More Questions than Answers About Romerica Group, Romerica Investments, and Their Supposed $2.5 Billion Project

A company called Romerica Investments, LLC filed applications with the US Army Corps of Engineers and the Texas Commission on Environmental Quality to develop hundreds of acres of land currently in the floodplain, the floodway and wetlands near the San Jacinto. The land is between Kingwood Lakes and the San Jacinto River, east of Woodland Hills Drive. If the Army Corps approves the permit, buildings could range up to 50 stories on land deed-restricted to single-family use. Meanwhile, numerous other questions have arisen about the maze of companies, including the Romerica Group, behind what Houston City Council Member Dave Martin has described as a $2.5 billion proposal.

Romerica Investments

Romerica Investments, LLC is one of many ostensibly related companies, according to the developer’s Romerica Group website.

Problem is: Dun & Bradstreet thinks Romerica Investments is out of business. And the Romerica Group is not registered with the Secretary of State to do business in Texas.

35 Companies Controlled by Two Men

Searches have revealed 35 companies so far that are registered with the Texas Secretary of State that belong to Gabriel M. Haddad and Fabio M. Covarrubias. Both men use multiple variations on their names, making it difficult to nail down a precise number of companies and partnerships that they control. They also register additional companies and partnerships in other states and countries, making ownership and accountability even more difficult to track.

Romerica Investments does not have a functioning public-facing informational website that I can find;, which was registered in 2016, still leads to a “Future Home of…” page. However, clicking on the Romerica Investment link from the Romerica Group home page takes you to a password-protected login page at separate website address for the Kingwood Marina Project. This website was registered by Romerica

A new and separate promotional website developed by Manlove Advertising and PR for the developers now implies that the Romerica Group will be responsible for the development. Yet there is no Romerica Group registered to do business in the State of Texas. This search of the Secretary of State’s SOS Direct database returned nothing close to the Romerica Group.

Romerica Group’s website says they have 12 projects currently “running” in the U.S. and Mexico. However, a review of the company’s many websites found only two related to real-estate development – one in each country. The US project in Kingwood has not been constructed and the website for the development in Mexico shows only conceptual drawings. The Romerica Group website shows nine related entities, discussed below.

Motor Sports Resort

In November 2014, Covarrubias and Haddad bought a race track in Angleton at One Performance Drive in the middle of farmland (see below). Built in 2005, it was originally called MSR Houston. MSR stood for Motor Speedway Ranch. Photos on the site suggest that the tallest building on the property is two to three stories. It sold memberships and track time to owners of high-performance vehicles who wanted to drive fast legally in a controlled environment.

Racetrack in Angleton caters to performance driving enthusiasts. As of 3/21/18, Google Earth showed only a track with some garage space and a few other small buildings.

AFTER the track fell into financial difficulties, Covarrubias and Haddad bought the property under the names Piffer and Giorgi in November, 2014,. They bought it through one of their 35 companies called Romerica Entertainment, LLC.

On Christmas Eve of 2014, Piffer (using the name Fabio M. Covarrubias) promised the members of the race track that Romerica Entertainment would make many improvements to the facility, including building a four-star hotel. More than four years later, there’s still no sign of the hotel in satellite photos, the Brazoria County appraisal district website or legal filings related to the property.

The Motor Sports Resort site mentions a real-estate company, MSR Houston Real Estate, that was supposedly introducing a master plan for the track by the summer of 2018. The MSR Houston web site does say, “Coming Soon,” but the Texas Secretary of State shows no record of such a company and a google search for it returned no results except the one below. I can find no details of a master plan on the website.

Tramontana and Lotus Driving Academy

The Romerica Group website also claims to have two other automotive related ventures:

  • Lotus Driving Academy located at the track.
  • MSR Tramontana LLC features a high-performance car. However, the site does not say what the group’s contribution to the vehicle is. It says that they are one-of-a-kind vehicles with “excellent levels of production and development” but doesn’t say how many have been built or how to buy one. Tramontana has a separate, dedicated website. That offers a little more detail. But on their partner page, they list a branding company, two fashion designers, and a web developer. I could find no references to manufacturing partners or where the vehicles were made.

FAMA Design

Romerica Group’s website also shows a company, FAMA Design, that sells rustic doors, windows and furniture online. Unfortunately, when you try to order something, you find that the site’s security certificate has expired. You get the following warning:

Warning message when you check out from FAMA Design.

Romerica Insurance

Romerica Insurance does not have its own web site. However, it does have several Facebook pages. They sell many different types of insurance, including – ironically – flood insurance. FaceBook also lists an office for the insurance company at the Angleton racetrack.

Romerica Real Estate

Romerica Real Estate does not have its own web site either. The link to Romerica Real Estate from the Romerica Groups Home Page is broken. (Houston Area Realors) says that the Romerica Real Estate “page is no longer active.” Same for FaceBook. A Google search returns dozens of other “page not found” error messages. The Texas Real Estate Commission (TREC) shows that the company’s account is “inactive.” TREC also lists the real estate company’s address as the racetrack in Angleton.

The Texas Real Estate Commission lists the Romerica Real Estate, LLC account as inactive even though it has not expired. Note that the TREC also lists the address for the real estate company at the race track.

Torrenova Cuernavaca

Another link from the Romerica Group Home Page goes to Torrenova Cuernavaca. The subhead says it deals with Romerica land in Mexico. Last month, clicking on the link yielded another dead-end search.

However, the Torrenova-Cueranvaca site has since been updated to include concept drawings. It shows no actual photos of anything the “company” has constructed, though the site does list prices. Like the Romerica Group itself, Torrenova Cuernavaca is not registered to do business in the state of Texas (though in fairness, the site is in Spanish).

American Vision EB-5

American Vision Regional Center also appears on the Romerica Group home page. American Vision’s contact page shows that the formal name for the company as “B US TOTAL INVESTOR, LLC.” It IS registered in the State of Texas. B US TOTAL INVESTOR lists American Vision Regional Center as its assumed name. Gabriel M. Haddad, one of the managers, lists his address on a street that does not exist.

American Vision Regional Center solicits investments through the U.S. Citizenship & Immigration Service EB-5 program. EB-5 visas offer a legal pathway into the U.S. for foreign investors, their spouses and family members under 21.

While the EB-5 program is real, the developer’s website features a building that purports to be part of the Marina project, but is not. The building’s construction was canceled due to lack of pre-leasing activity; it was actually designed for a project in downtown Houston on Waugh unrelated to the developers.


