They told Precinct 3 Commissioner Tom Ramsey and Houston City Council Member Fred Flickinger that they had “letters of no objection” (LONOs) from the Montgomery County Engineer and Harris County Flood Control District. See the red box on the page below.
LONO stands for Letter of No Objection.
The phrasing of the text implies “approval.” However, reading the text of the actual letters suggests that huge concerns remain about the project.
“…additional analysis will be required incorporating a definitive land plan.”
Brian Clark, PE, Montgomery County Engineer
Clark goes on to say that the land plan must be approved before any construction for any portion of the development can be approved. In addition, he says that additional analysis and construction plans must address Montgomery County’s following concerns:
Significant potential for erosion under homes, roads, utilities and bridge(s)
Need for emergency access and rescue planning during floods
Potential for increased floodplain levels due to future upstream development, which could place the entire project in the 100-year floodplain. “This creates a high risk of future flood blight, negatively impacting the tax base and endangering future residents,” he said.
Page 2 contains a lengthy list of information still required:
Detailed drainage master plan including specific lot, street, and detention pond sizing and locations.
Master plan that includes a comprehensive, no-rise, floodplain analysis for the 5-, 10-, 100- and 500-year Atlas 14 peak flows, along with drawings that show proposed grading and the extent of floodplain encroachment.
Atlas-14, 500-year water elevations in all models
Adequate mitigation for any fill in the 100-year floodplain
Develop and implement robust erosion control measures and geotechnical studies to ensure the long-term stability of the development
Design bridge and road network to guarantee adequate emergency access during the Atlas-14, 500-year storm
Analyze the proposed bridge location and describe how the proposed bridge will accommodate the dynamic (shifting) nature of Spring Creek
Emergency access plans must be approved by the county before any plans for sections in the subdivision will be reviewed
Submit documents indicating Army Corps approval, including any mitigation the Corps requires
Complete environmental due diligence documentation pertaining to Endangered Species Act
Approval of bridge plans by Harris County Flood Control District showing no modification to the main stem of Spring Creek will be required before MoCo provides any future letters of no objection.
Pages 2 and 3 contain cautions about:
Data and calculations made in the preliminary drainage analysis
A conditional letter of map revision (CLOMR) must be approved by FEMA before the county can approve bridge construction plans
The limited nature of the LONO itself.
The letter closes with a warning:
“This memorandum does not guarantee that the ‘developable areas’ presented in the report will remain unchanged as more information becomes available.”
Brian Clark, PE, Montgomery County Engineer
That sounds like quite a mountain to climb! Especially since MoCo Precinct 3 Commissioner Rich Wheeler took the Townsen Blvd. Extension off the County’s 2025 Road Bond. Harris County Precinct 3 Commissioner Tom Ramsey, PE, also vehemently opposes a bridge across Spring Creek. And the area upstream from this development is one of the fastest growing in the region…and the country, according to the Census Bureau.
Photos Make A More Compelling Case than Engineering Studies
Having spent years now studying how upstream development changes downstream assumptions about flooding, I hope this area does not get developed. Significant public safety concerns exist.
We should never forget what happened to Kingwood and Humble, and the I-69 and UnionPacific Railroad Bridges during Harvey.
Even if Scarborough/San Jacinto Preserve could build a bridge across Spring Creek, it would not form a reliable evacuation route in the event of another Harvey. Why? People coming south could be in floodwaters over their heads once they got off the bridge. See the pictures below.
Another view of Harvey at I-69. The Spring Creek bridge would come down in the flood, out of frame to the right.Water at this location reached 22 feet above flood stage.Townsen Road in Humble (center) where it crosses I-69. Photo courtesy of Harris County Flood Control District.I-69 during Harvey. Photo by Melinda Ray. So much for evacuation routes to the south.It took TXDoT almost a year to repair the I-69 bridge causing massive traffic jams on alternate routes.Harvey also destroyed the UnionPacific railroad bridge over the West Fork.
Even the I-45 and West Lake Houston Parkway bridges were damaged.
So, in my opinion, there is NO reliable evacuation route to the south. Period. End of story.
The developer can save his money on the engineering studies and cut his losses. The only way to salvage anything from this disaster-in-the-making is to donate the land to Texas Parks and Wildlife, take a tax deduction, and trumpet your concern for the environment.
