4/25/25 – A company called Ryko has proposed building a 5,500 acre development in southern Montgomery County, immediately west of US59. More than half of their land lies in the floodway and floodplains of Spring Creek and the West Fork.
The Ryko property is 20 times larger than the Woodridge Village property, which flooded hundreds of Kingwood homes twice in 2019. Did we learn anything from that experience?
Looking NW from over the US59/San Jacinto bridge at the general area where Ryko owns more than 5,500 acres it wants to develop.
A knowledgeable, concerned resident sent a list of concerns which I am reprinting below. However, the writer has asked to remain anonymous. I’ve also included links to posts and official documents at the end of the letter, so readers can find relevant information in one place.
– Start of Letter –
I am writing as a concerned citizen to express strong opposition to the proposed Ryko (Townsen) Development in southern Montgomery County and to raise questions about the lack of transparency and integrity surrounding its approval process, drainage study, floodplain impacts, and associated public funding mechanisms.
This project raises significant public interest concerns that demand further scrutiny before any development proceeds.
⚠️ Floodplain Fill and Inadequate Drainage Analysis
The development proposes significant floodplain fill in and near the 100-year and 500-year flood zones of Spring Creek and the West Fork San Jacinto River.
The developer’s own drainage study acknowledges increased water surface elevations during the 2- and 10-year storm events—then dismisses them for “future mitigation.”
The proposed Townsen Blvd bridge is modeled using outdated HEC-RAS v3.0.1 steady flow methods, failing to account for dynamic storm conditions or backwater effects common to this area.
Critically, the drainage report does not evaluate a Harvey-scale event, despite the project’s location at the confluence of two major watersheds severely impacted during Hurricane Harvey.
🛑 No Conditional Letter of Map Revision (CLOMR) has been approved by FEMA or signed by the Harris County Floodplain Administrator. Without this, any fill in the floodplain would violate federal NFIP regulations (44 CFR § 60.3).
🌊 Unequal Mitigation Practices Across County Lines
The drainage study mitigates 1:1 for fill in the 500-year floodplain in Harris County, but in Montgomery County, it only mitigates for fill placed in the 100-year floodplain.
While this may technically comply with Montgomery County’s regulations, it is not best practice, especially in a watershed with regional downstream consequences.
💧 Analogy: Filling the floodplain without mitigation is like filling half a bathtub with sandbags and expecting the water to stay still—it doesn’t. It simply gets pushed elsewhere, potentially flooding neighboring properties.
🗺️ Use of Outdated Models – MAAPnext Ignored
The report uses base models from the San Jacinto Regional Master Drainage Plan but fails to incorporate MAAPnext, the updated floodplain modeling system developed by FEMA and HCFCD.
MAAPnext is being adopted as the regulatory standard in Harris County and includes better data for rainfall, topography, and land use.
This development should be reevaluated using MAAPnext before any approvals are granted by FEMA, Montgomery County, or Harris County.
🚦 Traffic Analysis Skipped in Violation of County Review Order
Montgomery County regulations clearly require a Traffic Impact Analysis (TIA) to be reviewed before a Drainage Impact Analysis (DIA) is approved.
There is no indication that a TIA has been submitted or approved. Approving the drainage study without first completing the TIA violates the county’s own development review process.
📝 Montgomery County’s Own Records Show Deep Reservations
In the March 22, 2023 meeting minutes, Montgomery County engineers stated clearly that development in this flood-prone area “should be avoided.”
They also noted they may not support the required CLOMR/LOMR filings.
This clearly shows that the project is far from approved—despite misleading public statements to the contrary.
🌱 Wetlands Presence and Permitting Gaps
The drainage report states that wetlands are present throughout the site, but a formal wetland delineation and jurisdictional determination has not been completed.
If any of these wetlands are deemed jurisdictional under the Clean Water Act, then a Section 404 permit from the U.S. Army Corps of Engineers is required.
Proceeding without this determination and permit could constitute a federal violation.
