Tag Archive for: best practices

TCEQ Approves New Best Management Practices for San Jacinto Sand Mining

This morning, the TCEQ approved new Best Management Practices (BMPs) for Sand Mining in the San Jacinto Watershed. The effort to inventory, establish and publish BMPs for sand mining began shortly after Harvey. This web site contains thousands of pictures and 210 posts about area sand mine operations.

But the real credit for today’s agreement goes to:

  • The Lake Houston Area Flood Prevention Initiative (FPI)
  • Bill McCabe and Dave Feille (now deceased), two FPI steering committee members
  • Dianne Lansden, FPI founder
  • The Bayou Land Conservancy
  • Bill Dupre, professor emeritus in Geology from the University of Houston
  • State Representative Dan Huberty.

Others, too numerous to mention also picked up the baton and worked tirelessly for years to reach an agreement with the sand miners.

West Fork Sand Mine that will be affected by new best management practices. Photographed in August

McCabe composed the short article below that describes the significance of today’s events.


History of Project

The Lake Houston Grassroots Flood Prevention Initiative (FPI) formed shortly after Hurricane Harvey, led by a group of citizens concerned with the area’s future.  Its goal: to seek out and remedy issues that made Harvey’s flooding more devastating than expected. Early on, one issue became evident as a major area of concern for future floods —the effect of sand mining on sediment and pollution in the San Jacinto Watershed.

We had looked at litigation, legislation and negotiation solutions as ways to address this situation. Other groups were already pursuing Litigation and Legislation. So, we decided to address the future through negotiation with the sand-mining industry.  

Negotiation with TACA

We contacted the Texas Aggregates and Concrete Association (TACA), the industry representative for sand miners, and began negotiations on Best Management Practices (BMPs).  

Starting with a blueprint of Best Management Practices for sand mining developed by other states, we re-formulated them to fit the Texas situation. For several months FPI, TACA, and other groups and individuals worked on a document we could present to the Texas Commission on Environmental Quality (TCEQ).  Many individuals, including Representative Dan Huberty, Jill Boullion with the Bayou Land Conservancy, and former City officials from Humble and Kingwood, worked with us to fine tune a document for presentation.

Because TACA and FPI could not fully agree on the requirements for sand mining BMPs in the San Jacinto River Watershed, we presented separate Petitions to TCEQ. TACA presented its on June 12, 2020. FPI presented its a week later.  

Scope of Petitions

Although they differed in several key areas, both Petitions followed the same basic pattern. We focused on a three part approach: Pre-mining, Mining and Post mining.  

Following submittal, TCEQ conducted a series of stakeholder meetings and public input requests. The Commission fine-tuned our proposals and developed its own Rules and Guidance Documents.  

View the original Petitions and subsequent modifications on the TCEQ website. See Rulemaking: Best Management Practices for Sand Mining in the San Jacinto River Watershed – Texas Commission on Environmental Quality – www.tceq.texas.gov.

Final Approval, a Good First Step

On December 15th, TCEQ Commissioners approved the new BMP Rules document. It will become effective early next year. Although we did not get everything we would have wished for, this is a very good start and will help to hold sand miners to an accountable standard in the future.  

Between the Rules Document (Subchapter J, Best Management Practices for Sand Mining Facility Operations Within the San Jacinto River Basin, Sections 311.101 – 311.103 of 30 TAC Chapter 311, Watershed Protection) and the associated Guidance Document developed by TCEQ, we now have a comprehensive standard for the sand-mining industry to follow.

By Bill McCabe on 12/15/2021

1569 Days after Hurricane Harvey

Take Two Minutes To Help Reduce Flooding in San Jacinto Watershed

The Lake Houston Area Grassroots Flood Prevention Initiative needs your help. The group’s four-year effort to establish best management practices (BMPs) for sand mines in the San Jacinto River basin is drawing to a close. But one of the rules needs strengthening. Leave a public comment to that effect on the TCEQ website. It should only take two minutes.

Background: Proposed Rule is No Rule At All

Here’s the concern:

311.103 General Requirements (c) Pre-mining, Mining, and Post-Mining states: “If a BMP is infeasible, the operator shall use an alternative equivalent BMP and maintain documentation of the reason onsite.  The following considerations may be used to determine if a BMP is infeasible (financial considerations; health and safety concerns; local restrictions or codes; site soils; slope; available area; precipitation pattern; site geometry; site vegetation; infiltration capacity; geotechnical factors; depth to groundwater; and other similar considerations).

Allowing twelve (+ an infinite) number of reasons to avoid implementation of BMPs provides so much latitude as to make this rule useless for community protection.

Operators need only retain documentation of their “reason” onsite for not complying, without first getting approval for substituting BMPs.

The Lake Houston Area Grassroots Flood Prevention Initiative recommends that this rule be changed to include mandatory approval by the TCEQ for any variance from standard BMPs. The group also recommends the TCEQ make approved changes available for public inspection on its website.

Leave Public Comment Before Midnight Tuesday

If you agree, please go to the following link:  https://www6.tceq.texas.gov/rules/ecomments/ and register your concern. Use your own words or feel free to cut and paste the information in red below – before Tuesday, July 27th at midnight.


I am concerned about 311.103 General Requirements (c) Pre-Mining, Mining and Post-Mining. It gives sand mine operators free license to ignore BMPs for a virtually infinite number of reasons. No approval by the TCEQ is necessary. All operators need to do is keep a note in a file onsite.

There are always those who will bend the rules for their convenience or financial gain at the expense of protecting the community.

Therefore, I urge you to change the wording in this rule so that variation from the BMPs requires approval by the TCEQ. I also urge you to publish any variations on your website for public inspection.


Hurricane Harvey showed us the dangers of sediment blockages in the San Jacinto River. Federal, State and Local Governments are spending $222 million to remove them.

Sand Island was deposited during Harvey. It is gone now…but at great expense. The Army Corps said it blocked the San Jacinto West Fork by 90%.

To reduce such blockages in the future – and their associated risk of flooding – the Lake Houston Area Grassroots Flood Prevention Initiative has been working on your behalf since Harvey to get to this point. Please take two minutes to protect four years worth of effort. Take action now.

You can read the complete text of proposed BMPs here.

And you can read all of the proposed rules governing their implementation here.

Posted by Bob Rehak on 7/25/21

1426 Days after 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.

FEMA Case Studies Dramatize Value of Detention Ponds in Flood Reduction

On August 27, Montgomery County Commissioners will consider a request to close a loophole that lets developers avoid building detention ponds.

Stormwater detention basins store potentially damaging floodwaters temporarily until channels can safely carry water away. Here’s how they work.

Lack of Detention Ponds Contributes to Flooding

The lack of functioning detention ponds in the new Woodridge Village development contributed to the flooding of at least 196 homes across the southern county line on May 7th earlier this year. Since publishing a series of stories about flooding in Elm Grove, dozens of Montgomery County residents have contacted me about similar complaints.

Woodridge Village had only one of five detention ponds fully functioning when this shot was taken after the May 7th flood. Lack of retention for this clear cut area contributed to damaging 196 homes in Elm Grove and North Kingwood Forest, plus an unknown number of additional homes in Porter. Drone Footage courtesy of Jim Zura, ZuraProductions.com

All the stories follow a similar pattern. “We never flooded. Then a new development came in and we did.” Residents complain that frequently the new developments alter drainage without adding enough detention to mitigate flooding.

As population growth extends northward in Montgomery County, this will become an oft repeated story. It will affect everyone in Montgomery County, not just those in the southern part and Harris County…unless the loophole is closed.

