a nine-day deadline do not justify misrepresentation.
- Withdraw if necessary. If the client insists on deleting notes or shifting the boundary without basis, the analyst should decline the task and follow the firm's escalation and withdrawal procedure.
Recommended next step: Send a short written summary to the client and firm principal: the preliminary run places 14 parcels in the floodplain; no boundary shift will be made without an engineering basis; run notes will be retained; the exhibit can show the effective map and the preliminary run as separate, labeled panels. This protects the analyst, the firm, and the public record.
3. How should the analyst document the work and communicate with the county and the client?
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Documentation: Preserve the HEC-RAS project file, run notes, input assumptions, model version, date, and the preliminary exhibit. Record the client's request, the analyst's response, and any internal escalation in the project file or a memo. If an alternative scenario is later run, keep both scenarios and label which one is regulatory and which is sensitivity analysis. Do not overwrite the original run.
Communication with the client: Be direct but professional: 'I can present the preliminary floodplain and its uncertainty, and I can ask for engineering review of alternative assumptions. I cannot move the boundary 40 m or delete run notes without a technical basis.' Explain that deleting notes creates a record-integrity problem and exposes the client to greater risk at the hearing.
Communication with the county: Submit an exhibit that clearly identifies the data source, model status, date, and preparer. If the effective FEMA map is used, label it as the effective regulatory map and state that a preliminary updated run exists. If the preliminary run is shown, label it preliminary and include the assumptions. The county should see both the conclusion and the uncertainty. The analyst should not imply licensed engineering status. This approach preserves the client's ability to advocate while keeping the technical record truthful and reviewable.