Final Report on Imelda Says 62% of Flooding Outside of 100-Year Floodplain

Harris County Flood Control District released its final report on Tropical Storm Imelda this morning. It’s a work of incredible scholarship. If you really want to know what made this storm different, this is a must read.

While Imelda was the fourth wettest storm in Texas history when measured by total rainfall, Imelda produced incredible short duration rainfall rates that exceeded Harvey in the 5-, 15-, and 30-minute time periods. And that is the key to understanding why more homes flooded in the 500-year floodplain than the 100-year floodplain.

Few Structures In Lake Houston Area Flooded from River

Says Jeff Lindner, Harris County meteorologist, “Much of the structure flooding that occurred in the Kingwood area was not a result of flooding from the river, but instead flooding of local drainage systems that were overwhelmed from the intense short duration rainfall rates. Harvey remains the flood of record along the West Fork of the San Jacinto River.”

Almost Two-Thirds of Flooded Homes Outside 100-year Floodplain

Similar to other recent flooding events in Harris County a large number of flooded homes were located outside the 1% (100-yr) floodplain. Of the 3,990 homes flooded from Imelda, 2,479 (62%) were outside the 1% (100-yr) floodplain. 1,511 (38%) of the flooded homes were located inside the 1% (100-yr) floodplain.

“While house flooding did occur from creeks and bayous overflowing their banks, a large majority of the house flooding was a result of intense short duration rainfall rates overwhelming the internal drainage capacities and this is shown by the large number of homes that flooded outside the 1% (100-yr) floodplain,” says Lindner.

Rainfall Totals Throughout San Jacinto Watershed

See the actual rainfall measurements for gages throughout the San Jacinto Watershed below. All characterizations of floods (i.e., 100-year) are based on NOAA’s new Atlas 14 data.

San Jacinto River and Lake Houston
Cypress Creek
Spring Creek
Luce Bayou
Flooding of Local Tributaries: Green = 10-50 yr flood, Yellow = 50-100 yr, Red = 100-500 yr, based on high water marks.
1-Hour Peaks throughout county. Note blue bullseye over US59 and Beltway 8. That’s a 500-year intensity rate.
48 Hour Peaks throughout county. Notice extreme gradient from east to west. 28″ in northeast part of county and less than 2″ in the west.
Regional map. Parts of Liberty, Chambers and Jefferson Counties received a 1000-year rain. As bad as Imelda was, Harris County escaped the worst part of the storm.

Details Provide Clues to Reasons for Flooding

The final Imelda report has thousands of statistics for just about every location in the county and every time period between 5 minutes and 48 hours. Scanning it may give you a feeling for why you flooded or why you did not.

Increasing Frequency of Extreme Storms

The report also contains a discussion the number of extreme storms that have hit this area recently. Some key stats:

  • Three of five wettest tropical cyclones in Texas history occurred in the last 20 years (Imelda, Harvey, Allison)
  • Among Texas storms, four of the top five occurred in southeast Texas (Imelda, Harvey, Allison, and Claudette).
  • Imelda is also the 5th wettest tropical cyclone ever in the 48 contiguous United States.
  • Six of the wettest tropical cyclones in US history have occurred in Texas.
  • Six of the 10 wettest occurred in the last 22 years.
  • Three of the 10 wettest occurred in the last three years (Imelda, Florence, Harvey).

The table below shows the top ten wettest tropical cyclones by location and year in the 48 contiguous states.

Source: Harris County Flood Control final report on Imelda.

For the full report, click here.

Implications of Report Speak to Need for Change

Yesterday, I posted about an engineering company that made conservative and questionable assumptions about rainfall totals and more in their drainage analysis for Woodridge Village.

When far more homes flood in the 500 year flood plain than the 100, it’s clear that our infrastructure is not equipped to handle the kind of storms we’re now getting.

We can no longer allow developers and engineering companies to bet on the best case scenarios when the worst case scenarios are becoming the norm. We must start building infrastructure to handle bigger storms. The old norms are failing us.

For starters, we need Montgomery County to:

Posted by Bob Rehak on 11/11/2019

804 Days since Hurricane Harvey and 55 since Imelda

The conclusions expressed in this post represent my opinions on matters of public policy and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the great State of Texas.

Questionable Assumptions by LJA Engineering May Have Compounded Elm Grove Flooding

Questionable assumptions about soil composition, rainfall patterns, wetlands and floodplain status for Perry Homes’ troubled Woodridge Village development may have compounded flooding in Elm Grove and North Kingwood Forest. Previously, I have focused on other more obvious issues, such as missing detention ponds and expected rainfall totals. However, Elm Grove resident Jeff Miller who has been studying the LJA Drainage Report, urged me to explore these additional issues.

