Tag Archive for: Scarborough

Floodplain Maps for 5,316 Acres West of Kingwood Contradict Developer’s Claim

11/4/2025 – FEMA floodplain maps contradict a claim made by Scarborough Development/San Jacinto Preserve in a presentation made to the City of Houston and Harris County officials on 10/29/25.

The developer recently bought 5,316 acres, mostly in the floodplains and floodways of Spring and Cypress Creeks, and the San Jacinto West Fork. The land lies in both Montgomery County and the City of Houston’s extra territorial jurisdiction. The developer also wants to build a bridge into Harris County.

In documents obtained from the City of Houston, the developer claimed it would only be “developing land at or above the Atlas 14 100-year floodplain.” See copy in red box below.

Presented by developer to City of Houston and Harris County on 10/29/25.

However, superimposing their development plan on FEMA’s current floodplain maps developed before Atlas 14 contradicts that claim. Why?

The extent of proposed development matches the limits of pre-, not post-, Atlas 14 100-year floodplains.

Net: developing in this area is more dangerous than it may look. 500-year floodplains could soon become 100-year floodplains.

For more detail, see the discussion of Atlas-14’s history and the sequence of maps below.

A Brief History of Atlas 14

FEMA’s current floodplain maps for this area date to 2014, four years BEFORE the start of Atlas 14 in Texas. And to my knowledge, FEMA has not yet released new flood maps based on Atlas 14 for this region.

From FEMA floodplain map of Scarborough/SJP property. Effective date: 8/18/2014. Screen captured today.

NOAA began updating rainfall precipitation frequency estimates in 2004; they called the effort “Atlas 14.” But NOAA didn’t update Texas statistics until 2018. Such rainfall estimates form the basis for flood maps.

In Montgomery County (MoCo), pre/post estimates for the standard 100-year/24-hour rainfall varied by more than a third. MoCo adopted Atlas 14 values of ~16.1 inches for the 24-hr, 1% storm (at Conroe), up from the previous standard of ~12 inches. That’s an increase of 4.1 inches or 34%.

Just as important, until earlier this year, MoCo drainage regulations often let developers avoid building stormwater detention basins that would offset that additional rainfall.

Also consider that Montgomery County has been one of the fastest growing counties in the region and in America. Its population has grown by almost a third (31%) since 2018. That population growth comes with a growth of impervious cover (roofs, driveways, streets, parking lots, etc.) that doesn’t soak up rainfall.

I’m not aware of any recent studies that show the cumulative impact of additional rainfall and impervious cover together with a deficit of detention.

Given those issues, common sense says flood elevations would increase. And in fact, preliminary guidance from Harris County indicates that floodplains will expand by 50% to 100% when FEMA releases updated flood maps based on Atlas 14.

New Plans Show Development Extending to Old 100-Year Floodplain

When I first saw the developer’s new plans, the plans didn’t seem to match the claim that they would only develop land “at or above the Atlas 14 100-year floodplain.” That made me suspicious. So, I performed an experiment.

I superimposed the developer’s plans over FEMA’s current (pre-Atlas 14) map dated 2014. I then varied the opacity of the layers in Adobe Photoshop so I could see how the two matched up. Long story short, they matched perfectly. See the sequence of images below.

Layer 1: From FEMA’s Flood Hazard Layer Viewer. Scarborough property is in center between Spring Creek (diagonal) and West Fork (right). Brown areas = 500-year floodplain. Aqua = 100-year. Striped = floodway.

Next, I superimposed the development plan that Scarborough presented to City of Houston and Harris County.

Layer 2: Gray areas with waffle pattern represent claimed “net developable area.” Red = property boundary.

Then, I varied the opacity of the development plan until you could see the floodplains behind it.

Composite with partial transparency of overlay

Enlargement clearly shows that development stops at the old, pre-Atlas-14, 100-year floodplain.

White lines from 2014 FEMA map form boundary between 100- and 500-year floodplains. And waffle patterns from developer’s plans stop at white lines.