Case Studies Dramatize Value of Detention Ponds

Doubt the value of detention ponds? Consider these three case studies by FEMA. Each deals with severe rain events and explains how a pond helped reduce or eliminate flooding altogether – for homes that previously flood repetitively. Together, they make a pretty powerful case for closing the loophole.

The first talks about how a pond in Smithville, TX, that was under construction at the time of Harvey. It helped reduce the severity of flooding.

The second discusses a municipal pond in Pine Forest, a small town in Orange County, TX, north of Beaumont. After construction of the pond, “The community of roughly 500 residents and those living downstream from the ponds reported none of the flooding they had seen in the past.”

Victoria Project Protected Homes and Tax Base During Harvey

Closer to Houston, the third talks about a project in Victoria, TX. When Harvey hit the city of 68,000 in August 2017, 440 homes avoided flood damage. The City had completed the Lone Tree Creek Channel Improvement and Detention Facility Project there more than a decade earlier.

In 2005, the city recognized that its rapid residential growth created an overwhelmed drainage basin. Leaders began the planning stages of the Lone Tree Creek Project. “This project forced the creek to store water in the detention pond and not in the residential area,” said John Johnson, floodplain manager for Victoria.

Bottom line: “We are not moving the problem and recreating it elsewhere,” said Johnson.

“The quality of life is improved, and property resale is up as a result of this project,” said Johnson. “The tax base remained intact and property ownership stabilized in neighborhoods surrounding the Lone Tree Creek Channel. The quality of life is improved, and property resale is up as a result of this project.”

Learn More about Flood Mitigation Best Practices

For more information about flood mitigation best practices, see FEMA.

If you, or anyone you know, intend to speak at the Montgomery County Commissioners Court meeting on the 27th, use these real-world examples to reinforce the message to close the loophole.

Help Close the Loophole

Closing the loophole is a no brainer, or at least, it should be.  However, if the court on August 27 is packed by developers and not citizens, expect the status quomore flooding.

Posted by Bob Rehak on August 10, 2019 with drone footage from Jim Zura

711 Days since Hurricane Harvey

Thoughts expressed in this post represent my opinions on matters of public policy 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.

New Google Earth Image Shows Multiple West Fork Sand Mines Mixing Their Wastewater with Your Drinking Water

On its way to Lake Houston, your drinking water runs through a gauntlet of sand mines – some old, some new. Many discharge industrial process water directly into the San Jacinto River and its tributaries. The latest Google Earth LandSat images show a total of 11 between I-45 and US 59 on the West Fork doing just that. In addition, photos taken from a boat show another breach in a sand mine dike that happened more recently on Caney Creek, a tributary of the East Fork. Together, these images make a powerful case for moving mines out of the floodway and establishing best management practices for sand mines. The industry has fought both measures.

Dangers of Mining in Floodways

For miners in the Houston area, locating mines in floodways is a dangerous, but lucrative practice. Lucrative because there is less overburden for miners to move. Dangerous because rivers frequently sweep through mines during floods. The floods can then carry sediment downstream, which creates blockages that contribute to flooding.

Floods can also flush chloride-laden process water out of the mines and into your drinking water. That makes City of Houston water treatment costs more expensive. A former high level manager in the City’s water treatment department told me that he saw huge spikes in chlorides after every flood and tracked it to sand mines.

Pictures Aren’t Pretty

Massive breach in Triple-P mine on Caney Creek allows process water to mix with water in tributary for Lake Houston, source of drinking water for two million people.

After discovering the breach above, Josh Alberson whose boat we were in, spent an evening pouring over satellite images. Last week, he sent me a list of GPS coordinates to review additional suspected breaches or discharges. See the images below, all from the West Fork.

First mine north of confluence with Spring Creek. A local canoeist found three breaches in this mine last December.
Breach on right open since 2015. Breach on top left was closed after 2015. Harvey swept through all these mines in 2017.
Note the stream at about two o’clock that is carrying sediment and process water to the river.
Small pit in middle drains into West Fork.
Overflow from mine contaminating West Fork.
This pit has remained open for years at a time. Sometimes the water flows in, other times it flows out.
Follow the stream from the pit on the right to the river on the left.
It looks like someone actually installed two culverts and built a road over this breach.
Note several small breaches in the bottom of this image and how the river is about to invade the major pit in the upper right,
See the line of sediment in the clearcut area between the large green pond and the river. Discharges date back to 2006.
West Fork San Jacinto just east of I-45.

Rule Rather than Exception

I could go on. But you get the idea. The TCEQ has said 15 sand mines are currently active on the West Fork between I-45 and US59. You just looked at a dozen breaches. Historical images in Google Earth show dozens of additional breaches in this same area. This is the rule rather than the exception.

Legislative Session Ends Hope for Improvement

Meanwhile, TACA, the Texas Aggregate and Concrete association, lobbied against establishing and publishing best practices for the industry including setbacks from rivers that could prevent this type of danger.

As we went into this Texas legislative session, I had high hopes. Representative Dan Huberty introduced HB 909, a bill that would have required the TCEQ to adopt and publish a set of best management practices for sand mines.

I drove up to Austin to speak for the bill. Rob Van Til, a sand miner representing TACA, spoke against it. Watch the testimony online at this link for the Committee Broadcast Archives. Make sure you scroll down to 5/1/19 and click on the link for Environmental Regulation. It lasts about 20 minutes. Here’s a guide for those short on time. At:

  • 4:30 Huberty introduces the legislation to the committee.
  • 6:45 Adrian Shelley, representing an environmental group, speaks for the bill.
  • 8:45 Rob Van Til, representing TACA speaks against.
  • 10:45 Representative Erin Zwiener questions Van Til
  • 16.25 Bob Rehak speaks for HB 909
  • 20:00 Huberty asks for committee support

The images above show why we need to move mines out of the floodway. But sadly, HB 909 never made it out of committee. The 86th Legislature ends this week. It’s time to start gearing up for 2021.

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

Posted by Bob Rehak on May 27, 2019 with help from Josh Alberson

636 Days after Hurricane Harvey

Bayou Land Conservancy Supports HB 909, Publishing Best Practices for Sand Mining

The Bayou Land Conservancy sent this letter today to the Committee Clerk of the House Environmental Regulation Committee. The Conservancy has allowed me to publish it:

On behalf of Bayou Land Conservancy, I urge you to vote FOR HB 909 when the Environmental Regulation Committee meets to consider this bill. Bayou Land Conservancy is a non-profit, community-supported land conservation organization that preserves land along streams for flood control, clean water, and wildlife. We preserve 14,000 acres in the Houston region, focused on the Lake Houston watershed. This includes the San Jacinto River, cited in 2006 as one of America’s most endangered rivers due to a number of threats, including the high intensity of local aggregate mining. 

HB 909 would require the Texas Commission for Environmental Quality (TCEQ) to adopt and make accessible best management practices for aggregate producers to comply with applicable environmental laws and rules. 

This adoption of best management practices would be an important, and needed, step to ensure that aggregate production in Texas is done with sensitivity to the environment and to community standards. As the population of Texas continues to grow, with the corresponding increase in construction of buildings, roads, and bridges, there is greater risk to the quality of life and safety for many communities located near mining operations. 

As one of the nation’s leading aggregate producing states, we know Texas can lead in developing higher standards. We recommend best management practices that consider community values, such as: 

  • Employ public notice and stakeholder process guidelines to ensure mining operations are in step with local priorities and concerns 
  • Maintain setbacks or standards for siting operations away from sensitive areas or those with the highest likelihood to cause impacts 
  • Develop environmental impact statements for proposed mining operations 
  • Enact mitigation standards to reclaim the project area after facility closure 
  • Utilize progressive reclamation with a step-be-step restoration of the site over time rather than waiting for final closure 
  • Require the submission of an approved reclamation plan prior to permit approval 
  • Require the certification of financial security to perform reclamation activities before permit approval 
  • Require post-use conservation easements to ensure that the floodplain is left undeveloped and can provide a community amenity opportunity. 

