Tag Archive for: Army Corps

Possible Penalties for Wetlands Violations

The Army Corps of Engineers has acknowledged that neither Perry Homes, its subsidiaries nor its contractors sought a “jurisdictional determination” before filling the wetlands at the Woodridge Village construction site. Further, the Corps is now investigating whether those wetlands do fall within its jurisdiction and would have required a permit to fill.

We are a long way from determining whether there was any wrongdoing in that case and I am not alleging any.

But, in general, what could possible penalties be in wetlands cases and how are they determined? Several documents found on the EPA website give insight into how they think and assess penalties. Below is a summary plus links to the documents and several additional useful pages on the EPA enforcement website.

Corps and EPA Share Responsibility for Enforcement

The Corps of Engineers and EPA share responsibility for enforcing Section 404 of the Clean Water Act, which covers wetlands. Both civil and criminal penalties can apply to wetlands violations depending on circumstances. This page on the EPA’s site explains the shared authority.

Goals of Enforcement Program

EPA’s Section 404 enforcement program has three goals:

  • Protect the environment and human health and safety
  • Deter violations
  • Treat the regulated community fairly and equitably. 

Factors Considered in Initiating an Enforcement Action

A wide variety of factors determine whether EPA initiates an enforcement action. They include:

  • Amount of fill
  • Acres of wetlands filled
  • Environmental significance
  • Discharger’s compliance history

Largest Criminal Action in EPA History

At one end of the spectrum, you have criminal cases. Since enactment of the Clean Water Act, EPA and the Corps have used their criminal enforcement authorities sparingly, only for the most flagrant and egregious Section 404 violations. The most significant case ever:

  • On February 25, 2005 in the Southern District of Mississippi, a jury convicted Robert J. Lucas, Jr., his daughter, Robbie Lucas Wrigley, and his engineer, M.E. Thompson, Jr., on all 41 counts of an indictment which charged violations of Sections 402 and 404 of the Clean Water Act, mail fraud and conspiracy.
  • Lucas developed and sold hundreds of lots in the Big Hill Acres subdivision that impacted approximately 260 acres of wetlands without Corps of Engineers’ permits.
  • In developing the lots, Lucas filled wetlands for the construction of driveways and septic systems. The construction persisted after Lucas was ordered to desist by EPA and other agencies.
  • Wrigley sold lots and otherwise participated in the conspiracy knowing that the lots were saturated and could not support septic systems. 
  • M.E. Thompson, a professional engineer, wrongfully certified that the lots were suitable for septic systems, even after being told by the local health department to the contrary. 
  • In December 2005, the District Court sentenced Lucas to 108 months in prison and Wrigley and M.E. Thompson, Jr. to 87 months apiece.  The court fined each of the Defendants $15,000, assessed restitution of $1,407,400 for each Defendant and fined Lucas’s two companies Big Hill Acres, Inc., $4,800,000 and Consolidated Investments, Inc., $500,000.
  • The case represents the most significant criminal wetlands case in the history of the Clean Water Act.
  • The Decision was affirmed on appeal and the Supreme Court refused to consider it.

Factors Considered in Assessing Fines

At the other end of the spectrum, you have civil penalties with fines that can range from slaps-on-the-wrist to substantial.

This document explains how the agencies determine penalties. They use multiple factors, each with weighting, that are fed into a formula. EPA designed the formula to:

  • Require violators to promptly correct violations
  • Remedy harm caused by violations
  • Recover any economic benefit that accrued to violators, thereby assuring a level playing field for those who obey the law
  • Deter future violations
  • Promote fair and equitable treatment nationwide
  • Promote expeditious resolution (fast settlement)

Section 309 (d) of the CWA sets penalty factors for judges to use when determining the appropriateness of civil penalties.

  • Seriousness of violations
  • Economic benefit resulting from violations
  • History of violations
  • Good faith efforts to comply
  • Economic impact on violators
  • Other matters as justice may require

They refer cases to the Department of Justice when court ordered injunctive relief is necessary to remedy a violation, or when the violator has failed to comply with an administrative compliance order or consent order.

Formula Used in Assessing Fines

When calculating minimum settlement penalties, they use the following formula.

Penalty = Economic Benefit + (Preliminary Gravity Amount +/- Gravity Adjustment Factors) – Litigation Considerations – Ability to Pay – Mitigation Credit for Supplemental Environmental Projects

This determines the minimum penalty amount that the government will accept in the settlement of a case, in other words, “the bottom-line penalty” amount.

Economic Benefit Component Explained

Persons who violate the CWA by discharging dredged and/or fill material without Section 404 permit authorization or in violation of a permit may have obtained an economic benefit by obtaining an illegal competitive advantage (“ICA”), or as the result of delayed or avoided costs, or by a combination of these or other factors.

The objective of calculating and recovering economic benefit is to place violators in no better financial position than they would have been had they complied with the law.

Gravity Component Explained

The “gravity” component of the calculation considers whether the discharge endangers the health and welfare of persons. The greater the threat, the higher the weight. If the discharge has resulted in an imminent and substantial endangerment, they will apply the highest value for this factor.

Other Considerations

Secondary or Off-Site Impacts such as the extent to which discharges caused erosion and downstream sedimentation problems are considered.

Judges also consider the duration of violation. That’s the length of time that fill material has remained in place. Generally, the longer the duration, the higher the weight assigned to this factor.

Judges can also apply a Recalcitrance Adjustment Factor. The “recalcitrance” factor may be used to increase the penalty based on a violator’s bad faith, or unjustified delay in preventing, mitigating, or remedying the violation in question.

As distinguished from culpability, recalcitrance relates to the violator’s delay or refusal to comply with the law, to cease violating, to correct violations, or to otherwise cooperate with regulators.

Classes of Penalties

Section 309(g) of the Clean Water Act establishes two classes of administrative penalties. They differ with respect to maximum assessment for violations.

A Class I penalty may not exceed $11,000 per violation, or a maximum amount of $27,500.

A Class II penalty may not exceed $11,000 per day for each day during which the violation continues, or a maximum amount of $137,500.

EPA may also seek:

  • Injunctive relief
  • Criminal penalties (fines and/or imprisonment),
  • Civil penalties through judicial action.

Criminal Vs. Civil

When the Agency refers cases to the Department of Justice (DOJ) for civil and/or criminal enforcement under Section 309(d), EPA may seek civil penalties of up to $27,500 per day for CWA violations including the unauthorized discharge of fill.