Posted by Bob Rehak on 10/31/25
2985 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/2021/05/TS-Harvey-8-30-17-209.jpg?fit=1024%2C768&ssl=17681024adminadmin2025-10-31 17:53:272025-11-01 12:36:21Supposed “Letter of No Objection” to Floodplain Development Lists 3 Pages of Objections
10/30/25 – San Jacinto Preserve (aka Scarborough Development) presented new plans yesterday to the City of Houston District E Council Member Fred Flickinger and Harris County Precinct 3 Commissioner Tom Ramsey, PE, for the development of 5,316 acres most of which is in floodplains or floodways. The land lies where Spring Creek, Cypress Creek, Turkey Creek and the San Jacinto West Fork converge south of the Grand Parkway.
Meeting in Response to City’s Request for More Information
Council Member Flickinger and Commissioner Ramsey both had requested the City Planning Commission to defer approval of the new development by taking it off their consent agenda on 10/16/25 until the City could learn more.
General plan submitted to Houston Planning Commission didn’t show much detail.
In response, the District E office said the developer presented these two pages at the followup meeting on 10/29/25.
The first looks somewhat like a paisley shirt. The new plans show where homes and detention basins would be built, but they omit floodplain/floodway boundaries, streets and wetlands.
Note that the new plan still shows a proposed corridor for Townsen Road, which was taken off the Montgomery County 2025 Road Bond. It also shows a bridge across Spring Creek which Commissioner Ramsey previously (and strenuously) objected to.
The developer also presented the following summary sheet, designed to allay concerns. It says that out of the total 5,316 acres, only 2,012 are “intended” for development. 550 acres are set aside for detention and floodplain mitigation. And 2,754 acres are not “intended” for development – 52% of the total tract. See the pie chart below. Then compare the percentages to the map above.
My eye sees less green than gray in the map above. But the irregular shapes make it difficult to precisely quantify percentages. So, judge for yourself.
Troubling, Vague Language
The developer also presented this summary sheet along with the new plans.
Note that the Summary Sheet above uses words such as “intended,” “proposed,” and “limited.” They should raise red flags. They convey promises without legal obligations and beg for explanation that isn’t given.
But there may be an even bigger problem in the Summary Sheet. The developer claims it’s using updated flood maps. However, they don’t show the extent of floodplains and floodways. Nor do they show the difference between the existing and as-yet-unreleased new maps.
And note the reference to “wetlands mitigation credits.” That means they’re mitigating the wetlands they destroy, but doing it somewhere else, i.e., not on this site. So the mitigation may or may not help people in Humble, Kingwood and the Lake Houston Area. It all depends on where the credits are.
LONO References Demand Elaboration
The “LONO” references in the Summary Sheet stand for Letters of No Objection. They imply approval but mean something entirely different.
“LONO” is a formal statement issued by a regulatory authority to indicate that it has no objection to a proposed action, activity, or project — provided certain conditions are met and no specific approval is required under existing rules.
For instance, Harris County Flood Control District issued the LONO for a bridge across Spring Creek without seeing any plans. Such letters serve as an assurance during the early stages of a project that the regulator does not see a regulatory barrier. However, the letter does not relieve the applicant of responsibility for compliance with other requirements or liabilities that may arise.
I have not yet obtained a copy of the Montgomery County LONO, but have filed a FOIA request.
Much Green Space Could Not Be Developed Anyway
While the “52% green space” claim sounds like a concession to preservation and safety concerns, City of Houston regulations already prohibit building in floodplains and floodways without significant restrictions. And this land is almost ALL floodways and floodplains.
Floodplains shown by Ryko (the previous owner) in their drainage analysis.
Restrictions include:
Elevation of the first finished floor 2 feet above the 500-year flood elevation
Construction on stilts/piers to allow water to flow under the home without constricting the flow of water
A floodplain development permit
Flood insurance.
Such restrictions raise the price of building in such areas while lowering the demand, making development – and home ownership – much riskier.
From FEMA’s Base Flood Elevation Viewer.
At the southern end of the area, builders would have to raise homes 27.1 feet to comply with City of Houston regulations…if they could get a permit.
“Like Aiming a Fire Hose at Kingwood”
One of the most respected hydrologists in the region told ReduceFlooding.com that if that area got developed, it would be like “aiming a fire hose at Kingwood and Humble.”
