Tag Archive for: Laurel Springs RV Resort

Laurel Springs RV Park Still Ignoring FAA Safety Requirement

No. Airplanes won’t be taking off and landing at the Laurel Springs RV resort any time soon. The headline has to do with an FAA rule that prohibits wet-bottom stormwater detention basins within five miles of airports.

Because of this pond’s location near IAH airport, the FAA and City of Houston require the stormwater detention basin to have a dry bottom within 48 hours after a storm. The requirement helps discourage birds, especially geese and other large waterfowl, from taking up residence close to the airport. That’s an important consideration, especially during the migration season, which we are in right now.

Wet-bottom ponds attract ducks and geese that create a hazard for aircraft taking off, landing or circling.

Problem Still Not Fixed

I first posted about this in May of this year and was told that the “Resort” hadn’t hooked up electricity to its pumps yet. Now, it’s almost six months later. And the pond is still holding water longer than allowed.

A retired airline captain who lives near the RV resort keeps calling this to my attention.

Evidently, he takes bird strikes far more seriously than the City inspector or resort owners. And little wonder!

If you google “airplane damage from bird strikes,” you find this horrifying collection of images.

Screen capture from Google search.

16,000 Bird Strikes in U.S. Each Year

The FAA records 16,000 bird strikes in the U.S. each year. And they cause $400 million in damages to commercial aircraft.

Ninety percent of bird strikes happen under 3,000 feet during takeoff or landing. This video explains the dangers and shows dramatic footage of the damage birds can cause when they come through a windshield, hit a wing, or get sucked into an engine. The greatest danger is when planes are close to the ground and pilots have little time to react or recover.

In extreme cases, bird strikes have even brought down airliners. In 2009, US Airways pilot Chesley Sullenberger reported a “double bird strike” that crippled both engines just after takeoff. Luckily, he managed to ditch his plane in the Hudson River without any fatalities.

Every-Other-Day Occurrence at IAH

Lest you think the problem is rare or trivial in the Houston area, the FAA maintains a publicly available online database that lets you customize searches. You can search by State, Airport, Operator, Date Ranges, Aircraft Type, Engine Type, Damage, and even the type of birds or other wildlife involved.

In the first three quarters of 2022, the FAA received 149 reports of bird strikes at Bush Intercontinental Airport. That’s out of 272 days. So…

Planes landing or departing IAH hit birds on MOST days.

Bush IAH reported 155 in all of 2019, 98 in all of 2020, and 139 in all of 2021.

Laurel Springs Basin Still Holds Water Too Long

The approved drainage plans for the Laurel Springs RV Resort stormwater detention basin show the note below.

screen capture from detention and drainage permit plans
Basin should be dry 48 hours after a 100-year storm. But today, it wasn’t dry 48 hours after a less-than-1-year storm.

The relevant portions of this 28-page advisory and its update explain that…

The FAA discourages land uses that attract or sustain hazardous wildlife within five (5) miles of airports to protect aircraft.

The detention pond for the Laurel Springs RV Resort falls within that radius from Houston’s Bush Intercontinental Airport and therefore the FAA and City mandate dry-bottom detention basins.

Laurel Springs RV Resort Detention Basin. Photo taken 11/13/22, 48 hours after storm.

The official gage at the San Jacinto West Fork and US 59 – just blocks away – recorded 1.32 inches of rain on 11/11/2022.

rainfall 11.11.22
Official rainfall at nearest gage.

That amount is one third of a 1-year rain, according to Atlas-14 standards. That’s far less than a 100-year rain which the resort is required to pump out within 48 hours. But 48-hours later, as you can see, it’s still there.

The checkered history of this RV resort deserves yet another investigation. At one time, there were four simultaneous investigations into its drainage. Seems they still haven’t gotten the message. While the risk of a bird from their pond bringing down an airliner is very low, does any responsible individual want to defend ignoring FAA advice? Those are lessons learned the hard way.

Posted by Bob Rehak on 11/13/22

1902 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.