💰 Tax Abatements, Bond Spending, and Conflicts of Interest
In 2017, Montgomery County granted a tax abatement to the Ryko development before these drainage and environmental concerns were studied.
In fall 2024, the County extended that abatement and removed the requirement to build the Spring Creek bridge, still awarding nearly $28 million in tax benefits to the developer.
At the same time, the County included $42 million in the November 2024 road bond to fund the northern segment of Townsen Blvd—primarily benefitting this development.
Although this section of Townsen was later removed from the bond project list, residents do not trust that it won’t proceed anyway, and many now plan to vote against the bond.
🧾 PAC Influence and Consultant Conflicts
A political action committee called Montgomery in Motion was formed to promote the bond.
From what I understand, major engineering firms that stand to receive design contracts from the bond appear to be contributors.
It is suspected that support for the bond may be informally tied to future consultant work.
I have not yet found campaign finance disclosures, but a prominent engineering firm has been actively speaking to trade groups promoting the bond, and unsolicited text messages are being sent to voters.
With nearly $100 million of bond proceeds projected to go to consultants, this raises serious conflict of interest concerns.
✅ What Should Happen Now
No construction or floodplain fill should proceed without an approved FEMA CLOMR.
The drainage models must be rerun using MAAPnext for accuracy and relevance.
Montgomery County should require 1:1 mitigation for all floodplain fill, including in the 500-year zone.
Traffic and wetland reviews must be completed before any drainage approval is valid.
Campaign finance disclosures for Montgomery in Motion should be made public before the bond election.
County and agency leaders must publicly acknowledge that this project is not approved.
The people of Montgomery County deserve flood-resilient development, honest governance, and responsible fiscal stewardship. As it stands, this project and its supporting bond failed on all three counts.
Letter from Montgomery County Engineering objecting to Ryko’s preliminary drainage study on 6/18/24. “Given both the history of this development and a sincere concern for the safety of the public, I can in no way approve this primary drainage study nor should anyone as the risk is too high.”
A letter from Montgomery County Engineering on 7/23/24, rescinding the previous letter (without explanation) that objected to the drainage study.
Draft of a 10/25/24 letter from Chris Bennett of Harris County Flood Control to Daryl Hahn, Harris County Engineering’s Director of Permits. Letter states, “HCFCD review is limited to the proposed Spring Creek Bridge only.” It also clearly stated that additional permits, plans and studies were needed.
It remains to be seen whether we learned anything from the Woodridge Village experience.
Anonymous letter posted by Bob Rehak on 4/25/25
2796 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/04/Ryko-Land.jpg?fit=1100%2C733&ssl=17331100adminadmin2025-04-25 16:32:482025-05-06 14:08:27Lengthy Catalog of Concerns about Proposed Ryko Development
4/24/25 – My weird nephew Izzy called again this morning. He was all atwitter about Harris County’s new Climate-Justice Plan adopted by Commissioner’s Court on 4/10/25. And he could barely contain his excitement.
The Phone Call from Nephew Izzy
“They did it, Uncle Bob. They really, finally done did it?”
“Did what, Izzy?”
“We finally gonna get some climate justice, Uncle Bob.”
“I didn’t know climate broke the law, Izzy.”
“Oh, Uncle Bob! Justice is just a word they tag onto things they want.”
“What do they want, Izzy?”
“For starters, Uncle Bob, a carbon tax.”
“But Izzy, you can barely afford to put gas in that 1974 Lincoln of yours as it is.”
“I hadn’t thought of that, Uncle Bob. Maybe they’ll buy me a new ride. It’s getting hard to find parts for the Lincoln nowadays. Junkyards hardly carry dem anymore.”
“What else does the climate-justice plan do, Izzy?”
“They gonna make it so you can check out gardening tools at libraries.”
“That would mean you have to work, Izzy.”
“But think of all the things I could grow, Uncle Bob.”
“Cheetos don’t grow in gardens, Izzy.”
“They don’t?”
“They don’t.”
Brightening… “Well, they gonna make solar panels easier to get, Uncle Bob!”
“Where will you put them, Izzy? You live in an apartment.”