But the letter objecting to the study’s conclusions was later rescinded after it came under fire from MoCo Precinct 3 Commissioner James Noack. Noack was subsequently voted out of office by his constituents. The letter cited a “sincere concern for the safety of the public.” The risk of development was just too high, it said.
Leading Preservation Group Has Better Plan
The Bayou Land Conservancy, one of the leading conservation groups in the area, issued the following statement today after reviewing the plans above.
“Bayou Land Conservancy believes that the highest and best use of this entire tract is conservation that protects upstream and downstream communities from flooding, while preserving the quality of our drinking water.”
“Although the developer currently plans to set aside 52% of the available land with ‘no future plans of development,’ conservation easements would act as permanent protection of those areas and give the nearby community an assurance that they would remain green space forever.”
I couldn’t agree more. Just a mile downstream on the San Jacinto West Fork, townhomes in Forest Cove were flooded to the third floor. And some were swept off their foundations.
Forest Cove Townhome destroyed by Harveyone mile downstream from proposed developmenton West Fork.
Rather than make the public pay handsomely to buy out such properties after they flood, why not just keep the area natural?
The entire proposed development is laced with wetlands which act as natural sponges during floods.Proposed development photographed from a helicopter flying over the West Fork on 6/22/25.
All those trees create friction that reduces the speed of floodwaters coming into the Humble/Kingwood area. Removing them would increase the velocity of floodwaters that have already swept homes off their foundations.
Leaving this land natural would avoid future home damages and mitigation costs altogether. At a much lower cost to the public and unsuspecting home buyers.
Posted by Bob Rehak on 10/30/25
2984 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/2025/10/San-Jacinto-Preserve-Plan-2.jpg?fit=2550%2C1650&ssl=116502550adminadmin2025-10-30 20:02:482025-10-31 13:17:24New Plans to Develop 5,316 Acres West of Kingwood Mostly in Floodplains, Floodways
10/29/25 – Contractors have begun placing rebar and pouring concrete for two giant, cast-in-place junction boxes on either side of the UnionPacific Railroad tracks that cross Northpark Drive. The junction boxes will connect drainage systems on both sides of the tracks.
Construction Roadblocks Eliminated
Unanticipated utility conflicts held up drainage work for months. And the drainage work needs to be completed before Loop 494 can be completed, Northpark surface lanes can be paved, and contractors can start work on the bridge over the tracks/Loop 494. So this is another significant milestone.
Once complete, the junction boxes will comprise a significant link that conveys excess stormwater from west of the tracks to the Kingwood Diversion Ditch on the east.
Pictures Supplied by Lake Houston Redevelopment Authority
The pictures below show the start of work in the first of the two pits.
Clean out of debris from the twin 5′ bores in anticipation of construction of the junction boxes.Contractors start with the bottoms. Then they will build the sides and top.Picture: 10/28/29.Smoothing the concrete and placing anchors for the sides.10/28/29
The Lake Houston Redevelopment Authority anticipates completion of the boxes on both sides of the tracks by the end of the first week in November 2025, weather permitting.
Posted by Bob Rehak on 10/29/25
2983 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/10/20251029-Smoothing-Concrete-Junction-Box.png?fit=1063%2C1100&ssl=111001063adminadmin2025-10-29 21:21:022025-10-29 21:21:03Contractors Start Northpark Junction Boxes Next to Railroad Tracks
Supposed “Letter of No Objection” to Floodplain Development Lists 3 Pages of Objections
10/31/25 – On 10/29/25, Scarborough Development/San Jacinto Preserve pitched their plans to develop 5,372 acres in Montgomery County and build a bridge across Spring Creek to Harris County.
They told Precinct 3 Commissioner Tom Ramsey and Houston City Council Member Fred Flickinger that they had “letters of no objection” (LONOs) from the Montgomery County Engineer and Harris County Flood Control District. See the red box on the page below.
The phrasing of the text implies “approval.” However, reading the text of the actual letters suggests that huge concerns remain about the project.
Montgomery County Concerns
The letter from Brian Clark, Montgomery County engineer, dated 7/2/25 or one month before Ryko sold the land to Scarborough Development/San Jacinto Preserve, has no objection to the preliminary information provided but goes on to list three pages of concerns. They start with an underlined phrase in the second paragraph.
