Letters to the Army Corps and TCEQ keep pouring in. Without exception, they protest the permitting of the proposed high-rise development near River Grove in the flood plain and floodway of the West Fork.
If researching ideas for your own letters, consult the high-rises page of this web site, specifically the right hand column. It explains the controversy and how you can protest the permitting if you wish.
I have posted many of the letters, both from groups and individuals, to help give people ideas for how this process works. Today, I received a letter from an environmental scientist who spent almost three decades with the EPA. His name is Ken Teague and his letter impressed me – for the points it made. the succinct way he made them and a unique twist.
Mr. Teague suggested trying to get the EPA to elevate consideration of the permit by asking to have the West Fork considered as an Aquatic Resource of National Importance. He gave me permission to reprint his letter. See it below.
Text of Letter from Former EPA Employee
To: swg_public_ notice@usace.army.mil; 401certs@tceq.texas.gov; Kaspar.Paul@epa.gov; Martinez.maria@epa.gov; david_hoth@fws.gov; Rusty.Swafford@noaa.gov
Subject: SWG-2016-00384
Dear Sir/Ms: I have reviewed the subject PN and have the following comments:
I suggest that the wetlands proposed to be destroyed by this project may be Aquatic Resources of National Importance, and if so, I recommend the U.S. EPA elevate review of this permit application under EPA/USACE procedures.
The applicant has not met the Clean Water Act Section 404(b)(1) Guidelines. The information provided with the PN does not support that the applicant has conducted an appropriate alternatives analysis, or demonstrated efforts to avoid and minimize impacts to aquatic habitats. I strongly recommend USACE require the applicant to demonstrate they have met the requirements of the Guidelines.
Most of the components of the proposed project are not water dependent. The one component that is water dependent, the marina, has not been demonstrated to be needed. The USACE must review the proposed project for its water dependency. Non water-dependent projects should not be permitted if they impact aquatic habitats. Water dependent projects should only be permitted if they are demonstrated to be needed.
The applicant stated an existing 17.59-acre conservation easement exists within the commercial and residential district which is associated with a compensatory mitigation area for Department of the Army Permit SWG-99-26-012 verified on 25 May 1999. This permit was conditioned to place 21.90 acres (12.19 acres of wetlands and 8.99 acres of upland buffer) into a conservation easement. It is not clear what this means, but if it means the applicant is proposing to destroy aquatic habitats that were previously preserved as compensatory mitigation as compensation for previous destruction of aquatic habitats, such impacts to such mitigation absolutely must not be permitted.
The site is subject to flooding (see attached image). I assert that it is not in the public interest for the USACE to permit development in flood prone areas, so USACE should not permit the proposed actions. The applicant proposes to greatly elevate the areas it proposes to develop using soil from an undisclosed location. This elevation will change hydrology in surrounding areas, guaranteeing that nearby low elevation properties will flood much more frequently, for a longer duration, and greater depth, than is currently the case. This will almost certainly negatively impact nearby infrastructure and habitats. Permitting such changes would clearly not be in the public interest.
The applicant has not proposed mitigation, other than to say that they will either conduct permittee responsible mitigation or purchase credits from a mitigation bank. The USACE must provide the public the opportunity to review and comment on proposed mitigation. This does not meet the requirement.
Do not permit the proposed activity.
Sincerely,
(Signed) Kenneth G. Teague, PWS, Certified Senior Ecologist
Aquatic Resource of National Importance?
I’m not sure if the specific 47 acres of wetlands are an Aquatic Resource of National Importance. But I have no doubt that the West Fork of the San Jacinto is. And these wetlands help protect that resource, by holding and filtering water before it reaches Lake Houston.
Why is it so important? Five reasons come to mind:
This reach of the West Fork connects two lakes that provide water for two million people.
It provides industrial process water for a large portion of America’s refining and petrochemical plants.
Bald eagles, a threatened and protected species, live up and down the West Fork. Hundreds of other species of birds use the river and the forests that surround it as a migration corridor.
The shores of the river contain many bottomland hardwoods, bogs, marshes and wetlands that are all integral parts of a unique connected environment.
It’s a rare and beautiful natural resource that’s easily accessible to millions of people.