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.

66% Impervious Cover? Really?

Because the Laurel Springs RV Resort was grandfathered under old drainage regulations, it got away with building a detention pond that was half the size required by current regulations.

But assuming the developers were just shrewd businessmen who legally and successfully exploited the system, did they follow the rest of the rules? Let’s look at two other things.

  • The percentage of impervious cover on the site
  • How the number of parking spots increased 25% without the impervious cover increasing.
Laurel Springs RV Resort as of 10/22/22. The contractor still has one more “pour” to complete the concrete in the far upper right of the image.

Were Impervious Cover Calculations Correct?

Detention-pond volume calculations begin with impervious cover (i.e., land covered by concrete plus the entire detention pond area). See below.

66% impervious cover
Laurel Springs RV Resort Detention Pond calculations from approved permit plans.

The total site covers 20.032 acres. The proposed impervious portion, they claim, covers 13.349 acres. That works out to 66.6%. So one third of the site should be grass, trees and other vegetation. But since the entire 5-acre detention pond counts as impervious, mathematically, the remainder of the site can have no more than about 60% concrete and still comply with the percentage they promised.

But just eyeballing that trapezoidal area in the photo above, it seems much more than 60% is covered with concrete.

If my eyeball assessment is correct, then the detention pond is even more undersized than I initially thought because the percentage of impervious cover has increased and with it the amount of runoff.

I wish the developer would show us the basis for those calculations.

Plans Show Increase in Density With No Increase In Impervious Cover

The developer’s permit allows 182 RV spaces, but the plans show 226 – about a 24% increase. However, the impervious cover shown on the plans before and after the permit approval did not change. That could also affect detention pond capacity requirements. And explain why the percentage of concrete appears higher than they claim.

Why Underestimate Impervious Cover?

Why would a developer underestimate the amount of impervious cover? Two reasons:

  1. It would make the detention pond smaller and thus allow the remaining property to produce more income.
  2. By claiming they’re providing more detention than required, they can get a discount on their drainage fees. See page 10.

I’m not alleging they did anything illegal. I’m just saying that much more than 60% of that trapezoid in the photo above appears to be concrete and I sure would like to see how they arrived at their figures. I requested the drainage analysis twice and never got it. That should tell you something.

Posted by Bob Rehak on 10/23/22

1881 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.

Chain Link Fencing at Laurel Springs RV Resort Would Not Meet Exxon Land Development Commercial Guidelines

Since my last post on the Laurel Springs RV Resort, contractors have erected approximately 2000 feet of chain link fence, much of it within feet of Laurel Springs Lane. Exxon Land Development Commercial Development Guidelines generally prohibited chain link fencing except in rare instances where the fence was “not visible from the street or adjacent property.” See Section II-9-3 Screen Walls and Fencing and the pictures below.

Chain link fence along Laurel Springs Lane. Looking north. Photo taken 2/26.
Chain link fence between Edgewater Park and RV Park.

Because Exxon never owned this property, it was not subject to the deed restrictions that apply to Kingwood. So I’m not alleging anything illegal. However, the developer has disregarded community norms. Those deed restrictions give the Kingwood Area its distinctive character. Disregarding them has not endeared the developer to neighbors.

Other “Improvements”

The developer also made several other “improvements” in the last few days. He has:

  • Removed more trees
  • Brought in more dirt to raise the property even higher above Lakewood Cove
  • Approximately doubled the area covered by concrete
  • Finally erected a silt fence on the west side by the utility corridor, five months into construction
  • Hydroseeded the south bank of the detention pond and northern part of Edgewater Park where they cut down trees…after severe erosion caused Harris County to threaten a lawsuit.

However, there still appears to be no effort to replant the trees they cut in Edgewater Park. Nor have they placed permanent pumps to drain the retention pond; they’re still attempting to do that with portable pumps.

Photos Taken 3/28/2022

Here’s how the site looked tonight.