There is urgency for Texas to lead by enacting commonsense solutions that protect the community. 

Without development and implementation of best management practices, such as those outlined above that would keep sediment in place through floodplain preservation and mine reclamation, downstream communities will continue to be at risk of water quality degradation and flooding. 

Please vote YES on HB 909. 

(Signed) Jill Boullion 
Executive Director 

Please Support HB 909; Here’s How

Call. Write. Or testify in person TODAY. The committee meets to consider this bill tomorrow. The following representatives comprise the Environmental Regulation committee.

  • Rep. J. M. Lozano (512) 463-0463 
  • Rep. Ed Thompson (512) 463-0707
  • Rep. César Blanco (512) 463-0622
  • Rep. Kyle J. Kacal (512) 463-0412
  • Rep. John Kuempel (512) 463-0602
  • Rep. Geanie W. Morrison (512) 463-0456
  • Rep. Ron Reynolds (512) 463-0494
  • Rep. John Turner (512) 463-0576
  • Rep. Erin Zwiener (512) 463-0647
  • Committee Clerk: Scott Crownover. (512) 463-0776

If you can come to Austin to testify, please do. The meeting will be held Wednesday, May 1, in room  E1.026 of the Capitol Building. Most likely hearing time is in the evening around 8 p.m., but get I plan to get there early. Hope to see you there.

Posted by Bob Rehak on April 30, 2019

609 Days since Hurricane Harvey

Earth Week Part 2: Clearing Land for Sand Mining

Best management practices for sand mining in many states say that miners should avoid clearing land until they’re ready to mine it. The roots of trees and grasses help stabilize soil during floods.

Barren land exposed to three 500-year storms. Vegetation not only binds the soil, it reduces the velocity of floodwaters, reducing the potential for erosion. Picture taken on 9/14/2017 two weeks after Hurricane Harvey.

Land Cleared, Then Three 500-Year Storms

However, on Caney Creek in Porter, a sand miner cleared 60 acres right before three 500-year storms in 2015, 2016 and 2017.

Except for a tiny pond at the far end of this cleared area, no mining had occurred here when I took this photo shortly after Harvey.

With little vegetation to reduce the velocity of floodwaters, the miner lost sand from this area and a significant portion of his stockpile. Below is a closer shot of the stockpile.

34-acre stockpile suffered severe erosion during Harvey.

Sand Damage Downstream from Mine

Meanwhile, downstream from the mine, when Harvey’s floodwaters subsided, Kingwood residents found 30 acres of East End Park covered with sand, including this area that was once wetlands.

Eagle Point section of Kingwood’s East End Park. After Harvey, sand dunes replaced wetlands.

Extreme events like Harvey reveal the need for regulations that protect both miners and the public.

Restoring the trails in the park cost residents hundreds of thousands of dollars. Several months after the storm, trees covered by sand started dying and continue dying to this day. Eagles, other birds, and residents have lost valuable wetlands.

Bills to Regulate Sitting Idle

State Representative Dan Huberty introduced a bill that would establish best management practices for sand miners and another bill that would require miners in the San Jacinto watershed to follow them.

  • HB 909 calls for the TCEQ to adopt and publish best management practices for sand mines.
  • HB 1671 creates penalties for non-compliance with best practices defined under HB 909.

The legislature has taken no action on either bill since:

  • The Environmental Regulation Committee received HB 909 on 2/25/19.
  • The Natural Resources committee received HB 1671 on 3/4/19.

Time Running Out

With only 37 days left in this legislative session, hopes for both bills are quickly fading. If you would like to see them enacted, please email committee members:

House Environmental Regulation Committee

House Natural Resources Committee

Click here to see my top ten recommendations for sand mining practices that could reduce erosion. Each represents an opportunity for improvement relative to other states.

Posted by Bob Rehak on 4/23/2019

602 Days since Hurricane Harvey with 37 Days Left in the Legislative Session

For Earth Week: Sand Mine Reclamation Regulations Needed

Texas requires a reclamation plan to get a permit for sand mining. However, according to a spokesperson for the Texas Commission on Environmental Quality, Texas has no requirement to execute the plan when mining is done – except for a small pilot project on the Brazos River. Unscrupulous miners can and do walk away from mines without reclaiming the land when they are finished mining.

Abandoned sand mine in Humble, TX. No fencing. No grading. No vegetation on slopes. Note proximity to buildings on adjoining property and road.

No Attempts at Reclamation for 15 Mines in a Mile Radius

Abandoned sand mines like the one above on North Houston Avenue and Townsend blight the Humble area.  Across the street sits another abandoned mine and a concrete recycling facility. 

Abandoned concrete crushing facility once part of sand mine in Humble, TX.

A quick check of Google Earth shows that fifteen other abandoned sand pits lay in about a one mile radius near these. TACA, the Texas Aggregate and Concrete Association brags about how mines can be reclaimed, but are they?

Theory Vs. Reclamation Practice

We have the appearance of sand mine regulation. In practice, since the TCEQ began monitoring sand mines in 2011, the commission has levied only a few hundred fines statewide averaging about $800 per fine. That’s a slap on the wrist. Meanwhile, blights like these keep promising areas from re-developing. In the name of helping some businesses, bad actors in the industry harm others…and entire communities. Yet TACA fights legislative fixes.

Potential Legislative Fixes Falter

Two bills introduced in the legislature this year could help address this problem. Both have stalled in committee.

  • HB 1671 extends protections to the West Fork of the San Jacinto currently enjoyed by the John Graves District on the Brazos. It would require local mines to file a bond that guarantees reclamation before they begin mining. HB1671 was referred to the Natural Resources committee on March 4. Nothing has happened with it since then.
  • HB 2871 would require sand mines and other aggregate production operations to acquire a reclamation permit and to file a performance bond ensuring reclamation. Significantly, they would have to do both of these things before they could acquire a production permit. It also attaches civil and criminal penalties for non-compliance. The House Energy Resources committee heard public testimony on HB2871 on April 8, but the bill was left pending in committee. Again, nothing has happened with it since then.

With 38 days left in the legislative session, hopes for both bills are fading fast.

If this makes you angry, register your opinion.

First in a New Series

In coming days, I’ll illustrate other best practices where Texas falls short (and sometimes flat) compared to other states. The series will culminate with a peek inside the multi-million lobbying efforts of TACA.

I’m all for being business friendly, but when that starts to hurt other businesses and residents, I draw the line. That’s not being business friendly; that’s playing favorites.

Posted by Bob Rehak on 4/22/19

601 Days since Hurricane Harvey and 38 days left in the legislative session

Sand Mine Dike Remains Open for Years

In my last post, I talked about how certain sand mines on the San Jacinto could help reduce the rate of sedimentation in the river by following best management practices (BMPs) found in other areas. Those BMPs included:

  1. Locate mines outside of floodways.
  2. Establish performance bonds to cover the cost of cleanup.
  3. Increase the width of dikes.
  4. Decrease the slope of dikes.
  5. Control erosion with vegetation.
  6. Replant areas not actively being mined.
  7. Avoid clearing areas that will not soon be mined.
  8. Protect stockpiles from flooding.
  9. Mine only above the thalweg (deepest part of the river).
  10. Establish performance bonds to guarantee remediation of breaches and/or repurposing of mined areas once mining is complete

This Mine Missed 9 out of 10

The State of Texas does not require these BMPs for sand mines on the San Jacinto. But it should. Here’s a case study in what happens if you ignore these principles.