Long Shot, But Worth a Try
Lake Houston communities have proved for decades that low-impact development like we now have can co-exist with this unique environment without disturbing the wildlife that make it so special. But I doubt it could survive the kind of high-rise, high-density development that Romerica Investments has in mind.
As always, these are my opinions on matters of public policy. They are protected by the first Amendment of the U.S. Constitution and the Anti-SLAPP statutes of the great state of Texas.
Posted by Bob Rehak on January 21, 2019
510 Days after Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2019/01/Image-1-5.jpg?fit=742%2C576&ssl=1576742adminadmin2019-01-21 16:36:172019-01-21 19:06:15High-Rise Protest Letter from Former EPA Scientist Suggests Unique Approach
The State of Texas has received multiple appropriations from Congress and the U.S. Department of Housing and Urban Development (HUD) for long-term disaster recovery from Hurricane Harvey. But figuring out where and how to apply for help can be tricky. It depends on where you live.
The General Land Office (GLO) runs the Homeowner Assistance Program throughout the state with the exception of the City of Houston and Harris County. Both have their own programs. If you live outside the City or Harris County, review the types of assistance available immediately below. Links to City and County programs are further below.
Warning: some of these programs are still in development. HUD approved the City and County programs only last December. Another warning: the State is still administering programs, such as Economic Revitalization, that the City and County may not have implemented yet. Things change daily, so consider the information below a starting point.
Townhomes in Forest Cove on Marina Drive destroyed by Hurricane Harvey
For Those Outside Houston or Harris County…
Homeowner Assistance Program: Provides funding for rehabilitation and reconstruction of owner-occupied single-family homes damaged by Hurricane Harvey.
Local Buyout and Acquisition Program: Local governments may buyout or acquire eligible homes at a pre-storm or post-storm fair market value to move homeowners out of harm’s way outside of a floodplain to a lower-risk area.
Homeowner Reimbursement Program: Allows homeowners to be reimbursed for certain out-of-pocket expenses incurred for repairs to their home including reconstruction, rehabilitation or mitigation up to $50,000.
Affordable Rental Program: Provides funding for rehabilitation, reconstruction and new construction of affordable multi-family housing units in areas impacted by Hurricane Harvey.
Economic Revitalization Program: Allows for interim assistance to small businesses (up to $250,000) impacted by Hurricane Harvey through deferred forgivable loans in exchange for job creation or retention for low-to-moderate income employees. Small business within Harris County and the city of Houston will be eligible to apply for this program.
For Those Inside City of Houston…
If you live inside the City of Houston, you may qualify under one of these programs.
Homeowner Assistance Program (HoAP)
HoAP is the primary program to help homeowners whose homes were damaged during Hurricane Harvey. There are five options within HoAP to assist homeowners at different stages of recovery and with specific recovery needs. The first step in getting help is to take the Harvey Recovery Survey to assess if there are programs you may qualify or and to help identify what documents you will need before you make a formal application.
The Harvey Homebuyer Assistance Program (HBAP) provides up to $30,000 through a forgivable, interest-free loan for down-payment and/or close-cost assistance to qualified homebuyers. The program serves Houstonians earning up to 120% of Area Median Income (AMI). The City places a sale-restricted lien on the home for five years to ensure that the program is meetings its affordability objectives.
The Harvey Single-Family Development (HSFD) Program builds new single-family homes for low- and moderate-income Houstonians. These homes typically sell for under $200,000 to eligible buyers. The City places a sale-restricted lien on properties for sale to income-qualified buyers to ensure that the home remains affordable for a specified period.
As a majority-renter city, Houston needs more quality, affordable rental housing after Hurricane Harvey. As demand for housing continues to rise, workers may not be able to afford homes in areas that are safe from flooding and close to jobs and transit. Ensuring Houston’s continued economic growth depends on having transit-connected, resilient, and affordable housing options for people at all income levels. The Multifamily Program provides funding to repair existing and develop new multifamily homes across Houston. Developers will be able to apply for funding through a subrecipient selection process.
Many Houstonians live in single-family rental properties, or rental properties with fewer than eight units. These small rental properties are important for affordable housing, and many were damaged during Hurricane Harvey. The Harvey Recovery Small Rental Program assists landlords to make repairs and improve the quality of these properties.