The amount of concrete virtually doubled. They poured the dark gray area in the foreground last Saturday. A swimming pool will go between the concrete and the building under construction.
More downed trees litter the northern part of the property. Trucks have been bringing in more dirt to fill in low spots which became apparent after last week’s 2″ rain.
That blue/green material is called hydromulch, also referred to as hydro seeding. Looking SE toward Edgewater Park.
Looking E toward Lakewood Cove and Laurel Springs Lane as crews finish spraying for the day.
The hydroseeding crews were pulling silty water from the detention pond to mix with their material, even as portable pumps attempt to drain the pond before the next rain arrives tomorrow night.

More about Hydroseeding

Contractors use hydroseeding to stabilize slopes and accelerate the germination of grass which can reduce erosion. Water, seed, and nutrients are mixed into a gelatinous material and sprayed onto the ground. The gelatin adheres to slopes and retains just enough moisture to help the seed take root. We should see grass start to grow within 5-10 days. Crews add colored dye to the mix to make it easier to see. That helps them spray it evenly.

Should Have Hydroseeded Earlier

After the a five-inch rain in January, the south wall of the detention pond started slumping into Edgewater Park. Sediment several inches deep fanned out into the wetlands of Edgewater for approximately 150 yards, according to the TCEQ. And Harris County issued its cease-and-desist letter threatening the developer with a lawsuit. Since then, the developer has spent much of the last month trying to move the pond wall back onto his own property. I imagine the contractor now wishes he would have hydro seeded earlier.

Chain Link Fence Disregards Community Norms

Assuming surveyors were accurate, the chain link fence should now identify the southern boundary of the RV resort. However, given the history of this project, that could be a big assumption.

Thankfully, at least the chain link fence does not have razor wire on top of it. Regardless, it has all the charm of the prison in Huntsville.

While you review the Commercial Development Guidelines on fencing, scan the rest of the guidelines, too. Especially the ones that talk about setbacks, construction fencing, parking, tree preservation and more. They will give you a greater appreciation for the care taken by thousands who came before the Laurel Springs RV Resort.

Posted by Bob Rehak on 3/28/2022

1672 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.

Laurel Springs RV Resort Turns Into Giant Mud Bath

After a 2 inch rain on 3/22/22, the construction site at the Laurel Springs RV Resort turned into a giant mud bath, now being pumped into the Lakewood Cove storm sewer system. The whole point of the Stormwater Pollution Prevention Plan approved by the TCEQ is to prevent that.

Is This Part of A Bigger Marketing Plan?

Large ponds of muddy water covered the site from north to south and east to west, a tribute to the drainage still not installed after five months of site work. It makes one wonder whether the contractor’s tardiness is part of a marketing ploy.

Do they plan to market this RV resort as a mud bath/spa? Will they offer a special pit for ladies’ mud wrestling on WWF nights? Do they plan to turn part of the site into an all-weather ATV track? Will they rent this place out to kindergarten class reunions? Or will this be a practice range for politicians who want to learn how to sling mud? There’s just no telling. The secretive owners still have not divulged their marketing plans with the local residents.

Pictures Taken After 2″ Rain

Regardless, they have conspired with Mother Nature to create a world-class mud bath, as the pictures below show. I took the pictures below the morning after the gage at the West Fork and 59 recorded a two-inch rain.

Looking north toward entrance on right.
The ponds above the detention pond.
Let’s bring in some more mud. Note dirt piles at top of frame.
ATV terrain, northern part of site.
There’s nothing like mud to slow down work on a construction site. That’s why this must be intentional. Ooops. What happened to those silt fences on the west?
The creative approach to construction.
Even though they’ve installed a drain, they still haven’t installed pumps.

They started pumping this pond into the Lakewood Cove storm sewer system today. So much for keeping mud out of the sewers. That’s a major part of the Stormwater Pollution Prevention Plan approved by the TCEQ.

Posted by Bob Rehak on 3/23/2022

1667 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.

