Tag Archive for: sedimentation

SJRA Seeks Public Input on Sediment Trap Proposal

The San Jacinto River Authority (SJRA) recently completed a 246-page conceptual design study, in partnership with the Harris County Flood Control District, that explored the feasibility of implementing sediment trapping facilities (“sand traps”). The purpose: to remove sediment from the West or East Fork of the San Jacinto River. The results and findings of this study have been documented in an engineering report entitled “San Jacinto River and Tributaries Sediment Removal and Sand Trap Development.” 

Prior to proceeding to preliminary engineering design and any subsequent project phases, SJRA is seeking public input on the proposed project alternatives detailed in the report. The full report, as well as a brief summary document, are located on SJRA’s Flood Management Division website. 

How to Provide Input or Ask Questions

Please submit input and questions via email to floodmanagementdivision@sjra.net. 

Deadline: No later than April 29, 2022

Caution: The full study is dated 1/7/22. But the “brief summary” is dated 3/9/22. Make sure you at least read the executive study of the full report as well as the brief summary. There are important differences.

Overview/Purpose

SJRA says the purpose of the sediment trap study was to assess the feasibility of implementing a pilot project to trap and remove sediment from the West OR East Fork of the San Jacinto. The study only assessed locations where one or more Aggregate Production Operations (APOs) could partner with the the SJRA. They restricted the study this way to reduce costs; the SJRA does not have a source of funding to clean out sand traps and would rely on sand miners.

Initial Concerns

The decisions to:

  • Define the study objective as sediment reduction, not damage reduction and…
  • Only consider locations near sand mines…

…give me mixed emotions about this project.

Pros

On one hand, I look at this and say, “It’s a pilot project. Try it and see if there’s a benefit.” Sediment IS a problem and they believe they can remove up to 100% of the annual sediment load (from the West Fork).

Cons

On the other hand, the study authors, Freese & Nichols (F&N) claimed (in the San Jacinto River Basin Master Drainage Study) that of all the sediment coming into Lake Houston, two thirds comes from Spring and Cypress Creeks while only 13% comes from the West Fork upstream of US59.

Perhaps that’s because they’re using model inputs from a sediment gage at I-45 located 8.5 miles upstream from most of the large West Fork sand mines (page 34, paragraph 3 of full study).

Also, in their discussion of downstream sedimentation mitigation (page 51, paragraph 3 of full study), F&N says that their evaluation was confined to areas where natural processes rather than breeches of sand mine ponds likely contributed to sediment deposition. To see how limiting that is, see the photos of sand mine breeches and their results in this post.

West Fork Mouth Bar
The “Mouth Bar,” a giant sand bar that blocked the West Fork of the San Jacinto, backing the river up into Kingwood and Humble. Thousands of homes and businesses flooded behind this blockage. The above-water portion has since been removed, but most of the underwater portion remains.

In the entire 246-page F&N study and the three-page summary, the word “damage” occurs only once…in relation to erosion damage, NOT flood damage.

It appears that F&N did not even look at creating sand traps where they were most needed, in the headwaters of Lake Houston, because of cost and logistical considerations. Yet the Army Corps, City of Houston, and State of Texas are spending $200 million to dredge that area. One wonders whether SJRA should have looked harder for partners to clean out the traps.

Finally, if sediment traps only work financially near sand mines, the “solution” will not work on other tributaries that F&N alleges contribute 5X more sediment than the West Fork. They just don’t have the sand mines that the West Fork has.

Nature of Proposed Solution

Five years after Harvey, we have a conceptual design and a recommended location: rock-lined channels cut through one or two point bars at the West Fork Hallett mine.

Page 8 of the F&N study shows this schematic of the recommended solution.

The shot below shows the same area in real life. To put the magnitude of the proposed solution into perspective, the solution would cover a little more than an acre. But sand mines like Hallett cover 20 square miles on the banks of the West Fork between US59 and I-45.

2021 photo of sand bar outsde Hallett mine that would have a narrow channel cut through it to trap sand.

My Biggest Fears

My biggest fears with the proposed pilot study are that it:

  1. Asks people to chose from a limited menu.
  2. Could divert attention from better solutions that would reduce flood risk faster in the headwaters of Lake Houston.
  3. Might make the public think the problem is solved.
  4. Could open the door to river mining and further destabilize the riverine environment.
  5. Is not a transferrable solution.

For a pilot study, that last point is troubling.

Also, F&N worries that removing too much sediment from the West Fork could create a “hungry-water” effect that increases erosion downstream. But they have no way of directly measuring how much sediment the West Fork transports. Or what percentage they would remove. That’s because they’re relying on a sediment gage upstream from the sand mines. This introduces an element of risk in the pilot study.

Recommendations Should Be Based on a Holistic Examination of Alternatives

Note lack of vegetation on this steep-sided, eroding bank of Hallett mine on West Fork in foreground.

Before moving forward with the pilot study, I suggest a more holistic examination of additional alternatives that might have a greater impact on reducing flood damage, not just sedimentation. Examples include, but are not limited to:

More on the sand trap proposal in coming days. In the meantime, please review the SJRA’s sediment trap proposal and forward your comments to the SJRA. I will also print thoughtful letters, both pro and con, from responsible parties. Send them to: https://reduceflooding.com/contact-us/.