The wide shot below was taken in January of 2010. Notice the muddy brown area in the middle of the shot. Also notice the breach in the dike on the left hand side of the brown area and the stockpile right above it. Finally, notice that un-vegetated area in the point on the far left.

That’s where the original mined area was back in the 1980s. Whoever mined it at that point took sand directly from the river bank. Regardless, it was never replanted and the entire area remains vulnerable to erosion to this day.

That’s important because this mine, like all but one on the the West Fork, lies largely in the floodway. See the cross-hatched area below in the USGS flood hazard map.

As a result of being in the floodway, here’s what happened to it during Hurricane Harvey. Note multiple breaches in the dikes, the loss of the stockpile, and swirling floodwaters flowing through the mine from upper left to lower right. Finally note that Harvey inundated that original mined area that was not replanted.

This made me curious, so I reviewed the historical imagery for this location in Google Earth. Here’s the same mine in 2016. Same story. Just not quite as bad. They lost about a third of the stockpile. And nasty brown water flowed straight through the pits closest to the river.

Next, I zoomed in on the breach and scrolled back through time. It first showed up in 2006.

By early 2011, they were building roads out to the breach.

Here it is in late 2011. Note how the river below the breach has become clogged with sand.

In 2013, still wide open. Another flood. More sediment flushed downstream.

In 2014, still open!

In 2016, they’ve rebuilt the dike! But it’s skinny. Very vertical. Un-vegetated. And you can already see cracks and major signs of erosion developing in it.

Then along comes another flood at the end of the year.

And by the next day, most of the dike has been washed away.

By 2017, it was fixed again.

Then along came Harvey. And there it went again.

Spike the Dike

So how did this mine score overall? If you were applying these principles, it received an almost unperfect score.

  1. Locate mines outside of floodways.
  2. Establish performance bonds to cover the cost of cleanup.
  3. Increase the width of dikes.
  4. Decrease the slope of dikes.
  5. Control erosion with vegetation.
  6. Replant areas not actively being mined.
  7. Avoid clearing areas that will not soon be mined.
  8. Protect stockpiles from flooding.
  9. Mine only above the thalweg (deepest part of the river).
  10. Establish performance bonds to guarantee remediation of breaches and/or repurposing of mined areas once mining is complete

The breach first showed up in 2006 and was still open in 2014! Goin’ for the record! How much sand and sediment wound up downstream as a result?

No telling exactly. But whatever it was, they won’t be picking up the tab for the cleanup. You will be (Point #10)…which underscores the need for the State to adopt common sense guidelines like these. Perhaps if it had, we wouldn’t have had as much damage during Harvey.

As always, these are my opinions on a matter of public policy, protected by the First Amendment of the U.S. Constitution and the Anti-SLAPP statutes of the great State of Texas.

Posted on August 3, 2018 by Bob Rehak

339 Days since Hurricane Harvey

 

Best Management Practices that Could Reduce Sedimentation of the San Jacinto If Sand Mines Always Followed Them

Large areas within this mine are unvegetated and unmined, making them more susceptible to erosion.

Introduction

This post ties together months of research. It began with observations about Texas sand mines that did not seem to follow best practices adopted in the rest of the world.

My comments do not apply equally to all sand mines; some sand mines already follow these recommendations to varying degrees. My goal is not to condemn sand mines in general, but to suggest opportunities for improvement in some.

This post contains 75 footnotes at the end. Follow them back to hundreds of photos, posts, studies, presentations and articles that illustrate the issues at hand. 

Background

During Hurricane Harvey, millions of cubic yards of sand and silt migrated downstream into the Lake Houston area.[1],[2] Some originated from natural sources.[3] Some also likely originated from approximately 20 square miles of sand mines that have sprung up around the headwaters of Lake Houston.[4] The exact proportion by source is difficult to determine. However, the sand mining industry denies responsibility.[5]

Industry’s main argument is that floodwater inside the mines has insufficient velocity to carry sand and silt outside of the mine and into the river. However, photographic evidence, gravel deposited in dunes downstream, and USGS floodwater velocity measurements, taken together, contradict this argument.[6],[7]

Industry also cites a Brown & Root regional sedimentation survey for the San Jacinto Watershed. It showed that suspended solids in Cypress and Spring Creeks were greater than in the West Fork.[8] This study was conducted in the late 1990s and published in 2000 before the rapid growth of sand mining on the West Fork. Section 1.3.3 also cautions that these samples were taken at low-flow periods and should not be used to predict sedimentation during floods, when most sediment migrates.

“…the sediment load estimates presented herein may not adequately account for … sediment load during significant flood periods. … The monitoring program should be conducted during and following major flood events to verify the dominant sediment movements [emphasis added].”[9]

The sand mining industry, in essence, is saying, “Because more suspended solids come from Spring and Cypress Creeks during low flow periods, sand can’t be coming from the West Fork during floods,” a logical fallacy.

Sand mines in floodway. Sand bars within mine were caused during “river capture”. They prove sand was carried downstream. This photo taken on 10/28/2018 (after Harvey) also shows repairs to mine wall. During floods, the river tries to cut across meanders, runs through the mines, and scours pits.

This contention ignores several key facts:

  1. The landscape has changed dramatically since the Brown & Root report due to the rapid growth of sand mining.
  2. Sedimentation issues arise primarily as a result of floods, not normal flows.
  3. The sand mining industry is distorting Brown & Root findings.
  4. The vast majority of sand mines are on the West Fork and lie downstream from the Lake Conroe Dam, which released 79,100 cubic feet of water per second (cfs) during Harvey. That brought the West Fork peak flow in the area of the mines up to 130,000 cfs – 60% more peak flow than Spring Creek (82,100 cfs) and 364% more than Cypress Creek (28,100 cfs).[10]
  5. Sedimentation surveys of Lake Houston during the last 20 years show an increasing rate of sedimentation consistent with the growth of sand mining.[11],[12]

All of this suggests that sand mines contribute to AND increase natural rates of sedimentation.

After slowly building for years, the sand bar at the mouth of the West Fork has virtually tripled in size since 2015, threatening homes, businesses and infrastructure. The current Army Corps Emergency Dredging project will not address this and it is not clear where the money will come from to do so.

As the floodwaters from Harvey receded, massive amounts of sand became apparent. It clogged the San Jacinto River.[13] It left nearly continuous, bright, white trails of sand all the way from mines to the mouth of the San Jacinto – far in excess of the volume that was in the river before the flood.[14] It blocked drainage ditches.[15] It contributed to flooding that damaged thousands of homes and businesses.[16]

Removing these blockages could cost taxpayers and government hundreds of millions of dollars. The Army Corps of Engineers is already spending almost $70 million to dredge a two-mile stretch of new sand bars and dunes blocking the West Fork and local drainage ditches.[17] These blockages contribute to higher floods with smaller rains and continue to put Lake Houston area communities at increased risk for flooding.[18]

Dredging the remaining 11 miles of the West and East Forks in the Humble, Kingwood and Huffman areas will cost even more. Harris County Flood Control has included $50 million for dredging those reaches in its 2018 flood bond referendum and is seeking three partners to contribute similar amounts. If that is enough to restore normal flow to the East and West Forks, the total cost of dredging would be $270 million.

However, that may not be enough. A recent report compiled by two Lake Houston area geologists[19] studied the size and impact of a large sand bar at the mouth of West Fork that now causes the West Fork to flow uphill before it reaches Lake Houston. The size of this one sand bar alone likely exceeds the scope of USACE’s current dredging project by several fold.[20]

Many states and countries have established best management practices (BMPs) for sand mining to avoid such costs, and to help reduce erosion and consequent damage.[21]

If these BMPs were universally practiced by Texas sand mines, they could help increase margins of safety, reduce risks associated with future flooding, and reduce the costs associated with cleanup.

