In fairness, before getting into concerns, let me state several things about the plans.
The consulting engineer clearly labeled the drainage analysis as preliminary.
Each page of the drainage analysis contains a disclaimer that says, “Note: The drainage plan is conceptual in nature and the final drainage design shall be in conformance with the latest City of Houston Infrastructure Design Manual.”
Page 3 states that:
All structures will have an elevation two feet above the 500-year flood level.
All proposed structures will be built on piers to reduce the need for fill.
Dirt excavated from detention ponds will be hauled away from the site.
Questions Raised by Plans
However, the preliminary drainage analysis raised more questions than it answered. For instance:
It did not claim “no adverse impact” downstream. Why?
The drainage impact analysis was dated 2/19/25 and approved by the City’s Floodplain Group on 3/3/25. Why the long delay before making them public?
Why deny me the analysis, but give it to Bloch?
A Public Works employee told me the plans were based on new, post-Harvey flood maps. But Page 2 states that they’re based on 2007 maps.
With that in mind, the 2007 maps show virtually all of the proposed development in the 100-year floodplain. How much of that is now in the floodway? Neither Public Works, nor Harris County Flood Control District will reveal the new flood map for this development. Why the secrecy?
The drainage analysis does not show roadways or trails which have the ability to back water up into existing neighborhoods. Why?
The drainage analysis does not consider water draining into the area from Trailwood, Kingwood Lakes, Kings Forest or Kingwood Drive. Why? These wetlands already serve a flood-mitigation purpose that will likely be destroyed.
The drainage analysis conflicts with promotional literature provided by the developer. The literature, for instance shows the road network being built up to 60 feet and pedestrian paths being built up to 71 feet.
Ground level varies throughout the development. According to the USGS National Map, it averages about 50 feet, ranging down to 46. So how much fill would it take to raise the roads 10-15 feet?
Elevation profile of Romerica land from USGS National Map shows average height of about 50 feet.
The general plan shows approximately 6,000 feet of roadway, with the streets alone being 60 feet wide . (6000L x 60W x 10H = 3.6 million cubic feet.) That’s 133,333 cubic yards of fill. Yet the analysis claims they need only 16,966 cubic yards of fill. And they won’t be getting it from the detention basins, because they say they’re hauling all that off.
So, how are they accounting for another 100,000+ cubic yards of fill? How will they raise the streets?
Next, where is the outflow analysis for the detention basins? None is provided. So, we can’t see whether they are adding or subtracting to flood peaks.
Dubious Benefit of Detention in Floodplain
And then there’s the biggest question of all. Will flood-plain detention that quickly goes under water in floods provide any flood-reduction benefit?
Floodplains already serve as stormwater storage during floods. FEMA considers floodplain storage already “spoken for.”
Still, detention basins are allowed in floodplains with certain provisions. Harris County requires basins to drain by gravity. But the bottom of these basins is 10 feet below the level of adjacent Kingwood Lake and 4.5 feet below the level of Lake Houston. So gravity alone will never drain these ponds in a flood. Pumps would be required. And electricity is often knocked out in floods.
What the Romerica Property looked like in the May 2024 flood. Water rose to treetop level.
And if new basins fill at the same time as the river, it provides zero peak flow reduction. That is why claimed floodplain detention is often illusory. Especially when the pre-/post- runoff ratio will increase almost 4X (Page 5).
Flickinger Wisely Pulls Variance Approval from Planning Commission Agenda
The City of Houston Planning Commission was scheduled to review a variance request today for Romerica. However, City Council Member Fred Flickinger wisely requested deferral of consideration until 2/5/26. That should give us more time to sort out these inconsistencies.
The variance request has to do with not connecting the east-west street to other streets on the east. That’s because there are no streets in that area. A Kingwood Country Club golf course surrounds Romerica’s property in that direction.
The delay gives us extra time to examine the rest of their plans.
Posted by Bob Rehak on 1/22/2026
3068 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/2026/01/20240504-DJI_20240504090422_0214_D-2-copy.jpg?fit=1100%2C619&ssl=16191100adminadmin2026-01-22 21:47:302026-01-23 10:41:17Romerica’s Preliminary Drainage Analysis Raises Many Questions
1/21/26 – EB-5 visas are a special type of visa designed to attract foreign investment in American infrastructure projects and create American jobs. They put foreigners with approximately a million dollars to invest at the front of the immigration line. I asked ChatGPT, “What happens if you get an EB-5 visa, but then the project you invested in never gets built?”