Clark goes on to say that the land plan must be approved before any construction for any portion of the development can be approved. In addition, he says that additional analysis and construction plans must address Montgomery County’s following concerns:
Page 2 contains a lengthy list of information still required:
Pages 2 and 3 contain cautions about:
The letter closes with a warning:
That sounds like quite a mountain to climb! Especially since MoCo Precinct 3 Commissioner Rich Wheeler took the Townsen Blvd. Extension off the County’s 2025 Road Bond. Harris County Precinct 3 Commissioner Tom Ramsey, PE, also vehemently opposes a bridge across Spring Creek. And the area upstream from this development is one of the fastest growing in the region…and the country, according to the Census Bureau.
Text of Letters
Here is the entire letter, obtained via a FOIA request.
And here is the entire letter from HCFCD. It expresses many of the same concerns.
Photos Make A More Compelling Case than Engineering Studies
Having spent years now studying how upstream development changes downstream assumptions about flooding, I hope this area does not get developed. Significant public safety concerns exist.
We should never forget what happened to Kingwood and Humble, and the I-69 and UnionPacific Railroad Bridges during Harvey.
Even if Scarborough/San Jacinto Preserve could build a bridge across Spring Creek, it would not form a reliable evacuation route in the event of another Harvey. Why? People coming south could be in floodwaters over their heads once they got off the bridge. See the pictures below.
Even the I-45 and West Lake Houston Parkway bridges were damaged.
So, in my opinion, there is NO reliable evacuation route to the south. Period. End of story.
For more photos from Harvey, see Dawn of a Disaster.
The developer can save his money on the engineering studies and cut his losses. The only way to salvage anything from this disaster-in-the-making is to donate the land to Texas Parks and Wildlife, take a tax deduction, and trumpet your concern for the environment.
Posted by Bob Rehak on 10/31/25
2985 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.
New Plans to Develop 5,316 Acres West of Kingwood Mostly in Floodplains, Floodways
10/30/25 – San Jacinto Preserve (aka Scarborough Development) presented new plans yesterday to the City of Houston District E Council Member Fred Flickinger and Harris County Precinct 3 Commissioner Tom Ramsey, PE, for the development of 5,316 acres most of which is in floodplains or floodways. The land lies where Spring Creek, Cypress Creek, Turkey Creek and the San Jacinto West Fork converge south of the Grand Parkway.
Meeting in Response to City’s Request for More Information
Council Member Flickinger and Commissioner Ramsey both had requested the City Planning Commission to defer approval of the new development by taking it off their consent agenda on 10/16/25 until the City could learn more.
In response, the District E office said the developer presented these two pages at the followup meeting on 10/29/25.
The first looks somewhat like a paisley shirt. The new plans show where homes and detention basins would be built, but they omit floodplain/floodway boundaries, streets and wetlands.
Note that the new plan still shows a proposed corridor for Townsen Road, which was taken off the Montgomery County 2025 Road Bond. It also shows a bridge across Spring Creek which Commissioner Ramsey previously (and strenuously) objected to.
The developer also presented the following summary sheet, designed to allay concerns. It says that out of the total 5,316 acres, only 2,012 are “intended” for development. 550 acres are set aside for detention and floodplain mitigation. And 2,754 acres are not “intended” for development – 52% of the total tract. See the pie chart below. Then compare the percentages to the map above.
My eye sees less green than gray in the map above. But the irregular shapes make it difficult to precisely quantify percentages. So, judge for yourself.
Troubling, Vague Language
The developer also presented this summary sheet along with the new plans.
Note that the Summary Sheet above uses words such as “intended,” “proposed,” and “limited.” They should raise red flags. They convey promises without legal obligations and beg for explanation that isn’t given.
But there may be an even bigger problem in the Summary Sheet. The developer claims it’s using updated flood maps. However, they don’t show the extent of floodplains and floodways. Nor do they show the difference between the existing and as-yet-unreleased new maps.
To my eye, the outlines of the floodplains and floodways around areas containing homes look suspiciously like FEMA’s existing map for this area.
And note the reference to “wetlands mitigation credits.” That means they’re mitigating the wetlands they destroy, but doing it somewhere else, i.e., not on this site. So the mitigation may or may not help people in Humble, Kingwood and the Lake Houston Area. It all depends on where the credits are.
