City Defends RV Park Permit Despite Deficiencies

The City of Houston defended its permitting of the Kingwood Area’s first RV Park despite deficiencies in the process. The City claims the Laurel Springs RV resort meets old “grandfathered” standards. But concerned Lakewood Cove residents worry that the development does not meet current needs. They expressed concerns that:

The developer filed false information
Is building a detention pond that will only hold half the volume of current requirements
Did not document the impact of overflow from that undersized pond in a two paragraph drainage impact analysis
Said that overflow from the undersized pond would be funneled toward Lakewood Cove despite a regulation requiring that excess stormwater not cross adjoining private property lines.
Is building 226 RV pads with a permit that allows 182.
The amount of impervious cover in the plans did not change despite the addition of 25 percent more spaces.
The volume of the detention pond decreased during the review process.
The plans were not reviewed by a professional engineer (PE).

Below, read a summary of the City’s responses to each of these alleged deficiencies. To verify my summary, I’ve also included a PDF of the City’s entire response.

Filed False Info

The City did not really address this concern except to say that false information was filed by an agent who had no hand in the engineering. Apparently, filing false information under penalty of perjury is not an issue if you hire an agent.

Half the Detention Volume of Current Requirements

Despite getting the plans approved in October 2021, after detention requirements increased, the developer only had to meet 2020 requirements under a grandfathering clause based on the submission date (not the approval date) of the plans. So plans comply with the old requirements but not the current ones. Despite building a half-sized detention pond, the City still insists overflow won’t be a problem – except in a 100-year storm. The City ignores the fact that the pond is designed to hold a 100-year rain under older, lower standards.

*Several of the 380 Elm Grove homes that flooded on May 7, 2019, and a City High Water Rescue Vehicle.*

This is the same problem that happened in Woodridge Village, Elm Grove and North Kingwood Forest in 2019.

On May 7, 2019, Woodridge received 7.9 inches of rainfall – less than half of Atlas 14 expectations. Still 380 structures in Elm Grove and North Kingwood Forest flooded according to HCFCD.

In that case, the plans also met old requirements that had not increased to meet current rainfall expectations. The same Public Works Department that approved the drainage plans for Woodridge Village approved the Laurel Springs RV Resort plans.

Sketchy Drainage Impact Analysis

I’ve requested the full drainage impact analysis on three occasions. The City alludes to one, but still has not produced it. Instead, the City points to a two paragraph summary and seems satisfied with it. The City focuses primarily on the volume of water pumped into Lakewood Cove’s storm sewer system. It claims that if water overflows into people’s homes that will be due to a deficiency in how the Lakewood Cove lots were graded.

Where Will Overflow Go

The developer says that overflow from the undersized detention pond will go east toward Lakewood Cove (left in picture below) and then down a hill into Lakewood Cove’s detention pond near Hamblen Road. But the City says the opposite. It claims overflow will go west toward the Union Pacific railroad tracks (right in picture below). From there, sheet flow would go down into the County’s new Edgewater Park. The City did not express any concern about erosion of the track bed. But one wonders whether erosion could destabilize the railroad tracks which carry toxic chemicals.

*Laurel Springs RV Resort next to UP Railroad tracks and Utility Easement. City says overflow from pond at far end of clearing will be funneled toward tracks*, *even though developer says the opposite.*

*Woodridge Village erosion caused by half of the estimated amount of a current 100-year rain.*

Increase in RV Spaces

The developer changed the plans from 182 to 226 RV pads. The City approved with no further explanation. Nor did the City address the issue of a potential conflict with the permit.

No Increase in Impervious Cover

The City claims that when the number of spaces increased 25%, impervious cover did not and that calculations are still accurate. Public Works did not explain the apparent contradiction.

Decrease in Volume of Detention Pond

According to the City, the original detention-pond volume approved by the City must have been an “approximation” by the developer’s engineer. Even though the number decreased in final versions of the plans as the number of RV pads increased 25%, the City claims the developers still exceed the minimum detention requirements under the grandfathered 2020 regulations. They never address what will happen if rainfall exceeds 2020 assumptions, as it certainly will.

No Review by Professional Engineer

The City says reviewers work under the supervision of a professional engineer (PE), but PE’s do not actually review plans.

Summary

In summary, the City claims it didn’t make any mistakes. If homes flood, homeowners will be at fault because their sites must not be graded properly.

I wrote the City weeks ago about the potential erosion of the Union Pacific railroad tracks and still have not received a reply.

This seems to be a case of bureaucrats reviewing plans for literal compliance and ignoring the dangers of real-world deficiencies. If the higher requirements in 2021 regulations are not important, why did the City adopt them?

Here is the entire text of the letter sent by Lakewood Cove residents and the City’s responses, embedded in colored type.

Posted by Bob Rehak on 12/8/2021

1562 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.