  • The contact phone number for the site is disconnected. 
  • The office has been reported as vacant.
  • The site refers people to another site that does not exist (
  • The developers have been highlighted in for “touting fake EB-5 projects.” 
  • Foreign investors are suing the developers for fraud in Houston district court. (See MARIA DEL CARMEN BORBOLLA AND MARIA DEL CARMEN GOMEZ, CAUSE NO. 2018 – 07276, 157th Judicial Court, Harris County, Tx.) 
  • Clicking on the home page of takes the viewer to an unrelated site ( that sells religious books. is registered to a seemingly unrelated company in Paris, France.
  • The landing page for shows links to four sub-pages: Why EB-5?, Info For Investors, FAQs, and Our Parters. Links to each page are broken. They take you to a “page not found” error message on the bookstore site.

Warning to Potential EB-5 Investors

If you are considering investing in ANY EB-5 project, understand that the EB-5 program has been plagued by fraud. Visit this Securities and Exchange Commission page (Investor Alert: Investment Scams Exploit Immigrant Investor Program). It explains how to check out the validity of projects and recognize the warning signs of fraud.

The SEC’s first warning sign: “Promises of a visa or becoming a lawful permanent resident.” The text explains, “Investing through EB-5 makes you eligible to apply for a conditional visa, but there is no guarantee that USCIS will grant you a conditional visa or subsequently remove the conditions on your lawful permanent residency. USCIS carefully reviews each case and denies cases where eligibility rules are not met. Guarantees of the receipt or timing of a visa or green card are warning signs of fraud.

Copy on the About Us Page clearly states that their program was “…designated by the United States Citizenship and Immigration Services (USCIS) to offer Investor Visa / Green Card through the EB5 Immigrant Investor Program.”

Last line of copy shown above seemingly violates SEC guidelines.

To be clear, I am not accusing Romerica or its management of fraud. I am merely repeating US government advice for investors to be cautious in these circumstances.

Domain-Registration Dead End

A “WhoIs” database search for the owner of showed that the domain name is owned by Romerica Investments.

Although the domain was registered in 2016, it still shows a “Future Home of” page and nothing else. A WhoIs search for does not show a contact for the web site.

When Will Developers Appear to Answer Questions?

Numerous questions exist about the people applying for permits to build high-rises feet away from the floodway of the San Jacinto? They surely know that the area where they want to build 25-50 story high rises will soon be INCLUDED in the floodway when new flood maps are approved. Who would build there? Why?

I do not wish to speculate on the motives of the developers. I can only point out inconsistencies that do not inspire confidence. Especially for someone developing what Houston City Council Member Dave Martin has described as a $2.5 billion project. Especially when they’ve shown no evidence that they have ever built anything.

Despite my seven requests for a meeting, the developers have refused to meet publicly to answer questions. Their official point of contact at the Manlove Advertising and PR agency has stated that they may consider one AFTER the public comment period closes.

One can only hope that the Army Corps and TCEQ will exercise due diligence in consideration of these permit requests.

As always, these comments represent my opinions on matters of public policy. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted by Bob Rehak on February 17, 2019

538 Days After Hurricane Harvey

Kingwood Lakes Threatens Legal Action Over Portion of Proposed High-Rise Development

Kingwood’s Kingwood Lakes Community Association has threatened legal action over a portion of the proposed high-rise development between Lake Kingwood and the Barrington. Developers planned multi-family condominium units on stilts for that area. But deed restrictions limit construction to single-family housing compatible with surrounding architecture.

Milan Saunders
View from Milan Saunders home in Kingwood Lakes during Harvey. This is why Kingwood Lakes residents are so concerned about the diversion of drainage from the proposed high-rises and condos towards them.

Single-family usually means “one family in one house on one piece of land.” The developers had planned 65′ high, MULTI-FAMILY condos. That would not look anything like the classic homes in either Kingwood Lakes or the Barrington.

Drainage Issues Compound Deed Restriction Issues

Deed restrictions also prevent diversion of drainage onto the property of others. According to the US Army Corps’ public notice, the developers planned to divert runoff into Lake Kingwood. That lake is owned and maintained by the Kingwood Lakes subdivision. Without the permission of the Association, that would also constitute a deed restriction violation.

The letter warns that if development commences, the association will seek “judicial enforcement of deed restrictions, architectural guidelines and protection of its property. Such action may include claims for injunctive relief as well as relevant damages.”

The letter closes by saying that the Association hopes no further action will be required.

Kingwood Lakes addressed the letter to the Army Corps. However, the homeowners’ association also copied officials at Harris County Flood Control and the City of Houston.

To see the full text of the letter, click here.

Posted by Bob Rehak on 2/14/2019

534 Days after Hurricane Harvey

Search for Owners of High-Rise Properties Leads to Maze of More Than 30 Companies in Texas Alone

Romerica Investments LLC has filed permit applications with the Army Corps, City of Houston, and Harris County Flood Control. Romerica Investments hopes to build 5,000 mid-rise condos, a series of high-rise towers ranging from 25 to 50 stories, and a marina to hold 800 40-foot boats and 200 jet skis – all on property deed-restricted to “single-family residential” in a bald-eagle habitat protection zone. The property is near River Grove Park in the floodplain and floodway of the San Jacinto’s West Fork.

However, a title search revealed that Romerica Investments does not own the property on which it intends to build. A search for who does own the property led through a maze of more than 30 other entities in Texas. Two individuals run virtually all of them. The individuals sometimes use different names and different spellings of their names when registering their businesses with the Texas Secretary of State. They also list offices that are sometimes vacant; phone numbers that have been disconnected; and an address on a street that does not exist. In the case of the land in question, they even registered the company under the first name of one man and the last name of the other. Innocent mistakes or part of a pattern? You judge.

Maze Haze

I searched websites of the Harris County District Clerk and Appraisal District; the Texas Secretary of State; CorporationWiki; Dun & Bradstreet; and Google. The search revealed at least 32 companies in Texas associated with variations on Fabio M. Covarrubias’ name and 24 under variations of Gabriel M. Haddad’s name. A large degree of overlap exists between the companies controlled by the two men. See below.

Spider diagram courtesy of CorporationWiki showing the maze of relationships between companies and people in this post.