Soil Type Closer to Clay than Sandy Loam

The LJA engineers doing the drainage analysis for Perry based their runoff calculations on a soil type called “sandy loam.” Different soil types absorb rainfall at radically different rates. According to 2011 data from Texas A & M Agrilife Extension, water infiltration rates for:

  • Sand = 2″ – 6″ per hour
  • Loam = .6″ – 2″ per hour
  • Clay = .2″ – .6″ per hour

Clay absorbs water very slowly, so rain turns into runoff quickly. Two photos below show what the Woodridge Village construction site looked like ONE WEEK AFTER a 2″ rain. It still had ponding water that did not soak in.

The northeastern portion of Woodridge Village looking southwest. Photo taken on 11/4/2019 one week after a 2″ rain. Note the ponding water that has not yet infiltrated.
A closer shot of the main portion of the north side of the site, also taken on 11/4/2019. Note the ponding water here, too. USGS characterized parts of this portion of the site as WETLANDS.
From the USGS National Wetlands Inventory. Note how the ponding water in the photo aligns with where the wetlands were.
Drone footage of southern section taken two days after May 7th flood. Courtesy of Jim Zura, Zura Productions.

In May, a retired local geologist from a major oil company estimated that the clay content in Woodridge soil was at least 50%, and could be as high as 80%. However, he could not commit to an exact figure.

Going by the A&M infiltration figures above and assuming an infiltration rate of 2″ per hour for a mixture of sand and loam, and contrasting that with the minimum infiltration rate for clay, .2″ per hour, you get a difference of 10X.

What does all this mean?

Based solely on soil type, the LJA Engineering report could err in its runoff calculations by as much as 10X.

Sections 1.1 and 2.1.3 of the LJA report discuss the runoff based on soil type. No matter how sophisticated the calculations, if you base them on the wrong soil type, the result will be inaccurate. “Garbage in, garbage out” as they say in the computer business.

Before clearcutting, there may have been more sandy loam in a thin surface layer. But contractors likely disturbed or buried that when they removed vegetation from the site and regraded the area.

If LJA wishes to challenge this, I will be happy to reprint their response verbatim. I would love to see their soil report.

But I would like to know how they explain the presence of ponding water throughout the entire northern section of Woodridge Village a full week after a two-inch rain. (Note that the northern section is the steepest and largest. It comprises 2/3rds of the Woodridge Village’s acreage.)

I took the aerial shots above at around 2PM on 11/4/2019. Here are the rainfall totals for the previous 7 days. Graph courtesy of Harris County Flood Warning System.

The Presence of Wetlands Should Have Been a Signal

The presence of wetlands should have been a signal to the developer, but the LJA report does not mention the word “wetlands” once.

Many residents who used to hike and bike this area before it was clearcut have told me that they could always find standing water there even in summer. Here’s an interesting article that explains why wetlands stay wet. The authors says, “Wetlands typically form in gently sloping or topographically convergent portions of a landscape, where surface and ground waters meet.” That certainly fits Woodridge Village.

As Miller says, “Drone footage; many photos; and the constant presence of water in the S-2 detention pond and the rectangular pond where N3 should be confirm that the ground is saturated. When the soil is totally wet, water will move over the surface.” And as LJA says in the intro to its report, “The project site naturally drains to Taylor Gully.”

And that’s exactly where so many people flooded when contractors accelerated the runoff through clearcutting and by not providing adequate detention.

Balanced Storm Assumption Rarely Accurate

Section 2.1 of the LJA report says that LJA models assumed a “balanced storm.” “This distribution is constructed such that the depth specified for any duration occurs during the central part of the storm (intensity position = 50%).” [Emphasis added.]

But as Jeff Johnson, the Montgomery County engineer, pointed out, using a “balanced storm” bases calculations on ideal assumptions. He also pointed out that only a small percentage of storms conform with ideal conditions. (Johnson made these remarks at a Montgomery County Commissioners Court meeting at which they discussed closing a loophole in flood regulations.)

According to the US Geological Survey, this graph represents a balanced storm.

In the ideal balanced storm, most of the accumulation happens in the middle of the storm.


But the May 7th and Imelda storms did not follow this pattern. The heavy rainfall was front-loaded in both.

More than half of the total rainfall during the May 7th event fell at the outset, not in the middle of the storm. Thus, it did not conform to the balanced storm model upon which LJA based its calculations.
During the 11 hours of rainfall from Imelda, more than 50% fell in the first three hours, and almost 80% in the first 4 hours. Thus, Imelda was also “front-heavy”.