Fictional AI image created by ChatGPT
That opened up a Pandora’s box. Evidently, the U.S. Customs and Immigration Service (USCIS) and Securities & Exchange Commission (SEC) encounter this problem frequently. Here’s what I learned after a day of online exploration.
What Happens If Project Is Never Built?
For applicants, the consequences depend on where they are in the EB-5 process and why the project failed. The outcome can range from merely losing their investment to losing immigration benefits or both.
EB-5 is not a “pay-for-visa” program. USCIS requires:
Capital to be “at risk”
It must create at least 10 qualifying U.S. jobs per investor
Those jobs must actually be created, not just planned.
If the project is never built, job creation almost always fails — which is fatal to the visa.
ChatGPT
What happens to the visa depends on how the project fails and at which stage. There is no automatic protection. Approval of an EB-5 petition does not guarantee the success of the business or the return of capital. And the U.S. government does not underwrite or insure EB-5 investments.
Project failure is far more serious than in ordinary real-estate investing. EB-5 investors can lose both their investment AND their visa.
Red Flags in EB-5 Offerings
According to ChatGPT, these red flags appear repeatedly in failed EB-5 cases/projects.
“Job Cushion” Based Only on Future Projections
A legitimate EB-5 project should show at least 20-30% excess jobs based on hard construction costs alone. Danger signs include that cushion relying on future operations, such as a “Phase II.”
Developer with No Completed U.S. Projects
EB-5 visas are based on execution, not vision. USCIS does not care about renderings, master plans, press releases, or “international experience.” They only care whether buildings were actually built, certificates of occupancy were issued and operations began. Many EB-5 failures reportedly trace directly to “First U.S. Project.”
Vague Exit Strategy
EB-5 investors are almost always unsecured, subordinated, and last in line. Beware of phrases in promotional literature, such as “Sale Expected.” Repayment risk for investors may be extreme.
Floodway/Floodplain Location
A project located in a floodway or floodplain faces extraordinary engineering uncertainty. If construction is not feasible due to regulatory barriers, USCIS can later characterize the project as not viable from inception.
Refusal to Release Drainage Impact Analysis
If the project fails, this can become a material omission under federal securities law.
A Maze of Shell Companies
A complex web of LLCs and offshore entities may obscure ownership, transfer of funds, and transparency, especially if some entities are offshore or owned by foreign nationals.
Major Hotel-Chain-Involvement Claimed
Major hotel chains do not attach their names casually to projects. Saying major hotel chains are involved is a very common misrepresentation in EB-5 disputes. Brand usage without authorization has appeared repeatedly in prior SEC enforcement actions. Demand to see a signed letter of intent from any hotel chain touted as part of a project.
Why Hotels?
Hotels create not only construction jobs, they create permanent operational jobs, too – housekeeping, front desk, food & beverage, maintenance, management and more. This creates what EB-5 insiders call a “job factory.” Few other types of assets offer this.
Jobs can be modeled and assumed before anything is built. Reality is only tested years later…if the project gets built.
Hotels are also easy for foreign investors to understand. The psychological simplicity is powerful. But in the absence of a signed management agreement, beware.
Moreover, hotels are capital intensive, accommodating large numbers of EB-5 investors per project.
Finally, hotels can mask fatal land-use problems. EB-5 developers often propose them on floodplain land and wetlands, which conventional lenders avoid, but which foreigners may not understand.
A luxury hotel can be proposed almost anywhere on paper. And the difficulty of such sites can obscure the ultimate pending failure for years.
SEC and DHS investigators call this model “the hotel shell.” It’s a known “failure architecture.”
How Developers Can Quietly Fail EB-5 Projects
Most EB-5 projects do not collapse dramatically. They reportedly begin and then fade out according to a common pattern:
Promotion with a glossy website, roadshows, and a conceptual master plan. Capital is raised before execution risk is visible.
As time passes, investors are told of minor delays related to infrastructure costs, drainage requirements, off-site mitigation, and rising construction costs.