Criminal prosecution in wetlands cases usually involves someone who knowingly or negligently discharges fill, makes false or misleading statements on permit applications, or endangers other people.

For More Information and Exact Text

The discussion above summarizes 32-pages of technical/legal EPA and Army Corps documents. I urge you to consult the sources directly for their exact wording.

Other useful links, for those seeking even more information, include:

Posted by Bob Rehak on 11/18/2019

811 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.

Army Corps to Investigate Potential Wetland Violations on Perry Homes’ Woodridge Village Site

The Army Corps of Engineers is investigating whether Perry Homes, its subsidiaries and contractors violated Section 404 of the federal Clean Water Act. The Corps has regulatory authority for any fill material dumped into waters of the U.S. Those include perennial tributaries and adjacent wetlands.

No Record of Request for Jurisdictional Determination

When developers encounter wetlands, normally they seek a jurisdictional determination from the Corps. They want to ensure they are not violating the Clean Water Act. However, neither Perry Homes nor their subsidiaries (PSWA and Figure Four Partners) apparently sought such a determination. Neither did LJA Engineering, according to Corps records.

In June, a FOIA (Freedom of Information Act) request filed with the Corps of Engineers turned up NO RECORDS of any such request for the Woodridge property. See below.

Army Corps response to June 5, 2019, request for records pertaining to a request for jurisdictional determination on Woodridge Village Wetlands.

The LJA Engineering Drainage Analysis never even mentions wetlands. Wetlands are highly protected because of their ability to filter and retain floodwater, among other things. This multipage article by the USGS describes all the functions of wetlands and legislation affecting them.

Elm Grove Director Requests Investigation

In October, 2019, Beth Guide, a director of the Elm Grove Homeowners Association, went a step further than my FOIA request. She asked the Corps to investigate the legality of the loss of Woodridge Village wetlands. On November 13, 2019, US Congressman Dan Crenshaw received a letter from the Corps stating that the Corps was, in fact, investigating Ms. Guide’s request.

Corps Seeking Access to Property

The Corps is currently contacting Perry Homes (or subsidiary, Figure Four Partners) for access to the site. The Corps characterized the investigation as “an open purported unauthorized activity investigation.”

Colonel Timothy R. Vail, the Corps’ District Commander said, “…we continue to gather all the facts to determine if there is a violation of any of our statutes and if so, determine what might be the appropriate resolution.”

Presence and Importance of Wetlands

Numerous residents near the property noted the wetlands in question. The wetlands also appear in the USGS National Wetlands Inventory.

From the USGS National Wetlands Inventory

For the full text of the letter from the Corps to Congressman Crenshaw, click here.

Ms. Guide believes loss of these wetlands played a role in three floods which struck Elm Grove on May 3, May 7 and September 19 of this year. Before the loss of the wetlands, none of the surrounding neighborhoods ever flooded, according to nearby neighbors. Some of them lived in their homes for more than 30 years.

Typically, wetland vegetation slows down runoff. On the other hand, clearcutting/filling wetlands accelerates runoff. This simple science experiment shows how.

Accelerating runoff reduces the time of accumulation for floodwaters. That means more water reaches ditches faster and at the same time; none is retained upstream. That, in turn, makes floods peak higher.

Posted by Bob Rehak on 11/16/2019

809 Days since Hurricane Harvey and 58 since Imelda

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.

FEMA Concludes Partial Mouth-Bar Dredging

Over the weekend, Rachel Taylor, a Lake Houston area resident who lives near the mouth bar sent me the video below. It shows an idle dredge near its starting point. The video, plus reports from boaters, fueled speculation that the mouth bar dredging had concluded. That fact was confirmed this afternoon by Houston City Council Member Dave Martin. His office issued a press release stating that FEMA had finished dredging 500,000 cubic yards of sediment from the San Jacinto West Fork Mouth Bar.

Lake Houston area resident Rachel Taylor shot this video of the Great Lakes Dredge on 9/8/2019. The dredge had returned to its starting point, fueling speculation that it had completed its mission assignment.

FEMA Concludes Dredging Addtional 500,000 Cubic Yards

Said Council Member Dave Martin, “The Federal Emergency Management Administration’s (FEMA) mission assignment modification to address partial removal of the San Jacinto River West Fork mouth-bar has concluded.” The mission assignment authorized the United States Army Corps of Engineers (USACE) to remove an additional 497,400 cubic yards of debris from the West Fork near its confluence with Lake Houston. As of September 3, 2019, USACE removed 500,000 cubic yards of debris from the mouth-bar.

However, Martin never accepted the amount of debris included in the mission modification and continues to fight that number to this day.

Running, Year-Long Argument Over Volume

Council Member Martin and the City of Houston, through Chief Recovery Officer Stephen Costello, argued for almost a year to remove more sediment, believing that 500,000 cubic yards was much too low. But their pleas have fallen on deaf ears.

According to Martin, FEMA cannot explain how 497,400 cubic yards was calculated, even while the City of Houston has provided verifiable scientific data showing the volume deposited by Harvey near the mouth bar was 1.4 million cubic yards.

During a meeting in June, 2019, FEMA representatives verified the City’s estimate was sound. That lead Martin to believe another contract extension was feasible. In August, FEMA representatives again stated, “Your (City of Houston) data is NOT bad data”, leaving Martin with lingering questions as to why no additional modification had been granted.

Comparison of Two Reports

The analysis that FEMA used to justify their number (497,000 cubic yards) is a four-page table top study that does not begin to answer questions that were asked of the City of Houston by FEMA, which produced a 94-page comprehensive report. I previously analyzed and compared these two reports and believe there are major flaws in the Corps’ analysis which they tried to keep secret for months.

How You Can Help

As a result of the most recent meeting held in Austin, Texas, with representatives from FEMA, USACE, Texas Division of Emergency Management, City of Houston, and Governor Greg Abbott’s office, Council Member Martin along with Mayor Sylvester Turner have sent a letter to our Federal Congressional Delegation requesting action be taken to address the Hurricane Harvey debris remaining in the mouth-bar. This letter urges Senator John Cornyn, Senator Ted Cruz, Chairman Kevin Brady, and Congressman Dan Crenshaw to continue to support recovery of our area through requesting an additional mission modification from FEMA. It would enable dredging another one million cubic yards of sediment related to Hurricane Harvey.