 

The first two recommendations below are already practiced in Texas, but only on a small portion of the Brazos River.[22] The other recommendations represent things that Texas sand mines should do to improve performance relative to the best management practices elsewhere.[23]

Recommendations

  1. Locate mines outside of floodways.
  2. Establish performance bonds to cover the cost of cleanup.
  3. Increase the width of dikes.
  4. Decrease the slope of dikes.
  5. Control erosion with vegetation.
  6. Replant areas not actively being mined.
  7. Avoid clearing areas that will not soon be mined.
  8. Protect stockpiles from flooding.
  9. Mine only above the thalweg (deepest part of the river).
  10. Establish performance bonds to guarantee remediation of breaches and/or repurposing of mined areas once mining is complete

Discussion

  1. Locate mines outside of floodways.

A precedent exists. The 79th Texas Legislature enacted Senate Bill 1354, creating the John Graves Scenic Riverway on the Brazos River. This established a pilot program that will last until 2025. Its goal: to enhance water-quality protection by establishing specific regulations for quarries within the watershed. Regulations adopted under SB 1354 require a permit that forces new mines to operate outside of the 100-year floodplain.[24]

Prohibited activities include the operation of any quarry within 1,500 feet of a navigable water body, subject to specific exceptions.[25]

Currently, all but one sand mine on the San Jacinto lies partially or wholly within a floodway.[26] A common definition for a floodway is “the main channel of the river during a flood.” As Harvey proved, operating within a floodway puts both the mines and downstream communities at risk.

Miners prefer floodways because they typically contain concentrated deposits of sand. Less overburden also makes sand less expensive to mine. This increases profitability.[27]

However, when floodwaters invade mines, they can carry sand and silt downstream. Satellite and aerial images taken during and after Hurricane Harvey show that the river breached dikes, flowed across point bars, eroded stockpiles, destroyed a road, and carried exposed sand and sediment downstream.[28],[29]

While miners profit from mining in floodways, downstream communities bear the cleanup costs. Who will pay that cost? Currently, the answer is tax and rate payers through the City of Houston, Harris County, Coastal Water Authority, State of Texas, and Federal Government.[30]

When sand mines choose to operate in the floodway, industry profits and taxpayers take the loss.

Taxpayers are, in effect, forced to subsidize sand and gravel mines by bearing the clean-up costs.

 

By allowing mines to locate within floodways and then externalize costs, the State encourages risky behavior that can flood homes and damage entire communities.[31] In the future, not permitting mines to operate in floodways could reduce flood risks.

Some say, “You can’t regulate for 1000-year events like Harvey. That would damage industry.” That criticism, however, ignores the USGS report on peak streamflows during Harvey.[32] Issued in July 2018, it reclassified storm probabilities for areas affected by Harvey.

USGS now estimates, based on flow data at the Grand Parkway and the West Fork, that Harvey was NOT a 1000-year storm. USGS now says that a storm with the volume of Harvey has a 2.4 annual exceedance probability. That would make Harvey a 42-year storm.[33] On the East Fork, which received more rainfall during Harvey than the West Fork, the situation is even more dire. The sand mine on Caney Creek, which sits at the confluence of twofloodways, received a 33-year flood. And according to USGS, Harvey was only the fourth highest flood on record for that gage.[34]

Moreover, given the height and width of some mine dikes on the West Fork, it does not even take a storm of Harvey’s magnitude to breach dikes. Historical satellite imagery shows that West Fork mine dikes have been breached repeatedly, including during a non-tropical storm in 2015.[35]

  1. Establish performance bonds to cover the cost of cleanup.

Performance bonds are another major provision of the John Graves pilot program. Although performance bonds in that area ensure restoration and reclamation of mines, the strategy could be applied on the San Jacinto to ensure cleanup and repairs after floods.[36]

It is unclear whether a coalition of governmental entities will even be able to cover cleanup costs from Harvey. If it is possible, it could take years to build the coalition and budget funds for remediation. That delays cleanup and increases flood risk for more than a quarter million people.[37]

Therefore, mining companies that choose to operate in floodways should post performance bonds that guarantee cleanup can be completed in time to reduce risk from additional flooding.

This simple provision will help ensure a true cost accounting for sand that doesn’t allow mines to externalize mitigation costs associated with risky practices (i.e., locating mines in floodways, operating with dikes that won’t withstand the pressure of floods, etc.).

  1. Increase the width of dikes.

This point is related to #1 above about setbacks from rivers. Mines create dikes, in most cases, by not removing a thin strip of natural land between dredging pits and rivers. Currently, some mines operate so close to the river’s edge that floodwaters breach their dikes repeatedly.[38]

The wider the dikes, the stronger and less likely they are to fail. Wider dikes with gentler slopes can also sustain natural vegetation which binds their soil and reduces erosion. Wider dikes create a greater safety margin over time, especially against erosion on the cut bank sides of rivers. Wider dikes, if forested, can slow currents entering/leaving mines and trap sand.[39] And finally, wider dikes give the river room to expand during floods; that’s because some mines pile sand on top of natural dikes to increase their height. This artificially constricts the cross section of the river.

Engineers say that mechanical protections, which are prone to failure during high flows, are a poor substitute for natural protection.[40]

Because of the high volume of flow down the San Jacinto West Fork, especially when Lake Conroe opens its flood gates, 50-foot and 100-foot wide dikes have proven ineffective.[41]

Pits may operate for decades. During that time, their dikes may be eroded from both sides, especially when operators mine below the level of the thalweg (deepest part of the river bottom). When operators mine below the thalweg, levee breach, river capture, and subsequent erosion are virtual certainties during large flood events.[42]

For all these reasons, many states and countries often require greater setbacks between mines and rivers than Texas does. Texas has no requirement according to correspondence with the TCEQ, although it does require a 50-foot setback from adjoining property, and some might consider the river adjoining property because it belongs to the State of Texas.[43]

In contrast, many states require a 100-foot setback. Malaysia requires 50 meters. Some countries require 100 meters. Canada requires 450 meters for mining tar sands. Alaska requires a 1000-foot setback from all public water sources.[44] Louisiana requires a 1000-foot setback from public water supply wells.[45]

Washed out road INSIDE sand mine during Harvey. To all those who say currents inside the mines during a flood are not strong enough to pick up sand, I say, “Explain this.” Image from 8/30/2017.

San Jacinto floods have breached even 100-foot dikes because of the high volume of flow, especially when the SJRA releases water from the Lake Conroe dam.[46] SJRA reported that during Harvey, the flow at Highway 99 was 130,000 cubic feet per second, far higher than on Spring or Cypress Creeks.[47] One West Fork mine operator stated that the Good Friday flood of 2018 breached his dikes – even when there was norelease from the Lake Conroe Dam.[48]

The San Jacinto River Authority has been forced to release water from the Lake Conroe Dam in each of the last three years to preserve the dam during heavy rains. The amounts ranged from 7,000 to almost 80,000 cubic feet per second.[49]

High release rates, added to already heavy rainfalls, illustrate why it may be difficult to establish one safe setback distance for all of Texas. Considering site-specific criteria such as proximity to dams and highly developed areas, slope of floodplains, width of floodways, potential peak flows, and location of cutbanks may yield safer setbacks.[50]

In general, though, the wider the setback, the stronger the dike, the greater its resistance to erosion (especially over time), the less risk to the mine, and the safer downstream communities are.

  1. Decrease the slope of dikes.

BMPs in other states and countries also recommend gently slopingdikes to strengthen their resistance. They frequently recommend ratios of 1:3 or 1:4 (height:width).[51] Malaysia recommends up to a 1:10 ratio because low slopes help establish vegetation.[52] The near-vertical slope of many West Fork dikes means they receive direct, rather than glancing blows from floodwater.