Covarrubias Companies

The name Fabio M. Covarrubias pulls up the following:

  • B US TOTAL INVESTOR, LLC, aka American Vision Regional Center
  • Cova Capital Inc.
  • Fama Design Corporation
  • Lake Como Properties LLC
  • Pacifica Properties Inc.
  • Pacifica Properties LLC
  • Romerica Insurance LLC
  • Romerica Investments LLC
  • Romerica Real Estate LLC

The name Fabio M. Covarrubias Piffer (without a hyphen in the last names) is associated with:

  • Cova Assets Inc.
  • FAMA Ranch Company
  • MSR Serials LLC
  • North American Phosphates and Supplies Co.
  • Romerica Assets LLC
  • Romerica GP, LLC
  • Romerica Investments LLC
  • Romerica CW 3 LLC
  • Romerica E 6 LLC
  • Romerica R 1 LLC
  • Romerica RMR 4 LLC
  • Trio Sports Developments LLC

The name Fabio M. Covarrubias-Piffer (with a hyphen) is associated with:


Fabio Massimo Covarrubias-Piffer (full middle name with hyphen) is associated with:

  • Romerica Title, LLC

Haddad Companies

Gabriel Miguel Haddad’s name appears with:

  • B US TOTAL INVESTOR, LLC, aka American Vision Regional Center
  • Fama Design Corporation
  • Paban Corporate Services Inc.
  • Romerica Assets LLC
  • Romerica Insurance, LLC
  • Romerica Investments, LLC
  • Romerica Real Estate, LLC

The name Gabriel M. Haddad Giorgi appears with nine more LLCs in Texas:

  • Emprende Management, LLC
  • Romerica C.L. 2, LLC
  • Romerica CW 3, LLC
  • Romerica E 6, LLC
  • Romerica GP, LLC
  • Romerica RMR 4, LLC
  • Romerica M 5, LLC
  • Romerica R 1, LLC
  • Romerica Team, LLC

Gabriel Miguel (middle name spelled out) Haddad Giorgi is listed as the manager of:

  • Romerica Title, LLC

And finally, in a class all its own, the name Fabio M. Haddad Giorgi appears on the Certificate of Formation of:

In case you’re doing a double take, that’s the first name of one man with the last name of another. They amended that filing last year so that their names now appear as Fabio M. Covarrubias Piffer and Gabriel M. Haddad Giorgi.

Filing for Permit to Develop

Whew! Got all that? Now get this. Romerica Investments, the company that filed the permit application with the Corps, lists Mr. Covarrubias as both manager and director under two different names. Also note that the address on “Nuntucket” for Mr. Haddad does not exist; there is no such street. (Many of their filings use this misspelling. A Nantucket street does exist in Houston.)

Romerica Investments’ management information. Note the different names, addresses and positions for Mr. Covarrubias. Also note the different positions for Mr. Haddad and the misspelling of his street name. Google Maps street view shows rather expensive homes at this address, so “Suite C” seems odd.

Gabriel Miguel Haddad even registered Romerica Investments under the name Miguel Gabriel Haddad, flipping his first and middle names.

Company with Disconnected Phone Number Now Developing Multi-Billion Dollar Project

Dun & Bradstreet shows Romerica Investments as out of business. The company’s web site home page has shown “Future Home of…” for the last six years. After I pointed out some of these problems in previous posts, Manlove Advertising created a website suggesting that the Romerica Group will now develop the Kingwood Marina Project. See below.

Kingwood Marina website suggests that Romerica Group, not Romerica Investments will develop property. It also states that developers believe in “dialog with stakeholders,” but they have refused to meet publicly.

Here’s where the plot thickens. The Romerica Group does not legally exist in Texas. The Texas Secretary of State lists no such company. Romerica Group’s phone has been disconnected. The Group’s website contains broken links to other supposedly related companies, such as Romerica Real Estate. The Texas Real Estate Commission lists Romerica Real Estate as inactive. And their American Vision site as been linked by International Appraiser to fake projects seeking investments from foreigners in exchange for visas.

So Many Questions, So Little Time; Developers Refuse to Meet

These observations raise many questions. Despite the developers’ claimed “commitment to dialog with stakeholders at every level,” they have refused to meet publicly to answer questions before the end of the Army Corps’ comment period. I have personally requested a meeting by phone, email, or certified mail seven times in the last seven weeks – all to no avail.

Developers commonly use different companies to acquire, sell, or subdivide land. That doesn’t bother me. The fact that registrations for so many of these companies contain inconsistencies, inaccuracies, misspellings, wrong addresses, aliases, broken links, dead ends and disconnected phone numbers does concern me.

None of the companies shows projects they have completed. Sometimes one company lists another as the owner, but the companies may be incorporated in different states or different countries. Plus they’re selling:

My advice: Buyers beware. I use the term “buyers” in a global sense to include officials granting permits. I’m not buying any of this.

As always, these posts contain my opinions on matters of public policy which are protected by the First Amendment of the US Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted by Bob Rehak on February 14, 2019

534 Days since Hurricane Harvey

Manlove Changing High-Rise Website, but Problems Remain

Last night, I posted about some problems with the copy in the new website for the high-rise Kingwood Marina project. This morning, The Manlove Agency started changing the copy in many of the FAQs without explanation. Their disclaimer did not change, however.

I have screen captures of the original text. If anyone wants to see it, please email me.

Rather than do an hourly critique of the website, I’m going to give them a day or two to vet their facts. Then I will revisit it. Use extreme caution in the meantime. For instance,:

  • Their video still says they will have slips for 800 boats. But the Army Corps’ public notice states 640. A huge “disconnect”!
  • The copy still states that Romerica Group will now develop the property. The Texas Secretary of State has no listing for a Romerica Group. The phone number listed in their website is disconnected. And their name appears nowhere on the permit application.
  • The copy still says the development will be 364 acres although the Corps Public Notice states 331.
The developer has acquired all of the property in red, but only the portions marked Project Area are included in the current project.

Fixing One Problem Creates Another

Yesterday, I pointed out that raising the property to 57 feet would not make them flood safe. Manlove revised yesterday’s copy to suggest that the buildings will now have an additional five feet of fill beneath them. The developer will now raise them 17 feet above their current elevation, not 12 as stated in the original permit application. This would result in the loss of more than 1800 acre-feet of floodplain storage capacity and could impact surrounding communities.

Offending Copy About Permit Approval Removed

Manlove removed the copy about the City, County and Corps permitting the site for construction after finding no impact on surrounding communities. I confirmed with Harris County Flood Control that they never issued a permit for the property. The Corps is currently evaluating a permit. Hence, this public comment period. I’m confirming whether the City issued a permit to begin excavation.