Overall, dredging in the San Jacinto removed more than 2 million cubic yards of sediment. That will help reduce the effects of potential future flooding, but it will not restore the conveyance of the river.

Granting a second mission modification allows the use of existing pre-positioned resources as well as an estimated savings of nearly $20 million for mobilization.

The City of Houston has secured a third disposal site, Barry Madden’s property south of the river, that has already received USACE permits for another 500,000 cubic yards of sediment disposal.

Request from Council Member Martin

Martin asks residents who support the request for additional dredging to contact their federal representatives. Martin says he remains committed to removing additional sediment in the mouth-bar and will continue to fight for additional dredging at that location.

Why We Still Have A Problem

Last weekend, boaters, canoeists and kayakers reported that water depth in the mouth bar was only 3-5 feet deep. Even though the Corps has so far refused to release its plans or survey results, that’s very close to the estimate I calculated when dividing 500,000 cubic yards by the acreage within the dredge area.

However, boaters also report the water upstream from the mouth bar is almost 40 feet deep in places.

This will herd water into an underwater box canyon.

As water hits that wall, it will also slow down, dropping more sediment out of suspension faster. That, in turn, will accelerate re-deposition and quickly fill in the area that FEMA just spent $90 million dredging. What a tragic waste of tax dollars!

Benefits of Additional Dredging

Creating a consistently wide and deep channel through the mouth bar that connects upstream areas with the Lake beyond FM1960 will reduce flood damages to properties regionally and provide for increased resilience to transportation systems, water treatment systems, public/private utilities, emergency response facilities, petrochemical industries, and other critical infrastructure, in the West Fork, San Jacinto River Watershed, plus Harris, Montgomery, and Liberty Counties.

Last year, the Corps estimated the flood protection benefits to be on the order of $200 billion.  

FEMA regulations allow the agency to restore a river to a prior good condition if a risk to health and human safety exists.

Given that petrochemical industries in the region produce a significant amount of the nation’s petroleum-based energy products, reducing flood risks to these plants and their workers who reside in flood-prone areas will provide greater resiliency and a National security benefit. 

Environmental benefits include reduced risks to water treatment plants from flooded sand mines and chemical spills which are threats to human health and safety. Non-monetary benefits include reduced risks to life, especially among residents with insufficient means.

Start writing. It’s your home and your community.

Posted by Bob Rehak on 9/10/19

742 Days since Hurricane Harvey

Lake Houston Area Geologists Propose Dredging Objectives to Restore Conveyance, Safety

Secrecy surrounds current dredging plans for the mouth bar of the San Jacinto West Fork. We know that the Corps will finish removing 500,000 cubic yards next week. However…

Unkowns at This Time

… we don’t know exactly where they are removing sediment, how wide the area is, how deep it is, and whether they will cut a channel through the sediment dam or just shave some off the top.

Mouth Bar of the San Jacinto West Fork immediately after Harvey

The Corps’ refusal to divulge plans puts residents in a bind. How can we know whether they have restored conveyance and safety? We must take their word. We don’t even have a post-dredge survey showing us how they intend to leave the river.

Two Prominent Geologist Suggest Objectives

With those caveats in mind, I asked Tim Garfield and RD Kissling what objectives they would set to restore conveyance and safety. Garfield and Kissling are two prominent area geologists who first brought the mouth-bar problems to the public’s attention. Between them, they have more than 80 years of oil field experience at the highest levels, studying river basins around the world.

Here’s how they responded: “Our overriding objectives are simple:

  • Restore flow conveyance of the west fork into Lake Houston
  • Survey the entire area being dredged for depth upon completion.
  • Extend the upstream dredging which ended near Kings Harbor through the mouth bar area. Said another way, don’t make water flow uphill. Eliminate the ramp.
  • Continue the 400’ wide, approximately 20′ deep channel past the SMB until it connects into the relict channel where it is 20’ deep or deeper near the FM1960 bridge.
  • Develop and implement a plan for regular maintenance dredging.
  • Define responsibilities, budget and source of funding for future dredging.
  • Define a schedule of regular depth surveys in order to determine where sediments are re-accumulating and to have a better baseline for future storm events.
  • Build and utilize 2D- or 3D-models to help guide future dredging decisions.
  • Resolve disposal issues. Identify long-term placement areas and potential partnerships with industry.”

Who Will Achieve Desired Results?

These objectives make sense to me. They describe what the river used to look like before the mouth bar set up and contributed to flooding 7,000 homes and businesses. They also describe what we need to do to keep the problem from recurring. If the Corps doesn’t achieve the desired result, I hope the City, Harris County and State can. You can help by urging elected representatives to get FEMA to designate the mouth bar sediment as Category A.

Corps May Share Results When Dredging Complete

According to Congressman Dan Crenshaw’s office, the Corps has finally agreed to share with outside sources the 1D HEC-RAS model it built. Reportedly, the Corps sent a copy of the model and data to Stephen Costello, the City of Houston’s Chief Recovery Officer. Crenshaw’s office is also trying to obtain the Corps’ dredging plans and make them public.

It will be interesting to see how the Corps’ dredging results line up with Garfield’s and Kissling’s objectives.

Posted by Bob Rehak on 8/31/2019

732 Days since Hurricane Harvey


FEMA/Corps To Stop Dredging Mouth Bar Before Finishing Job; What You Can Do

Having barely scratched the surface of the mouth bar of the San Jacinto West Fork, FEMA and the Army Corps will pack up their gear next week and call their job done. Last-ditch pleas by the City of Houston, Harris County and the State of Texas to get the federal government to extend its dredging program have fallen on deaf ears, perhaps because of the shifting of disaster relief funds to the construction of migrant detention facilities.

Mouth bar of the West Fork shortly after start of supplemental dredging. Photo courtesy of BCAeronautics.

Regardless, the bottom line is this: the Corps and FEMA will leave millions of cubic yards of sediment in place without restoring conveyance of the West Fork to a prior good condition.

The pullout caps months of arguments over how much sediment Harvey deposited. The City estimated 1.4 million cubic yards and the Corps 500,000.

According to City Council Member Dave Martin, the Corps agreed Harvey deposited 1.4 million cubic yards of sediment in the river near the mouth bar. The Corps also agreed, said Martin, that there was nothing wrong with the Tetra Tech study that arrived at that total.