Laurel Springs RV Resort Update: Mysterious Black Spots and Other News

In the two weeks since I last posted about the “RV Resort” under construction on Laurel Springs Lane, a lot has happened. Among other things, I’ve noticed contractors repeatedly covering up black spots in the detention pond that have a habit of mysteriously reappearing.

Mysterious Black Spots Keep Reappearing

Photo taken 3/5/22. Note difference of color in puddles just inches from each other.
Wide shot also taken on 3/5 shows bulldozer filling in one black area while another leaks into pond. Note streak in water and see below.
Also taken 3/5. Pond was being manually pumped into Lakewood Cove Storm sewer system and thence into Lake Houston. The pumping explains the streak.
On 3/10/22, I noted these black areas at the western end of the pond emerging from freshly bulldozed areas.
Photo taken 3/11. The situation was worse and the bulldozers were back.
On 3/14, the floor of the detention pond had been smoothed out, but the black spots were making another embarrassing comeback.
Close up of same spot taken on 3/15.

I have dozens of other shots that show similar patterns. But you get the idea.

I asked the Railroad Commission if they could identify oil seepage from photos. The answer was no. But they did send an investigator out. Unfortunately, he arrived after everything had been covered up.

The contractor acknowledged the black spots, but claimed they were just seepage from rotting mulch. But why would a contractor place mulch below an area being excavated? That would just raise the level of the pond they were deepening. The mystery continues.

The Railroad Commission of Texas found no records of abandoned oil or gas wells on this property, although many are nearby.

As a show of good faith, I wish the developer would have an independent lab confirm what this stuff is now that it’s being pumped to a storm sewer system that feeds into Lake Houston.

Other Recent Activity

In other news:

  • The developer has removed hundreds of truckloads of debris from below the detention pond.
  • They have excavated material from the southern walls of the pond and moved it north. This effectively shifted the pond back onto the developer’s property while elevating other portions of the property.
  • Contractors erected posts for what appears will be a chain link fence at the southern edge of the resort.
  • Contractors have finished tying the detention pond into the Lakewood Cove Storm Sewer system.
  • They also installed more underground drainage throughout the property.

The photographs below illustrate the points above.

Photo taken 2/23/22 shows part of debris pulled up from south of detention pond. Also note the black spots in the detention pond.
Taken 3/16/22. Photo courtesy of reader. Used with permission. Note fence posts along left. These would appear to confirm the property boundary.
The detention pond intake valve in the foreground is now connected with the pump housings on higher ground. However, the pumps may not yet be installed. And the housing still looks sealed off. Photo taken 3/15/22.
Additional dirt is being brought in to raise the elevation of the site. Photo taken 3/13/22. Note water still ponding on site from a half inch of rain on 3/15. This soil is not as porous as the stormwater pollution prevention plan claims.
Rebar being laid for the next concrete pour on 3/14/22.

Posted by Bob Rehak on 3/16/22

1660 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.

RV Resort Detention-Pond Drain Finally Being Installed in Approved Location

Four months after Laurel Springs RV Resort contractors started tying into the Lakewood Cove storm sewer system, they may finally finish the job in the next few days. I spotted them yesterday and today, digging a trench from the pumps to the pond.

At their present rate of progress, and with gasoline prices spiraling out of control, one wonders whether RVs will be able to afford gas to get here when this job is complete.

Troubled History of Project

The storm sewer tie in comes more than a month after an aborted attempt to dig a trench through the wall of their half-sized detention pond and install pipes that drained the resort’s stormwater directly into Edgewater Park. Both actions violated state and city permit requirements. They also caused the state, city and Harris County to launch four investigations into construction practices at the RV resort. Subsequently, the Harris County Attorney sent a cease-and-desist letter to the resort’s owner and threatened a lawsuit.

Detention Pond Storm Sewer Tie In Started in Early December

Laurel Springs RV Resort detention pond drainage tie in as of 12/05/21. Contractor has tunneled under Laurel Springs Lane to Lakewood Cove storm sewer system on far side.
Drainage plans approved by City of Houston for this portion of the job site. SE corner of detention pond below is in upper left of diagram above.