Angled surfaces deflect and diffuse incoming energy. Nowhere is this principle more evident than in the design of military, supersonic aircraft that handle wind forces at thousands of miles per hour.[53]

  1. Control erosion with vegetation.

Sloping dikes more gradually strengthens their resistance to floods, but by itself will not prevent erosion, especially on cutbanks. Planting them with grass and/or native trees and other vegetation can bind the soil, slow water down, reduce erosion and help retain sand within the mine boundaries.[54]

Virtually all states and countries recommend planting native grasses and trees to help bind soil.[55] Revegetating after plants have been removed can take years. Therefore, the best, cheapest and simplest practice is to leave native vegetation in place and simply not remove it wherever possible when constructing mines

  1. Replant areas not actively being mined.

Mining has exposed 20 square miles of sand surface to erosion along the West Fork between I-45 and I-69 and along the East Fork in Porter.[56] Not all of that area is actively being mined. Loose sand, exposed to floodwaters, exposes downstream communities to unnecessary risk. Replanting with native grasses and trees can bind the soil, reduce water velocity and reduce erosion during floods. Keeping soil in place is the best way to keep it out of rivers.

Louisiana best management practices state: “It is prudent to practice good soil conservation and seed bare ground during the post-mining phase to aid in minimizing and/or reducing the potential for stormwater to wash sediment loads from unvegetated areas into nearby waterways. Natural regeneration takes time and during that process much sediment could be washed away as sheet, rill or gully erosion over that period.”[57]

  1. Avoid clearing areas that will not soon be mined.

Delay grubbing until the last possible moment to reduce erosion and risk from floodwaters. (Same theory as #6.)

The Louisiana best management practices for sand mining state: “It is very important to only clear and grub acreage needed for the immediate term. Clearing or grubbing too much land too early in the construction phase of the mining operation will dramatically increase the potential for environmental impacts from surface water runoff and will increase the costs to control runoff from the mining site.”[58]

Large areas of mines on both the East and West Forks have been grubbed years before they were mined. These areas then flooded and contributed disproportionately to downstream sedimentation.[59]

  1. Protect stockpiles from flooding.

Sand in stockpiles is especially vulnerable during floods because it is so loose. During Harvey, sand mines adjacent to Kingwood lost four of six stockpiles completely. Another eroded severely. Only one escaped with little loss, the one on the highest ground, protected by a large swath of trees. Mines that locate stockpiles in floodways risk losing their entire inventory and contributing disproportionately to downstream sedimentation.[60],[61]

Half of this mine lies within not one, but two floodways (cross-hatched areas). The part of the stockpile that eroded most is in the the 100-year floodplain. See right side of red circle.

  1. Mine only above the thalweg.

Thalweg is pronounced taal-veg. It is a geological term for the deepest part of a river. West Fork sand mines remove sand to depths approaching 50 feet. That’s far below the West Fork’s thalweg.

The greater the differential between river bottom and pit bottom, the greater the likelihood of pit capture[62]during floods. Water migrates from areas of high pressure to low and from high elevation to low. With dikes of only fifty feet or less, river capture of mines is a virtual certainty during floods.[63],[64] This increases river bottom erosion upstream. It alters the gradient of the river. And it creates a hungry water effect downstream that contributes to bank erosion, property loss, tree loss, infrastructure damage, and increased sedimentation.[65]

All these things happened during Harvey when the river ruptured dikes and cut across point bars through sand pits.

In separate reviews of scientific literature and on-site studies, Ladson and Judd, and Jacobs Engineering described the ways rivers capture pits.[66]

  • Lateral migration of the river channel into the pit
  • Sub-surface piping from surface water into pits and subsequent failure of pit walls
  • Water cascading into a gravel pit as flood waters rise
  • Erosion by water returning to the river from the pit as the flood recedes.

Ladson and Judd also found that floodplain mining can have delayed impacts.[67]

  • “The low-resistance…high-flow conveyance path provided by the open area of a gravel mine can alter floodplain hydraulics during high flows.”
  • “Mining on floodplains may reduce groundwater levels on adjacent areas where water is removed by pumping and may affect groundwater quality.”
  • “Floodplain mines may lead to river channel changes that include erosion, bed degradation and damage to infrastructure.”

Sand removed from a pit also creates a void that induces river water as well as ground water from surrounding areas to migrate into the pit. This can reduce the flow in the river and negatively impact aquatic species.

When the water table drops below the level of roots, surface vegetation can also die back, contributing to more erosion.[68]

Finally, mining below the thalweg loots water from river authorities. Mines use state property to process their product without paying for it, unlike smaller businesses and individuals, who must pay fees to subsidence districts, water authorities and municipalities based on usage.[69] Pits expose more water to air, increasing evaporation and water loss.

By mining above the level of the thalweg, all these problems can be reduced or avoided, including those of fairness and equitable treatment.

     10. Establish performance bonds to guarantee remediation of breaches and/or repurposing of mined areas once mining is complete.

 Reclamation or remediation of sand mines, and repair of breaches should also be covered by performance bond(s). Obtaining a permit requires a mine to file a remediation plan, but it does not force mines to remediate. Operators can simply walk away from pits, creating safety hazards, eyesores, and economic development headaches for communities.[70]

Defunct Humble sand mine on North Houston Road just north of Townsend Blvd. Note steep, unvegetated slopes, lack of berms, and lack of fencing, all violations of best practices in most states. Luckily, this pit will be filled with spoils from the Army Corps dredging project and then graded to match surroundings. 

On the positive side, mines can be turned into lakes for residential communities, storage pits for spoils, parks, storm water detention facilities, marinas and wetlands.[71]

But these all represent costs long after all the profit has left the site with the last sand truck. Abandoned pits and equipment, in some cases, remain eyesores in the community that discourage economic development.[72]

In two observed cases, mine dikes were damaged in storms, yet no one repaired the breaks for years. West Fork mine dikes have remained broken for three years in one case and six in another, while rainwater has washed accumulated pit sediment into the river.[73],[74]

Performance bonds should cover not just the cost of remediation but also the cost of maintenance (i.e., mowing, watering, fencing, etc.) until abandoned property can stabilize and/or be sold.

Conclusion:

Rates of sedimentation on the West Fork have increased rapidly in recent years.[75] This likely was the result of three unusually heavy rains in 2015, 2016, and 2017. Harvey was the coup de grâce.

It was also a wake-up call. It exposed the weaknesses in Texas regulations. It  underscored the importance of adopting common-sense best management practices like those outlined above to help improve public safety, reduce damage to infrastructure, and avoid such widespread flood damage to homes and businesses in the future.

The consequences of ignoring these recommendations potentially include:

  • Destruction of downstream communities through increased flooding…again
  • More loss of life
  • Unfair imposition of remediation costs on taxpayers
  • Hidden “subsidies” that distort the true cost of cement and its usage
  • Loss of faith in the ethical standards of businesses and the free enterprise system
  • Loss of faith in government institutions to protect people and property
  • Loss of home and business values
  • Reduction of property tax income to city and county governments
  • Reduction in perception that Texas is a desirable place to live.

If we are to maintain faith in government, private enterprise and free markets, we must have a full and fair cost accounting that recognizes the damage and cleanup costs due to sand from mines. These costs have been externalized by miners. For decades, this issue remained invisible because the problem was sub-acute. That made it easy for government to “kick the can down the road.” Harvey changed all that.

The problem is now critical and must be addressed.

Increased rates of sedimentation are putting Lake Houston itself at risk. The Lake currently represents the source of drinking water for approximately 600,000 people. But the City of Houston expects to have 2 million people using surface water from the lake within the next few years as new water treatment plants come online. The increasing rate of reduction in its capacity conflicts directly with the expected increase in customers.