Waffling by Corps

As late as last Friday, Martin said, the Corps agreed to write a letter to FEMA, recommending dredging more than the 500,000 cubic yards. The letter would say that almost a million cubic yards of Harvey-related sediment remained in the river and should be removed. However, at a meeting in Austin this Tuesday, the Corps revealed that FEMA told it not to write the letter. The Corps now intends to demobilize equipment as soon as it finishes dredging 500,000 cubic yards from the mouth bar. That should only take until next week.

These developments confirm speculation that the Corps “backed into” the 500,000 cubic yard number for reasons unrelated to Harvey. Mystery still surrounds how they arrived at that number. The Corps refused to release many documents related to their decision. A review of their 4-page analysis obtained from the City found numerous issues, logical flaws, and questionable assumptions – uncharacteristic of the Corps.

Next Steps

With the year-long dredging program now almost complete and perhaps less than a quarter of the sediment removed that is required to restore the natural flow of the river, what will happen next? We have some hope.

  • The Corps has finally approved Berry Madden’s property as a storage site for 500,000 cubic yards. That should be enough to get the next phase of the program started while the City seeks additional storage sites.
  • The City has committed to a maintenance dredging program according to Martin.
  • The State and Harris County have earmarked $30 million and $10 million respectively to continue dredging.
  • Additional funds may become available early next year through SB7.
  • Callan Marine has agreed to remain on site and do the dredging.

Your Help Is Needed

However, to make that money stretch far enough to finish the job, we will need FEMA and the Corps to designate the remaining sediment as Category A. City Council Member Dave Martin is sending this letter to all congressional and senatorial representatives in the area. Designating the sediment as Category A will:

  • Enable reimbursement from FEMA
  • Allow the City of Houston to utilize existing resources and pre-positioned contracts.
  • Save nearly $20 million associated with mobilization.

Please Contact These Officials

Here’s how you can help. Send the letter below to:

Tell them that you support the Category A designation and see the mouth bar removal as crucial to public safety with a letter like the one below.

Sample Letter

Subject: PLEASE CLASSIFY MOUTH BAR REMNANTS AS CATEGORY A

Dear _____________: 

Thank you for helping to make dredging of the San  Jacinto West Fork a priority.  It will help reduce flooding, protect property, save lives, and improve public safety.  

However, part of the existing mouth-bar located at the confluence of the San Jacinto River and Lake Houston remains.  

I’m writing to enlist your support in urging the Federal Emergency Management Administration (FEMA) to designate that remaining debris as Category A for reimbursement.  

Category A designation will allow the City of Houston to:  

  • Utilize existing resources and pre-positioned contracts  
  • Save nearly $20 million associated with mobilization  
  • Protect life, property and safety  

Field data collected by the City of Houston and provided to FEMA demonstrates that the remaining debris was directly associated with Hurricane Harvey. As of August 20, 2019, the City of Houston has proactively secured a third United States Army Corps of Engineers permitted disposal site needed for the additional debris.  

Your assistance is crucial to rehabilitate the San Jacinto River to its prior good condition.  Please urge FEMA to grant this Category A designation. It will let the City of Houston continue rebuilding from Harvey.  

Sincerely,  

INSERT  

YOUR NAME  

YOUR ADDRESS  

Posted by Bob Rehak on 8/30/2019 with drone photo from BCAeronautics

731 Days since Hurricane Harvey

Recently Obtained Documents Raise Questions about Amount of Sediment in Mouth Bar Due to Harvey

ReduceFlooding.com has obtained a copy of the study withheld by the Army Corps that the Corps used to justify dredging only 500,000 cubic yards from the mouth bar of the San Jacinto West Fork. The Corps refused to supply it in response to my Freedom of Information Act (FOIA) request in June. However, the City of Houston did supply the Corps document in response to a similar FOIA request. Now, thanks to Council Member Dave Martin, the public has an opportunity to compare the two studies side by side for the first time.

Kings River resident near mouth bar wading in knee deep water almost to West Fork channel marker. Caution: do not let children attempt this. Pockets of deeper water may exist that could cause drowning. Picture taken eight days ago. The island being excavated in the distance has since been removed; see last image in post.

After reviewing the Corps document, I can see why the Corps refused to supply it. It has more holes in it than a West Texas stop sign.

History of Controversy

For almost a year, the City and the Army Corps have argued over how much sediment was deposited in the mouth bar of the San Jacinto river by Hurricane Harvey. That determines how much dredging FEMA will fund. Initially, the City recommended working with two Texas Water Development Board sedimentation surveys conducted in 2011 and 2018. But no measurements exist from the period immediately BEFORE Harvey – only AFTER. So the Corps rejected that idea.

Corps Demands then Rejects Stockton Protocol

To determine Harvey volume, the Corps then required the City to provide direct measurement of the sediment through something called the Stockton Protocol. (See this memo from Stephen Costello, Houston’s Chief Recovery Officer, outlining this request and the reasons for it.)

The Stockton Protocol combines ultra-high-resolution CHIRP seismic data with core sampling. The seismic identifies layer thickness and the core sampling identifies layer composition. (Note: the process is somewhat like the oil field practice of confirming seismic with core samples from exploratory wells.) The hope: that by analyzing changes in sediment composition (such as color, grain size, roundness, hardness, etc.), researchers can differentiate Harvey sediment from other floods and then measure it accurately.

Core sample from Tetra Tech Study. Different colors and consistencies indicate sediment came from different floods.

The Army Corps recommended a Texas A&M Galveston professor, Dr. Timothy Dellapenna, to do the research. However, the City of Houston and A&M could not agree on contract terms. Therefore, the City hired Tetra Tech, to perform the research that Dr. Dellapena outlined.

Corps Produces Own Analysis

Tetra Tech concluded Harvey deposited 1.4 million cubic yards in the mouth bar (although they didn’t state it that clearly). The Corps rejected Tetra Tech’s results and produced its own study. That study concluded Harvey deposited only 283,000 cubic yards in the mouth bar – one fifth as much. However, the Corps authorized 500,000 cubic yards to compensate for the margin of error and additional sediment they would have to dredge just to reach the mouth bar.

At the end of the day, even with 500,000 cubic yards, those two estimates still vary by almost 3X. According to Houston City Council Member Dave Martin, the Corps never explained why they rejected the Tetra Tech analysis.

The Corps simply accepted its own results and started dredging without public explanation or input. The Corps document raises many questions that may or may not have valid answers.