No Public Meeting

The developers have refused to meet with the community to address the many concerns surrounding this project. I have personally tried SIX times to set up such a meeting. They agreed to have a private meeting with me. I said I would agree if I could videotape it. They refused. So the private meeting was cancelled, too.

As always, the content of this post represents my opinions on matters of public policy. Those opinions are protected by the First Amendment of the US Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted on February 13, 2019, by Bob Rehak

533 Days after Hurricane Harvey

High-Rise Developers Make New Claims, Give Themselves Most Generous Disclaimer in History of Words

The developers of the proposed high-rise development near River Grove Park launched a new web site today, In it, they make many new claims designed to put the public’s concerns to rest. It had the opposite effect on me. Why?

  • They told the Corps the Marina would hold 640 boats. It’s 160 boats larger now. The website video states 800.
  • The Army Corps thinks the development is 331 acres. The website claims 364.
  • After telling community leaders they would hold a public meeting before the close of the comment period, they now say after.
  • After previously touting their connections to an Italian architectural firm, Torrisi and Procopio (which I suspected was a fake site), they now say Skidmore Owings and Merrill (SOM) developed the design. But SOM in San Francisco referred me to their legal department, which did not take my calls. The Italian site was developed in English and registered in Aruba by a Canadian Company.
  • They now claim that a subsidiary of Romerica Investments, the Romerica Group, will develop the project. They claim Romerica Group has existed since 2007 and is located in Houston. The Texas Secretary of State has no listing for Romerica Group. Neither do Florida, Delaware or Alberta, Canada – other known locations where the developers have incorporated. The phone number listed on the Romerica Group website is disconnected. The office was unoccupied last time I checked several weeks ago.
  • “Romerica Group” does not appear on any of the permit applications associated with this project at the Army Corps, City of Houston or Harris County Flood Control.
  • Romerica Investments does not own the property being permitted.
  • They claim that 25-story condominium towers are single family homes. That’s the world’s largest family!
  • They say that only the northern half of the development is subject to height restrictions without offering any proof that “single-family residential” deed restrictions have been removed from the southern half.
  • They claim they’re creating a connection to Hamblin Road (sic), which the Corps Public Notice does not mention and no one in Forest Cove seems to know about.
  • They claim that “Both the city and county have approved construction and permits have been issued, they have determined that the community will not have an adverse effect on surrounding communities.” This makes it sound like they have been given permits for the entire development. Not true. Neither is the second half of the statement. Developers requested a permit to start excavating the marina. They promised they would haul excavated material offsite. However, things changed by the time the Corps issued its public notice. The public notice states that they will use the fill to raise the elevation 12 feet. Hmmm. Sounds like cause to revoke those permits to me!
  • They again claim that raising elevations to 57 feet will make the buildings flood safe when the area has flooded over 57 feet at least six times in the last 25 years.
  • They call roads an alternative mode of transportation!
  • They think ExxonMobil is spelled Exxon Mobile.

But the best part is this! Read the disclaimer. It’s the most self-generous disclaimer in the history of words. Nobody is responsible for anything the site says. Make sure you read the fine print.

Ain’t nobody responsible for nothin’.

As always, this post represents my opinions on matters of public policy. They are protected by the First Amendment of the United States Constitution and the Anti-SLAPP Statute of the Great State of Texas.

Posted by Bob Rehak on February 12, 2019

532 Days since Hurricane Harvey

History of Proposed High-Rise Property Tied to Flooding For Decades

Romerica Investments proposed high-rise marina property has a long history of flooding. In fact, the flooding which has gotten progressively worse through the years, has stymied one developer after another.

The property flooded 52 times since Lake Houston was built in 1955. That means it floods almost every year. And in the last year (February ’18 to January ’19). it flooded SIX times.

Timeline Shows Link Between Flooding, Sales, Lawsuit

As you review this chronology, clicking on the links will take you to the actual deeds. Here’s a timeline that shows how sales of the property relate to water and flooding. As you review it, remember all deed restrictions run with the land. That means they carry forward from one buyer to the next…unless the original entity imposing the restrictions consents to removing them.

Notice how subsequent transfers summarize restrictions in the earlier transfers: “This conveyance…is made and accepted subject to any and all … restrictions … relating to the property, but only to the extent that they are … shown of record in the herein above mentioned County…”

We could find no documents in county records removing the single-family residential restriction that Friendswood Development Company placed on the property. The developer has provided none to date.

Title and Flood History

  • 1950 – Foster Lumber Company sells 3200 acres to City of Houston for the purpose of creating Lake Houston.
  • 1955 – Lake Houston created.
  • 1973 – City of Houston sells two tracts of land not inundated by Lake Houston to Friendswood Development Company and King Ranch. City puts several deed restrictions on property. The significant ones: 1) No use that could alter the reservoir capacity of Lake Houston through fill or erosion. 2) Any fill must be compensated with excavation immediately adjacent to the fill. 3) City reserved the right to enforce pollution controls on activities up to the 51 foot contour elevation line. This is significant because it would include marina operations. The Lake and river normally pool at 42.5 feet back to the US59 bridge.
  • 1994 – In October, historic flooding hits area. Crest at US59 = 67.30 feet.
  • 1994 – On December 30, Friendswood and King Ranch sell property to Holley-Strother Kingwood Lakes Estates, LTD. Deed restrictions limit property use to “single family residential homes with accompanying greenbelt, park, pool, recreational facilities and for no other purpose or purposes” for a period of 40 years. Also, drainage cannot be altered in a way that affects surrounding property. Finally, before the developers could begin construction, they had to get a declaration of use restrictions affecting all the property approved in writing by the grantor. This would force homebuyers to abide by the deed restrictions, too.
  • 1998 – West Fork crests at 60.1 feet at US59 on 11/15.
  • 2001 – 2007 – River crests above 50 feet inundating Holley-Strother property seven times in seven years.
  • 2007 – June 18, FEMA approves new Flood Insurance Rate Maps (FIRMS). This put a large part of the Holley Strother property in the floodway for the first time. City of Houston also adopted a new ordinance that prohibited the City Engineer from permitting any buildings in a floodway.
Current flood map used by FEMA and CoH is dated 6/17/2007. Expansion of floodway (crosshatched area) kept Holley-Strother from developing land. COH rules prohibit building in floodway. Current developer appears to be rushing to get property permitted before flood maps are updated again. Updates will likely show all high-rise portion in floodway.
  • 2008 – West Fork floods and crests at 62.8 feet at US59 on September 18. Holley and Strother excavate a lake on the southern portion of their land to help build up the level of the Barrington, which is still under construction. On September 30, Holley and Strother sue the City. They claim that the City Ordinance against building in the floodway constitutes “illegal taking” of their land under the 14th amendment of the U.S. Constitution.
  • 2009 – 2012 – Floods above 50 feet inundate the property three more times.
  • 2015 – 2016 – Property floods SIX more times between March, 2015 and May, 2016. Highest crest at US59 is 61.95 feet on 5/29/16.
  • 2017 – On August 29, Hurricane Harvey sets new record for highest crest on the West Fork – 69.18 feet.

