Hallett Sand Mine complex on San Jacinto West Fork.

Last Chance to Reduce Flood Risk from Sand Mining

1/24/25 – Only hours remain to reduce your flood risk from sand mining.

The public comment period for the Texas Commission on Environmental Quality’s (TCEQ) proposed new best management practices (BMPs) for sand mines closes tonight at 11:59 PM. As of this morning, fewer than 200 people statewide had left comments. That’s less than 1% of all the homes and businesses that flooded in the Lake Houston Area alone.

Small Response Says People No Longer Care About Flooding

And that’s a pathetically small number considering sand mining’s contributions to flooding in this area. Sediment released from the mines during floods accumulates at the mouths of rivers streams and ditches, blocking drainage. Accumulated sediment also reduces the conveyance of rivers and streams.

Blockages and reduced conveyance contributed to an estimated billion dollars in damages during Harvey. They have also cost almost $200 million to dredge in the last five years.

Yet the new BMPs do nothing to address this problem. They show the heavy hand of lobbyists on a state agency eager to create the appearance of public protection.

What We Need

In my opinion, the mines need to be on higher ground, farther from rivers. And the setbacks need to retain their natural vegetation. This will reduce the chances of:

  • Erosion at greater than natural rates
  • Rivers migrating into mines over time
  • Pit capture (That’s when a river starts flowing through a mine pit.)
  • Floodwaters inundating the mines and carrying off sediment
  • Downstream sediment accumulations that contribute to flooding homes and businesses.
Hallett and surrounding mines on the San Jacinto West Fork on May 3, 2024. This was during what amounted to a 2- to 10-year rainfall, according to HCFCD. However, flood levels downstream reached 100-year levels, a testament to the reduced conveyance of the West Fork.

The dikes around sand mines are supposed to protect them in a 100-year flood. But as you can see in the photo above, it doesn’t really work that way.

Submitting Your Comment Should Take Less Than 2 Minutes

Please help. Submit public comments to the TCEQ that urge them to include BMPs that address better sediment control.

Here’s how. It should only take a minute or two. Follow these simple steps.

  1. Copy the text between the two lines below.
  2. Go to the TCEQ web page for submitting comments.
  3. Paste the text into their webform or use your own words.

RE: APO BMP List Proposal

TCEQ’s proposed list of Best Management Practices for Aggregate Production Operations completely ignores mining issues that contribute to flooding in the Houston area.

Most mines on the East and West Forks of the San Jacinto were inundated last year in what amounted to 2- to 10-year rainfall. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people. 

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

I also support the concerns and list of alternative BMPs proposed by Texans for Responsible Aggregate Mining.


Hurry. There are only hours left. So please don’t put this off. Your voice could make a difference for thousands.

west fork mouth bar before dredging
West Fork mouth bar formed during Harvey and was 8-10 feet above water line in place. Picture taken before dredging. This backed water up into the Humble/Kingwood/Atascocita Area.

Posted by Bob Rehak on 1/24/25

2705 Days since Hurricane Harvey