The USGS gauge used by the Corps for its analysis stopped working during the peak of Harvey when most sediment would have been moving. The Corps report did not acknowledge this.

Corps Analysis Requires Explanations Never Supplied

Why did the Corps:

  • Base its analysis on a gage at US59 that stopped functioning during the peak of Harvey, when most sediment was moving?
  • Assume Harvey distributed sediment in the same patterns over the same distances as lesser storms?
  • Ignore build up of sediment from Tax Day and Memorial Day storms at the mouth bar as a factor that could have increased the percentage of sediment falling out of suspension during Harvey?
  • Not consider bank erosion downstream from the gage, relying instead on standard charts for “bed-load transport” for sandy rivers?
  • Ignore approximately 20 square miles of sand mines in the West Fork floodway where loose sand and silt were inundated by 131,000 cubic feet of water per second, unlike previous storms?
  • Use a 1-D instead of a 2- or 3-D model for this complex environment?
  • Not publicly disclose model inputs/outputs and data for peer review and validation?
  • Initially reject the use of two TWDB surveys, then reverse course and base all of their findings on them – without explaining why?
  • Exclude extreme data from their study, even though Harvey was one of the most extreme rainfall events in U.S. history?
  • Mislabel all charts, graphs and photos in its report?
  • Refuse to disclose their report in response to a FOIA request, contrary to official Army policy?
  • Omit the organization’s name and the author’s name from the report?
  • Treat the volume that Tetra Tech found related to Harvey in the mouth bar area alone as if it represented the total volume deposited in the entire West Fork by Harvey?

Corps Rejects Use of TWDB Surveys, Then Bases Own Analysis On Them

To estimate Harvey-related volume, the City initially proposed analyzing two Texas Water Development Board sedimentation surveys from 2011 and 2018.

The Corps rejected that idea, suggested the Stockton Protocol, rejected those findings, then based its own analysis on the two TWDB surveys it rejected earlier. This is like following a Three-Card Monte game!

Here is the full text of the Corps’ 4-page unsigned study. We now know that…

Basically, the Corps tried to estimate the amount of sediment that Harvey’s flow could theoretically carry. That would depend on velocity and sediment size/weight. But the gage at US 59 stopped recording at the peak of Harvey. So they also had to estimate the discharge (volume of flow in cubic feet per second [cfs]). Then they used industry-standard curves to estimate sediment transport based on estimated discharge. But they discarded rates over 45,000 CFS because they produced unexpectedly high values.

They also ignored the presence of mile-wide sand mines upstream. The river ruptured the dikes of those mines and captured the pits during Harvey.

West Fork Sand Mine Complex inundated by Harvey. This reach of the river is normally about 150 feet wide. On this day, the day AFTER Harvey’s peak, the flow was more than a mile wide.

Corps Rules Out Extremes for Extreme Event

The Corps says in its report, “there are no measurements above 45,000 cubic feet per second.” Yet the combined peak flows coming from the West Fork, Spring and Cypress Creeks reached approximately 240,000 cubic feet per second during Harvey – five times more. The faster and higher the flow, the more sediment that can be transported downstream and over greater distances.

When the industry-standard sediment transport curves yielded unacceptably high results, the Corps resorted to a simple 1-D model (developed earlier for another purpose) to calculate the sediment load, because flows beyond 45,000 cubic feet per second “produced sediment loads far beyond a reasonable range.”

Corps Assumes Harvey Transported Same Percentage To Mouth Bar as Other Storms

One potentially fatal assumption: The Corps assumes that Harvey transported the same percentage of its sediment load to the mouth bar as all other storms between 2011 and 2018. Said another way, they assume that Harvey behaved LIKE all other storms. Yet not all those floods inundated sand mines.

Moreover, had the Corps measured river bank erosion at intervals between 2011 and 2018, they would have found that virtually all of it occurred during Harvey and very little occurred during Tax Day, Memorial Day and other storms.

Quantum Leap in Erosion Not Factored In

Harvey’s erosive power was NOT proportional to other storms, as the photos below show. River banks eroded more than a hundred feet during Harvey in many places. Yet the Corps report never even mentions erosion.

In 2011, the distance from the ridgeline of this home on Riverbend Drive to the West Fork was 326 feet.
On 1/23/2017, after the Tax and Memorial Day Floods, the distance had decreased only 2 feet.
This shows how much shoreline Harvey ALONE eroded. The yellow line is exactly the same length as after the 2016 floods.
After Harvey, the new distance to the river bank was 216 feet – 108 feet less.

The Tax and Memorial Day Floods combined eroded this river bank by 2 feet. Harvey alone eroded it another 108 feet – 50 times more!

Photographic analysis shows similar quantum leaps in erosion related to Harvey elsewhere along the West Fork.

  • Another home west of River Grove Park lost 27 feet between 2011 and early 2017, but 111 feet in Harvey.
  • River Grove Park lost 0 feet from 2011 to early 2017, but 74-feet in Harvey.
  • Romerica lost 62 feet between 2011 and early 2017, but 144 feet in Harvey.

Net: In four days, Harvey eroded from 2X to 75X more sediment than all other storms during the previous six years. It did NOT act proportionally.

The shearing force of 240,000 cubic feet per second coming down the West Fork literally pulled thousands of trees out by their roots and dislodged sediment disproportionately compared to previous floods (see below). The Gallery page of this web site clearly shows the extent of this devastation. It contains 450 images taken from a helicopter on 9/14/2017, two weeks after Harvey.

Hurricane Harvey ripped trees out by their roots to a degree that previous storms did not. This increased erosion exponentially compared to other storms.

Corps Assumes Mouth Bar Growth Did Not Affect Percentage Deposited by Harvey

The Army Corps also assumes that Harvey transported the same fraction of the total sediment load (20%) to the mouth bar that all storms did between 2011 and 2018. That’s a dubious assumption for several reasons:

  • Previous storms progressively built a wall across the mouth of the West Fork that grew higher and higher during the study period.
  • As it grew, that wall increasingly slowed water down and likely accelerated the rate of deposition behind it (which helps explain why the Corps had to dredge its way to the mouth bar).

Yet the Corps based its estimate on a constant 20%. Page 3 of their report spells out the assumption. Harvey, they say, deposited approximately the same fraction of sediment at the mouth bar as all other storms did during the period between surveys.