Questions Remain

And so history repeats itself. The current rush to beat redrawing of the flood maps reminds one of the events in 2007 and 2008.

I have numerous questions about this project. About the safety of building high rises in an old meander of the San Jacinto. About the wisdom of approving a permit to build such immense structures on the edge of the floodway – when we know the flood maps will soon be revised again. About expanding a marina toward the river when the river is migrating toward the marina at the rate of 20 feet per year.

Who are These People?

Meanwhile, I’m also struggling with questions about the developers. I’m struggling to understand the maze of companies, partnerships, addresses, and registrations in other states and countries. These two men have 19 entities here in Texas alone.

This raises so many questions that I hope the Corps extends the public comment period yet again until we can learn who these men are and where their money comes from. The community needs to understand who we are dealing with. But they have not yet consented to a public meeting despite numerous requests.

As always, these are my opinions on matters of public interest. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP statute of the great State of Texas.

Posted by Bob Rehak on February 6, 2019

531 Days since Hurricane Harvey

Rehak Letter about Proposed High-Rise Development Spells Out New Concerns

For the past six weeks, I’ve struggled to understand what the Army Corps considers when reviewing a new permit application. I have also struggled to organize everything I learned about the high-rise project, and the applicant. My protest letter re: Public Notice SWG-2016-00384 will be emailed today. It’s too long to include within the body of this post, so I’m going to include a summary here and a link to a PDF of the entire letter.

Water skiing, anyone? Photo by Sidney Nice of Atascocita Point after Harvey.
Imagine trying to evacuate 640 40-boats before a storm. The biggest threat to water quality is the one thing in this development that needs to be near the river: the marina.

Main Concerns

My main concerns are:

  1. This development appears to violate legally binding deed restrictions. We can find no documents registered with the county clerk that legally change allowable land use from “single family residential” to commercial, retail and hotel high rises.
  2. An article in International Appraiser lists these developers among EB-5 regional centers touting fake projects.
  3. Although the developers claim to have development experience, they have shown none. 
  4. Dunn & Bradstreet lists Romerica Investments, LLC (the applicant) as having no sales, no assets, no working phone, and being out of business. Romerica Investments also does not own the property for which it seeks the permit. 
  5. The developers many websites touting this project appear to violate rules from the SEC, FTC, FINRA, National Association of Realtors, and Texas Real Estate Commission governing real-estate investment advertising. See letter section 15 (e) XX on page 15.
  6. The developers are foreigners who operate through a maze of companies that makes it hard to understand whom the community is dealing with.
  7. The developers are being sued by investors for fraud. 
  8. They have provided no market research to demonstrate a need for this kind of development in the Kingwood area. The little market research we found raises serious concerns about their experience, due diligence, the feasibility of this project, and whether it would be economically viable.
  9. The developers propose to build high-rises in an area that will soon be reclassified as floodway. Moreover, the river is migrating toward this property at a rate that could soon destroy it. This raises significant concerns about public safety, flood risk, evacuation, and the stability of buildings.
  10. If approved, this development will destroy bald eagle habitat, impair water quality, increase erosion, and worsen flooding.
  11. Developers have not responded to multiple requests to meet to clear up questions.

Needs and Welfare of the People

Many environmental, wildlife, flooding, and conservation concerns have been expressed in previous letters by the Sierra Club, Galveston Bay Foundation, KSA and others. I recap most of those and add a few. But I also have spent much time researching a category called “Needs and Welfare of the People.”

One huge thing I believe we need: Confidence in the legitimacy of the developers.

Their refusal so far to appear at a public meeting to answer questions about their development raised red flags. I found many others. Four pages worth. See pages 16-19 in the letter. A small sampling:

The people of Kingwood don’t need another Gucci outlet as much as they need freedom from flooding. I therefore called for a moratorium on all flood plain permitting until flood mitigation measures can be put in place and safety restored.


Any one of these factors by itself might be sufficient to deny the permit request. Taken together, they leave no doubt; the negatives far outweigh any positives. According to Army Corps guidelines, the permit must therefore be denied. Too many questions remain unanswered about the developers and the development to approve this permit.

Sending Copies to Other Agencies

In addition to the Army Corps, I am copying:

  • TCEQ
  • Texas Parks and Wildlife Department 
  • US Fish and Wildlife Service
  • EPA
  • Congressman Dan Crenshaw
  • Senator John Cornyn
  • Senator Ted Cruz
  • Houston City Council Member Dave Martin
  • Harris County Flood Control
  • FBI

Only 3 Weeks Left to Register Your Objections

Deadline: March 1. If you haven’t yet sent your letter, please do so right away. Only 400 letters have been received so far by the Corps. Time is running out. You can download the full text of my letter. You can review and download other sample letters here. Feel free to copy any portions of the letters that reflect your concerns.

Or send them in their entirety and say, “I agree!” Here’s a customizable word.doc that you can download and send. Remember to insert your name and contact information on the first page and your name again on the last page. You can then send it by clicking on the links in the letter.

I am sending my letter only in a digital format because of all the hyperlinks embedded in it.

Emailed Letters Preferred

The recipients have expressed a desire for electronic versions over paper copies anyway. Electronic makes it easier for them to forward and file the documents; no scanning necessary.

As always, the thoughts in the letter and this post represent my opinions on matters of public interest. They are protected by the First Amendment of the United States Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted on February 9, 2019 by Bob Rehak

529 Days since Hurricane Harvey

High-Rise Property May Be Deed Restricted to Single-Family Residential

A search for deed restrictions on property proposed for high-rise development turned up some huge surprises today. I had previously posted about height restrictions within Friendswood Commercial Development Guidelines. It turns out that the Friendswood Commercial Development Guidelines do not apply in this case – because the property was restricted to single-family residential. Specifically, I’m talking about the section of land circled below. It’s just south of the Barrington subdivision in Kingwood.