Service provider agencies help HCDD implement important programs, including support for people experiencing homelessness, those living with HIV/AIDS, and mental health services. Agencies can apply for funding through this program through a subrecipient selection process.
This program is intended to assist residents to move out of areas that have been impacted by multiple disasters or are at high risk of flooding from future disasters. The program is currently under development. City of Houston residents interested in a buyout option should visit the Harris County Control District’s Voluntary Home Buyout Program website.
City of Houston Contact Info
City of Houston Housing and Community Development Department
These represent starting points. If you were damaged during Harvey and need help recovering, explore these links. They may help. Each has a screening survey to make sure you qualify. Start there. Good luck.
Posted on January 20, 2019 by Bob Rehak
509 Days After Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/11/SJR_511_030.jpg?fit=1800%2C1200&ssl=112001800adminadmin2019-01-20 09:33:502019-01-20 09:47:59How and Where to Seek Disaster Recovery Help from Hurricane Harvey
Thursday night, the Kingwood Service Association (KSA) added its voice to the growing chorus concerned about a proposed high-rise development in the floodplain near River Grove Park. KSA is the largest private group in the Kingwood area. It represents more than 30 community associations, which comprise more than 70,000 residents. It also manages the five private parks in the Kingwood area including two adjacent to the proposed development along Woodland Hills Drive.
The letter addresses concerns that BOTH the TCEQ and Army Corps will consider during the permit evaluation process. TCEQ rules on water quality issues (Clean Water Act Section 401) for the Corps. The Corps rules on Section 404 concerns.
The applicant, Romerica Investments, LLC must respond to every concern submitted by residents. So email them now or forever hold your peace.
Here is the text of KSA’s letter, which is also linked on the High Rise Page in the right hand column. I inserted the pictures and captions into KSA’s letter; they are not part of the original. I put them there to help illustrate the concerns for people who may not be familiar with all of the issues surrounding this controversial development.
Text of KSA Letter
Evaluation Branch, North Unit Regulatory Division, CESWG-RD-E Galveston District U.S. Army Corps of Engineers P.O. Box 1229 Galveston, Texas 77553-1229
Enclosed are the comments of the Kingwood Service Association, regarding the U.S.Army Corps of Engineers (Corps) Galveston District, Section 10/404 proposed Permit Application No. SWG-2016-00384, Romerica Investments, LLC, located in waters of the United States (U.S.) and wetlands adjacent to the West Fork of the San Jacinto River, Kingwood, Harris County, Texas.
The Kingwood Service Association (KSA) is a Kingwood-wide homeowners association representing thirty-two (32) residential and commercial associations in the Kingwood area. The following comments are being made on behalf of Kingwood residents concerned about the impact of the proposed development on the Kingwood community.
KSA owns and operates two parks adjacent to the proposed permit area, River Grove Park and Deer Ridge Park. During Hurricane Harvey, both of these parks flooded with 10 to 20 feet of water. River Grove Park is located on the West Fork of the San Jacinto River between the river and the proposed commercial and residential areas. This park was covered by 20 feet of water. As the flood waters receded, it left 6 feet of sand covering half of the park area. River Grove Park has flooded at least 6 times in the past 12 months. This experience raises serious concerns about the environmental impact of a development that calls for adding fill material to approximately 330 acres located north and east of River Grove Park, and which would raise the grade level of the area 12 feet from 45 feet to 57 feet.
We are very concerned about the overall impact of this development on the community because it would be built where Hurricane Harvey created some of the worst flooding in 100-year or greater floodplains/floodways; will fill and displace about 200 acres of 100-year floodplain/floodway, which will raise water levels and increase the possibility of flooding for others; will fill in wetlands that are crucial for soaking up water and reduced flows, velocities, and increased sedimentation of the West Fork of the San Jacinto River in its 100-year floodplain/floodway; is subject to further flooding in the future; and destroys more of the natural beauty, water quality, and wildlife habitat of the West Fork of the San Jacinto River.
In the review of this permit application, we ask the Corps to consider all relevant public interest review factors in 33 CFR 320-332 including conservation, economics, aesthetics, air quality, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, and the needs and general welfare of the people.
We think that, at a minimum, the following areas should be addressed by USACE and TCEQ during the permitting process.
