1/13/25 – The Texas Commission on Environmental Quality has proposed new Best Management Practices (BMPs) for mining in response to a mandate from the 2023 session of the Texas Legislature. However, in my opinion, the recommended BMPs will do little to nothing to help control sediment pollution from mines in the Lake Houston Area.
The BMPs feel like little more than a half-hearted attempt on the part of a reluctant regulator to create the illusion of environmental protection.
You can find the proposed BMPs at this page on the TCEQ website. You may submit comments on them electronically. To be considered, TCEQ must receive your input by 11:59 p.m. on January 24, 2025. Your email should reference “APO BMP List Proposal.”
Please let the TCEQ know what you think even if you disagree with me.
Notable Omissions
The TCEQ’s recommended BMPs do not really address the biggest mining issues we have in the upper San Jacinto watershed.
I urge you to urge TCEQ to develop BMPs that address:
Discharge of sediment-laden water
Pit capture (when a river starts flowing through a mine)
Periodic flooding.
The proposed BMPs do not cover these issues at all.
The final report of a TCEQ investigation into a West Fork pit capture last year didn’t even mention the phrase. Do they not consider it a problem? I sure wish the TCEQ could enlighten us on this issue. I documented seven instances of pit capture in the Lake Houston watershed last year alone. There may have been more; many mines are in remote, difficult-to-access locations.
Sediment Pollution Reduces Water Quality, Increases Flood Risk
All three of the bullet points above add up to a big problem called “sediment pollution.” Dredging costs for the City of Houston and Army Corps approached $200 million dollars as of October 2023. Better BMPs would likely have reduced or delayed that expenditure of public funds.
At an October 2023 town hall meeting in Kingwood, Mayor Pro Tem Dave Martin presented this summary showing dredging costs totaling $186 million.
But those costs paled in comparison to the damages to 13,000 homes and businesses that flooded in the Lake Houston Area behind giant sand bars that formed sediment dams at the mouths of the East and West Forks of the San Jacinto.
Nor do the costs reflect extra water filtration at the City’s Northeast Water Purification plant.
To be fair, nature causes some erosion. The question is whether local mining practices accelerate it.
Photos of Sediment Pollution Related to Discharges, Pit Capture and Flooding
See the pictures below. I will submit these as part of my comments on the draft BMPs. Feel free to submit them as part of yours, too.
Confluence West Fork and Spring Creek near US59 Bridge. This is a frequent sight. Twenty square miles of mines are upstream on the right in a 20-mile reach of the river.San Jacinto East Fork capturing a mine in Plum Grove.Effluent from the Hallett Mine settling pond (white in upper right) on San Jacinto West Fork escaping into adjacent property owned by others.Close up of same effluent from same pondDike of abandoned Williams Brothers Mine (upper right) eroded by the San Jacinto West Fork (lower left) about to give way……was taken out by flooding from Hurricane Beryl shortly after I took the photo above this one.
Hallett sold the San Jacinto West Fork sand pit below to a real estate developer. Within months, the river captured the pit.
West Fork flows into the pit at the north end……and flows out at the south end.The pit in question is to the right of the S-turn in the river (middle). Here you can see both the entry (lower right) and exit (upper right) breaches in the dikes.
River Speed During Floods High Enough to Stir Up and Carry Even Largest Particles of Sand
Now, let’s discuss the speed of floodwaters and whether it’s sufficient to entrain sand in pits and carry it downstream.
Flood inundated both sides of the West Fork during May 2024.My drone measured logs floating through the captured pit at 5 MPH, more than fast enough to scoop up and carry off the largest grains of sand and other sediment.See below.Industry-standard graph shows the speed necessary to erode, transport and deposit sand/sediment of different particle sizes. Blue line indicates measured speed of water. Red indicates range of typical sand sizes.Another West Fork pit capture at the Hallett Mine after floodwaters receded. Notice how natural channel of the river has been virtually cut off.Effluent from the Hallett Mine (upstream in upper right) polluting the West Fork at the Northpark/Oakhurst Ditch (middle foreground). Water flows right to left.Reverse angle shows proximity of pollution to homes.Same ditch blocked by sand increases flood risk for those homeowners.Farther downstream, the Kingwood Diversion Ditch (top middle) also became blocked by sediment. A Harris County Flood Control District study found that the Diversion Ditch was one of the two most dangerous flooding problems in Kingwood.Broken dike at the Triple PG sand mine in Porter. Industrial waste water is flowing out of the mine into White Oak Creek which joins Caney Creek and the San Jacinto East Fork before flowing into Lake Houston.