LJA Assumed Woodridge Was Outside of 100-Year Floodplain

LJA also assumed (see section 1.5 of its report) that Woodridge Village was “outside of the 100-year floodplain.” For permitting purposes, that is technically true. LJA was going by accepted maps. But that area is not shown as flood plain only because FEMA did not model it. Note in the Montgomery County Flood Plain Map shown below how ALL FLOODPLAIN MAPPING STOPS AT THE COUNTY LINE.

That straight diagonal line you see is the Harris-Montgomery County Line.

Any engineer experienced in working with flood plains should know that physical boundaries do not stop abruptly at political boundaries. Any competent engineer should have questioned this.

Engineering Codes of Ethics Discourage Such Conduct

While LJA did what regulations required, they had a higher ethical obligation to protect people as licensed engineers. See the Code of Ethics of the NSPE – the National Society of Professional Engineers. It states:

“…engineers are expected to exhibit the highest standards of honesty and integrity. Engineering has a direct and vital impact on the quality of life for all people. Accordingly, the services provided by engineers require honesty, impartiality, fairness, and equity, and must be dedicated to the protection of the public health, safety, and welfare. Engineers must perform under a standard of professional behavior that requires adherence to the highest principles of ethical conduct.”

Under Fundamental Canons, the Society’s Code of Ethics also requires engineers to “Hold paramount the safety, health, and welfare of the public.”

Also see Professional Conduct and Ethics for Texas Engineers.

The latter states “In order to safeguard, life, health and property, to promote the public welfare, and to establish and maintain a high standard of integrity and practice, the rules relating to professional conduct in this title shall be binding on every person holding a license and on all firms authorized to offer or perform engineering services in Texas.” In this regard, LJA failed the people of Elm Grove and North Kingwood Forest dismally.

Overlooked Ethical Obligations Contribute to Dramatic Miscalculations

Ignoring the missing flood plain information, not mentioning wetlands, and mischaracterizing soil composition all contributed to dramatic miscalculations. Add those problems to ignoring new statistics that showed flood plain maps would need to be redrawn based on NOAA’s new Atlas 14, and that a 100-year storm would include 40% more rainfall.

Sometimes when you’re eager to make a project happen, optimism leads one to make “best-case” assumptions. But in my opinion, engineers should act on “worst-case” assumptions” to product public safety.

Sometimes, the cost of failure is simply unthinkable. This is one of them. Elm Grove flooding wasn’t as spectacular as a dam or a bridge failing, but it likely affected far more people.=

Webster and Spurlock law firms are currently trying to subpoena correspondence between LJA and Perry Homes and its subsidiaries. The Perry Homes gang is trying just as hard to stonewall production. It will be interesting to see what pressure, if any, they put on LJA to ignore these obvious problems…if the documents ever become public.

An even bigger ethical question: With such obvious problems, why did Montgomery County Commissioners and the City of Houston approve permits for this development?

Posted by Bob Rehak on 11/10/2019 with help from Jeff Miller and video from Jim Zura

803 Days after Hurricane Harvey and 51 after Imelda

The thoughts in this post represent my 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.

Woodridge Village Update: More Dirt, Denials, Delays

Twenty-three days ago, Houston Mayor Sylvester Turner read a letter to a packed town hall meeting at the Kingwood Community Center. The letter was from a lawyer named J. Carey Gray. Mr. Gray laid out a timetable for accelerating completion of the detention ponds on the troubled Perry Homes’ development, Woodridge Village, just north of Elm Grove. The first deliverable: completing the S2 pond in 30-45 days – even though it was already largely completed.

As of early this week, contractors have performed no new excavation work on the site since early August. See pictures below.

One Piece of Equipment Moves Closer to S2 Pond

This piece of Rebel Construction equipment moved from the site entrance to north of the S2 pond last Thursday. It looks as though its in danger of actually doing some work. Photo by Jeff Miller on 11/7/2019.

Dirt Continues to Flow From Construction Site

Construction has slowed to a virtual standstill for three months. Between that time and the time the photos below were taken, we had Imelda and a 2.12-inch rain on October 29.

On the 29th, yet more mud washed out of the development into the City’s storm drains, despite the City’s Cease and Desist Letter.

This and photos immediately below were taken on 10/29/2019 near Woodridge Village Construction entrance on Fair Grove Drive and Creek Manor Drive in Kingwood.
Dropping back a little farther, you can see the silty runoff from the construction site. Notice the contrast between that and the clear water coming from a resident’s lawn through the curb break.
Contrast appears a little clearer in this closeup.
You can see the contrast even better where the water enters this storm drain. Muddy water is coming from the construction site. Clear water from the neighborhood to the south.
These sand waves covered Fair Grove Drive just outside the construction site entrance...despite silt fencing.
Here’s a picture of water going into the S2 Detention pond at the north end of Village Springs Drive.
And here it is coming out of S2 into Taylor Gully. S2 is behind the trees on the left. This shot is looking north.

