Ryko land

Lengthy Catalog of Concerns about Proposed Ryko Development

4/25/25 – A company called Ryko has proposed building a 5,500 acre development in southern Montgomery County, immediately west of US59. More than half of their land lies in the floodway and floodplains of Spring Creek and the West Fork.

The Ryko property is 20 times larger than the Woodridge Village property, which flooded hundreds of Kingwood homes twice in 2019. Did we learn anything from that experience?

Ryko land
Looking NW from over the US59/San Jacinto bridge at the general area where Ryko owns more than 5,500 acres it wants to develop.

A knowledgeable, concerned resident sent a list of concerns which I am reprinting below. However, the writer has asked to remain anonymous. I’ve also included links to posts and official documents at the end of the letter, so readers can find relevant information in one place.

– Start of Letter –

I am writing as a concerned citizen to express strong opposition to the proposed Ryko (Townsen) Development in southern Montgomery County and to raise questions about the lack of transparency and integrity surrounding its approval process, drainage study, floodplain impacts, and associated public funding mechanisms.

This project raises significant public interest concerns that demand further scrutiny before any development proceeds.

⚠️ Floodplain Fill and Inadequate Drainage Analysis
  • The development proposes significant floodplain fill in and near the 100-year and 500-year flood zones of Spring Creek and the West Fork San Jacinto River.
  • The developer’s own drainage study acknowledges increased water surface elevations during the 2- and 10-year storm events—then dismisses them for “future mitigation.”
  • The proposed Townsen Blvd bridge is modeled using outdated HEC-RAS v3.0.1 steady flow methods, failing to account for dynamic storm conditions or backwater effects common to this area.
  • Critically, the drainage report does not evaluate a Harvey-scale event, despite the project’s location at the confluence of two major watersheds severely impacted during Hurricane Harvey.

🛑 No Conditional Letter of Map Revision (CLOMR) has been approved by FEMA or signed by the Harris County Floodplain Administrator. Without this, any fill in the floodplain would violate federal NFIP regulations (44 CFR § 60.3).

🌊 Unequal Mitigation Practices Across County Lines
  • The drainage study mitigates 1:1 for fill in the 500-year floodplain in Harris County, but in Montgomery County, it only mitigates for fill placed in the 100-year floodplain.
  • While this may technically comply with Montgomery County’s regulations, it is not best practice, especially in a watershed with regional downstream consequences.

💧 Analogy: Filling the floodplain without mitigation is like filling half a bathtub with sandbags and expecting the water to stay still—it doesn’t. It simply gets pushed elsewhere, potentially flooding neighboring properties.