This post deals only with the section in red where most of the high rises will go, but deed restrictions also exist on other related parcels of land in the proposed development.

Relevant Property History Starts in 1994

Some concerned residents and I conducted a title search with the help of the County Clerk’s website and a friendly title company. The land in the circle has changed hands twice since 1994. Friendswood Development company sold it to Holley-Strother Kingwood Lake Estates, Ltd. on December 30, 1994. Holley and Strother sold it to the current owners in 2012. The land has actually been sold more than twice, but only among companies controlled by the same individuals. It’s also been the subject of an eight year law suit related to flood plain issues. More on those items in subsequent posts.

Key Elements of Deed Restrictions

Deed restrictions in the first sale specify four key elements:

  • Single-family residential
  • Compatible architecture in harmony with structures on adjoining land.
  • No alteration of drainage for surrounding areas
  • Applies to all subsequent buyers for a period of at least 40 years (until 2036)

Here’s actual language for the first two:

Screen capture of paragraph 5 from the deed.

What Developer Wants to Build

According to the US Army Corps of Engineers Public Notice, Romerica Investments, LLC has applied for a permit to construct commercial, condominium and hotel towers up to 500 feet high on a 25 acre parcel. Here’s a scale drawing that shows what this would like compared to the Barrington if permitted. You can see examples of what they plan in this video posted on an architect’s website.

That hardly looks like single-family residential housing. I talked to experts in city planning, real estate and sales. They all agreed that “single family residential” usually means “one family in one structure on one lot.”  

Drainage Deed Restrictions, Too.

Hindering or obstructing existing drainage channels or ditches, which serve adjoining property owners – without the written consent of the owners – is also prohibited. (See Paragraph 8.)

The Corps’ public notice also states that the developer plans to put “285 cubic yards of fill into 771 linear feet of streams adjacent to the West Fork of the San Jacinto.” That would seem to be another deed restriction violation.

I’m not sure about you, but I moved to Kingwood, a master-planned community, because deed restrictions ensured these kinds of things did not happen.

To my knowledge, the developers have not even attempted to gain permission to disrupt drainage from other villages, such as Kingwood Lakes, Deer Cove, Trailwood and Barrington.

Deed Restrictions Binding on Successors

Another key clause in the deed restrictions reads:

Deed restrictions normally “run” with the land. Said another way, when the first buyer sells the land to a second buyer, the second buyer must abide by the same restrictions that the first buyer had, and so forth in perpetuity. Subsequent buyers may add restrictions, but not remove them without the consent of the ORIGINAL grantor. The original grantor in this case was Friendswood Development Company.

Click here to download the complete deed restrictions.

No Documents Found Removing Restrictions

We could find no recorded documents on the County Clerk’s web site or in a title search that removed deed restrictions on this property. A former Friendswood executive told me, “If there is not a recorded document removing the restrictions, then they have not been removed.” So…

The Burden of Proof is on the Developers

I am requesting the developers to show the legally recorded document that removes the deed restrictions. However, so far they have not responded to my certified mail or phone calls requesting a public meeting.

The Corps informed me yesterday that the developer has designated Leah Manlove Howard of Manlove Advertising and PR as their new point of contact. Her contact information is:

Romerica Investments, LLC
One Performance Drive
Angleton, TX 77515
Telephone: 281-487-6767
POC: Ms. Leah Manlove Howard

This raises so many questions that I hope the Corps extends the public comment period yet again. The community needs to understand who we are dealing with.

As always, these are my opinions on matters of public interest. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP statute of the great State of Texas.

Posted by Bob Rehak on February 6, 2019

526 Days since Hurricane Harvey

Will High-Rise Marina Project Meet Army Corps’ Criteria for “Needed”?

As we saw in a previous post, Army Corps regulations stipulate that a developer must prove there is a need for his/her project before destroying wetlands. Further, the Corps assumes that the developer has done due diligence in assessing market conditions.

“Has Romerica Investments done due diligence? Is this project needed?” In my opinion, the answer is no. It consists of condominiums 65-feet high in the flood plain, plus 25-50 story retail, commercial and hotel structures arranged around a marina. That marina is in the floodway of the San Jacinto River’s West Fork.

Looking northwest from the southeastern tip of the proposed high-rise marina district Imagine 50-story high rises in the narrow strip of land between the lake and the Barrington in the background. Look below to see the scale.

But growth in the Humble ISD has slowed from 6% to 1% because of concerns over flooding. The number-one need we have now is to restore safety by mitigating flood risk. This project will worsen flood risk and there is little demand for it – especially in this location. The Corps should deny this permit until the safety of the community can be assured.

Drawn to vertical scale.

The developer plans to build more than 3 million square feet of hotel, commercial, retail and residential space in the floodplain. Yet, since Harvey, we can’t fill all the homes we have – even those on higher ground. About a quarter of the retail space in Town Center and King’s Harbor is still vacant. There’s little demand for commercial space. And existing hotels can handle travelers just fine, thank you.

Previous Attempt to Build Retail Mall in Kingwood Failed

It’s also hard to see how Kingwood’s population would support another shopping mall and theater. We already have a major 1.2 million SF regional mall right across the river in Humble. We also have three theaters with 44 screens within 5 miles. Also, consider that online shopping and streaming services, such as Amazon and Netflix, are stealing market share from malls and movie theaters all over America.

A previous attempt to build a small mall in Kingwood resulted in abject failure. The mall was on the southwest corner of Kingwood Drive and US59. After sitting vacant for years, HCA bought the structure and converted it into a community hospital.

Market Review Does Not Consider Location-Specific Factors

The market review conducted by the applicant mentioned none of this. It focused on job growth in Texas and Houston. It totally ignored the local Kingwood market and site-specific considerations. Conducted before Harvey, the survey has NOT been updated to reflect flooding concerns.

That said, most existing homes and businesses in Kingwood are on much higher ground. Raising this project 12 feet above its current elevation to 57′ won’t raise it out of harms way. Far from it. We’ve had six floods higher than that since 1994 – an average of one every FOUR years. That’s an increase over the previous 65 years when we had just three – one every 22 years..