Of course, flooding, not sediment is the real issue in Elm Grove. However, sediment can block storm drains and contribute to flooding. That’s why the City has an ordinance prohibiting discharges of sediment into the City’s sewer system. It’s one area where the City has real leverage with the Perry gang. That’s why so much emphasis has been placed on sediment in this controversy.

City Inspectors Visit Site

Thursday and again Friday, City inspectors checked the construction site for discharges. We dodged a huge bullet Thursday. Parts of Houston received five inches of rain. But the Lake Houston Area received less than one inch.

Photo taken 11/7/2019 by Jeff Miller of a City Inspector photographing Woodridge S2 detention pond.
Photo taken 11/7/2019 by Jeff Miller shows same City Inspector walking along Taylor Gully just south of Woodridge.

Denials, Finger Pointing, Objections on Legal Front

Webster and Spurlock, lawyers for hundreds of Elm Grove flood victims, have brought another defendant into the suit. It is Texasite LLC of Montgomery, Texas. Legal filings do not describe exactly what the new defendant did on site. The company has no web site that I can find. Even the Texas Secretary of State can’t shed much light on the matter; the company’s Certificate of Formation simply says it is organized to “conduct lawful business.”

That said, whatever they allegedly did, they aren’t accepting responsibility for it. Texasite:

  • Denies they harmed anyone
  • Asserts that plaintiffs caused their own injuries through negligence
  • Asserts that third parties caused the damage. Those third parties include God.

In other legal news, Webster and Spurlock filed a notice of intent to take a deposition by written questions from LJA Engineering. The list of information they seek is two pages long.

PSWA and Figure Four Partners, two Perry Homes subsidiaries being sued, objected to items #2 and #3 on the list. They included “letters, emails, and other correspondence/communications between LJA Engineering & Surveying” and the defendants “with regard to the Woodridge Village Development.” The defendants argued in their objection that the request was overly broad because it didn’t limit the time period or subject matter. So sayeth Counselor J. Carey Gray, who wrote the overly vague letter to the City of Houston re: completion of the detention ponds. According to documents on file with the Harris County District Clerk, the judge has not yet ruled on Perry’s objection to production of the evidence.

Delays Also Continue on Construction of More Detention

I flew over the Woodridge Village construction site on Monday, 11/4 and saw no evidence of construction activity, despite the assurances made by Counselor Gray. The images below show the lack of activity from several different angles.

Looking N at the extreme western tail of the construction site that borders Woodland Hills Drive (left). This and all photos below taken on 11/4/2019.
Looking NE across the north and south sections of the site. Detention pond S1 runs along the diagonal tree line from the lower left. Detention Pond N2 is in the upper right. These two ponds comprise 23% of the total detention capacity by volume.
Detention pond N3 is supposed to go along the trees in the background to the left of the S2 pond. It has not been started yet. Notice the one piece of yellow equipment at work clearcutting more land on the middle left.
Close up of where the N3 pond will eventually go. It will start in the bottom left and curl around the upper right.
Looking west. No construction activity on the northeast corner of the site in the foreground.
From this angle, looking SW, it’s easy to see all the standing water on the site. We received two inches of rain SIX days before. So much for LJA’s assumption that this site contained sandy loam. The ponding water after such a long period suggests a high clay content. That in turn explains the rapid and huge runoff rates that flooded Elm Grove.
More ponding water indicating high clay content.
Looking west at the NW corner of the site. This is where the non-existent N1 pond should be.
Looking North. The largest detention pond on the site, N2, will go in that triangular green area (center). Contractors were supposed to deepen and enlarge it. The partial detention capacity you see here now was developed by Montgomery County in 2006 as mitigation for another site. So the detention capacity you see in this image, by itself, would not reduce Elm Grove flooding potential. Saying it did would be like trying to sell a ticket that someone else already bought.

I’m Shocked, Shocked I Tell You

So what are we to make of the continued lack of construction activity? To paraphrase the exchange between Strasser and Renault in the movie Casablanca, I am shocked – SHOCKED – Perry would promise the Mayor of Houston that it would accelerate construction of new detention ponds and then not do it.

Posted by Bob Rehak on 11/9/2019, with photos an updates from Jeff Miller.

802 Days since Hurricane Harvey and 50 Days since Imelda

The thoughts expressed in this post represent my opinions on matters of public policy and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.