New maps reflecting higher rainfall rates and more impervious cover will likely show those white lines cutting well into the brown so-called developable areas, if not eliminating some altogether.

Where Did Developer’s Claim Come From?

So, where did the developer’s Atlas 14 claim come from? I have talked to three people who were in the meeting. Not one could tell me with certainty. They all expressed reservations and doubts about it.

I have also reached out to Scarborough several times to understand their position, but they have yet to return phone calls or emails.

So, I’m going to remain skeptical until I see proof of their claim and FEMA’s new Atlas 14 maps. FEMA may release them in 2026. But the proposed maps will then go through public comment and revision cycles. That could mean they won’t become official for at least another three years.

Make This An Election Issue

In my opinion, the best use for this property would be to turn it into a state park. That would help protect areas both up and downstream. With an election coming up next year, our representatives will have their ears to the ground. The time to start a letter-writing campaign is now. Contact all candidates.

Turn this into an election issue.

Make sure we elect someone who is more interested in protecting public safety than private profits.

Posted by Bob Rehak on 11/4/25

2989 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.

Supposed “Letter of No Objection” to Floodplain Development Lists 3 Pages of Objections

10/31/25 – On 10/29/25, Scarborough Development/San Jacinto Preserve pitched their plans to develop 5,372 acres in Montgomery County and build a bridge across Spring Creek to Harris County.

They told Precinct 3 Commissioner Tom Ramsey and Houston City Council Member Fred Flickinger that they had “letters of no objection” (LONOs) from the Montgomery County Engineer and Harris County Flood Control District. See the red box on the page below.

LONO stands for Letter of No Objection.

The phrasing of the text implies “approval.” However, reading the text of the actual letters suggests that huge concerns remain about the project.

Montgomery County Concerns

The letter from Brian Clark, Montgomery County engineer, dated 7/2/25 or one month before Ryko sold the land to Scarborough Development/San Jacinto Preserve, has no objection to the preliminary information provided but goes on to list three pages of concerns. They start with an underlined phrase in the second paragraph.

“…additional analysis will be required incorporating a definitive land plan.”

Brian Clark, PE, Montgomery County Engineer

Clark goes on to say that the land plan must be approved before any construction for any portion of the development can be approved. In addition, he says that additional analysis and construction plans must address Montgomery County’s following concerns:

  • Significant potential for erosion under homes, roads, utilities and bridge(s)
  • Need for emergency access and rescue planning during floods
  • Potential for increased floodplain levels due to future upstream development, which could place the entire project in the 100-year floodplain. “This creates a high risk of future flood blight, negatively impacting the tax base and endangering future residents,” he said.

Page 2 contains a lengthy list of information still required:

  • Detailed drainage master plan including specific lot, street, and detention pond sizing and locations.
  • Master plan that includes a comprehensive, no-rise, floodplain analysis for the 5-, 10-, 100- and 500-year Atlas 14 peak flows, along with drawings that show proposed grading and the extent of floodplain encroachment.
  • Atlas-14, 500-year water elevations in all models
  • Adequate mitigation for any fill in the 100-year floodplain
  • Develop and implement robust erosion control measures and geotechnical studies to ensure the long-term stability of the development
  • Design bridge and road network to guarantee adequate emergency access during the Atlas-14, 500-year storm
  • Analyze the proposed bridge location and describe how the proposed bridge will accommodate the dynamic (shifting) nature of Spring Creek
  • Emergency access plans must be approved by the county before any plans for sections in the subdivision will be reviewed
  • Submit documents indicating Army Corps approval, including any mitigation the Corps requires
  • Complete environmental due diligence documentation pertaining to Endangered Species Act
  • Approval of bridge plans by Harris County Flood Control District showing no modification to the main stem of Spring Creek will be required before MoCo provides any future letters of no objection.

Pages 2 and 3 contain cautions about:

  • Data and calculations made in the preliminary drainage analysis
  • A conditional letter of map revision (CLOMR) must be approved by FEMA before the county can approve bridge construction plans
  • The limited nature of the LONO itself.