1. This proposal will fill 42.35 acres of wetlands with 68,323 cubic yards of fill material on 331.45 acres and fill 771 linear feet of streams with 285 cubic yards of fill material. There are significant concerns about the environmental impact of the elimination of 42.35 acres of wetlands. These concerns fall into the following areas:
a. Elimination of a natural area inhabited by eagles, deer, and other animals native to the area without sufficient mitigation in the same watershed.
Nesting bald eagles, a protected species, on West Fork of San Jacinto. Photo courtesy of Emily Murphy. The Houston Police Deportment Lake Patrol has reportedly sighted seven other eagle’s nests in the area, according to Murphy who frequently kayaks the river.
b. Decrease in the quality of the water supply for the City of Houston, which is downstream of the development, as a result of the increase in erosion and increase in deposition of sediment caused by the elimination of wetlands and the increase in infrastructure.
One of the drainage ditches that the proposed high-rise development would use is so over-burdened, that incision already is threatening existing development. Any addition to flow would destroy properties.
c. Decrease in the quality of the water supply for the City of Houston caused by the contamination of water run-off by the addition of parking spaces for 8,000 plus vehicles that could increase contaminants, such as motor oil, being washed into the San Jacinto River.
d. Increase of erosion and acceleration of deposition of sediment due to an increase in the speed of water run-off caused by the additional infrastructure, elimination of wetlands, and increase in grade level of the area.
High-rises for the proposed development would fill in wetlands where eagles fish and nest. The high-rises would also be built in an old meander of the San Jacinto West Fork, which contains unstable soil that is prone to flooding.
e. Determine the impact of filling in 42.35 acres of wetlands on eagles nesting in that area. Eagle nests have been spotted in the vicinity by Kingwood residents.
Eagles nest on the 16th hole of Kingwood Country Club’s Island Course, immediately adjacent to the proposed high-rise development.
2. Impact on the ability for residents to use the recreational facilities as a result of the increase in flooding caused by the increase of grade level from 45 feet to 57 feet that would inhibit the flow of water during significant rain events and cause the acceleration of water run-off potentially increasing erosion and accelerating the deposition of sediment in the San Jacinto River.
3. Economic impact on the villages immediately surrounding the development area as a result of the potential increase in flooding caused by the development. This could cause a significant decrease in the value of the homes located in these villages.
4. Economic impact on the community that would be caused by adding 8,000 plus vehicles to the traffic patterns of the community without a plan to mitigate this impact. The increase of this much traffic in a single area would have a negative impact on the attractiveness of purchasing a home in Kingwood, which has a reputation for being the “Liveable Forest”.
5. Completion of an environmental impact study before further consideration of this permit application. This study should include a full hydrological study of the project’s impact, an environmental impact to the large wetlands habitat without mitigation in the same watershed, and socioeconomic impact of such a huge development on an existing master planned community.
6. Impact on boat navigation on the West Fork of the San Jacinto River caused by the potential addition of 640 boats. Navigation on the West Fork has been impaired for decades and getting worse due to the acceleration of sediment deposition caused, in part, by sand mines upstream of the project area. This development has the potential to add to that sediment deposition.
This sand bar is currently not being addressed by the Emergency West Fork Dredging Project. It backs water up throughout the Humble/Kingwood area where thousands of homes and businesses flooded during Harvey. Erosion caused by the new development would add more sediment, make the marina useless, and destroy FEMA’s investment in dredging to date.
7. Require the applicant to provide documentation about how it will provide for operation and maintenance dredging of the site so that Section 10 navigation will continue over the lifetime of the development and after floods.
We are requesting that the Corps schedule a public hearing on this application to allow residents to gather additional information on the proposed development and provide further comments. In addition, considering the potential significant negative impact of this development on the community, we request that the Corps and TCEQ seriously consider denying this permit application.
We appreciate this opportunity to provide public comment on this proposed permit application.
Sincerely, Dee M. Price, President Kingwood Service Association
Feel free to echo these concerns or add to them in your letters to the Army Corps and TCEQ.
Posted by Bob Rehak on 1/19/19
509 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2019/01/2EaglesInNest.jpg?fit=1200%2C960&ssl=19601200adminadmin2019-01-18 22:53:212019-01-19 11:09:38KSA Adds to Growing Chorus of Concerns Over Proposed New High-Rise Development
High-Rise Protest Letter from Former EPA Scientist Suggests Unique Approach
Letters to the Army Corps and TCEQ keep pouring in. Without exception, they protest the permitting of the proposed high-rise development near River Grove in the flood plain and floodway of the West Fork.