“Well, I could stick one in my window…”
“And do what with it?”
“Hook it up to my deep frier.”
“You got me there, Izzy. I’m all for sustainable fried chicken.”
Hair Gone Wild
“You know the beauty of climate justice, Uncle Bob?”
“No.”
“You can plug just about anything into it.”
“I can see that, Izzy.”
“Yeah, Lina Hidalgo might finally get some hair justice.”
“What do you mean?”
“You know how her hair always be shootin’ out all over the place from Houston’s humidity?”
Harris County Judge Lina Hidalgo voted for the new Climate Justice Plan.
“Hmmmm, yesssss?”
“I look that way, too, sometimes when I wake up. I sure could use some hair justice myself.”
“Personally, Izzy. I’d settle for some good, old-fashioned criminal justice. You know…keep the thieves, murderers and rapists in jail…that kind of stuff.”
“Geez, Uncle Bob. You’re so old fashioned. That went out with the Nineties.”
“Look, Izzy. Is climate justice going to make you safer from hurricanes?”
“I heard they might spend some of the extra tax money to fix flooding, Uncle Bob.”
“Where? Behind Rodney Ellis’ house?”
“Who’s Rodney Ellis, Uncle Bob?”
“He’s the guy trying to take your tax dollars, Izzy.”
“I can’t afford no more deductions from my pay check, Uncle Bob. I barely got change left over for them cheesy fries at Burger King.”
“Case closed, Izzy.”
Posted by Bob Rehak on 4/24/25
2795 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2025/04/20230524-Hicaldo-Hair.jpg?fit=1200%2C797&ssl=17971200adminadmin2025-04-24 15:30:582025-04-26 09:30:13County’s Climate-Justice Plan Gets Weird Nephew Izzy All Excited
4/23/25 – At a Town Hall meeting on 4/14/25, Montgomery County Precinct 3 Commissioner Ritch Wheeler implied that Harris County had “approved” a proposed 5,500 acre Ryko floodplain development in MoCo. It did not.
Wheeler, who is newly elected, likely misunderstood the nuances of reports and the outcome of meetings his predecessor held.
Documents Clear Up Misunderstanding
Harris County Flood Control District (HCFCD) and Harris County Engineering did meet with the developer. They reviewed the developer’s preliminary drainage impact analysis when James Noack was the MoCo Precinct 3 Commissioner.
But Harris County did not approve anything in Montgomery County. That includes the development. They didn’t even review a complete drainage impact analysis.
Harris County only issued a “Letter of No Objection” to a portion of a preliminary study that concerned a bridge across Spring Creek.
Moreover, the letter and other associated documents made it clear that “not objecting” was conditional.
Engineers clearly labelled the Drainage Impact Analysis as “Preliminary.” HCFCD requested many supporting documents before it could make a final determination. Those requests included a geotechnical report (soil survey), site plans and a U.S. Army Corps permit (to name just three).
Such pre-development meetings help engineers, developers and regulators scope out the concerns of each other at an early stage before they invest thousands of hours in a project.
What Wheeler Said
Wheeler implied that Harris County had approved Ryko’s drainage impact analysis. And he implied that the approval covered the whole development which lies entirely in Montgomery County.
The purpose of Wheeler’s Town Hall Meeting was to talk about Montgomery County’s 2025 road bond and the Townsen Blvd. project within it, that ran through Ryko’s proposed development.
At one point, Wheeler said, “I don’t want to get too far in the weeds on the water portion of it (meaning flooding). … But I will tell you, they (Ryko) did submit a drainage impact analysis to the county. They also submitted it to Harris County. Harris County has already approved it.“
That didn’t sound right. So, I checked.
What Harris County Said
The highly technical, preliminary drainage analysis covered both the development and a bridge into Harris County. That may have added to Wheeler’s confusion.
Harris County says that it does NOT approve development plans in other counties.
Harris County DID issue a “Letter of No Objection” to the Harris County portion of the proposed bridge over Spring Creek.