Destruction like we experienced during Harvey is rarely caused by one thing. It results from multiple failures on multiple levels. They compound each other. To restore and maintain margins of public safety, we need to address each cause. To the extent that sand mines contributed to the problem, they can also help solve it by modifying business practices as described above.

How You Can Help

This is an election year. TACA has tripled its lobbying budget. But TACA can’t vote and you can. Make this an election issue and quiz each candidate for their positions on common sense regulations affecting sand mines.

These are my opinions of a matter of public policy protected under the First Amendment of the U.S. Constitution and the Anti-SLAPP statutes of the great State of Texas.

For a downloadable, printable copy of this document including footnotes, click on Best Management Practices for Sand Mines.

Posted by Bob Rehak on August 1, 2018

338 Days since Hurricane Harvey

#####

Footnotes

[1]https://reduceflooding.com/2018/07/06/army-corps-of-engineers-awards-dredging-bid-on-west-fork-emergency-project/. USACE will remove 1.8 million cubic yards from a 2 mile stretch where some of the worst deposits are found. When complete, eleven miles will remain to be dredged. The cost to remove sediment from the first 2-miles is $69,814,060.

[2]https://reduceflooding.com/2018/07/27/why-we-must-remove-mouth-bar-on-west-fork-of-san-jacinto/

[3]Spring and Cypress Creeks

[4]https://reduceflooding.com/2018/05/22/where-did-all-the-sand-come-from/

[5]https://reduceflooding.com/2018/06/07/taca-spells-out-industry-position-on-societal-and-environmental-benefits-of-sand-mining/

[6]https://reduceflooding.com/2018/06/23/do-local-sand-mines-follow-best-management-practices/

[7]https://reduceflooding.com/2018/07/25/a-closer-look-at-sand-issues-on-the-east-fork-of-the-san-jacinto/

[8]https://reduceflooding.com/wp-content/uploads/2018/03/BrownRoot-Dredging-Recs.pdf

[9]Page 15, https://reduceflooding.com/wp-content/uploads/2018/03/BrownRoot-Dredging-Recs.pdf

[10]https://reduceflooding.com/wp-content/uploads/2018/03/Hurricane-Harvey-Peak-Inflows-36×24.pdf

[11]https://reduceflooding.com/2018/07/01/a-model-for-the-future-of-the-san-jacinto/

[12]https://reduceflooding.com/wp-content/uploads/2018/03/Harvey-Flood-Full-Length-8.pdf

[13]https://reduceflooding.com

[14]See 450+ photos at https://reduceflooding.com/gallery/

[15]https://reduceflooding.com/2018/03/19/how-deep-was-the-sand-deposited-by-harvey-at-river-grove-park/

[16]https://reduceflooding.com/2018/06/10/damage-map-neighborhoods-in-lake-houston-area-hardest-hit-by-harvey/

[17]https://reduceflooding.com/2018/07/06/army-corps-of-engineers-awards-dredging-bid-on-west-fork-emergency-project/

[18]https://reduceflooding.com/2018/04/11/army-corps-finishes-sedimentation-survey-field-work-on-first-leg-of-west-fork/and https://reduceflooding.com/2018/04/03/4-33-inches-of-rain-created-the-third-largest-flood-in-16-years-on-the-east-fork-of-the-san-jacinto/

[19]https://reduceflooding.com/wp-content/uploads/2018/07/Mouth-Bar-Rev-16.pdf

[20]https://reduceflooding.com/wp-content/uploads/2018/07/Mouth-Bar-Rev-16.pdf

[21]https://reduceflooding.com/sand-mining/

[22]https://reduceflooding.com/2018/07/01/a-model-for-the-future-of-the-san-jacinto/

[23]Personal observations derived from a study of best and actual practices

[24]Page 6, https://www.tceq.texas.gov/assets/public/comm_exec/pubs/sfr/087_08.pdf

[25]Page 5, https://www.tceq.texas.gov/assets/public/comm_exec/pubs/sfr/087_08.pdf

[26]https://hazards-fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd

[27]Consultation with three different geologists

[28]https://reduceflooding.com/2018/06/23/do-local-sand-mines-follow-best-management-practices/,

[29]https://reduceflooding.com/wp-content/uploads/2018/03/West-Fork-Sand-Stockpiles2.pdfand https://reduceflooding.com/2018/07/25/a-closer-look-at-sand-issues-on-the-east-fork-of-the-san-jacinto/

[30]Item CI-61, Page 8 in project list of Harris County Flood Bond Proposal, https://www.hcfcd.org/media/2881/2018bondprojecttable2018-07-19-1600.pdf

[31]https://reduceflooding.com/2018/06/10/damage-map-neighborhoods-in-lake-houston-area-hardest-hit-by-harvey/and https://reduceflooding.com/2018/07/25/a-closer-look-at-sand-issues-on-the-east-fork-of-the-san-jacinto/

[32]https://reduceflooding.com/wp-content/uploads/2018/07/sir20185070.pdf

[33]https://reduceflooding.com/2018/07/11/usgs-report-on-peak-streamflows-during-harvey-significantly-revises-flood-probabilities/  Note: this number is currently being verified by USGS, Harris County Flood Control and FEMA.

[34]Page 9, Gage 08070500, line 32, https://reduceflooding.com/wp-content/uploads/2018/07/sir20185070.pdf

[35]https://reduceflooding.com/2018/06/23/do-local-sand-mines-follow-best-management-practices/

[36]Page 7, https://www.tceq.texas.gov/assets/public/comm_exec/pubs/sfr/087_08.pdf

[37]Lake Houston Area Chamber of Commerce estimates current population is 286,000.

[38]https://reduceflooding.com/2018/06/23/do-local-sand-mines-follow-best-management-practices/

[39]https://reduceflooding.com/2018/05/04/two-modest-proposals-to-reduce-the-amount-of-sand-coming-downstream/

[40]Page 2, https://reduceflooding.com/wp-content/uploads/2018/07/Jacobs_and_Moroka_2015_Risk_assessment_of_floodplain_mining_pits_in_the_mid-Goulburn_Valley.pdf

[41]https://reduceflooding.com/2018/07/22/how-floodplain-mining-can-lead-to-river-capture/

[42]https://reduceflooding.com/2018/07/22/how-floodplain-mining-can-lead-to-river-capture/

[43]Correspondence with TCEQ.

[44]See https://reduceflooding.com/sand-mining/  Compare best practices from various states and countries by searching on the word “setbacks” within regulations from various states and countries.

[45]Page 18, https://reduceflooding.com/wp-content/uploads/2018/06/LouisianaRecommendedBMPs.pdf

[46]https://reduceflooding.com/2018/07/22/how-floodplain-mining-can-lead-to-river-capture/

[47]https://reduceflooding.com/wp-content/uploads/2018/03/Hurricane-Harvey-Peak-Inflows-36×24.pdf

[48]Conversation between SJRA board members and mine executive during mine tour.

[49]https://reduceflooding.com/wp-content/uploads/2018/05/2018_FloodWarn_Training_Kingwood.pdf

[50]See Section 3.3, https://reduceflooding.com/wp-content/uploads/2018/07/Jacobs_and_Moroka_2015_Risk_assessment_of_floodplain_mining_pits_in_the_mid-Goulburn_Valley.pdf. This report contains an excellent discussion of mitigation strategies for both new and existing pits beginning on page 47.