If researching ideas for your own letters, consult the high-rises page of this web site, specifically the right hand column. It explains the controversy and how you can protest the permitting if you wish.
I have posted many of the letters, both from groups and individuals, to help give people ideas for how this process works. Today, I received a letter from an environmental scientist who spent almost three decades with the EPA. His name is Ken Teague and his letter impressed me – for the points it made. the succinct way he made them and a unique twist.
Mr. Teague suggested trying to get the EPA to elevate consideration of the permit by asking to have the West Fork considered as an Aquatic Resource of National Importance. He gave me permission to reprint his letter. See it below.
Text of Letter from Former EPA Employee
To: swg_public_ notice@usace.army.mil; 401certs@tceq.texas.gov; Kaspar.Paul@epa.gov; Martinez.maria@epa.gov; david_hoth@fws.gov; Rusty.Swafford@noaa.gov
Subject: SWG-2016-00384
Dear Sir/Ms: I have reviewed the subject PN and have the following comments:
Sincerely,
(Signed) Kenneth G. Teague, PWS, Certified Senior Ecologist
Aquatic Resource of National Importance?
I’m not sure if the specific 47 acres of wetlands are an Aquatic Resource of National Importance. But I have no doubt that the West Fork of the San Jacinto is. And these wetlands help protect that resource, by holding and filtering water before it reaches Lake Houston.
Why is it so important? Five reasons come to mind:
Long Shot, But Worth a Try
Lake Houston communities have proved for decades that low-impact development like we now have can co-exist with this unique environment without disturbing the wildlife that make it so special. But I doubt it could survive the kind of high-rise, high-density development that Romerica Investments has in mind.
As always, these are my opinions on matters of public policy. They are protected by the first Amendment of the U.S. Constitution and the Anti-SLAPP statutes of the great state of Texas.
Posted by Bob Rehak on January 21, 2019
510 Days after Hurricane Harvey
How and Where to Seek Disaster Recovery Help from Hurricane Harvey
The State of Texas has received multiple appropriations from Congress and the U.S. Department of Housing and Urban Development (HUD) for long-term disaster recovery from Hurricane Harvey. But figuring out where and how to apply for help can be tricky. It depends on where you live.
The General Land Office (GLO) runs the Homeowner Assistance Program throughout the state with the exception of the City of Houston and Harris County. Both have their own programs. If you live outside the City or Harris County, review the types of assistance available immediately below. Links to City and County programs are further below.
Warning: some of these programs are still in development. HUD approved the City and County programs only last December. Another warning: the State is still administering programs, such as Economic Revitalization, that the City and County may not have implemented yet. Things change daily, so consider the information below a starting point.
For Those Outside Houston or Harris County…
For Those Inside City of Houston…
If you live inside the City of Houston, you may qualify under one of these programs.
Homeowner Assistance Program (HoAP)
HoAP is the primary program to help homeowners whose homes were damaged during Hurricane Harvey. There are five options within HoAP to assist homeowners at different stages of recovery and with specific recovery needs. The first step in getting help is to take the Harvey Recovery Survey to assess if there are programs you may qualify or and to help identify what documents you will need before you make a formal application.
Get started with homeowner recovery
Harvey Homebuyer Assistance Program
The Harvey Homebuyer Assistance Program (HBAP) provides up to $30,000 through a forgivable, interest-free loan for down-payment and/or close-cost assistance to qualified homebuyers. The program serves Houstonians earning up to 120% of Area Median Income (AMI). The City places a sale-restricted lien on the home for five years to ensure that the program is meetings its affordability objectives.
Harvey Single-Family Development Program
The Harvey Single-Family Development (HSFD) Program builds new single-family homes for low- and moderate-income Houstonians. These homes typically sell for under $200,000 to eligible buyers. The City places a sale-restricted lien on properties for sale to income-qualified buyers to ensure that the home remains affordable for a specified period.