The capital stack breaks (the order in which money is repaid if something goes wrong). EB-5 money alone cannot carry the project as lenders withdraw, interest rates rise, appraisals come in low, or construction bids exceed the estimate.
Then silence! No press releases. No construction start. Updates stop. Investors receive only quarterly status letters. This phase can last years.
Finally, the USCIS deadline arrives. No construction. No jobs. No recovery of investment. And visa revocation.
To Verify Whether Developers Have Actually Completed Projects
Do not rely on marketing materials. Do your own due diligence.
Ask for Certificates of Occupancy from previous projects. Crosscheck those with county appraisal records. Check improvement values, year built, and square footage. If improvement value is near zero after several years, the project has not been built.
Look for building-permit close outs. If permits remain open for years, that’s a red flag.
Check for litigation. Search federal courts, bankruptcy courts and securities litigation. EB-5 failures often involve investor lawsuits, SEC actions and receiverships.
And finally look for consistency of the developer’s track record. Be wary if completed projects are small (or overseas), but proposed projects are grandiose.
Posted by Bob Rehak on 1/21/2026 based on ChatGPT responses to multiple questions
3067 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/2026/01/20260121-Failed-EB5-Investment.jpg?fit=1100%2C733&ssl=17331100adminadmin2026-01-21 20:05:212026-01-21 20:39:33Red Flags for EB-5 Visa Applicants, Projects
1/20/26 at 3:30 PM – Consideration of a plat variance for a swamp development scheduled for a vote by the Houston Planning Commission on 1/22/26 has been delayed until at least 2/5. Houston City Council member Fred Flickinger requested the deferral at 12:25 PM today.
Shortly after 3PM, I received confirmation from both Dustin Hodges, Flickinger’s Chief of Staff, and Vonn Tran, Director of Houston’s Planning and Development Department, that the variance request by Roman Arrow, LLC will be delayed as requested by Flickinger.
So, if you were planning to go downtown to protest the development at this Thursday’s meeting, save your time. Hopefully, we will learn more about the developer’s plans before the 2/5 meeting. You can attend then.
About the Development
Roman Arrow, aka Romerica, has proposed building two luxury hotels and 120 villas/condos up to 8,600 square feet each in and around the swamps between Kingwood Lakes and the Barrington, just east of Woodland Hills Drive in Kingwood.
Solid green areas represent wetlands. Source: National Wetlands Inventory. Roman Arrow land is outlined in red. They propose development in two phases.View from current entry road during a month that received two inches of rain.Romerica Roman Arrow land is virtually all in the hundred year floodplain (aqua). Although when new flood maps are released the floodway of the West Fork (cross hatched area at bottom) will likely expand north.
For more information about the proposed development see the their high-level plans and variance application:
Phase One includes a 297,600-square-foot Fairmont Hotel with 400 rooms and 90 condominium residences.
Phase Two includes another 226,085-square-foot hotel with 37 8,611-square-foot villas, each on one third acre lots.
Media relations at the Fairmont chain has not returned phone calls or emails to verify their supposed involvement in the Kingwood development.
Refusal to Comply with FOIA Request
I have requested the drainage impact analysis submitted to and approved by Houston Public Works. However, Houston Public Works says that it belongs to the developer, so they have requested a ruling from the Texas Attorney General Ken Paxton on whether they can release it.
My point of view is that once Houston Public Works approved it, the approval and anything the approval was based on became public information and should be produced forthwith. Attorney General reviews usually take 45 days.
Other government agencies, such as Liberty County and Montgomery County routinely produce such studies in response to Freedom of Information Act Requests. Houston must have its own policy. And that policy merits review in my opinion. It makes a mockery of any pretext to transparency.
Having said that, I know many people in the City who would produce it in a minute if something weren’t holding them back.
Posted by Bob Rehak on 1/20/2026
3066 Days since 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/2026/01/Romerica-Outline-copy.jpg?fit=2210%2C1498&ssl=114982210adminadmin2026-01-20 17:10:252026-01-20 17:18:28Plat Variance for Swamp Development Deferred by Planning Commission
Romerica’s Preliminary Drainage Analysis Raises Many Questions
1/22/26 – Despite the City of Houston appealing my FOIA request for Romerica’s drainage impact analysis to the Texas Attorney General, this morning the City emailed both the analysis and a new general plan for Romerica’s proposed floodplain development to another Kingwood resident, Chris Bloch. Bloch shared his copies with me and they raise many questions.
