New TCEQ Sand Mining BMPs Ignore Pit Captures
12/13/24 – Proposed new Texas Commission on Environmental Quality (TCEQ) Best Management Practices (BMPs) for sand mines ignore what miners are supposed to do in the case of pit captures. “Pit capture” happens when a river breaks through the dikes of a sand mine. It can have serious consequences including, but not limited to:
- Increased erosion and river instability
- Altered hydrology
- Water quality degradation
- Habitat loss and ecosystem disruption
- Infrastructure risks
- Channel realignment
- Economic impacts (cost of mitigation)
Identifying Pit-Capture Pros and Cons
In some circumstances, pit capture can also produce benefits. The balance between benefits and risks depends on the specific geomorphological and ecological context of the river and the sand mine pit. To maximize benefits while mitigating risks, scientists recommend:
- Performing a hydrological and ecological assessment before and after capture.
- Using adaptive management strategies to guide the development of the captured pit.
- Integrating the site into regional plans for flood control, habitat creation, or recreation.
However, the new TCEQ sand mine BMPs mention no such studies, despite the fact that at least six pits were captured on the East and West Forks of the San Jacinto during floods this year. Plus, consider this. The City is getting ready to spend another $34 million to dredge another million cubic yards of sand from the confluence of the two forks.
Instead, the new TCEQ BMPs emphasize concepts under headings such as “Be a Good Neighbor,” “Practice Good Housekeeping,” and “Select Appropriate Equipment.” This is stuff most guys learned in a middle school shop class. Under “Good Housekeeping,” one recommendation urges miners to adequately maintain sanitary facilities. But they forgot the “Wash hands after using a port-a-potty” requirement.
My overwhelming impression after reading the new BMPs was a yawn. Why bother?
The new BMPs are more notable for what they don’t include than what they do include.
And they don’t include anything about the B-52 sized elephant in the broom closet – pit capture.
I discovered the pit capture above in June of this year. It likely occurred in the May flood. And Hallett has done nothing to mitigate it since.
Perhaps they and the TCEQ feel the benefits outweigh the consequences. But of course, they aren’t footing the $34 million dredging bill.
In August of this year, TCEQ issued a report on another pit capture slightly downstream from here. It didn’t mention this pit even though it was open at the time and multiple people filed complaints. Nor did it mention the term “pit capture.” And the report made several other mistakes. For instance, Hallett claimed the expert witness TCEQ identified works for them, the but the TCEQ listed the employee as working for a Hallett competitor. No wonder the Texas Sunset Commission called TCEQ a reluctant regulator.
Leave a Public Comment
So what’s a mere citizen who enjoys clean water to do?
The TCEQ is soliciting public comment on their new BMPs for sand mines. I know what my comment will be about. If you wish to leave a public comment:
Feedback or comment must be provided to Jess Robinson, MC 175, Office of Legal Services, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087. Comments may also be submitted electronically. To be considered for this project, input must be received by 11:59 p.m. on January 24, 2025, and should reference “APO BMP List Proposal.”
Posted by Bob Rehak on 12/13/24
2663 Days since Hurricane Harvey