Horrifying! Aren’t they? The truly horrifying part is that I have thousands of similar shots. These are not isolated instances.
This is THE biggest environmental problem in the Lake Houston Area. We have industrial waste polluting the drinking water supply for 2 million people and the TCEQ BMPs don’t even address the problem.
Don’t forget to reference “APO BMP List Proposal” when you submit the web form. Greater setbacks of mines from rivers could solve all the problems discussed above.
Posted by Bob Rehak on 1/13/25
2694 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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/01/20240504-DJI_20240504164238_0406_D.jpg?fit=1100%2C619&ssl=16191100adminadmin2025-01-13 17:53:172025-01-13 19:12:07Better Sand-Mining BMPs Needed to Control Sediment Pollution
1/11/25 – On July 15, 2020, Neel-Schaffer Engineering delivered the Kingwood Area Drainage Study to sponsors Harris County Flood Control District (HCFCD), City of Houston and Lake Houston Redevelopment Authority/TIRZ 10.
HCFCD held a community meeting to discuss the results. The District delivered a 24-page high-level summary to the community at the time. However, I have now obtained the full two-volume, 620-page report and posted it on the Reports Page of ReduceFlooding.com under the Harris County Flood Control District Tab.
There were so many graphics in Volume 1, that I had to split it up into three parts to avoid the 32-meg file-size limitation of my web server. Warning: all parts comprise more than 50 megs.
But those maps contain a wealth of detail not available in the high level summary. For instance, they show floodplains down to the individual house level, the level of service for different stream segments, and which structures would flood in different mitigation scenarios and rainfall intensities.
The report focused on areas where structures would flood in less than a 100-year rainfall.
Full Reports of Follow-Up Studies Still Not Available
I posted about the high-level findings back in 2020. To refresh your memory, the report studied a large number of drainage features in Kingwood and concluded that mitigation of the Taylor Gully and the Kingwood Diversion Ditch were the two most important.
HCFCD recommended that the two projects: G103-38-00 (Kingwood Diversion Ditch) and G103-80-03.1B (Taylor Gully) move to the next phase: engineering design. Additionally, HCFCD recommended the Taylor Gully project be reanalyzed to determine how the use of Woodridge Village for detention could modify the recommended plan.
However, HCFCD has not released the full report on either. The District says it intends to present the full report on the Diversion Ditch to Commissioners Court on February 6th and may release it after that.
In the meantime, the maps in the Kingwood Area Drainage Study may be the best guide to flood risk in the area for realtors and those considering buying a home.
MAAPnext and FEMA still haven’t released the preliminary results of a massive floodplain update they have been working on since Harvey.
Posted by Bob Rehak on 1/11/25
2692 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/01/KW-Area-Drainage-Sudy-Map-Kingwood-Center.jpg?fit=1100%2C594&ssl=15941100adminadmin2025-01-11 19:16:032025-01-11 19:27:17Full Kingwood Area Drainage Study Now Available Online
1/10/25 – Sometimes it seems transparency issues with Harris County government just never cease. For instance…
You go to the Harris County Flood Control District (HCFCD) website to look for “active construction projects” in your area. But the “Active Construction Projects” page is not working. And it hasn’t worked for months.
You wanted to know what HCFCD had done for you before voting on a 63% tax increase they requested. But the latest document posted in the download section of their website is from 2020 – more than four years ago.
Screen capture from HCFCD.org on 1/10/25 at 6:30PM showed last update to Document section was in 2020.
You lead a flood coalition representing hundreds of thousands of people and seeking to participate in public online meetings about flood control. You repeatedly ask for notice of the meetings, but get none.
You file a Freedom of Information Act (FOIA) Request for a preliminary engineering report that HCFCD wants public comments on. But they refuse to give it to you and protest the request to the State Attorney General.
All of these scenarios are real. And current.
The Deeper You Dig, the More You Suspect
What are they trying to hide? Do they really want public input? Are they trying to cover up embarrassing incompetence? Government waste? Is this a case of bureaucratic laziness? Or do they just not want to deal with a public that might dare to disagree.
Two things are certain. The harder you push, the more they talk about how transparent they are. And the penchant for secrecy undermines trust in Harris County Government.