Contractor Now Working on Approved Tie In

Wednesday around noon, 3/02/22, workers started excavating around the circular pump housing.
By early morning 3/3/22, they had already laid the first section of pipe.
By noon on 3/3/22, they had laid another section of pipe and were excavating their way to the corner of the pond.

Rec Center Being Framed Out

In separate news, workers started framing the RV Resort recreation building yesterday.

This shows the status on the morning of 3/3/22.

Spiraling Cost of Gasoline Could Affect Demand

I heard a story on the radio this morning that gasoline in Toronto has now topped $8.50 USD per gallon. With gasoline prices spiraling out of control, it’s unclear how many people will be traveling in RVs anytime soon. The larger ones get as little as 6 miles per gallon.

I remember taking a trip through the Yukon Territory several years ago when gasoline was half that price and seeing an RV fill up for more than $1000.

That’s comparable to the cost of a 2500 square-foot penthouse suite in a luxury 5-star hotel.

Now imagine doubling that cost to stay in something one tenth the size.

As they say in Hollywood, “Timing is everything in show business.” You could say the same for the RV park business.

Posted by Bob Rehak on 3/3/22

1647 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.

Laurel Springs RV Resort Construction Pushes Forward Despite Investigations

Despite investigations by local, county and state authorities into construction practices at the Laurel Springs RV Resort near Lakewood Cove, contractors seem to have stepped up the pace of construction. They’ve also launched a major cleanup effort around the detention pond. Contractors triggered a cease-and-desist letter from the County Attorney, with the threat of a lawsuit, after it became apparent the developer was emptying its stormwater into Harris County Precinct 4’s Edgewater Park contrary to permits and approved plans. Contractors also apparently cut down a wide swath of trees in the northern part of the park.

Photos Showing Construction Activity Since Last Friday

Looking west toward Sorters-McClellan Bridge over 59. Edgewater Park on left. RV Resort on right. Silt fence at the base of the pond corresponds to approximate southern boundary of RV Resort on survey. Taken 2/24/22.
Looking south along Laurel Springs Lane at freshly poured concrete at entrance. Taken 2/24. This afternoon (2/25), trucks were pouring more concrete.
Pipes being laid in northern part of RV Resort. Note water still ponding from rain in early January. Soil reports in the site’s stormwater pollution prevention plan claimed the soil was sandy loam which would have absorbed the rain by now.
Still no pipe from the corner of the detention pond leading to the pump housing in the round white concrete housing at top of frame. 2/23/22.

The detention pond was to have drained into the Lakewood Cove storm sewer system with the aid of pumps. But there’s no inlet yet at the pond.

Looking east toward Laurel Springs on 2/19/22.
Plans approved by City of Houston for pumping stormwater in detention pond into Lakewood Cove’s storm sewer system.
Contractors pulling up tree debris from below detention pond. 2/18/22. Looking SW.
Looking south toward Edgewater Park. Contractors initially piled the debris on the western (right) wall of detention pond, but ran out of room. They then started hauling it round to northern edge of pond where trucks are carting it away.

Investigations Still in Progress

Neither the County, City, nor Texas Commission on Environmental Quality would comment on the status of their investigations this week except to say that they are still ongoing. According to the Harris County District Clerk’s website, Harris County has not yet filed a lawsuit against the developer.

Overall, the developer appears to be cleaning up its act. But as you can see in the first shot, they seem to have made a significant and serious intrusion on Edgewater Park.

Posted by Bob Rehak on 2/25/22

1641 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.

RV Resort Getting Ready to Pour Concrete, Baffling Activity at Detention Pond

Construction activity at the Laurel Springs RV Resort near Lakewood Cove kicked into overdrive today as workers laid forms to prepare for concrete and more pipes went into the ground. Also, the detention pond seemed to change shape in ways that could reduce its capacity.