🗺️ Use of Outdated Models – MAAPnext Ignored
  • The report uses base models from the San Jacinto Regional Master Drainage Plan but fails to incorporate MAAPnext, the updated floodplain modeling system developed by FEMA and HCFCD.
  • MAAPnext is being adopted as the regulatory standard in Harris County and includes better data for rainfall, topography, and land use.
  • This development should be reevaluated using MAAPnext before any approvals are granted by FEMA, Montgomery County, or Harris County.
🚦 Traffic Analysis Skipped in Violation of County Review Order
  • Montgomery County regulations clearly require a Traffic Impact Analysis (TIA) to be reviewed before a Drainage Impact Analysis (DIA) is approved.
  • There is no indication that a TIA has been submitted or approved. Approving the drainage study without first completing the TIA violates the county’s own development review process.
📝 Montgomery County’s Own Records Show Deep Reservations
  • In the March 22, 2023 meeting minutes, Montgomery County engineers stated clearly that development in this flood-prone area “should be avoided.”
  • They also noted they may not support the required CLOMR/LOMR filings.
  • This clearly shows that the project is far from approved—despite misleading public statements to the contrary.
🌱 Wetlands Presence and Permitting Gaps
  • The drainage report states that wetlands are present throughout the site, but a formal wetland delineation and jurisdictional determination has not been completed.
  • If any of these wetlands are deemed jurisdictional under the Clean Water Act, then a Section 404 permit from the U.S. Army Corps of Engineers is required.
  • Proceeding without this determination and permit could constitute a federal violation.
💰 Tax Abatements, Bond Spending, and Conflicts of Interest
  • In 2017, Montgomery County granted a tax abatement to the Ryko development before these drainage and environmental concerns were studied.
  • In fall 2024, the County extended that abatement and removed the requirement to build the Spring Creek bridge, still awarding nearly $28 million in tax benefits to the developer.
  • At the same time, the County included $42 million in the November 2024 road bond to fund the northern segment of Townsen Blvd—primarily benefitting this development.
  • Although this section of Townsen was later removed from the bond project list, residents do not trust that it won’t proceed anyway, and many now plan to vote against the bond.
🧾 PAC Influence and Consultant Conflicts
  • A political action committee called Montgomery in Motion was formed to promote the bond.
  • From what I understand, major engineering firms that stand to receive design contracts from the bond appear to be contributors.
  • It is suspected that support for the bond may be informally tied to future consultant work.
  • I have not yet found campaign finance disclosures, but a prominent engineering firm has been actively speaking to trade groups promoting the bond, and unsolicited text messages are being sent to voters.
  • With nearly $100 million of bond proceeds projected to go to consultants, this raises serious conflict of interest concerns.
✅ What Should Happen Now
  • No construction or floodplain fill should proceed without an approved FEMA CLOMR.
  • The drainage models must be rerun using MAAPnext for accuracy and relevance.
  • Montgomery County should require 1:1 mitigation for all floodplain fill, including in the 500-year zone.
  • Traffic and wetland reviews must be completed before any drainage approval is valid.
  • Campaign finance disclosures for Montgomery in Motion should be made public before the bond election.
  • County and agency leaders must publicly acknowledge that this project is not approved.

The people of Montgomery County deserve flood-resilient development, honest governance, and responsible fiscal stewardship. As it stands, this project and its supporting bond failed on all three counts.

– End of Letter –

For More Information

For posts about the Ryko development, see:

22.11.19 A Townsen Bridge Across Spring Creek

25.04.17 MoCo Commissioner Taking Townsen Blvd. Extension Off 2025 Road Bond

25.04.18 Bald Eagles Live Where Developer Wants to Build 7,000 Homes

25.04.19 Building 7,000 Homes Here Would Accelerate Subsidence

25.04.20 Far More Proposals in State Flood Plan Than Funds For Them

25.04.23 Harris County Did NOT Approve Ryko Development

For official documents, see:

Pre-Project Meeting Minutes of lead Ryko engineering company with Harris County Engineering and Flood Control District from 2/27/23.

Townsen Bridge Development Meeting Minutes between the lead Ryko engineering Company and Montgomery County Engineering (Extracted from Drainage Analysis below as separate file. Was Appendix A.) MoCo Engineering office states that development should be avoided due to high risk of flooding during extreme events. 3/22/23

Letter from Montgomery County Engineering objecting to Ryko’s preliminary drainage study on 6/18/24. “Given both the history of this development and a sincere concern for the safety of the public, I can in no way approve this primary drainage study nor should anyone as the risk is too high.”

A letter from Montgomery County Engineering on 7/23/24, rescinding the previous letter (without explanation) that objected to the drainage study.

Preliminary drainage impact analysis submitted by Ryko’s engineers on 10/3/24.

Draft of a 10/25/24 letter from Chris Bennett of Harris County Flood Control to Daryl Hahn, Harris County Engineering’s Director of Permits. Letter states, “HCFCD review is limited to the proposed Spring Creek Bridge only.” It also clearly stated that additional permits, plans and studies were needed.

Montgomery County subdivision regulations: See section on Traffic Impact Analysis Requirements.

It remains to be seen whether we learned anything from the Woodridge Village experience.

Anonymous letter posted by Bob Rehak on 4/25/25

2796 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.