Let’s dissect just one of the examples above – the FOIA request.
Details on Kingwood Diversion Ditch FOIA Request
After Hurricane Harvey, Harris County Flood Control District commissioned a Kingwood Area Drainage Study. Commissioners approved it on August 13, 2019.
HCFCD held a Community Engagement Meeting to discuss the study on October 20, 2020. It found 85% of the storm water runoff from Montgomery County went into the natural channel of Bens Branch rather than being diverted into the Kingwood Diversion Ditch.
The Drainage Study also found the Bens Branch drainage channel has less than a 2-year level of service. This translates to a greater than 50% chance of structural flooding in any given year.
Looking E at where Kingwood Diversion Ditch (horizontal) splits off from Bens Branch (vertical) just north of Northpark Drive (out of frame to right).
The Drainage Study recommended increasing the conveyance capacity of the Diversion Ditch and completely blocking flow from Montgomery County into the natural channel of Bens Branch through Kingwood. The Study listed improvement of the Kingwood Diversion Ditch and Taylor Gully as the two top priorities to avoid future flooding in Kingwood.
Excessive flow entering the natural channel of Bens Branch is the root cause of the erosion of the Bens Branch channel. The Diversion Ditch is supposed to siphon water out of Bens Branch, but it’s obviously not working as planned,
After release of the Kingwood Drainage Study, Harris County Commissioners authorized a preliminary engineering study for improvement of the Kingwood Diversion Ditch. Neel-Schaffer, Inc. received the contract on June 29, 2021. The value was $437,685 and specifications called for the report to be issued in 300 days.
Excessive Delays
However, HCFCD held a Virtual Community Engagement Meeting on March 7th, 2024, to discuss the results of this study. This was 982 days after the contract – more than three times the duration specified.
The stated purpose of the meeting was to obtain questions and solicit public comment.
To formulate reasonable questions and comments, Chris Bloch, a retired Kingwood engineer and flood fighter, filed a FOIA request on March 6th to obtain the full report. But HCFCD denied his request.
HCFCD said the report was still in draft form and had the County Attorney send a letter to The Texas Attorney General objecting to disclosure of some of the information included in the Preliminary Engineering Report.
The Attorney General allowed HCFCD to keep the draft secret. But public comments on the secret report were due on March 20, 2024, two weeks after the meeting that presented only high-level findings.
Bloch’s beef? “As an engineer familiar with Kingwood drainage conditions, it is impossible to make reasonable questions or comments on a Study which cannot be seen.” He concluded, “It is clear, the priority of improving Kingwood Drainage does not seem to have any urgency.”
Block wrote me on December 14, 2024 about his ordeal. That was:
283 days after the close of public comments
1,264 days after the contract for the Preliminary Engineering Report was authorized
1,516 days after the Kingwood Drainage Study Community Engagement Meeting.
Block says he requested a meeting with Flood Control personnel responsible for the report, but they did not respond. He still hasn’t received the report.
Ray of Light
There is a ray of light, however. 1318 days after the study was commissioned, HCFCD says they have plans to finally review it with Harris County Commissioners Court on February 6, 2025. HCFCD indicates they may give the report to Bloch after that … if commissioners approve it.
Do you have a similar story about government transparency? Please send it to me using the contact form of this website.
Posted by Bob Rehak on 1/10/25 using information from Chris Bloch
2691 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/01/20220322-DJI_0041.jpg?fit=1100%2C733&ssl=17331100adminadmin2025-01-10 20:40:542025-01-11 11:55:23Transparency Issues Undermining Trust in Harris County Government
Better Sand-Mining BMPs Needed to Control Sediment Pollution
1/13/25 – The Texas Commission on Environmental Quality has proposed new Best Management Practices (BMPs) for mining in response to a mandate from the 2023 session of the Texas Legislature. However, in my opinion, the recommended BMPs will do little to nothing to help control sediment pollution from mines in the Lake Houston Area.
The BMPs feel like little more than a half-hearted attempt on the part of a reluctant regulator to create the illusion of environmental protection.
You can find the proposed BMPs at this page on the TCEQ website. You may submit comments on them electronically. To be considered, TCEQ must receive your input by 11:59 p.m. on January 24, 2025. Your email should reference “APO BMP List Proposal.”
Please let the TCEQ know what you think even if you disagree with me.