This constant 20% contradicts numerous anecdotal reports from lakeside residents and boaters claiming that Harvey carried vastly more sediment to the mouth bar (and their yards/docks) than previous storms. The wife of the resident wading across the river in the image above told me that, on a scale of 1 to 5, the Tax and Memorial Days floods deposited sediment in her yard equal to a 1. But Harvey, she said, was a 6. In other words, off the scale.

No wonder the Corps didn’t want the public looking at this!

Taxpayers Deserve Independent Scientific Review

Professionals rarely like to have their conclusions questioned. However, those who have confidence in their conclusions welcome peer and public review. They encourage second opinions and provide all of their data for review. They also welcome the opportunity to explain and defend their results. None of those things happened in this case.

Instead, the Corps concealed its results as if this involved national security, not public safety. Why? That may be the biggest question of all associated with this project.

The Corps has an excellent, hard-earned reputation. This study undermines it.

As mentioned above, the Tetra Tech study may also have flaws, but the Corps never revealed what its concerns were.

Only one thing is certain. Public safety rests on wildly differing studies. Taxpayers deserve an independent scientific review to resolve the differences between these two studies. The City concurs with the findings in this post and also calls for an independent scientific review. The Corps could not be reached for comment; their new public affairs officer does not list her phone number.

Dredging will likely end next week, with the Corps proclaiming it has restored the conveyance of the river to pre-Harvey conditions (when they have no pre-Harvey measurements).

So we need an independent scientific review to happen quickly. Email you Congressmen and Senators immediately.

Corps Plans Still Being Kept from Public

The Corps still has not released its dredging plans, despite a FOIA request made in June when mouth bar dredging started.

Visual observations of the operation suggest that they are dredging a wide area by three feet, to a total depth of about five feet, instead of trying to cut a channel through the mouth bar. That would leave something like an underwater mesa, still blocking the flow and still trapping sediment. Water coming downriver would have to climb a steep hill to get over it.

If that is an accurate assessment, the Corps would leave a sediment wall under the water approximately 30-35 feet high and 1-2 miles long in the mouth of the West Fork.

Congressman Dan Crenshaw reviews progress of dredging operation on Friday, August 16. Looking southwest towards Atascocita. Notice how the small island in the first image above has now been removed. The mouth bar itself will remain in place, most of it underwater now where it is invisible to the public.

Others Scrambling to Pick Up the Pieces

It may look like the Corps has dredged. But it also looks like the Corps will leave 80-90% of the mouth bar in place. Remember, sand bars are like ice bergs in the sense that what you see above water is small compared to the amount you can’t see below water.

At this point, City, County, State and Federal leaders are scrambling to put together a plan to address the rest of the sediment. Some of that sediment is clearly pre-Harvey. I will discuss options for removal of that portion and maintenance dredging in a future post.

Posted by Bob Rehak on 8/20/2019

721 Days after Hurricane Harvey

As in previous posts on this subject, I promise the Corps that I will print their rebuttal verbatim if they disagree with any of the points in this post.

Army Corps Now 70% Complete with Its Portion of Mouth Bar Dredging

The Army Corps has released a new summary of its progress on dredging the mouth bar. The report indicates that Great Lakes, the contractor is now 70% complete. They have dredged 350,000 out of 500,000 cubic yards.

Great Lakes started dredging the mouth bar on June 25th, 2019, as part of a $17,085,861 extension of the original contract (FEMA mission assignment SWD-30).

Current area of operation is the blue area on the far right. Sediment removed from that area is being pumped 10 miles back upstream to Placement Area #2, a sand mine near Kingwood College, on the far left.

Between the start of mouth bar dredging and August 12, Great Lakes dredged an average of 6,363 cubic yards per day. If they can keep that pace up, they should be done by approximately Labor Day – three months ahead of schedule. That’s HALF the predicted time.

Remainder of Project Still Not Decided

What comes next? That still has not been finalized. City, County and State officials have been meeting in the background to determine that. The Army Corps still has not accepted or rejected Berry Madden’s property as a third placement area. And the $30 million appropriated by the State for mouth bar dredging won’t even become available until September 1st.

Meanwhile, Callan Marine, the subcontractor from the original West Fork Emergency Dredging job has pulled its equipment back to the dock opposite Forest Cove. However, Callan has not yet started disassembling its equipment and removing it from the river. According to Houston City Councilman Dave Martin, Callan has agreed to stay temporarily while officials attempt to work out details for the next phase of dredging.

RD Kissling and Tim Garfield, two local geologists who first brought the mouth bar issue to the public’s attention, estimate that 500,000 cubic yards is about one-fourth of the total sediment that must be removed to fully restore conveyance of the West Fork.

How Shallow is It?

The Corps has not yet released (or even developed) plans for mouth bar dredging. We do know the volume they intend to remove, and the general area they intend to remove it from. However, they have refused to divulge how much of a dent their efforts will make in solving the problem.

This photo of a Kings River resident wading across the river shows how shallow it is near the orange channel marker. This resident says boats “beach” behind his property almost every day. Note: Deeper pockets may exist, especially near dredging equipment. The risk of drowning is real. Do not let children attempt this. Photo taken Sunday, August 10, 2019.
The resident made it almost to the channel marker without getting his shorts wet. Shot taken with 6X telephoto lens.
The lake/river within this area averages two to three feet deep. 500,000 cubic yards would lower the average level by another three feet as this calculation shows.

Problem With Stopping after 500,000 CY

The problem with stopping after the Corps finishes its 500,000 cubic yards is that the river behind this area is much deeper. Where the Corps stopped dredging just past Kings Harbor, the river is now 25-30 feet deep. And places are even deeper according to fishermen. That means water coming downriver will be forced to flow uphill in this area. That will force it to slow down and more sediment will rapidly drop out of suspension. Some experts have suggested dredging a deep channel through this area to help restore full conveyance of the river. However, the Army Corps intends to stop after 500,000 cubic yards.

How Army Corps Sees its Role

The Army Corps has prepared a series of FAQs that represent its position on the remainder of mouth bar dredging. Among them:

“Q: What is USACE Galveston District’s plan for the rest of the mouth bar?“

“A. There is no additional work planned for the mouth bar. The current plan for the modification addressing material near the mouth bar can be found on the placemat. USACE Galveston District has no authority to conduct any additional work in the West Fork of the San Jacinto River or Lake Houston. The San Jacinto River is not an authorized federal waterway, the Corps of Engineers dredging operations are currently limited to dredging Harvey-related material. The ongoing work under the contract modification will remove the remainder of material attributable directly to Hurricane Harvey. The sedimentation from recurring annual flows are not within USACE Galveston District’s mission assignment from FEMA. Water flows on the West Fork of San Jacinto River were restored to pre-Harvey levels in December 2018.”