Harris County Engineering and HCFCD provided four documents in response to a Freedom of Information Act request. They show definitively what Harris Country regulators saw when and how they responded. They include:
A 2/27/23 conference report of a “pre-project” meeting between Ryko, its engineers, and the regulators. HCFCD communicated its concerns about the Harris County portion of the bridge project, potential downstream impacts, and hydrology models to be used in the final drainage impact analysis.
The draft of a 10/25/24 letter from Chris Bennett of Harris County Flood Control to Daryl Hahn, Harris County Engineering’s Director of Permits. The letter clearly states, “HCFCD review is limited to the proposed Spring Creek Bridge only.” It also clearly stated that additional permits, plans and studies were needed.
A 4/17/25 email from Emily Woodell, HCFCD Chief External Affairs Officer. She stated, “Our organization does not conduct development reviews for compliance with the requirements of other agencies or jurisdictions. In this case, … it appears the only element reviewed by the Flood Control District was an analysis related to the proposed bridge crossing.” Woodell further stated that “to date” Ryko had never submitted any plans for the development itself to HCFCD for review.
Ryko property outlined in red. Floodways and floodplains in shades of blue.From preliminary drainage impact study.
HCFCD’s letter also made it clear that they had not checked all of the 272 pages in the drainage impact analysis. At that point, they were simply taking the word of licensed professional engineers hired by the developer.
No Response Yet from Montgomery County Engineering
I also submitted a FOIA request to Montgomery County Engineering for their copies of the developer’s construction plans and a more recent drainage impact analysis. To date, they have not responded.
Hilarious Mistake in Drainage Impact Analysis
The preliminary drainage impact study submitted by Woolpert Engineering on behalf of Ryko contains a hilarious mistake in the second sentence of the Executive Summary. The engineers say the development lies east of 59; it’s west.
To me, that calls for third-party engineers to dive deeper into the drainage impact study. No telling what else they might find.
Posted by Bob Rehak on 4/23/25
2794 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/2025/04/20250423-Ryko-DIA-Floodplains-.jpg?fit=1100%2C704&ssl=17041100adminadmin2025-04-23 17:55:082025-04-25 14:47:55Harris County Did NOT Approve Ryko Development
Lengthy Catalog of Concerns about Proposed Ryko Development
4/25/25 – A company called Ryko has proposed building a 5,500 acre development in southern Montgomery County, immediately west of US59. More than half of their land lies in the floodway and floodplains of Spring Creek and the West Fork.
The Ryko property is 20 times larger than the Woodridge Village property, which flooded hundreds of Kingwood homes twice in 2019. Did we learn anything from that experience?
A knowledgeable, concerned resident sent a list of concerns which I am reprinting below. However, the writer has asked to remain anonymous. I’ve also included links to posts and official documents at the end of the letter, so readers can find relevant information in one place.
– Start of Letter –
I am writing as a concerned citizen to express strong opposition to the proposed Ryko (Townsen) Development in southern Montgomery County and to raise questions about the lack of transparency and integrity surrounding its approval process, drainage study, floodplain impacts, and associated public funding mechanisms.
This project raises significant public interest concerns that demand further scrutiny before any development proceeds.
⚠️ Floodplain Fill and Inadequate Drainage Analysis
🛑 No Conditional Letter of Map Revision (CLOMR) has been approved by FEMA or signed by the Harris County Floodplain Administrator. Without this, any fill in the floodplain would violate federal NFIP regulations (44 CFR § 60.3).
🌊 Unequal Mitigation Practices Across County Lines
💧 Analogy: Filling the floodplain without mitigation is like filling half a bathtub with sandbags and expecting the water to stay still—it doesn’t. It simply gets pushed elsewhere, potentially flooding neighboring properties.
🗺️ Use of Outdated Models – MAAPnext Ignored
🚦 Traffic Analysis Skipped in Violation of County Review Order
📝 Montgomery County’s Own Records Show Deep Reservations
🌱 Wetlands Presence and Permitting Gaps
💰 Tax Abatements, Bond Spending, and Conflicts of Interest
🧾 PAC Influence and Consultant Conflicts
✅ What Should Happen Now
The people of Montgomery County deserve flood-resilient development, honest governance, and responsible fiscal stewardship. As it stands, this project and its supporting bond failed on all three counts.