Getting Ready for Concrete

The shot below shows what will become the main entrance/exit opposite Mystic Glen Loop in Lakewood Cove.

Entrance/Exit to RV Resort. Concrete building pad for recreation center. The two rectangular areas in front of the three cargo containers will be the first RV pads. Blue pipes will carry fresh water.
Plans that correspond to the photo above.
Concrete forms also extend south toward the detention pond, out of sight at bottom of frame.

Baffling Work at Detention Pond

The work at the detention pond today was hard to explain. For the last few days, workers have pulled dirt and tree debris up onto the southwestern wall of the detention pond. Here’s how it looked yesterday around noon.

SW wall of RV Resort detention pond photographed on 2/17/2022.

Trucks have moved a portion of it to the western wall.

Looking east. Excavator loading debris onto truck which will back it around to the western wall (out of frame to the lower left). This and all photos below taken 2/18/22.
Truck transplanting debris on western wall.

The wide shot below shows where they have been piling it on the western wall and puts the activity in context.

Looking South toward Edgewater Park in background.
But it wasn’t all going to the western wall. Bulldozers spread some into the Laurel Springs RV Resort detention pond.
The area where contractors laid pipe between the pond (left) and ponding water (right).
Meanwhile, another bulldozer seemed to push dirt from the outside of the pond’s southern wall to the inside.
It appeared as though contractors were attempting to shift the entire wall to the north. If accurate, that could reduce the pond’s already constrained capacity.

Did the developer’s surveyors make a mistake initially? We shall know soon enough if the County conducts its own survey.

If that tree debris gets plowed into the pond wall, it could weaken the structural integrity of the pond as the woody material decays.

Reducing Pond Capacity?

I’m especially concerned about the potential loss of capacity in the detention pond. It already had only half the current capacity required to meet current City of Houston standards.

The further along construction gets, the harder it is to undo mistakes if they happen. So we need to monitor this closely.

Posted by Bob Rehak on 2/18/22

1634 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.

Harris County Attorney Threatens Lawsuit Against RV Resort Owner, Contractor

The Harris County Attorney has threatened the Laurel Springs RV Resort owner and contractor with a lawsuit. The Cease and Desist letter also includes, strangely enough, the Lakewood Cove Homeowners Association.

The County Attorney alleges the HOA owns the property on which the RV Resort is being built. However, the HOA claims it does not and believes their inclusion is an error.

The Harris County Appraisal District (HCAD) shows that LS RV Resort, LP bought the property on 9/22/21. HCAD’s ownership history goes back to 1985 and shows five previous owners. The Lakewood Cove HOA is not among them. Lakewood Cove started being built out around 2005.

Harris County Complaints

The County Attorney’s letter cites the following complaints. That the contractor, Higbie Ventures of Texas, Inc., and owner, LS RV Resort, LP:

Orange clay discharge in Edgewater Park wetlands after unpermitted discharge.

The County alleges trespass and destruction of county property. The trespass allegation may include trespass of bulldozers as well as trespass by water.

Photo taken 2/14/22 looking east toward Laurel Springs and Lakewood Cove along southern boundary of RV Resort. Edgewater Park is on right. The RV park property ends near the right edge of the detention pond, but trees contractors cleared trees well beyond that.
Looking south. 2/14/22 at 1PM. Contractors have been pulling dirt and debris back from Edgewater Park and piling it along wall of detention pond. Note ponding water still visible near trees in background.

In the photo above, the pipes laid through the wall were near the eroded area under water in the center of the frame. The developer has since spread dirt in this area to cover up the pipes, but no one who I have interviewed has seen the pipes being removed.

Harris County Demands

Harris County demands that the trespassing and discharges cease immediately and that the detention pond wall be repaired. The County also seeks damages and an injunction requiring the buried pipe to be removed.

The discharge was first documented on Saturday, 1/29/22 and the pipe installation on 1/31/22. The County Attorney’s letter is dated February 1, 2022.

Both Precinct 4 Parks Department and the Harris County Engineering Department inspected the site and documented damage.