The build-it-and-they-will-come mentality in post-Harvey Houston invites disappointment down the road. It will create white elephants that leave permanent scars on the landscape after destroying the fragile wetlands that we so desperately need to absorb and store floodwaters.

Raising Elevation Will Raise Costs

However, raising the entire project 12 feet WILL raise costs. And therefore, it will price sales and rentals far above the rest of the market – in an area (i.e., floodplain) that people are wary of after Harvey.

In my opinion, the combination of higher costs, less demand, less traffic, remote location, and local opposition will doom this project from the start.

Incomplete Market Analysis

The developer’s market conditions report looks only at economic growth projections for the State of Texas and City of Houston.

  • It does not include any evaluation of local Kingwood-specific factors, such as occupancy rates. 
  • It includes no staples of market analysis such as traffic counts or trading radius.
  • It does not consider the feasibility of anchor attractions, such as the marina and retail mall. For instance, can the West Fork even accommodate the volume and size of boats in the marina? Will retailers support a mall at the end of a dead-end road, four miles from the nearest highway, devoid of any through traffic, that floods every time we get four inches of rain?
  • It says comparable projects around the country were surveyed, but makes no mention of them. It contains no competitive analysis.
  • It reads like a prospectus targeted at investors, but contains no mention of risk.
  • The authorship of the analysis is redacted; we do not know who conducted the survey or what credentials they have.
  • Finally, it contains no mention of flooding or Harvey. 

These omissions feel like serious flaws in Romerica’s market analysis. The Corps should not approve a permit based on such work. There is no demonstrable need to destroy these wetlands.

Posted by Bob Rehak on 2/1/2019

521 Days since Hurricane Harvey

How Corps Will Evaluate High-Rise Permit Application

Romerica Investments, LLC has applied for a permit to build a high-rise development in the floodplain of the San Jacinto River. They call the proposed development the Kingwood Marina Project. Because it involves adding 12 feet of fill material to the floodplain of the San Jacinto River, the Army Corps of Engineers has become involved. The Corps rules on any permit application that involves “discharge” of fill into “waters of the United States.”

Proposed layout for the Kingwood Marina Project.

The fill would stretch approximately three quarters of a mile from north to south along Woodland Hills Drive and approximately .85 miles from east to west on both sides of the Barrington. If you want to know what the Corps considers when making such rulings, or why and how the TCEQ interprets “water quality” for them, read on.

Public Interest Review

As a result of several recent laws and judicial decisions, the Corps’ permitting process has evolved to include consideration of the full public interest by balancing favorable impacts against detrimental impacts. This is known as the ‘‘public interest review.’’ We are at that stage now.

The Corps’ main criteria for evaluating applications includes four high-level considerations:

  • Need for the project
  • Extent and permanence of detrimental effects
  • Effect on wetlands
  • Relative weight of various additional factors

The additional factors below also apply to the proposed High-Rise Kingwood Marina Project:

  • Conservation
  • Economics
  • Aesthetics
  • General environmental concerns
  • Historic, cultural, scenic, and recreational values.
  • Fish and wildlife values
  • Flood hazards
  • Floodplain management
  • Land use
  • Navigation
  • Shore erosion and accretion
  • Recreation
  • Water supply and conservation
  • Water quality
  • Safety
  • Considerations of property ownership
  • Needs and welfare of the people

Public Interest Described in More Detail

“All factors which may be relevant to the proposal must be considered,” says the intro to Corps regulations on page 398. The regulations (33 CFR 320-332) then go into more detail on many of these factors. The regs elaborate on dozens of things that the law requires the Corps to evaluate.

Here’s my summary and interpretation of those that likely apply. Keep in mind that I’m looking at these with the proposed Kingwood Marina high-rise project in mind. So I have omitted some items that do not apply, such those for coastal developments. For the exact text of each, consult this Department of the Army legal document. I am not a lawyer and do not offer legal advice.

The regulations start with a discussion of four high-level, over-riding factors. 

The first thing reviewers look at is the “need for the project.” If needed, they then consider the extent and permanence of any detrimental effects relative to any benefits that the project provides.

In that regard, wetlands play a major role and get special mention. But the Corps also reviews the 17 other factors listed above that have to do with “the public interest.” Then they weigh them all – pros and cons. Something that’s very important on one project may carry no weight on another. The reviewers have wide latitude to use their own judgment.

What Does the Army Corps Consider Value of Wetlands to Be?

Section 320.4 B (2) I-iviii on page 398 states: Wetlands perform functions important to the public interest, such as:

  • Providing nesting, spawning, and rearing space for animals, birds and fish
  • Moderating natural drainage, sedimentation, salinity, flushing, and other environmental benefits
  • Shielding other areas from erosion or storm damage 
  • Storing storm and flood waters
  • Purifying water 
  • Providing unique natural value to a local area

Further section B (3) recognizes that although a particular alteration of a wetland may constitute a minor change, the cumulative effect of numerous piecemeal changes can result in major impairment of wetland resources. This section seems to say, “We can afford to lose some wetlands, but at a certain point, “Enough is enough!”

The Corps looks at each wetland as part of a complete and interrelated wetland environment. 

Corps Consults Others on Wetlands

The district engineer may undertake, where appropriate, reviews of particular wetland areas in consultation with the:

  • Regional Director of the U. S. Fish and Wildlife Service
  • Regional Director of the National Marine Fisheries Service of the National Oceanic and Atmospheric Administration
  • Regional Administrator of the Environmental Protection Agency
  • Local representative of the Soil Conservation Service of the Department of Agriculture
  • Head of the appropriate state agency to assess the cumulativeeffect of activities in such areas (TCEQ and/or TPWD).

The district engineer may conclude that the benefits of a project outweigh the damage to wetlands. However, when evaluating whether wetlands can be filled, the engineer must consider the guidelines in the Clean Water Act (Section 404(b)(1) guidelines (40 CFR part 230.10(a) (1), (2), (3)).

In addition, state regulatory laws or programs for classification and protection of wetlands must be considered.

Fish and Wildlife Considerations

In accordance with the Fish and Wildlife Coordination Act (paragraph 320.3(e) of this section) district engineers must consult with:

  • The Regional Director, U.S. Fish and Wildlife Service
  • The head of the Texas Parks and Wildlife. 

The engineer must consider conservation of wildlife resources and preventing harm to them due to proposed permit activity. The Army must give full consideration to the views of those agencies when deciding whether to issue, deny or condition permits.