– End of Letter –
For More Information
For posts about the Ryko development, see:
22.11.19 A Townsen Bridge Across Spring Creek
25.04.17 MoCo Commissioner Taking Townsen Blvd. Extension Off 2025 Road Bond
25.04.18 Bald Eagles Live Where Developer Wants to Build 7,000 Homes
25.04.19 Building 7,000 Homes Here Would Accelerate Subsidence
25.04.20 Far More Proposals in State Flood Plan Than Funds For Them
25.04.23 Harris County Did NOT Approve Ryko Development
For official documents, see:
Pre-Project Meeting Minutes of lead Ryko engineering company with Harris County Engineering and Flood Control District from 2/27/23.
Townsen Bridge Development Meeting Minutes between the lead Ryko engineering Company and Montgomery County Engineering (Extracted from Drainage Analysis below as separate file. Was Appendix A.) MoCo Engineering office states that development should be avoided due to high risk of flooding during extreme events. 3/22/23
Letter from Montgomery County Engineering objecting to Ryko’s preliminary drainage study on 6/18/24. “Given both the history of this development and a sincere concern for the safety of the public, I can in no way approve this primary drainage study nor should anyone as the risk is too high.”
A letter from Montgomery County Engineering on 7/23/24, rescinding the previous letter (without explanation) that objected to the drainage study.
Preliminary drainage impact analysis submitted by Ryko’s engineers on 10/3/24.
Draft of a 10/25/24 letter from Chris Bennett of Harris County Flood Control to Daryl Hahn, Harris County Engineering’s Director of Permits. Letter states, “HCFCD review is limited to the proposed Spring Creek Bridge only.” It also clearly stated that additional permits, plans and studies were needed.
Montgomery County subdivision regulations: See section on Traffic Impact Analysis Requirements.
It remains to be seen whether we learned anything from the Woodridge Village experience.
Anonymous letter posted by Bob Rehak on 4/25/25
2796 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
County’s Climate-Justice Plan Gets Weird Nephew Izzy All Excited
4/24/25 – My weird nephew Izzy called again this morning. He was all atwitter about Harris County’s new Climate-Justice Plan adopted by Commissioner’s Court on 4/10/25. And he could barely contain his excitement.
The Phone Call from Nephew Izzy
“They did it, Uncle Bob. They really, finally done did it?”
“Did what, Izzy?”
“We finally gonna get some climate justice, Uncle Bob.”
“I didn’t know climate broke the law, Izzy.”
“Oh, Uncle Bob! Justice is just a word they tag onto things they want.”
“What do they want, Izzy?”
“For starters, Uncle Bob, a carbon tax.”
“But Izzy, you can barely afford to put gas in that 1974 Lincoln of yours as it is.”
“I hadn’t thought of that, Uncle Bob. Maybe they’ll buy me a new ride. It’s getting hard to find parts for the Lincoln nowadays. Junkyards hardly carry dem anymore.”
“What else does the climate-justice plan do, Izzy?”
“They gonna make it so you can check out gardening tools at libraries.”
“That would mean you have to work, Izzy.”
“But think of all the things I could grow, Uncle Bob.”
“Cheetos don’t grow in gardens, Izzy.”
“They don’t?”
“They don’t.”
Brightening… “Well, they gonna make solar panels easier to get, Uncle Bob!”
“Where will you put them, Izzy? You live in an apartment.”
“Well, I could stick one in my window…”
“And do what with it?”
“Hook it up to my deep frier.”
“You got me there, Izzy. I’m all for sustainable fried chicken.”
Hair Gone Wild
“You know the beauty of climate justice, Uncle Bob?”
“No.”
“You can plug just about anything into it.”
“I can see that, Izzy.”
“Yeah, Lina Hidalgo might finally get some hair justice.”
“What do you mean?”
“You know how her hair always be shootin’ out all over the place from Houston’s humidity?”