LONO References Demand Elaboration
The “LONO” references in the Summary Sheet stand for Letters of No Objection. They imply approval but mean something entirely different.
“LONO” is a formal statement issued by a regulatory authority to indicate that it has no objection to a proposed action, activity, or project — provided certain conditions are met and no specific approval is required under existing rules.
For instance, Harris County Flood Control District issued the LONO for a bridge across Spring Creek without seeing any plans. Such letters serve as an assurance during the early stages of a project that the regulator does not see a regulatory barrier. However, the letter does not relieve the applicant of responsibility for compliance with other requirements or liabilities that may arise.
In the case of the proposed bridge across Spring Creek, there are no laws against bridges. However, the HCFCD letter clearly laid out the need for additional studies, plan reviews and permits.
I have not yet obtained a copy of the Montgomery County LONO, but have filed a FOIA request.
Much Green Space Could Not Be Developed Anyway
While the “52% green space” claim sounds like a concession to preservation and safety concerns, City of Houston regulations already prohibit building in floodplains and floodways without significant restrictions. And this land is almost ALL floodways and floodplains.
Restrictions include:
Such restrictions raise the price of building in such areas while lowering the demand, making development – and home ownership – much riskier.
At the southern end of the area, builders would have to raise homes 27.1 feet to comply with City of Houston regulations…if they could get a permit.
“Like Aiming a Fire Hose at Kingwood”
One of the most respected hydrologists in the region told ReduceFlooding.com that if that area got developed, it would be like “aiming a fire hose at Kingwood and Humble.”
Yet Chapter 11.086 of the Texas State Water Code requires “no adverse impact” on surrounding areas.
The preliminary drainage study by the previous owner of the land came under fire from Montgomery County Engineering.
But the letter objecting to the study’s conclusions was later rescinded after it came under fire from MoCo Precinct 3 Commissioner James Noack. Noack was subsequently voted out of office by his constituents. The letter cited a “sincere concern for the safety of the public.” The risk of development was just too high, it said.
Leading Preservation Group Has Better Plan
The Bayou Land Conservancy, one of the leading conservation groups in the area, issued the following statement today after reviewing the plans above.
“Bayou Land Conservancy believes that the highest and best use of this entire tract is conservation that protects upstream and downstream communities from flooding, while preserving the quality of our drinking water.”
“Although the developer currently plans to set aside 52% of the available land with ‘no future plans of development,’ conservation easements would act as permanent protection of those areas and give the nearby community an assurance that they would remain green space forever.”
I couldn’t agree more. Just a mile downstream on the San Jacinto West Fork, townhomes in Forest Cove were flooded to the third floor. And some were swept off their foundations.
Rather than make the public pay handsomely to buy out such properties after they flood, why not just keep the area natural?
All those trees create friction that reduces the speed of floodwaters coming into the Humble/Kingwood area. Removing them would increase the velocity of floodwaters that have already swept homes off their foundations.
Leaving this land natural would avoid future home damages and mitigation costs altogether. At a much lower cost to the public and unsuspecting home buyers.
Posted by Bob Rehak on 10/30/25
2984 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.
Contractors Start Northpark Junction Boxes Next to Railroad Tracks
10/29/25 – Contractors have begun placing rebar and pouring concrete for two giant, cast-in-place junction boxes on either side of the UnionPacific Railroad tracks that cross Northpark Drive. The junction boxes will connect drainage systems on both sides of the tracks.
Construction Roadblocks Eliminated
Unanticipated utility conflicts held up drainage work for months. And the drainage work needs to be completed before Loop 494 can be completed, Northpark surface lanes can be paved, and contractors can start work on the bridge over the tracks/Loop 494. So this is another significant milestone.
Once complete, the junction boxes will comprise a significant link that conveys excess stormwater from west of the tracks to the Kingwood Diversion Ditch on the east.
Pictures Supplied by Lake Houston Redevelopment Authority
The pictures below show the start of work in the first of the two pits.
The Lake Houston Redevelopment Authority anticipates completion of the boxes on both sides of the tracks by the end of the first week in November 2025, weather permitting.
Posted by Bob Rehak on 10/29/25
2983 Days since Hurricane Harvey