“Q: Who can the public contact for additional concerns with the maintenance of the San Jacinto River?“

“A. For concerns with the maintenance of the San Jacinto River, please contact Harris County Flood Control District, the San Jacinto River Authority and the City of Houston.”

Punt!

Meanwhile the City is still arguing with the Corps about how they arrived at 500,000 cubic yards. More on that later. I have obtained the Corps’ estimate through a FOIA request to the City of Houston. It raises many questions that I am still trying to sort through. More on that later.

Posted by Bob Rehak on August 14, 2019

715 Days since Hurricane Harvey

Government Gone Wild: Army Corp Refuses to Release Dredging Documents that Explain Decisions, Delays

The Army Corps has refused to release documents that explain key decisions, delays and plans related to West Fork mouth bar dredging, and a potential placement area for the spoils. At issue are the Corps’ decisions to dredge only 500,000 cubic yards from the area of the mouth bar and to delay approval of the City’s proposed placement area for long-term dredging.

As a result of a Freedom of Information Act (FOIA) request related to these decisions, I also learned that the Corps:

  • Is dredging near the mouth bar without a plan
  • Is almost done with the mouth bar project and hopes to have a plan before it finishes
  • Has repeatedly delayed a decision on a new placement area that could have saved millions of tax dollars.

Meanwhile, the Corps continues sending sediment to a mine that leaks it back into the river. That mine – in the floodway – has a dubious environmental record at best. This seems to be a case of Government Gone Wild.

Dueling Studies Offer Different Opinions of Harvey-related Mouth Bar Volume

The City of Houston and Army Corps have reportedly argued for a year or more about how much sediment Harvey deposited in the mouth bar. Late last year, FEMA required the City to perform a core-sample study using something called the Stockton Protocol. The City hired Tetra Tech to do it. And Tetra Tech concluded Harvey deposited 1.4 million cubic yards. Here is their study.

The Corps, however, evidently did not buy the results. The Corps conducted another study for FEMA using a different protocol. It concluded Harvey deposited 500,000 cubic yards.

The Corps, however, refused to release the results of that study for public review.

FEMA and the Corps went ahead and hired Great Lakes to dredge that volume from the mouth bar. That job is now more than half complete.

As part of their refusal to release their study, they cited the need to keep “pre-decision” information confidential so that inter- and intra-agency personnel could debate the merits of proposals freely. I get that. What I don’t get is how they justify this as “pre-decision.” The job is almost complete!

Dredging Without a Plan

While inventorying the documents that the Corps DID send me, I also discovered that they are now dredging the mouth bar area – without a plan. I know this because I requested the plan and they did not supply it. A Corps representative then explained that they are still working on the plan. They hope to have it done before they complete the $17 million job.

Wasteful Spending?

The Corps could be saving much of that money by using Berry Madden’s property near Kings Lake Estates as a disposal site. That’s because they need more than 5,000 gallons of diesel per day and two extra boosters (plus their crews) to pump sediment 10 miles upriver to an old West Fork sand mine in the floodway.

At the current price of diesel (about $3/gallon), that’s about $15,000 per day for fuel alone. More than $100,000 per week. And more than $400,000 per month. Waaaaay more than the limit on my gas cards. So what does the Corps get for all that?

Dike Breaches of Placement Area in Floodway

Minor floods last December breached the dike of that sand mine at least three times. Sediment continues to sweep out of the mine.

Placement Area #2 near Kingwood College on West Fork. This image is from February, but it is the same mine, whose dikes were breached in December.

It has caused additional shoaling (see below) that will need to be removed some day near the I-69 bridge. It even buried Great Lakes pipes, causing cost overruns for Phase 1.

Shoaling has become so bad through this reach of the river that it buried Great Lakes pipeline, resulting in cost overruns.

A year ago, this same mine was caught on camera deliberately sending its process water straight into the West Fork.

Video provided to ReduceFlooding.Com. Source wishes to remain anonymous.

Yet, while approving this site, the Corps reportedly has environmental concerns over a much closer disposal site that would require less fuel and fewer boosters. It’s also on higher ground and out of the floodway. It’s Berry Madden’s property in Humble immediately west of Kings Lake Estates between the West Fork and 1960.

Five different proposed placement areas on Madden property avoid wetlands (the cross-hatched areas).

The Corps may or may not have good reasons for disliking the property, but they won’t reveal them whatever they are.

After more than a year of environmental and archeological studies costing Madden more than $100,000, the Corps still has not approved or rejected his property. Nor have they explained delays in approving or rejecting it. The documents that the Corps DID supply show that they are throwing one obstacle after another in Madden’s path. Despite the fact that he’s on higher ground and farther from the river than the current placement area.

Meanwhile, the Corps subsidizes the sub-optimal sand mine/placement area above. Go figure!

Potential Setback for Future Dredging

One of the consequences of NOT having an approved site to store additional spoils is that it could delay future phases of dredging. Those potentially include:

  • Additional mouth bar dredging
  • 59 to River Grove Park
  • Maintenance dredging
  • Mouths of ditches such as Ben’s Branch

FOIA Scorecard

I filed my Freedom of Information Act (FOIA) request with the Army Corps 50 days ago. I requested:

  • Their plans for mouth-bar dredging
  • Conference reports of meetings where the mouth bar was discussed
  • Documents relating to the approval of Berry Madden’s property in Humble as a potential storage site.

About a month ago, they requested a clarification. “What do you mean by ‘plans’?” Seriously! The U.S. Army Corps of Engineers needed to have the concept of plans explained????!!!

After more delays and excuses, five days ago, I received a compact disk in the mail with approximately 800 total pages of material. The Corps:

  • OMITTED any mouth-bar plans.
  • OMITTED the Corps study that contradicted the Tetra Tech study.
  • WITHHELD 118 pages of material that could have explained their decision.
  • REDACTED key correspondence relating to Madden’s property.
  • SUBSTITUTED dredging status reports from contractor meetings for conference reports of meetings among City, State and Federal officials where decisions about the mouth bar were considered.