“Hmmmm, yesssss?”
“I look that way, too, sometimes when I wake up. I sure could use some hair justice myself.”
“Personally, Izzy. I’d settle for some good, old-fashioned criminal justice. You know…keep the thieves, murderers and rapists in jail…that kind of stuff.”
“Geez, Uncle Bob. You’re so old fashioned. That went out with the Nineties.”
“Look, Izzy. Is climate justice going to make you safer from hurricanes?”
“I heard they might spend some of the extra tax money to fix flooding, Uncle Bob.”
“Where? Behind Rodney Ellis’ house?”
“Who’s Rodney Ellis, Uncle Bob?”
“He’s the guy trying to take your tax dollars, Izzy.”
“I can’t afford no more deductions from my pay check, Uncle Bob. I barely got change left over for them cheesy fries at Burger King.”
“Case closed, Izzy.”
Posted by Bob Rehak on 4/24/25
2795 Days since Hurricane Harvey
Harris County Did NOT Approve Ryko Development
4/23/25 – At a Town Hall meeting on 4/14/25, Montgomery County Precinct 3 Commissioner Ritch Wheeler implied that Harris County had “approved” a proposed 5,500 acre Ryko floodplain development in MoCo. It did not.
Wheeler, who is newly elected, likely misunderstood the nuances of reports and the outcome of meetings his predecessor held.
Documents Clear Up Misunderstanding
Harris County Flood Control District (HCFCD) and Harris County Engineering did meet with the developer. They reviewed the developer’s preliminary drainage impact analysis when James Noack was the MoCo Precinct 3 Commissioner.
But Harris County did not approve anything in Montgomery County. That includes the development. They didn’t even review a complete drainage impact analysis.
Moreover, the letter and other associated documents made it clear that “not objecting” was conditional.
Engineers clearly labelled the Drainage Impact Analysis as “Preliminary.” HCFCD requested many supporting documents before it could make a final determination. Those requests included a geotechnical report (soil survey), site plans and a U.S. Army Corps permit (to name just three).
Such pre-development meetings help engineers, developers and regulators scope out the concerns of each other at an early stage before they invest thousands of hours in a project.
What Wheeler Said
Wheeler implied that Harris County had approved Ryko’s drainage impact analysis. And he implied that the approval covered the whole development which lies entirely in Montgomery County.
The purpose of Wheeler’s Town Hall Meeting was to talk about Montgomery County’s 2025 road bond and the Townsen Blvd. project within it, that ran through Ryko’s proposed development.
At one point, Wheeler said, “I don’t want to get too far in the weeds on the water portion of it (meaning flooding). … But I will tell you, they (Ryko) did submit a drainage impact analysis to the county. They also submitted it to Harris County. Harris County has already approved it.“
That didn’t sound right. So, I checked.
What Harris County Said
The highly technical, preliminary drainage analysis covered both the development and a bridge into Harris County. That may have added to Wheeler’s confusion.
Harris County says that it does NOT approve development plans in other counties.
Harris County DID issue a “Letter of No Objection” to the Harris County portion of the proposed bridge over Spring Creek.
Harris County Engineering and HCFCD provided four documents in response to a Freedom of Information Act request. They show definitively what Harris Country regulators saw when and how they responded. They include:
HCFCD’s letter also made it clear that they had not checked all of the 272 pages in the drainage impact analysis. At that point, they were simply taking the word of licensed professional engineers hired by the developer.
No Response Yet from Montgomery County Engineering
I also submitted a FOIA request to Montgomery County Engineering for their copies of the developer’s construction plans and a more recent drainage impact analysis. To date, they have not responded.
Hilarious Mistake in Drainage Impact Analysis
The preliminary drainage impact study submitted by Woolpert Engineering on behalf of Ryko contains a hilarious mistake in the second sentence of the Executive Summary. The engineers say the development lies east of 59; it’s west.
To me, that calls for third-party engineers to dive deeper into the drainage impact study. No telling what else they might find.
Posted by Bob Rehak on 4/23/25
2794 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.