Owner/Contractor Response

Since the County Attorney’s Cease and Desist letter, the contractor has worked to clear erosion and pull back debris from the County’s Edgewater Park. However, Higbie appears to have piled dirt in front of the inlet and outlet pipes without actually removing them. It’s unclear whether the pipes remain in the wall of the pond. No sources I have talked to have seen them removed and aerial images show that ponding water remains near the outlet location. It took three days to put the pipes in, so you would think it would take at least a day or two to take them out. But no such activity has been observed by many neighbors who have contacted me. However, the developer sometimes works at night.

HOA Status

Current Lakewood Cove HOA officers say they can find no record of ever having owned the RV property or of having an interest in it. The County Attorney (CA) has not returned their calls for two weeks. The CA did not return my call. Nor has the CA returned calls from Precinct 4 staff. I have not had time to obtain a title search. Let’s hope somebody at the County Attorney’s office can explain the alleged ownership issue with the HOA. And that the contractor removes the pipe from the pond wall (if it’s still there).

To see the County Attorney’s Cease and Desist Letter, click here.

Posted by Bob Rehak on 2/14/22

1630 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.

TCEQ Says RV Resort Discharge Not Allowed by Permit

The TCEQ says discharges of sediment-laden stormwater are not allowed across public or private property under the terms of its Construction General Permit.

Two weeks ago, I photographed contractors at the Laurel Springs RV Resort construction site discharging silty stormwater from its detention pond into the wetlands and cypress ponds of Harris County’s Precinct 4 Edgewater Park.

stormwater runoff discharge
Photographed on Saturday, January 29. Laurel Springs RV Resort dug a trench through the southern wall of its undersized detention pond to discharge silty stormwater onto public property at top of frame.

Not long after that, I photographed them laying pipe in the trench to create a permanent conduit for stormwater into the park.

Response From Texas Commission on Environmental Quality

So, I emailed the photos to people at the TCEQ responsible for water quality, Stormwater Pollution Prevention Plans, and Construction General Permits. I asked if their permit allowed them to discharge silty stormwater into Edgewater Park. The short answer: NO.

Earl Lott, Director of the Water Quality Division of the TCEQ wrote back a lengthy email. In it, he concluded…

“…[their] general permit does not give the permittee the right to use private or public property for conveyance of stormwater and certain non-stormwater discharges…”

Earl Lott, Director, TCEQ, Office of Water

CGP Covers Activities During Construction, SWP3 Prior to Construction

Mr. Lott also noted that “Large construction site operators must comply with the conditions of the stormwater Construction General Permit (CGP) TXR150000 under the Texas Pollutant Discharge Elimination System (TPDES) Program. The CGP requires construction operators to control pollutants in stormwater during construction activities. Construction site primary operators that disturb greater than one acre of land are required to develop a Stormwater Pollution Prevention Plan (SWP3) and implement best management practices (BMPs) prior to construction activities beginning.” [Emphasis added.]

“As part of the SWP3,” Lott continued, “a description of BMPs used to prevent and reduce pollution in stormwater must be included and the BMPs must be inspected and evaluated to determine the effectiveness of controlling stormwater leaving the property.”

“The SWP3 must include a description of any sediment control practices used to remove eroded soils from stormwater runoff, such as a sedimentation basin. These controls must minimize sediment discharges from the site,” said Lott. [Emphasis added.]

So what did the Laurel Springs RV Resort’s SWP3 and Permit obligate them to do? For the full text of this 162 page document, click here. (14 Meg Download). The first have of this document includes the SWP3. The second includes the permit to discharge under the Texas Pollution Discharge Elimination System. There are many redundancies between the two. I’ll cover the SWP3 today and the Permit another day.

Concerns About SWPPP Plan

I want to make it clear that Mr. Lott’s comments related only to discharges of stormwater into Edgewater Park. However, after reading the RV Resort’s SWP3 and Permit, I have personal concerns listed below. The TCEQ may or may not share them. The TCEQ has up to 60 days from the date of an initial complaint to file a full report.