First, Some Disclaimers
In fairness, before getting into concerns, let me state several things about the plans.
Questions Raised by Plans
However, the preliminary drainage analysis raised more questions than it answered. For instance:
Ground level varies throughout the development. According to the USGS National Map, it averages about 50 feet, ranging down to 46. So how much fill would it take to raise the roads 10-15 feet?
The general plan shows approximately 6,000 feet of roadway, with the streets alone being 60 feet wide . (6000L x 60W x 10H = 3.6 million cubic feet.) That’s 133,333 cubic yards of fill. Yet the analysis claims they need only 16,966 cubic yards of fill. And they won’t be getting it from the detention basins, because they say they’re hauling all that off.
Next, where is the outflow analysis for the detention basins? None is provided. So, we can’t see whether they are adding or subtracting to flood peaks.
Dubious Benefit of Detention in Floodplain
And then there’s the biggest question of all. Will flood-plain detention that quickly goes under water in floods provide any flood-reduction benefit?
Floodplains already serve as stormwater storage during floods. FEMA considers floodplain storage already “spoken for.”
Still, detention basins are allowed in floodplains with certain provisions. Harris County requires basins to drain by gravity. But the bottom of these basins is 10 feet below the level of adjacent Kingwood Lake and 4.5 feet below the level of Lake Houston. So gravity alone will never drain these ponds in a flood. Pumps would be required. And electricity is often knocked out in floods.
And if new basins fill at the same time as the river, it provides zero peak flow reduction. That is why claimed floodplain detention is often illusory. Especially when the pre-/post- runoff ratio will increase almost 4X (Page 5).
Flickinger Wisely Pulls Variance Approval from Planning Commission Agenda
The City of Houston Planning Commission was scheduled to review a variance request today for Romerica. However, City Council Member Fred Flickinger wisely requested deferral of consideration until 2/5/26. That should give us more time to sort out these inconsistencies.
The variance request has to do with not connecting the east-west street to other streets on the east. That’s because there are no streets in that area. A Kingwood Country Club golf course surrounds Romerica’s property in that direction.
The delay gives us extra time to examine the rest of their plans.
Posted by Bob Rehak on 1/22/2026
3068 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.
Red Flags for EB-5 Visa Applicants, Projects
1/21/26 – EB-5 visas are a special type of visa designed to attract foreign investment in American infrastructure projects and create American jobs. They put foreigners with approximately a million dollars to invest at the front of the immigration line. I asked ChatGPT, “What happens if you get an EB-5 visa, but then the project you invested in never gets built?”
That opened up a Pandora’s box. Evidently, the U.S. Customs and Immigration Service (USCIS) and Securities & Exchange Commission (SEC) encounter this problem frequently. Here’s what I learned after a day of online exploration.
What Happens If Project Is Never Built?
For applicants, the consequences depend on where they are in the EB-5 process and why the project failed. The outcome can range from merely losing their investment to losing immigration benefits or both.
EB-5 is not a “pay-for-visa” program. USCIS requires:
What happens to the visa depends on how the project fails and at which stage. There is no automatic protection. Approval of an EB-5 petition does not guarantee the success of the business or the return of capital. And the U.S. government does not underwrite or insure EB-5 investments.
Project failure is far more serious than in ordinary real-estate investing. EB-5 investors can lose both their investment AND their visa.
Red Flags in EB-5 Offerings
According to ChatGPT, these red flags appear repeatedly in failed EB-5 cases/projects.
“Job Cushion” Based Only on Future Projections
A legitimate EB-5 project should show at least 20-30% excess jobs based on hard construction costs alone. Danger signs include that cushion relying on future operations, such as a “Phase II.”
Developer with No Completed U.S. Projects
EB-5 visas are based on execution, not vision. USCIS does not care about renderings, master plans, press releases, or “international experience.” They only care whether buildings were actually built, certificates of occupancy were issued and operations began. Many EB-5 failures reportedly trace directly to “First U.S. Project.”