Government Gone Wild

After several phone calls in which I tried to cajole them into supplying the Corps’ study, I received another email from the Corps. It said that they considered my original FOIA request closed. They then asked me to submit another one for the same material that I requested in June. They seem to be treating this as a national-security issue, not a public-safety issue. Why?

Here’s the explanation from the Corps. The letter claims that they need to keep pre-decision information secret in order to foster free discussion between its employees and other government agencies and to avoid confusing the public.

Unfortunately, that does not allow informed discussion among the public, whose safety is at stake. Nor does it recognize the fact that they have already made a decision, i.e, to dredge 500,000 cubic yards and have half-completed the project. So how does this qualify as “pre-decisional”?

You’ll have to ask the man who signed this letter.

He has the title “Initial Denial Authority.” How many levels are there?

In my opinion, this is clearly a government agency out of control. The Corps has made a decision to dredge only 500,000 cubic yards – despite scientific evidence supporting a higher volume of 1.4 million cubic yards. And that scientific evidence was acquired using a protocol that the CORPS AND FEMA DEMANDED.

Who Will Pick Up the Pieces?

That leaves the State, County, City and the public in the lurch. Maybe a Congressional investigation could sort this out. That’s what it will take.

At this point, it’s not clear how, when or if the mouth-bar job will be finished. Five hundred thousand cubic yards is a small fraction of what needs to be removed to restore conveyance to the river.

It’s also not clear how many more hurdles the Corps will put in the way of a placement area farther from the river on higher ground. Or why.

A curtain of secrecy has descended upon this job. I will continue to follow the story. The public has a right to know.

Open Offer to Corps to Rebut Criticisms

If the Corps feels I have criticized it unjustly, I invite a spokesperson to explain the Corps point of view. I promise to reprint the rebuttal verbatim.

Posted by Bob Rehak on 8/9/2019

710 Days since Hurricane Harvey

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

Now You See It; Now You Don’t. Second Biggest Blockage on West Fork GONE!

These two images, taken almost two years apart, show one of the most dramatic improvements to West Fork conveyance – the removal of a giant blockage that the Army Corps nicknamed Sand Island.

Sand Island mysteriously appeared during Harvey almost overnight and virtually blocked the entire West Fork of the San Jacinto. Today, the blockage is gone as the before/after photos below show.

Taking Time to Reflect on Accomplishments

This is what Sand Island looked like two weeks after Harvey. It appeared virtually overnight. I took this shot from a helicopter.

Facing east. Sand Island blocks the entire west fork of the San Jacinto. The Kingwood Country Club is in the upper left portion of the photo. Shot from a helicopter on 9/14/2017.

Bayou Land Conservancy Provides the “After” Photo

Suzanne Simpson, Land Stewardship Director for the Bayou Land Conservancy, was doing a wetlands inventory with her drone near River Grove Park this morning. She captured a similar shot below of the same area.

After more than a year of dredging, Sand Island is finally gone. The Army Corps and Great Lakes have restored conveyance on this portion of the San Jacinto West Fork, immediately downstream from River Grove Park. Shot by Suzanne Simpson with a drone on 7/18/2019.

A Job Well Done

This pair of images shows the dramatic improvement in conveyance to this portion of the river. Kudos to the Army Corps and their contractors, especially Great Lakes, which managed this portion of dredging.

Clearing the river of blockages like these should have a dramatic impact on conveyance and help reduce future flooding.

Great Lakes is now working on the mouth bar farther downriver, while Callan Marine is dredging the area near Kings Harbor. Only the mouth bar was/is a bigger blockage on the West Fork than Sand Island.

Additional thanks go to FEMA for funding the project, the Texas Division of Emergency Management, former Congressmen Ted Poe, and the City of Houston.

Since dredging started almost a year ago, the Corps has removed 1.8 million cubic yards of sediment. That’s enough sand to fill the Astrodome.

Posted by Bob Rehak on 7/18/2019

688 Days After Hurricane Harvey

Mouth Bar Dredging Begins

It appears that dredging of the mouth bar of the San Jacinto West Fork has officially begun. Two weeks ago, I reported that the Great Lakes dredge had maneuvered into position. Then this weekend, residents started sending me pictures taken from the river showing equipment in operation.

Mouth Bar Imagery from RD Kissling

RD Kissling, a Lake Houston area resident and geologist, who first helped bring the mouth bar to the public’s attention sent me the photo and video below last week. “The dredge is up and running,” he said.

The image with the canoe below, Kissling said, “This is me standing in shin deep water about 200 yards south of the exposed mouth bar, looking north towards the bar and Scenic Shores.  There is another small channel about 20 yards south of me then the bar shoals again.”

Lake Houston Area geologist RD Kissling standing in shin-deep water 200 yards south of the mouth bar. This image, more than any other I have seen, dramatizes how critical the need for dredging has become...and how hilarious the Romerica proposal is to build a marina for more than 600 40-foot yachts.
Video shot by RD Kissling from the southernmost exposed portion of the mouth bar.  Starts looking west towards the dredge then swings around to the east.

Mouth Bar Images from Today Shot by Jeff Kristoff

Then Jeff Kristoff, a Kingwood resident, sent me the pictures below today. They show an excavator on the upstream end of the bar and dredging equipment immediately south of the bar. It appears there may be two excavators breaking up vegetative growth and sediment. Farther upstream, near River Grove Park, dredgers reportedly ran into submerged logs that had been covered by sand.

The loops in the pipelines will allow the dredge to maneuver up and downstream as it works. Note first of two excavators in background breaking up vegetation at edge of mouth bar.
Excavators can also be used to more or lift pipe for repairs.

Ultimate Plans Still Not Announced Yet

Exactly where or how much the Corps and its partners plan to dredge has not yet been announced. The Corps last issued a press release for the project on June 10, three weeks ago, and has not yet responded to a Freedom-of-Information-Act request for the dredging plans.

Because it’s hard to believe that the U.S. Army would move on a project this large without a plan, I can only conclude that all parties have not yet reached an agreement on volume and a permit for placement of the sediment.

For the time being, it looks as though the Corps will use Placement Area 2 on Sorters Road…at least initially. Pumping ALL of the sediment 10 miles upstream would hike the cost hugely because it would require at least 5 booster pumps. Each uses 1000 gallons of diesel per day.

For speculation on where and how much they might dredge, see this post.

Posted by Bob Rehak on July 4, 2019, with images and video from RD Kissling and Jeff Kristoff

674 Days since Hurricane Harvey