Notable Omissions
The TCEQ’s recommended BMPs do not really address the biggest mining issues we have in the upper San Jacinto watershed.
I urge you to urge TCEQ to develop BMPs that address:
The proposed BMPs do not cover these issues at all.
The final report of a TCEQ investigation into a West Fork pit capture last year didn’t even mention the phrase. Do they not consider it a problem? I sure wish the TCEQ could enlighten us on this issue. I documented seven instances of pit capture in the Lake Houston watershed last year alone. There may have been more; many mines are in remote, difficult-to-access locations.
Sediment Pollution Reduces Water Quality, Increases Flood Risk
All three of the bullet points above add up to a big problem called “sediment pollution.” Dredging costs for the City of Houston and Army Corps approached $200 million dollars as of October 2023. Better BMPs would likely have reduced or delayed that expenditure of public funds.
But those costs paled in comparison to the damages to 13,000 homes and businesses that flooded in the Lake Houston Area behind giant sand bars that formed sediment dams at the mouths of the East and West Forks of the San Jacinto.
Nor do the costs reflect extra water filtration at the City’s Northeast Water Purification plant.
To be fair, nature causes some erosion. The question is whether local mining practices accelerate it.
Photos of Sediment Pollution Related to Discharges, Pit Capture and Flooding
See the pictures below. I will submit these as part of my comments on the draft BMPs. Feel free to submit them as part of yours, too.
Hallett sold the San Jacinto West Fork sand pit below to a real estate developer. Within months, the river captured the pit.
River Speed During Floods High Enough to Stir Up and Carry Even Largest Particles of Sand
Now, let’s discuss the speed of floodwaters and whether it’s sufficient to entrain sand in pits and carry it downstream.
Horrifying! Aren’t they? The truly horrifying part is that I have thousands of similar shots. These are not isolated instances.
This is THE biggest environmental problem in the Lake Houston Area. We have industrial waste polluting the drinking water supply for 2 million people and the TCEQ BMPs don’t even address the problem.
Please register your opinion with the TCEQ at: https://tceq.commentinput.com/?id=NdefHRZiG. Help improve the quality of life for your family and community.
Don’t forget to reference “APO BMP List Proposal” when you submit the web form. Greater setbacks of mines from rivers could solve all the problems discussed above.
Posted by Bob Rehak on 1/13/25
2694 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.
Full Kingwood Area Drainage Study Now Available Online
1/11/25 – On July 15, 2020, Neel-Schaffer Engineering delivered the Kingwood Area Drainage Study to sponsors Harris County Flood Control District (HCFCD), City of Houston and Lake Houston Redevelopment Authority/TIRZ 10.
HCFCD held a community meeting to discuss the results. The District delivered a 24-page high-level summary to the community at the time. However, I have now obtained the full two-volume, 620-page report and posted it on the Reports Page of ReduceFlooding.com under the Harris County Flood Control District Tab.
There were so many graphics in Volume 1, that I had to split it up into three parts to avoid the 32-meg file-size limitation of my web server. Warning: all parts comprise more than 50 megs.
But those maps contain a wealth of detail not available in the high level summary. For instance, they show floodplains down to the individual house level, the level of service for different stream segments, and which structures would flood in different mitigation scenarios and rainfall intensities.
The report focused on areas where structures would flood in less than a 100-year rainfall.
Full Reports of Follow-Up Studies Still Not Available
I posted about the high-level findings back in 2020. To refresh your memory, the report studied a large number of drainage features in Kingwood and concluded that mitigation of the Taylor Gully and the Kingwood Diversion Ditch were the two most important.
HCFCD recommended that the two projects: G103-38-00 (Kingwood Diversion Ditch) and G103-80-03.1B (Taylor Gully) move to the next phase: engineering design. Additionally, HCFCD recommended the Taylor Gully project be reanalyzed to determine how the use of Woodridge Village for detention could modify the recommended plan.
The District then commissioned preliminary engineering studies for each in June, 2021. It held community meetings to discuss the Taylor Gully results in December, 2022, and Diversion Ditch results in March, 2024.
However, HCFCD has not released the full report on either. The District says it intends to present the full report on the Diversion Ditch to Commissioners Court on February 6th and may release it after that.
In the meantime, the maps in the Kingwood Area Drainage Study may be the best guide to flood risk in the area for realtors and those considering buying a home.
MAAPnext and FEMA still haven’t released the preliminary results of a massive floodplain update they have been working on since Harvey.
