Public Comment Period for TWDB State Flood Assessment Closes October 3

The TWDB (Texas Water Development Board) has completed its first statewide assessment of flooding. The public comment period on the first draft is open now, but closes on October 3.  That’s next Wednesday at 5pm. I plan to write about what I believe is an error of omission. You may have other concerns. One thing is certain. If something isn’t in the report, legislators won’t give it a high priority in the next session.

What/who is TWDB?

The Texas Water Development Board (TWDB) provides leadership, information, education, financial assistance, and support for planning,  conservation and development of water resources throughout the state.

First Draft of Statewide Flooding Study

The TWDB just finished a draft of its first statewide assessment of flood risks, planning, and mitigation, and is seeking public comment.

Download the 69-page report here.

The cover note on page one says, “Your information and thoughts on flood mitigation in our state are vital to this first comprehensive assessment on flooding in Texas. As such, please consider taking part in the public review and comment period on the Draft State Flood Assessment.”

“Your input will inform decision-making regarding the need for, and benefits of, future flood planning and financial investment.”

The public review and comment period ends at 5:00 p.m. on October 3, 2018. You can email comments to:

The executive summary states the main reasons for and conclusions of the report:

  • Flooding has never been assessed at the statewide level.
  • Flood risks pose a serious threat to lives and livelihoods.
  • Much of Texas is either unmapped or uses out-of-date maps, leading to widespread
  • confusion.
  • Rainfall drives most flood events in Texas, but the rainfall data used to inform planning
  • and design are decades old.
  • Texas does not have a statewide strategic plan to address flood risk management.
  • Significant funding is required to mitigate flooding in Texas.
  • Stakeholders identified the need for additional resources directed toward floodplain
  • management and mitigation.
  • Sound science and data are the core elements of effective planning and flood mitigation.

Other Key Findings

Several things jumped out at me. One that hit home on page 26 said, “Local hazard mitigation planning … is not sufficiently scoped to provide collaborative, watershed-based strategic flood planning.”

Another on page 26 also resonated. “Only half of stakeholders reported that their jurisdiction has identified flood risk and conducted local planning efforts to develop mitigation solutions.” The Lake Houston area suffers from this problem. We are affected by Montgomery County which has no flood control district. And until recently, the SJRA had no flood mitigation division. The SJRA is trying to launch a watershed-wide study on flood mitigation, but has been trying to cobble together funding for it since March.

On page 32, the report addresses another issue that has plagued our area. It draws the distinction between planning for water supply and flood control, and the confusion between the two. Remember the protestations of the SJRA about Lake Conroe NOT being a flood control reservoir?

Floodplain Mapping, Planning and Sedimentation

The report includes very little discussion of sedimentation and its role in flooding. Chapter 4 discusses floodplains and mapping. In regard to riverine flooding, it states, “The boundaries of a natural floodplain change with each flood event as sediments are scoured and deposited within the river channel and upon adjacent lands.”

Chapter 5 also briefly mentions sedimentation in regard to planning. On Page 26, the report states that TWDB works with farmers to control sediment. However, there is no mention of sand mining in floodways, a major omission in my opinion.

Flood Mitigation

Chapter 6 on page 33 begins the discussion of flood mitigation activities. Generally, they fall into two categories: structural and non-structural. The chart below indicates the type of activities discussed by stakeholders during input sessions. The size of the rectangles indicates the frequency of responses.

Rectangle size represents frequency of responses when asked about flood mitigation activities.

Sadly, there is no mention of sediment control in regard to flood mitigation. Such omissions, represent, in my opinion, the biggest flaw in this first draft and merit public comment.

Anticipated statewide mitigation costs range from $31.5 to $36.0 billion. However, there is a statewide flood funding shortfall of $18.0 to $26.6 billion after subtracting available funds. You can draw your own conclusions from that.

The remainder of this chapter discusses funding issues.

Confusing Roles and Responsibilities

Chapter 7 discusses other barriers to implementing flood mitigation programs. They include:

  • Lack of access to local match funding sources. Only 20% of communities have a funding source for local match requirements of grant programs.
  • Confusing funding options. Currently five state agencies and five federal agencies share responsibilities for administering 16 funding programs.
  • Complicated application processes. 42 percent of stakeholders requested additional technical training and guidance in navigating the complex deadlines, requirements, and paperwork associated with both state and federal funding programs.
  • Lack of staffing. Stakeholders said insufficient staffing at all levels of government slows down the flood mitigation process. Chokepoints exist at every step of project timelines which exacerbate this issue.
  • Lack of training. No state-level requirement exists for training or certification of floodplain administrators or others with flood-related responsibilities. This problem is especially acute in rural areas. Respondents from small communities report difficulty in attending classes because of a lack in staff availability, travel funding, or related resource constraints.
  • Prolonged timelines. Project timelines for flood mitigation grant programs can take anywhere from months to years between the start of an application to the start of construction or project implementation (if non-structural). The more complex the processes, the lengthier the application review and disbursement period. Stakeholders expressed frustration with this aspect of project implementation, requesting more streamlined processes and increased transparency.

If this sounds familiar, perhaps its because I blogged about it months ago.

What I Plan to Do

Studies like these become legislative guides. If there’s no focus on sedimentation, the problem doesn’t merit debate in the next session. So…

I plan to write and ask them to include a paragraph about how excessive sedimentation contributed to flooding on the San Jacinto and how sand mines in floodways exacerbated that problem.

As always, these are my opinions on a matter of public policy, protected by the First Amendment of the United States Constitution and the Anti-SLAPP statute of the Great State of Texas.

The email address is: I would put Statewide Flood Assessment Public Comment in the subject line to ensure your thoughts are filed correctly.

All comments received by the deadline (Wednesday at 5pm) will be considered. For more information, visit If you have any questions, please contact Dr. Mindy Conyers of TWDB’s Surface Water staff at 512-463-5102.

Posted on September 30, 2018 by Bob Rehak

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