A couple weeks ago, I posted about rules governing the application of sand mining best management practices (BMPs). Now the Texas Commission on Environmental Quality (TCEQ) is accepting public comments on the BMPs themselves. Think of the difference this way: how/when to enforce guidelines vs the guidelines themselves.
More than 90 people responded to the enforcement question. Thank you. The TCEQ left so many “outs,” it was doubtful whether sand mines would ever have had to follow any of the BMPs.
Comments Coming Due on BMPs, Not Just Rules Governing Them
Now it’s time to consider the content of the BMPs themselves and provide public comment.
We have more time this time – until August 19. So I will publish a series of posts about different aspects of the BMPs that I believe could be improved.
Today, I will simply give you an overview of the major categories of recommendations. In coming days, I will discuss major areas of concern. These will be things where, in my opinion, the sand mines in the San Jacinto watershed fall short of ideal practices in ways that directly contribute to flooding.
Some Caveats
Having said that, let me also qualify that last statement three ways:
Not all sand mines are bad actors, but some are.
We need sand to make concrete.
Sediment comes from both man-made and natural sources. While massive amounts of sand clogged our river after Harvey, it’s unclear what proportion of that came from sand mines.
It’s easy to see that floodwaters eroded stockpiles, breached levees, and swept sediment downstream. It’s also easy to see how suboptimal sand mining practices contributed to those issues.
Sand mining increased the width of the exposed sediment adjacent to the river by an average of 33X.
However, it’s not clear how much suboptimal sand mining practices contributed to blockages, such as the East and West Fork Mouth Bars, Sand Island, and the giant side bar that blocked the Kingwood Diversion Ditch. Some likely also came from erosion of the river bed itself as well as upstream developers with suboptimal practices of their own.
It will take someone smarter than me to figure that how much came from where.
The BMPs being considered by the TCEQ have to do with:
Vegetative and Structural Controls to help reduce erosion
Pre-Mining site evaluation, drainage studies and site preparation
Mining activities, such as dredging, processing, maintenance, and the handling of petroleum products
Post-Mining site stabilization, debris removal, and property grading
Requirements for a final stabilization report.
I will discuss each of these in coming days before the deadline. I will also show photos that illustrate how current practices fall short of BMPs and contribute to sedimentation.
Sand mine pumping wastewater directly into San Jacinto West Fork
Another sand mine discharging wastewater directly into the West Fork.
Two things ARE clear, however. We can and must do better if we want to reduce:
Financial hemorrhaging
Flooding from man-made blockages that clog our rivers.
How to Make a Public Comment
Submit written comments on BMPs to Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
More details to follow in the coming days.
Posted By Bob Rehak on 7/8/2021
1440 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/2021/08/20191104-RJR_4225.jpg?fit=2000%2C1333&ssl=113332000adminadmin2021-08-08 19:19:232021-08-08 19:19:27Comments Due to TCEQ on Sand-Mining BMPs by August 19
The Texas Water Development Board (TWDB) has reorganized the sea of flood-related information and redesigned the TexasFlood.org website to provide a more user-friendly resource for Texans who want to increase their flood awareness and preparedness.
Given the deadly nature of flood events and the rapid timeframe in which they can occur, remaining flood-ready is essential.
One Feature Shows Flood Spread and Inundated Buildings by Gage Height
TexasFlood.org provides fundamental information on emergency preparation for and recovery from flood events, as well as web tools to better understand flood risk, in a format that is easy to access and easy to understand.
Select a gage and a height and see instantly how far the floodwaters will spread. This shows spread based on the USGS Gage at FM1485 and the East fork.
I selected the height of the highest gage reading during the May floods this year at FM1485 and the East Fork. Then I zoomed in and found that 36 structures were in danger of being inundated. You can even see their locations!
Information like this is not only useful when considering purchasing a building, but also when considering whether to evacuate.
Other Useful Features
TexasFlood.org also features resources and tools that allow users to:
Review lake levels and river heights
Check current precipitation totals and weather conditions
Evaluate potential flood risk
See the impacts of different hypothetical flooding scenarios
Identify and connect with their local floodplain administrator
Learn the primary types of flooding and basics of flood insurance
The website highlights the reasons why emergency preparedness is vital to proper flood preparedness, including the importance of floodproofing and awareness of second-order damages after a flood event.