The letter closes with a warning:

“This memorandum does not guarantee that the ‘developable areas’ presented in the report will remain unchanged as more information becomes available.”

Brian Clark, PE, Montgomery County Engineer

That sounds like quite a mountain to climb! Especially since MoCo Precinct 3 Commissioner Rich Wheeler took the Townsen Blvd. Extension off the County’s 2025 Road Bond. Harris County Precinct 3 Commissioner Tom Ramsey, PE, also vehemently opposes a bridge across Spring Creek. And the area upstream from this development is one of the fastest growing in the region…and the country, according to the Census Bureau.

Text of Letters

Here is the entire letter, obtained via a FOIA request.

And here is the entire letter from HCFCD. It expresses many of the same concerns.

Photos Make A More Compelling Case than Engineering Studies

Having spent years now studying how upstream development changes downstream assumptions about flooding, I hope this area does not get developed. Significant public safety concerns exist.

We should never forget what happened to Kingwood and Humble, and the I-69 and UnionPacific Railroad Bridges during Harvey.

Even if Scarborough/San Jacinto Preserve could build a bridge across Spring Creek, it would not form a reliable evacuation route in the event of another Harvey. Why? People coming south could be in floodwaters over their heads once they got off the bridge. See the pictures below.

US59 at West Fork during Harvey
Another view of Harvey at I-69. The Spring Creek bridge would come down in the flood, out of frame to the right. Water at this location reached 22 feet above flood stage.
west fork flood during Harvey
Townsen Road in Humble (center) where it crosses I-69. Photo courtesy of Harris County Flood Control District.
I-69 during Harvey. Photo by Melinda Ray. So much for evacuation routes to the south.
I-69 repairs
It took TXDoT almost a year to repair the I-69 bridge causing massive traffic jams on alternate routes.
UP Rail Bridge Wash Out
Harvey also destroyed the UnionPacific railroad bridge over the West Fork.

Even the I-45 and West Lake Houston Parkway bridges were damaged.

So, in my opinion, there is NO reliable evacuation route to the south. Period. End of story.

For more photos from Harvey, see Dawn of a Disaster.

The developer can save his money on the engineering studies and cut his losses. The only way to salvage anything from this disaster-in-the-making is to donate the land to Texas Parks and Wildlife, take a tax deduction, and trumpet your concern for the environment.

Posted by Bob Rehak on 10/31/25

2985 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.

Developer Buys 5300 Acres of Floodplains, Floodways, Wetlands from Ryko

Update 10/16/25 at 10am – The Planning Department intends to recommend deferring consideration of the general plan discussed below until after the City of Houston District E and Harris County Precinct 3 have have met with the new owner.

10/15/2025 – San Jacinto Preserve and a sister company, Scarborough Houston LLC have purchased approximately 5300 acres of land west of Kingwood from Ryko Development and its sister company, Pacific Indio Properties.

Ryko tried for years to develop the property, most of which is floodplains, floodways and wetlands where the San Jacinto West Fork, Spring Creek, Turkey Creek and Cypress Creek all converge.

Concerns about flooding may have triggered Ryko’s sale after a succession of rapid-fire setbacks:

  • May 2024 floods and the second largest release from Lake Conroe in the history of the SJRA rekindled memories of Harvey’s devastation.
  • A Townsen Blvd. extension through the property was taken off Montgomery County’s 2025 Road Bond at the request of neighboring residents and MoCo Precinct 3 commissioner Ritch Wheeler.
  • The Montgomery County Engineer blasted Ryko’s drainage study
  • Harris County Flood Control did not approve Ryko’s flood-mitigation plans.
  • Harris County Precinct 3 Commissioner Ramsey lined up against a bridge that would connect the area to Humble.

Sale of Property to San Jacinto Preserve, LP, Scarborough Houston LLC

Under public pressure on all sides and faced with the loss of connectivity and critical infrastructure support, Pacific Indio sold the property to San Jacinto Preserve, LP and Scarborough Houston LLC in August of this year. Here is the Special Warranty Deed.