Get started with recovery for homebuyers
Harvey Multifamily Program
As a majority-renter city, Houston needs more quality, affordable rental housing after Hurricane Harvey. As demand for housing continues to rise, workers may not be able to afford homes in areas that are safe from flooding and close to jobs and transit. Ensuring Houston’s continued economic growth depends on having transit-connected, resilient, and affordable housing options for people at all income levels. The Multifamily Program provides funding to repair existing and develop new multifamily homes across Houston. Developers will be able to apply for funding through a subrecipient selection process.
Harvey Recovery Small Rental Program
Many Houstonians live in single-family rental properties, or rental properties with fewer than eight units. These small rental properties are important for affordable housing, and many were damaged during Hurricane Harvey. The Harvey Recovery Small Rental Program assists landlords to make repairs and improve the quality of these properties.
Get started with recovery for landlords
Harvey Public Services Program
Service provider agencies help HCDD implement important programs, including support for people experiencing homelessness, those living with HIV/AIDS, and mental health services. Agencies can apply for funding through this program through a subrecipient selection process.
Buyout Program
This program is intended to assist residents to move out of areas that have been impacted by multiple disasters or are at high risk of flooding from future disasters. The program is currently under development. City of Houston residents interested in a buyout option should visit the Harris County Control District’s Voluntary Home Buyout Program website.
City of Houston Contact Info
City of Houston Housing and Community Development Department
For Those in Harris County, but Outside Houston…
If you life outside Houston, but inside Harris County, start here.
Harris County Contact Info
In Summary
These represent starting points. If you were damaged during Harvey and need help recovering, explore these links. They may help. Each has a screening survey to make sure you qualify. Start there. Good luck.
Posted on January 20, 2019 by Bob Rehak
509 Days After Hurricane Harvey
KSA Adds to Growing Chorus of Concerns Over Proposed New High-Rise Development
Thursday night, the Kingwood Service Association (KSA) added its voice to the growing chorus concerned about a proposed high-rise development in the floodplain near River Grove Park. KSA is the largest private group in the Kingwood area. It represents more than 30 community associations, which comprise more than 70,000 residents. It also manages the five private parks in the Kingwood area including two adjacent to the proposed development along Woodland Hills Drive.
The letter addresses concerns that BOTH the TCEQ and Army Corps will consider during the permit evaluation process. TCEQ rules on water quality issues (Clean Water Act Section 401) for the Corps. The Corps rules on Section 404 concerns.
The applicant, Romerica Investments, LLC must respond to every concern submitted by residents. So email them now or forever hold your peace.
Here is the text of KSA’s letter, which is also linked on the High Rise Page in the right hand column. I inserted the pictures and captions into KSA’s letter; they are not part of the original. I put them there to help illustrate the concerns for people who may not be familiar with all of the issues surrounding this controversial development.
Text of KSA Letter
Evaluation Branch, North Unit
Regulatory Division, CESWG-RD-E
Galveston District
U.S. Army Corps of Engineers
P.O. Box 1229
Galveston, Texas 77553-1229
Texas Commission on Environmental Quality
401 Coordinator
MSC-150
P.O. Box 13087
Austin, Texas 78711-3087
Re: Permit Application No. SWG-2016-00384, Romerica Investments, LLC
Dear Corps and TCEQ,
Enclosed are the comments of the Kingwood Service Association, regarding the U.S.Army Corps of Engineers (Corps) Galveston District, Section 10/404 proposed Permit Application No. SWG-2016-00384, Romerica Investments, LLC, located in waters of the United States (U.S.) and wetlands adjacent to the West Fork of the San Jacinto River, Kingwood, Harris County, Texas.
The Kingwood Service Association (KSA) is a Kingwood-wide homeowners association representing thirty-two (32) residential and commercial associations in the Kingwood area. The following comments are being made on behalf of Kingwood residents concerned about the impact of the proposed development on the Kingwood community.
KSA owns and operates two parks adjacent to the proposed permit area, River Grove Park and Deer Ridge Park. During Hurricane Harvey, both of these parks flooded with 10 to 20 feet of water. River Grove Park is located on the West Fork of the San Jacinto River between the river and the proposed commercial and residential areas. This park was covered by 20 feet of water. As the flood waters receded, it left 6 feet of sand covering half of the park area. River Grove Park has flooded at least 6 times in the past 12 months. This experience raises serious concerns about the environmental impact of a development that calls for adding fill material to approximately 330 acres located north and east of River Grove Park, and which would raise the grade level of the area 12 feet from 45 feet to 57 feet.