One-Stop Information Shop
The TWDB has gathered important information from other local, state, and federal entities to provide the most relevant information for Texans in one convenient online location. Hurricane season runs through November 30 each year. And historically speaking, 80% of the storms for this year are still in front of us. Just today, the National Hurricane Center highlighted another area of concern in the Atlantic, bringing the active total to three.
So TWDB encourages all Texans to check out the revamped TexasFlood.org. Learn how to pack a flood kit, download resources to prepare family, review individual flood risk, plan an evacuation route, and more.
Posted by Bob Rehak on 8/7/2021 based on a press release by TWDB
1439 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20210807-Screen-Shot-2021-08-07-at-8.33.26-PM.jpg?fit=1200%2C659&ssl=16591200adminadmin2021-08-07 20:49:572021-08-07 20:53:35Improved TexasFlood.org Website Shows Spread of Floodwaters and Inundated Buildings by Gage Height
Below is a quick digest of six flood-related stories affecting the Lake Houston Area.
Dredging is a Slow Go
Mechanical dredgers are slowly working their way through the channel south of Royal Shores. It connects the East and West Forks of the San Jacinto. Without dredging, the dredging equipment itself would not be able to make it through the channel.
However, the pace of the dredging is painfully slow. You can see the progress by comparing the two pictures below. I took them 22 days apart.
Taken on July 11, 2021Taken on August 2, 2021. Google Earth shows they went a little more than 600 feet in a little more than three weeks.
At about 200 feet per week with about 2,000 more feet to go, they should reach the East Fork in about another ten weeks.
Several boaters have commented on how the dredges can wait hours for a pontoon to ferry dirt back to the placement site. Their net takeaway: very inefficient. During a July 8 meeting at the Kingwood Community Center, Stephen Costello called this method of dredging “unsustainable.” He’s sooooo right. We will run out of luck long before we run out of places to dredge.
Mechanical dredging (shown in the photos above) is far slower and less efficient than hydraulic. Great Lakes hydraulic dredges removed 500,000 cubic yards of sediment from the mouth bar area in just two months – July and August of 2019. DRC’s mechanical dredges removed another 600,000+ cubic yards in the 19 months between January 2020 and July 2021.
Interestingly, Google Earth shows that when the dredgers reach the East Fork, they will be closer to the Triple PG Sand Mine in Porter than the current placement area south of River Grove Park. The Triple PG mine will also be less than half the distance of a mine that the Army Corps previously pumped spoils to from the mouth bar– the Eagle Sorters Mine on the West Fork.
Hmmmm. Triple PG. A placement area for East Fork spoils? A return to hydraulic dredging? Interesting thoughts.
Seasonal Lowering of Lake Conroe
Seasonal lowering of Lake Conroe has started as planned. SJRA is releasing 75 cubic feet per second, according to their dashboard.
Seasonal release is shown as a City of Houston (COH) Diversion.
When the lowering started on August 2, a day late, the lake was at 200.87. So releasing 75 CFS has brought the lake down .19 feet, a little more than 2 inches. Barring large rainfalls, this rate should reach the objective of 200 feet by September 1.
The National Hurricane Center shows two areas of concern in the Atlantic as of 2PM, Friday August 6th.
A few hundred miles south of the Cabo Verde Islands, a tropical wave (orange area) and a broad area of low pressure could turn into a tropical depression by late this weekend or early next week. Formation chance through 5 days…medium…60 percent.
Another tropical wave approaching the Lesser Antilles is a lower threat. NHC predicts development, if any, of this system will be slow and occur early next week. Formation chance through 5 days…low…20 percent.
NOAA Issues Mid-Season Hurricane Outlook
Another forecast released two days ago by NOAA says that atmospheric conditions are still conducive for an above-average hurricane season. See their predictions in the right hand column below. These numbers include the five named storms so far this season.
Attorney General Lawsuit Against Triple PG Mine Still Active
Craig Pritzlaff of the TCEQ assures me that despite visible lack of progress in the Attorney General’s lawsuit against the Triple PG mine for illegal discharges, the AG has not dropped the case. “Indeed, very few, if any, cases referred to the AG for civil prosecution are ever dropped,” he says. “Litigation, particularly environmental litigation, is a complicated and lengthy process. That process was further complicated by the COVID-19 pandemic, which halted court dockets across the State throughout 2020 and into 2021.”
Condos 250 Feet from 250,000 CFS
A Chinese developer is building yet more condos even closer to the West Fork in the Kings Harbor neighborhood.