Based on my observations, contractor performance does not match contractor promises in the SWP3 in many cases. Also, several key elements of the plan were left blank. And some claims were just plain false, misleading or erroneous.

Below is a list of my concerns. You may find others.

  1. The plan is undated and appears never to have been revised even though it should have been.
  2. Clearing started in October. As Lott said, the contractor should have put pollution prevention measures in place before construction, but didn’t.
  3. Page 15 – The discussion of runoff coefficients is misleading. If sand comprised the top 18 inches of soil, water would not still be ponding on the site. We’ve had less than an inch of rain in the last 20 days. It would appear that the contractor overstated the potential for water to infiltration.
  4. Pages 16 and 17 – Construction schedule left blank.
  5. Page 18 – Says locations of support activities are included, but blanks not filled in.
  6. Page 18 – Says no wetlands have been found near site when adjoining property is full of them.
  7. Page 18 – Can’t see where they planned temporary erosion control measures during construction. Until yesterday, they had no silt fencing along the southern property line and still have no along the western property line.
  8. Page 18 – No source listed for fill materials. They have used Sprint Sand & Clay. But Sprint’s contract prohibits them placing fill in the 500-year flood plain. I have photographed the contractor spreading Sprint fill into the 500-year area.
  9. Page 22 – Contractor lists the size of the site as 20 acres and claims 20 acres are sandy loam. But then he says 20 acres out of 20 acres is 74%. Hmmmm. No wonder he has six tax forfeitures in his past.
  10. Page 22 – Contractor relied on USDA’s Natural Resources Conservation Service (NRCS) for soil data. But NRCS says its data is invalid for a site of this size. It falls below the limits of resolution for NRCS sampling.
  11. Page 34 – Before clearing, contractor failed to mark the southern property line. Employees then cut down a corridor of trees approximately 50 feet wide for a distance of about 750 feet. Contractor then piled dirt in corridor which eroded into Edgewater Park.
  12. Page 40 – I can see no measures in use to slow down velocity of sheet flow.
  13. Page 40 – I can see no temporary erosion controls in place on portions of the site where they are no longer working.
  14. Page 41 – Exits have been mud pits so vehicles have tracked dirt out of the site and spread it into streets where it washes into storm sewers.
  15. Page 41 – They have perimeter protection installed only along one side and have even bypassed that.
  16. Page 42 – No protection of storm sewer inlets until yesterday (about 5 months late).
  17. Page 42 – They claim a sediment basin would put public safety as risk, but don’t explain why.
  18. Page 42 – Contractor should have drained the detention pond through a 24 inch reinforced concrete pipe leading to the City’s storm sewer system, but chose to use the wetlands in Edgewater Park instead.
  19. Page 43 – Says discharge of standing water into a storm sewer will not be allowed, but residents have photographed them doing it.
  20. Page 43 – Covers vehicles tracking dirt out of the site. It requires stabilized construction entrances and/or regular street sweeping. This is basic “good housekeeping” stuff that has been in short supply since this construction site found the spotlight.
  21. Page 44 – Says “No discharges of Stormwater…will take places under this SWPPP.” See photos above.
  22. Page 45 – Says “Maintenance and repairs will be conducted within 24 hours of inspection report.” But only in the last two days has the contractor started removing eroded dirt from the county’s park caused by the discharge weeks ago.
  23. Page 45 – Says “Sediment will be removed from sediment fences … before it reaches 50% of the above ground height of the barrier.” Sediment was placed against the new southern silt fence that already exceeds that height.
  24. Section 8 on page 45 requires the contractor to select the most effective erosion control measures for specific site conditions from a page-long list of options. The contractor chose NONE.

How To Report Violations to the TCEQ

I urge residents who live close to the RV Resort to read the SWPPP and report additional violations/problems to the TCEQ if they see them.

Posted by Bob Rehak on 2/13/22

1629 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.