We are very concerned about the overall impact of this development on the community because it would be built where Hurricane Harvey created some of the worst flooding in 100-year or greater floodplains/floodways; will fill and displace about 200 acres of 100-year floodplain/floodway, which will raise water levels and increase the possibility of flooding for others; will fill in wetlands that are crucial for soaking up water and reduced flows, velocities, and increased sedimentation of the West Fork of the San Jacinto River in its 100-year floodplain/floodway; is subject to further flooding in the future; and destroys more of the natural beauty, water quality, and wildlife habitat of the West Fork of the San Jacinto River.
In the review of this permit application, we ask the Corps to consider all relevant public interest review factors in 33 CFR 320-332 including conservation, economics, aesthetics, air quality, general environmental concerns, wetlands, historic properties, fish and wildlife values, flood hazards, floodplain values, land use, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, and the needs and general welfare of the people.
We think that, at a minimum, the following areas should be addressed by USACE and TCEQ during the permitting process.
1. This proposal will fill 42.35 acres of wetlands with 68,323 cubic yards of fill material on 331.45 acres and fill 771 linear feet of streams with 285 cubic yards of fill material. There are significant concerns about the environmental impact of the elimination of 42.35 acres of wetlands. These concerns fall into the following areas:
a. Elimination of a natural area inhabited by eagles, deer, and other animals native to the area without sufficient mitigation in the same watershed.
b. Decrease in the quality of the water supply for the City of Houston, which is downstream of the development, as a result of the increase in erosion and increase in deposition of sediment caused by the elimination of wetlands and the increase in infrastructure.
c. Decrease in the quality of the water supply for the City of Houston caused by the contamination of water run-off by the addition of parking spaces for 8,000 plus vehicles that could increase contaminants, such as motor oil, being washed into the San Jacinto River.
d. Increase of erosion and acceleration of deposition of sediment due to an increase in the speed of water run-off caused by the additional infrastructure, elimination of wetlands, and increase in grade level of the area.
e. Determine the impact of filling in 42.35 acres of wetlands on eagles nesting in that area. Eagle nests have been spotted in the vicinity by Kingwood residents.
2. Impact on the ability for residents to use the recreational facilities as a result of the increase in flooding caused by the increase of grade level from 45 feet to 57 feet that would inhibit the flow of water during significant rain events and cause the acceleration of water run-off potentially increasing erosion and accelerating the deposition of sediment in the San Jacinto River.
3. Economic impact on the villages immediately surrounding the development area as a result of the potential increase in flooding caused by the development. This could cause a significant decrease in the value of the homes located in these villages.
4. Economic impact on the community that would be caused by adding 8,000 plus vehicles to the traffic patterns of the community without a plan to mitigate this impact. The increase of this much traffic in a single area would have a negative impact on the attractiveness of purchasing a home in Kingwood, which has a reputation for being the “Liveable Forest”.
5. Completion of an environmental impact study before further consideration of this permit application. This study should include a full hydrological study of the project’s impact, an environmental impact to the large wetlands habitat without mitigation in the same watershed, and socioeconomic impact of such a huge development on an existing master planned community.
6. Impact on boat navigation on the West Fork of the San Jacinto River caused by the potential addition of 640 boats. Navigation on the West Fork has been impaired for decades and getting worse due to the acceleration of sediment deposition caused, in part, by sand mines upstream of the project area. This development has the potential to add to that sediment deposition.
7. Require the applicant to provide documentation about how it will provide for operation and maintenance dredging of the site so that Section 10 navigation will continue over the lifetime of the development and after floods.
We are requesting that the Corps schedule a public hearing on this application to allow residents to gather additional information on the proposed development and provide further comments. In addition, considering the potential significant negative impact of this development on the community, we request that the Corps and TCEQ seriously consider denying this permit application.
We appreciate this opportunity to provide public comment on this proposed permit application.
Sincerely,
Dee M. Price, President
Kingwood Service Association
Feel free to echo these concerns or add to them in your letters to the Army Corps and TCEQ.
Posted by Bob Rehak on 1/19/19
509 Days since Hurricane Harvey