See new construction bottom center. Lai finished the units at the right earlier this year. The nearest unit above will be about 250 feet from the San Jacinto West Fork.
During Harvey, more than 250,000 cubic feet per second came through this area. It flooded homes and businesses more than 10,000 feet from the river.
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/2021/08/20210802-DJI_0286.jpg?fit=1200%2C799&ssl=17991200adminadmin2021-08-06 16:46:402021-08-07 19:38:36Digest: Updates on Six Lake Houston Area Flood-Related Stories
Comments Due to TCEQ on Sand-Mining BMPs by August 19
A couple weeks ago, I posted about rules governing the application of sand mining best management practices (BMPs). Now the Texas Commission on Environmental Quality (TCEQ) is accepting public comments on the BMPs themselves. Think of the difference this way: how/when to enforce guidelines vs the guidelines themselves.
More than 90 people responded to the enforcement question. Thank you. The TCEQ left so many “outs,” it was doubtful whether sand mines would ever have had to follow any of the BMPs.
Comments Coming Due on BMPs, Not Just Rules Governing Them
Now it’s time to consider the content of the BMPs themselves and provide public comment.
We have more time this time – until August 19. So I will publish a series of posts about different aspects of the BMPs that I believe could be improved.
Here is a draft of the 24-page document listing all BMPs that the TCEQ is considering.
Today, I will simply give you an overview of the major categories of recommendations. In coming days, I will discuss major areas of concern. These will be things where, in my opinion, the sand mines in the San Jacinto watershed fall short of ideal practices in ways that directly contribute to flooding.
Some Caveats
Having said that, let me also qualify that last statement three ways:
It’s easy to see that floodwaters eroded stockpiles, breached levees, and swept sediment downstream. It’s also easy to see how suboptimal sand mining practices contributed to those issues.
Sand mining increased the width of the exposed sediment adjacent to the river by an average of 33X.
USGS calculations, photographs, and first responder reports during Harvey also indicate that the velocity of the river was sufficient to transport not just sand, but large chunks of gravel.
However, it’s not clear how much suboptimal sand mining practices contributed to blockages, such as the East and West Fork Mouth Bars, Sand Island, and the giant side bar that blocked the Kingwood Diversion Ditch. Some likely also came from erosion of the river bed itself as well as upstream developers with suboptimal practices of their own.
It will take someone smarter than me to figure that how much came from where.
The Public Policy Question
It is clear, however, that we’re investing $222 million in dredging to eliminate sediment blockages that contribute to flooding. And many sand mines have shown, in my opinion, a callous disregard for the cleanup costs they externalize to the public sector. One is even currently being sued by the Texas Attorney General.
Scope of BMPs Being Proposed
The BMPs being considered by the TCEQ have to do with:
I will discuss each of these in coming days before the deadline. I will also show photos that illustrate how current practices fall short of BMPs and contribute to sedimentation.
Two things ARE clear, however. We can and must do better if we want to reduce:
How to Make a Public Comment
Submit written comments on BMPs to Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
More details to follow in the coming days.
Posted By Bob Rehak on 7/8/2021
1440 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.
Improved TexasFlood.org Website Shows Spread of Floodwaters and Inundated Buildings by Gage Height
The Texas Water Development Board (TWDB) has reorganized the sea of flood-related information and redesigned the TexasFlood.org website to provide a more user-friendly resource for Texans who want to increase their flood awareness and preparedness.
Given the deadly nature of flood events and the rapid timeframe in which they can occur, remaining flood-ready is essential.
One Feature Shows Flood Spread and Inundated Buildings by Gage Height
TexasFlood.org provides fundamental information on emergency preparation for and recovery from flood events, as well as web tools to better understand flood risk, in a format that is easy to access and easy to understand.
I selected the height of the highest gage reading during the May floods this year at FM1485 and the East Fork. Then I zoomed in and found that 36 structures were in danger of being inundated. You can even see their locations!
Information like this is not only useful when considering purchasing a building, but also when considering whether to evacuate.
Other Useful Features
TexasFlood.org also features resources and tools that allow users to:
The website highlights the reasons why emergency preparedness is vital to proper flood preparedness, including the importance of floodproofing and awareness of second-order damages after a flood event.
One-Stop Information Shop
The TWDB has gathered important information from other local, state, and federal entities to provide the most relevant information for Texans in one convenient online location. Hurricane season runs through November 30 each year. And historically speaking, 80% of the storms for this year are still in front of us. Just today, the National Hurricane Center highlighted another area of concern in the Atlantic, bringing the active total to three.