[51]Compare best practices found on this page: https://reduceflooding.com/sand-mining/

[52]https://reduceflooding.com/wp-content/uploads/2018/06/Malaysia-Sand-mining.pdf

[53]http://www.migflug.com/jetflights/the-10-fastest-aircraft-in-the-world.html

[54]Page 47, https://reduceflooding.com/wp-content/uploads/2018/07/Jacobs_and_Moroka_2015_Risk_assessment_of_floodplain_mining_pits_in_the_mid-Goulburn_Valley.pdf

[55]For example, see page 11 of Louisiana Best Management Practices for description. https://reduceflooding.com/wp-content/uploads/2018/06/LouisianaRecommendedBMPs.pdf.

[56]Estimate calculated from Google Earth.

[57]Page 29, https://reduceflooding.com/wp-content/uploads/2018/06/LouisianaRecommendedBMPs.pdf

[58]Page 20, https://reduceflooding.com/wp-content/uploads/2018/06/LouisianaRecommendedBMPs.pdf

[59]https://reduceflooding.com/2018/07/25/a-closer-look-at-sand-issues-on-the-east-fork-of-the-san-jacinto/

[60]https://reduceflooding.com/gallery/page/15/

[61]https://reduceflooding.com/wp-content/uploads/2018/03/West-Fork-Sand-Stockpiles2.pdf

[62]https://reduceflooding.com/wp-content/uploads/2018/07/Austrailia-Ladson-Mining-River-Stability.pdf

[63]https://reduceflooding.com/2018/07/22/how-floodplain-mining-can-lead-to-river-capture/

[64]Page 20, https://reduceflooding.com/wp-content/uploads/2018/07/Jacobs_and_Moroka_2015_Risk_assessment_of_floodplain_mining_pits_in_the_mid-Goulburn_Valley.pdf

[65]Pages 251-255, https://reduceflooding.com/wp-content/uploads/2018/07/Austrailia-Ladson-Mining-River-Stability.pdf

[66]Page 251, https://reduceflooding.com/wp-content/uploads/2018/07/Austrailia-Ladson-Mining-River-Stability.pdf

[67]Page 250, https://reduceflooding.com/wp-content/uploads/2018/07/Austrailia-Ladson-Mining-River-Stability.pdf

[68]Page 255, https://reduceflooding.com/wp-content/uploads/2018/07/Austrailia-Ladson-Mining-River-Stability.pdf

[69]Personal experience as a business owner.

[70]https://reduceflooding.com/2018/07/01/a-model-for-the-future-of-the-san-jacinto/

[71]https://reduceflooding.com/wp-content/uploads/2018/06/TACA-White-Paper.pdf

[72]https://reduceflooding.com/2018/06/07/taca-spells-out-industry-position-on-societal-and-environmental-benefits-of-sand-mining/

[73]https://reduceflooding.com/2018/06/07/taca-spells-out-industry-position-on-societal-and-environmental-benefits-of-sand-mining/

[74]https://reduceflooding.com/2018/06/23/do-local-sand-mines-follow-best-management-practices/

[75]https://reduceflooding.com/2018/07/27/why-we-must-remove-mouth-bar-on-west-fork-of-san-jacinto/

 

More About Sand Mining than You Ever Wanted to Know

Regular readers of this site will notice something new today – a top-level page that contains links to information about sand mining best practices.

The page features four categories of information about sand mining:

  • Best management practices from other states and countries
  • Academic articles and case studies
  • Texas laws and regulations
  • Observations

The material within each category ranges from easy-to-understand to for-experts-only. Descriptions beneath each link hint at the nature, content and authorship of the entry along with its degree of difficulty.

I hope to expand the page over time. If you know of additional valuable references, please send me links.

Knowledge: Your Best Defense

People who have closely followed the sand mining debate in the Lake Houston area know that the Texas Aggregate and Concrete Association and others have pushed back against this website.

Sand mine in Porter next to Caney Creek covers approximately 600 acres as of Hurricane Harvey. Kingwood’s East End Park, just downstream from here, had 30 acres covered with sand up to 10 feet high after Harvey.

I believe that such debate is healthy. I also believe that informed people can make better decisions about what’s in the public interest and their own self-interest.

Start with Louisiana

If you want to learn more, the Louisiana Best Management Practices represent a great place to start. Louisiana has geology, topology, weather, climate and vegetation much like ours. Beyond that, the document is clear, concise, well-illustrated and well researched…and balanced. It contains sections that explain why we need sand mining and how it’s done. It also contains good descriptions of the dangers. Then it describes best management practices and explains how they can help mitigate those dangers.

Similarities Around the World

As you explore best practices, notice their similarity throughout the world. Our problems are not unique.

Pay particular attention to recommendations pertaining to:

  • Setbacks from the river
  • Slopes of dikes
  • Location and protection of stockpiles
  • Vegetative ground cover
  • Buffer zones
  • Remediation
  • Erosion control

Huge Gaps Exist Between Desired, Required, and Actual Practices

Be mindful of the distinctions between desired, required and actual practices. Best practices lead to best outcomes. Required practices usually lead to minimally acceptable outcomes. Actual practices sometimes fall short of even those. That’s why I’ve also included the section on laws.

Statewide, sand mine operators received more than 600 fines for violations in the last five years.

After reviewing laws and best practices, browse through the aerial photos of sand mines on this site and ask yourself, “Are they complying with laws and observing the industry’s best management practices?”

If your answer is “No”, ask “Why?” And DEMAND answers.

Finding the Solution to Pollution

Sand comes at us from many sources, some natural and some man-made. We can’t stop nature, but we can stop harming ourselves.

  • Our lake and river are rapidly filling with sediment.
  • Drainage ditches are backing up into neighborhoods.
  • Water filtration costs are high.
  • Turbidity is high.
  • Oxygen in the water is low.
  • Recreation, boating and fishing are impaired.
  • Dredging will cost tens, if not hundreds, of millions of dollars.
  • Maintenance dredging will cost even more.

Demand Excellence, Not Just Compliance

We must hold the mines to the highest standards if they want a license to operate next to the source of drinking water for millions of people. Violations are simply not acceptable.

Also, any solution must acknowledge that this region is prone to repetitive flooding. We’ve had FIVE five-hundred year storms in the last 24 years (1994, 2001, 2015, 2016, 2017). During each, we also had huge releases from Lake Conroe that exacerbated flooding.

If mine design cannot withstand these types of events, we invite disaster. The most sediment transport happens during floods; it’s time we started planning for them.

How You Can Help

All of us are smarter than one of us. You may see things that I missed. Please review the aerial photos, best practices and laws. If you see opportunities for improvement, send them to me.

Example: Alaska, I noticed, discourages mining within 1000 feet of a public water source. Here, the sand mines operate right next to ours and even drive trucks through it.

Sand mines on the west fork of the San Jacinto adjacent to Kingwood. Note how close they are operating next to the source of our drinking water. Also note what appears to be a breach of the dike between the mine on the left and the river about two-third of the way up the left side of the photo. Photo taken after Harvey on 9/14/2017.

 

Sand mine on the West Fork of the San Jacinto adjacent to Kingwood. Industry best practices elsewhere discourage running vehicles through water sources. Here the operator built a road right through the river. Also notice the steepness of the dikes. Most best management practices recommend setting them back from the river, sloping them at 3:1 to 10:1 and planting them with vegetation such as grass to retard erosion. 

 

Fresh sand deposits after Harvey coming out of the sand mines on the west fork of the San Jacinto adjacent to Kingwood. Note that the height of the dune is engulfing several medium sized trees on the right. Also note the road leading to the river on the left and machinery at work in an area unprotected by dikes.

Let’s compile of list of such observations, then start a dialog with the sand mining industry to encourage voluntary compliance with best practices and improve disaster planning.

Posted on 6/15/18 by Bob Rehak

Day 290 since Hurricane Harvey