Water-Quality Considerations

Applications for permits for activities which may adversely affect the quality of waters of the United States will be evaluated for compliance with applicable effluent limitations and water quality standards, during the construction and subsequent operation of the proposed activity. The evaluation should include the consideration of both point and non-point sources of pollution. The Clean Water Act assigns responsibility for control of non-point sources of pollution to the states. In our case, that’s the TCEQ.

Scenic and Recreational Values

Full evaluation of the general public interest requires that due consideration be given to the effect which the proposed structure or activity may have on values such as those associated with scenic rivers.

Consideration of Property Ownership

Authorization of work or structures by the Corps does not convey a property right. Nor does it authorize any injury to property or invasion of others’ rights.

An inherent aspect of property ownership is a right to reasonable private use. However, this right is subject to the rights and interests of the public in the navigable and other waters of the United States. It includes environmental protection.

Because a landowner has the general right to protect property from erosion, applications to erect protective structures will usually receive favorable consideration. However, if the protective structure may cause damage to the property of others, adversely affect public health and safety, adversely impact floodplain or wetland values, or otherwise appears contrary to the public interest, the district engineer will so advise the applicant and inform him of possible alternative methods of protecting his property. 

A landowner’s general right of access to navigable waters may not create undue interference with access to, or use of, navigable waters by others. If it does, the authorization will generally be denied.

The applicant’s signature on an application is an affirmation that the applicant possesses or will possess the requisite property interest to undertake the activity proposed in the application

In the absence of overriding public-interest factors that may be revealed during the evaluation of the permit application, a permit will generally be issued. But first, the engineer must receive favorable state determination. That state determination must take into account:

Similarly, a permit will generally be issued for Federal and Federally-authorized activities; another federal agency’s determination to proceed is entitled to substantial considerationin the Corps’ public interest review.

Threatened Species

The Endangered Species Act (16 U.S.C. 1531 et seq.) declares the intention of the Congress to conserve threatened and endangered species and the ecosystems on which those species depend. The Act requires that federal agencies, in consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service, use their authorities in furtherance of its purposes by carrying out programs for the conservation of threatened species, (editorial comment: such as the bald eagle which nests and feeds near this property).

Floodplain Management

Floodplains possess significant natural values and carry out numerous functions important to the public interest. These include:

  • Water-resources value (natural moderation of floods, water quality maintenance, and groundwater recharge);
  • Living-resource values (fish, wildlife, and plant resources);
  • Cultural-resource values (open space, natural beauty, scientific study, outdoor education, and recreation); and
  • Cultivated-resource values (agriculture, aquaculture, and forestry).

Although a particular alteration to a floodplain may constitute a minor change, the cumulative impact of such changes may result in a significant degradation of floodplain values and functions and in increased potential for harm to upstream and downstream activities.

Executive Order 11988 and Floodplains

In accordance with the requirements of Executive Order 11988, district engineers, as part of their public interest review, should avoid to the extent practicable, long and short term significant adverse impacts associated with the occupancy and modification of floodplains, as well as the direct and indirect support of floodplain development whenever there is a practicable alternative. For those activities which in the public interest must occur in or impact upon floodplains, the district engineer shall ensure, to the maximum extent practicable, that the impacts of potential flooding on human health, safety, and welfare are minimized, the risks of flood losses are minimized, and, whenever practicable the natural and beneficial values served by floodplains are restored and preserved.

In accordance with Executive Order 11988, the district engineer should avoid authorizing floodplain developments whenever practicable alternatives exist outside the floodplain.If there are no such practicable alternatives, the district engineer shall consider, as a means of mitigation, alternatives within the floodplain which will lessen any significant adverse impact to the floodplain.

Water Supply and Conservation

Water is an essential resource, basic to human survival, economic growth, and the natural environment. Water conservation requires the efficient use of water resources in all actions which involve the significant use of water or that significantly affect the availability of water for alternative uses including opportunities to reduce demand and improve efficiency in order to minimize new supply requirements. Actions affecting water quantities are subject to Congressional policy as stated in section 101(g) of the Clean Water Act which provides that the authority of states to allocate water quantities shall not be superseded, abrogated, or otherwise impaired.


Protection of navigation in all navigable waters of the United States continues to be a primary concern of the federal government.

District engineers should protect navigational and anchorage interests in connection with the NPDES (National Pollutant Discharge Elimination System) program by recommending to EPA or to the state, if the program has been delegated, that a permit be denied unless appropriate conditions can be included to avoid any substantial impairment of navigation and anchorage.

The NPDES permit program addresses water pollution by regulating point sources that discharge pollutants into waters of the United States.

Environmental Benefits

Some activities that require Department of the Army permits result in beneficial effects to the quality of the environment. The district engineer will weigh these benefits as well as environmental detriments along with other factors of the public interest.


When private enterprise makes application for a permit, it will generally be assumed that appropriate economic evaluations have been completed, the proposal is economically viable, and is needed in the market place.However, the district engineer in appropriate cases, may make an independent review of the need for the project from the perspective of the overall public interest. The economic benefits of many projects are important to the local community and contribute to needed improvements in the local economic base, affecting such factors as employment, tax revenues, community cohesion, community services, and property values. Many projects also contribute to the National Economic Development (NED), (i.e., the increase in the net value of the national output of goods and services

Deadline for Comments Extended to March 1

Because of the prolonged government shutdown, the Army Corps has extended the deadline for public comments on the proposed Kingwood Marina high-rise development.

Comments and requests for additional information should reference USACE file number, SWG-2016-00384, and should be submitted to:


Evaluation Branch, North Unit
Regulatory Division, CESWG-RD-E
U.S. Army Corps of Engineers
P.O. Box 1229
Galveston, Texas 77553-1229
409-766-3869 Phone
409-766-6301 Fax


The TCEQ will evaluate water quality issues for the Corps. You can email water quality comments to  Please ensure that all comments reference USACE permit application no. SWG-2016-00384.

Rehak Comments To Follow

As I have studied the Corps’ and TCEQ’s decision-making processes and criteria, I have also studied possible impacts of the proposed high-rise project. I intend to send my comments to the Corps, TCEQ, Texas Parks and Wildlife, the US Fish and Wildlife Service and the EPA. I will publish those when complete – hopefully by the end of this week.

As always, these represent my opinions on matters of public policy. They are protected by the First Amendment of the U.S. Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted by Bob Rehak on 1/31/2019

520 Days since Hurricane Harvey