Posted by Bob Rehak on 1/11/25
2692 Days since Hurricane Harvey
Transparency Issues Undermining Trust in Harris County Government
1/10/25 – Sometimes it seems transparency issues with Harris County government just never cease. For instance…
You go to the Harris County Flood Control District (HCFCD) website to look for “active construction projects” in your area. But the “Active Construction Projects” page is not working. And it hasn’t worked for months.
You wanted to know what HCFCD had done for you before voting on a 63% tax increase they requested. But the latest document posted in the download section of their website is from 2020 – more than four years ago.
You lead a flood coalition representing hundreds of thousands of people and seeking to participate in public online meetings about flood control. You repeatedly ask for notice of the meetings, but get none.
You file a Freedom of Information Act (FOIA) Request for a preliminary engineering report that HCFCD wants public comments on. But they refuse to give it to you and protest the request to the State Attorney General.
All of these scenarios are real. And current.
The Deeper You Dig, the More You Suspect
What are they trying to hide? Do they really want public input? Are they trying to cover up embarrassing incompetence? Government waste? Is this a case of bureaucratic laziness? Or do they just not want to deal with a public that might dare to disagree.
Two things are certain. The harder you push, the more they talk about how transparent they are. And the penchant for secrecy undermines trust in Harris County Government.
Let’s dissect just one of the examples above – the FOIA request.
Details on Kingwood Diversion Ditch FOIA Request
After Hurricane Harvey, Harris County Flood Control District commissioned a Kingwood Area Drainage Study. Commissioners approved it on August 13, 2019.
HCFCD held a Community Engagement Meeting to discuss the study on October 20, 2020. It found 85% of the storm water runoff from Montgomery County went into the natural channel of Bens Branch rather than being diverted into the Kingwood Diversion Ditch.
The Drainage Study also found the Bens Branch drainage channel has less than a 2-year level of service. This translates to a greater than 50% chance of structural flooding in any given year.
The Drainage Study recommended increasing the conveyance capacity of the Diversion Ditch and completely blocking flow from Montgomery County into the natural channel of Bens Branch through Kingwood. The Study listed improvement of the Kingwood Diversion Ditch and Taylor Gully as the two top priorities to avoid future flooding in Kingwood.
Excessive flow entering the natural channel of Bens Branch is the root cause of the erosion of the Bens Branch channel. The Diversion Ditch is supposed to siphon water out of Bens Branch, but it’s obviously not working as planned,
After release of the Kingwood Drainage Study, Harris County Commissioners authorized a preliminary engineering study for improvement of the Kingwood Diversion Ditch. Neel-Schaffer, Inc. received the contract on June 29, 2021. The value was $437,685 and specifications called for the report to be issued in 300 days.
Excessive Delays
However, HCFCD held a Virtual Community Engagement Meeting on March 7th, 2024, to discuss the results of this study. This was 982 days after the contract – more than three times the duration specified.
The stated purpose of the meeting was to obtain questions and solicit public comment.
To formulate reasonable questions and comments, Chris Bloch, a retired Kingwood engineer and flood fighter, filed a FOIA request on March 6th to obtain the full report. But HCFCD denied his request.
HCFCD said the report was still in draft form and had the County Attorney send a letter to The Texas Attorney General objecting to disclosure of some of the information included in the Preliminary Engineering Report.
The Attorney General allowed HCFCD to keep the draft secret. But public comments on the secret report were due on March 20, 2024, two weeks after the meeting that presented only high-level findings.
Bloch’s beef? “As an engineer familiar with Kingwood drainage conditions, it is impossible to make reasonable questions or comments on a Study which cannot be seen.” He concluded, “It is clear, the priority of improving Kingwood Drainage does not seem to have any urgency.”
Block wrote me on December 14, 2024 about his ordeal. That was:
Block says he requested a meeting with Flood Control personnel responsible for the report, but they did not respond. He still hasn’t received the report.
Ray of Light
There is a ray of light, however. 1318 days after the study was commissioned, HCFCD says they have plans to finally review it with Harris County Commissioners Court on February 6, 2025. HCFCD indicates they may give the report to Bloch after that … if commissioners approve it.
Do you have a similar story about government transparency? Please send it to me using the contact form of this website.
Posted by Bob Rehak on 1/10/25 using information from Chris Bloch
2691 Days since Hurricane Harvey