Vague Exit Strategy
EB-5 investors are almost always unsecured, subordinated, and last in line. Beware of phrases in promotional literature, such as “Sale Expected.” Repayment risk for investors may be extreme.
Floodway/Floodplain Location
A project located in a floodway or floodplain faces extraordinary engineering uncertainty. If construction is not feasible due to regulatory barriers, USCIS can later characterize the project as not viable from inception.
Refusal to Release Drainage Impact Analysis
If the project fails, this can become a material omission under federal securities law.
A Maze of Shell Companies
A complex web of LLCs and offshore entities may obscure ownership, transfer of funds, and transparency, especially if some entities are offshore or owned by foreign nationals.
Major Hotel-Chain-Involvement Claimed
Major hotel chains do not attach their names casually to projects. Saying major hotel chains are involved is a very common misrepresentation in EB-5 disputes. Brand usage without authorization has appeared repeatedly in prior SEC enforcement actions. Demand to see a signed letter of intent from any hotel chain touted as part of a project.
Why Hotels?
Hotels create not only construction jobs, they create permanent operational jobs, too – housekeeping, front desk, food & beverage, maintenance, management and more. This creates what EB-5 insiders call a “job factory.” Few other types of assets offer this.
Jobs can be modeled and assumed before anything is built. Reality is only tested years later…if the project gets built.
Hotels are also easy for foreign investors to understand. The psychological simplicity is powerful. But in the absence of a signed management agreement, beware.
Moreover, hotels are capital intensive, accommodating large numbers of EB-5 investors per project.
Finally, hotels can mask fatal land-use problems. EB-5 developers often propose them on floodplain land and wetlands, which conventional lenders avoid, but which foreigners may not understand.
A luxury hotel can be proposed almost anywhere on paper. And the difficulty of such sites can obscure the ultimate pending failure for years.
SEC and DHS investigators call this model “the hotel shell.” It’s a known “failure architecture.”
How Developers Can Quietly Fail EB-5 Projects
Most EB-5 projects do not collapse dramatically. They reportedly begin and then fade out according to a common pattern:
To Verify Whether Developers Have Actually Completed Projects
Do not rely on marketing materials. Do your own due diligence.
Posted by Bob Rehak on 1/21/2026 based on ChatGPT responses to multiple questions
3067 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.
Plat Variance for Swamp Development Deferred by Planning Commission
1/20/26 at 3:30 PM – Consideration of a plat variance for a swamp development scheduled for a vote by the Houston Planning Commission on 1/22/26 has been delayed until at least 2/5. Houston City Council member Fred Flickinger requested the deferral at 12:25 PM today.
Shortly after 3PM, I received confirmation from both Dustin Hodges, Flickinger’s Chief of Staff, and Vonn Tran, Director of Houston’s Planning and Development Department, that the variance request by Roman Arrow, LLC will be delayed as requested by Flickinger.
So, if you were planning to go downtown to protest the development at this Thursday’s meeting, save your time. Hopefully, we will learn more about the developer’s plans before the 2/5 meeting. You can attend then.
About the Development
Roman Arrow, aka Romerica, has proposed building two luxury hotels and 120 villas/condos up to 8,600 square feet each in and around the swamps between Kingwood Lakes and the Barrington, just east of Woodland Hills Drive in Kingwood.
For more information about the proposed development see the their high-level plans and variance application:
For even more information, consult yesterday’s post.
Media relations at the Fairmont chain has not returned phone calls or emails to verify their supposed involvement in the Kingwood development.
Refusal to Comply with FOIA Request
I have requested the drainage impact analysis submitted to and approved by Houston Public Works. However, Houston Public Works says that it belongs to the developer, so they have requested a ruling from the Texas Attorney General Ken Paxton on whether they can release it.
My point of view is that once Houston Public Works approved it, the approval and anything the approval was based on became public information and should be produced forthwith. Attorney General reviews usually take 45 days.
Other government agencies, such as Liberty County and Montgomery County routinely produce such studies in response to Freedom of Information Act Requests. Houston must have its own policy. And that policy merits review in my opinion. It makes a mockery of any pretext to transparency.
Having said that, I know many people in the City who would produce it in a minute if something weren’t holding them back.
Posted by Bob Rehak on 1/20/2026
3066 Days since 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.