Both buyers have common ownership and management, as with Ryko and Pacific Indio. Companies often try to limit liability by setting up different companies for different projects. That way, if one part of the empire encounters trouble, it won’t bring down other parts.

In this case, the names of two men keep showing up: Ryan Burkhardt and James R. Feagin. Among the many companies under their control:

Scarborough Lane Development appears to be at the top of the food chain and headquarters in Addison, TX, a north Dallas suburb. All the other companies list the same address. So even though company names change, the same people control everything.

Scarborough Lane Development’s website says its “always committed to protecting the environment.” And it brags that it is “capable of handling the most challenging development projects.” We shall see.

Land Virtually Covered by Floodplains, Floodways

This project will test their talent as this map in Ryko’s drainage analysis shows. Only the small, dark gray areas in the red outline are above the 500-year floodplain.

Ryko drainage impact study illustration showing outline and floodplains.
Ryko’s drainage impact analysis showed this map of floodplains, floodways and streams on their property (outlined in red).

But keep in mind, that the floodplains will soon expand when FEMA releases new maps based on data acquired after Hurricane Harvey. The floodplain mapping above is from 2014. It predates the Memorial Day Flood, Tax Day Flood, Harvey, and the May 2024 flood.

On Houston Planning Commission Agenda for 10/16/25

San Jacinto Preserve’s (SJP) general plan is on the Houston Planning Commission’s consent agenda for Thursday, 10/16/25. See below. Their engineers chose to render the floodplains in barely distinguishable shades of gray this time.

Lisa Clark, who Chairs the Houston Planning Commission, also represents the San Jacinto Preserve.

Both Harris County Precinct 3 and City of Houston District E have requested the planning commission to postpone consideration until they have had the opportunity to meet with the developer and learn more about the plans.

Here is the General Plan that SJP submitted to the Planning Commission.

For a full-size, high-resolution PDF, click here.

This is a pretty high-level plan. It shows planned major thoroughfares, easements, pipelines, property boundaries, drill sites, and floodplains/floodways. But it’s not yet a plat that shows the street layouts of neighborhoods or homesites.

However, it does still show a Townsen Blvd. extension bridging across Spring Creek into Humble. That piqued my interest.

I called Mr. Burkhardt in Addison for clarification, but he did not return my phone call to confirm exactly what their plans are. So we shall have to wait and see. They will have challenges, no doubt.

MoCo Residents Successfully Protest Connectivity Plan

Yesterday, Benders Landing Estates (BLE) Property Owners Association (immediately north of the SJP property had a proposal on the Montgomery County Commissioners Court Agenda. SJP wanted to connect their new neighborhoods through a quiet, residential street (Shady Hills Landing Lane) in BLE.

They felt the street was not suited to handling the volume of traffic that a 5000+ acre development would generate. And their plan to block SJP access through the street succeeded.

Commissioners voted to abandon a one-foot-wide portion of Shady Hills Landing Lane in Benders Landing Estates Section 7. The land will vest to adjoining property owners, who can then effectively block SJP residents from exiting any new subdivisions through their property.

Commissioners Court unanimously approved the measure. It was a minor victory and likely will not affect the long-term war. But it showed the will of the community.

Profits Over People?

The San Jacinto Preserve development comes with inherent flood risks. At this point, we need to wait and see what they propose. At a minimum, it will likely include:

  • A new drainage-impact analysis
  • New plats that show the exact location of homes and their density relative to floodplains
  • Street layouts
  • The amount of impervious cover added
  • How much forest is lost
  • Flood-mitigation plans
  • A no-adverse-impact statement from Texas-certified engineers.
  • Environmental/wetlands studies including impacts on water quality in Lake Houston
Wetlands in SJP floodplain

One seasoned hydrologist held out little hope for the safe development of this property. She told me that developing it would be like aiming a firehose at Kingwood. She also suggested that the developer was putting “profits over people” and that the people of Humble and Kingwood should oppose it for their own safety. Check back often as news develops.

Posted by Bob Rehak on 10/15/25

2969 Days since 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.