So TWDB encourages all Texans to check out the revamped TexasFlood.org. Learn how to pack a flood kit, download resources to prepare family, review individual flood risk, plan an evacuation route, and more.
Posted by Bob Rehak on 8/7/2021 based on a press release by TWDB
1439 Days since Hurricane Harvey
Digest: Updates on Six Lake Houston Area Flood-Related Stories
Below is a quick digest of six flood-related stories affecting the Lake Houston Area.
Dredging is a Slow Go
Mechanical dredgers are slowly working their way through the channel south of Royal Shores. It connects the East and West Forks of the San Jacinto. Without dredging, the dredging equipment itself would not be able to make it through the channel.
However, the pace of the dredging is painfully slow. You can see the progress by comparing the two pictures below. I took them 22 days apart.
At about 200 feet per week with about 2,000 more feet to go, they should reach the East Fork in about another ten weeks.
Several boaters have commented on how the dredges can wait hours for a pontoon to ferry dirt back to the placement site. Their net takeaway: very inefficient. During a July 8 meeting at the Kingwood Community Center, Stephen Costello called this method of dredging “unsustainable.” He’s sooooo right. We will run out of luck long before we run out of places to dredge.
Mechanical dredging (shown in the photos above) is far slower and less efficient than hydraulic. Great Lakes hydraulic dredges removed 500,000 cubic yards of sediment from the mouth bar area in just two months – July and August of 2019. DRC’s mechanical dredges removed another 600,000+ cubic yards in the 19 months between January 2020 and July 2021.
Interestingly, Google Earth shows that when the dredgers reach the East Fork, they will be closer to the Triple PG Sand Mine in Porter than the current placement area south of River Grove Park. The Triple PG mine will also be less than half the distance of a mine that the Army Corps previously pumped spoils to from the mouth bar– the Eagle Sorters Mine on the West Fork.
Hmmmm. Triple PG. A placement area for East Fork spoils? A return to hydraulic dredging? Interesting thoughts.
Seasonal Lowering of Lake Conroe
Seasonal lowering of Lake Conroe has started as planned. SJRA is releasing 75 cubic feet per second, according to their dashboard.
When the lowering started on August 2, a day late, the lake was at 200.87. So releasing 75 CFS has brought the lake down .19 feet, a little more than 2 inches. Barring large rainfalls, this rate should reach the objective of 200 feet by September 1.
The Lake Conroe Association is still fighting the lowering in Montgomery County District Court. Judge Mike Mays set a hearing date for Tuesday, August 24, 2021 at 2PM.
Tropics Heating Up
The National Hurricane Center shows two areas of concern in the Atlantic as of 2PM, Friday August 6th.
A few hundred miles south of the Cabo Verde Islands, a tropical wave (orange area) and a broad area of low pressure could turn into a tropical depression by late this weekend or early next week. Formation chance through 5 days…medium…60 percent.
Another tropical wave approaching the Lesser Antilles is a lower threat. NHC predicts development, if any, of this system will be slow and occur early next week. Formation chance through 5 days…low…20 percent.
NOAA Issues Mid-Season Hurricane Outlook
Another forecast released two days ago by NOAA says that atmospheric conditions are still conducive for an above-average hurricane season. See their predictions in the right hand column below. These numbers include the five named storms so far this season.
Attorney General Lawsuit Against Triple PG Mine Still Active
Craig Pritzlaff of the TCEQ assures me that despite visible lack of progress in the Attorney General’s lawsuit against the Triple PG mine for illegal discharges, the AG has not dropped the case. “Indeed, very few, if any, cases referred to the AG for civil prosecution are ever dropped,” he says. “Litigation, particularly environmental litigation, is a complicated and lengthy process. That process was further complicated by the COVID-19 pandemic, which halted court dockets across the State throughout 2020 and into 2021.”
Condos 250 Feet from 250,000 CFS
A Chinese developer is building yet more condos even closer to the West Fork in the Kings Harbor neighborhood.
During Harvey, more than 250,000 cubic feet per second came through this area. It flooded homes and businesses more than 10,000 feet from the river.
The developer is also hoping to sell/develop that grassy area in the bottom center of the photo for $1.45 million.
I guess money has a short memory.
That concludes this month’s digest.
Posted by Bob Rehak on 8/6/2021
1438 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.