Posted by Bob Rehak on March 27, 2022

1671 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.

How Soon We Forget!

How soon we forget. Hurricane Harvey was just 4.5 years ago. Since then I have documented dozens, if not hundreds of questionable practices that erode margins of flood safety.

It Didn’t Have to Be That Bad

Harvey was the largest rainfall event in the history of North America. However, with better regulations and construction practices, it didn’t have to be as destructive as it was.

  • Lax regulations;
  • Willful blindness;
  • Development and construction practices that pushed the safety envelope;
  • Relentless destruction of forests and wetlands near rivers and streams;
  • And homebuyers who didn’t realize their true flood risk…

…made Harvey’s destruction worse than it otherwise would have been.

No one factor by itself would explain Harvey’s destruction. But put them all together, and it’s like “death of a thousand cuts.”

The sheer volume of material – more than 1,000,000 words on this site – makes it difficult for people to see the big picture sometimes. To put 1,000,000 words into perspective, the average novel contains only about 100,000. So I’m condensing the website into a book that includes the themes below.

No One Wins Arguments with Mother Nature

During an interview with Milan Saunders and his daughter Lori, Milan said, “No one wins arguments with Mother Nature.” How profound! It doesn’t matter how many surveys, studies and engineer stamps you have on your home’s title. If you don’t:

  • Respect the rivers.
  • Give them room to roam.
  • Protect wetlands.
  • Allow plenty of margin for safety…

…you will flood.

Thought courtesy of Milan Saunders, Chairman/CEO of Plains State Bank. That’s his daughter Lori’s house during Harvey.

Understanding the Causes of Flooding

Excess sedimentation is one of them. Sediment pollution is the single most common source of pollution in U.S. waters. Approximately 30% is caused by natural erosion, and the remaining 70% is caused by human activity.

Large islands built up during Harvey blocked both drainage ditches and rivers. Below, you can see a large sand island (top) built up at the confluence of the Kingwood Diversion Ditch where it reaches the San Jacinto West Fork at River Grove Park. This sand bar reached 10-12 feet in height above the waterline and helped back water up into Trailwood, the Barrington and Kingwood Lakes and Kings Forest. Before the Army Corps dredged this island, River Grove flooded five times in six months. It hasn’t flooded since.

The Kingwood Diversion Ditch and West Fork San Jacinto were almost totally blocked by sediment dams deposited during Harvey.

The second photo above was taken a few hundred yards downstream on the West Fork from the first. It shows “Sand Island” – so nicknamed by the Army Corps. It took the Corps months to dredge this island which they say had blocked the West Fork by 90%.

A certain amount of this sedimentation can be explained by natural erosion. But mankind also contributed to the sheer volume by other practices which I will discuss below.

Respect the Rivers

The red polygons in the satellite image below surround 20-square miles of sand mines on the West Fork of the San Jacinto in a 20 mile reach of river between I-45 and I-69. That exposes a mile-wide swath of sediment to erosion during floods and increases the potential for erosion by 33x compared the river’s normal width.

Even without floods, mines sometimes flush their waste into the rivers. The shot below on the top right shows the day the West Fork turned white. The TCEQ found the source of the pollution upstream: a sand mine that had flushed 56 million gallons of sludge into the West Fork (bottom right).

Influence of sand mines of West Fork San Jacinto water quality.

End the War on Wetlands

Wetlands are nature’s detention ponds. During storms, they hold water back so it won’t flood people downstream. But we seem to want to eradicate wetlands. The images below show the Colony Ridge development in Liberty County. Wetlands (right) are being cleared (left) to make way for the world’s largest trailer park. The acceleration of runoff wiped out FM1010 during Harvey. The road still has not been repaired.

Colony Ridge in Liberty County.

Conservation Costs Much Less than Mitigation

Halls Bayou at I-69 near Fiesta. Image on left shows whole subdivisions that that to be bought out before detention ponds on right could be built.

All across Harris County, especially in older areas inside Beltway 8, apartment complexes, homes and businesses are built right next to bayous and channels. This makes it difficult to enlarge streams or build detention ponds when necessary. One study showed that preservation of floodplains is 5X more cost effective than mitigation after homes flood. Yet private developers keep crowding bayous and residents keep demanding public solutions.

Respecting Individuals’ Property Rights While Protecting Others’

In Texas, it sometimes feels that an individual’s right to do what he/she wants with property trumps others’ rights NOT to flood. You may think you’re protected by all those public servants reviewing and approving plans. But what happens when developers and contractors decide to ignore the approved plans? Here’s a prime example: the Laurel Springs RV Resort near Lakewood Cove.

The approved plans said that “Stormwater runoff shall not cross property lines.” So what did the contractors do? They pumped their stormwater over the development’s detention pond wall. When that took too long, they dug a trench through the wall. Then they laid pipes through the wall to permanently empty the sludge into the wetlands of Harris County’s new Edgewater Park.

This apparently violated the developer’s City of Houston permit, the Texas Water Code, TCEQ’s construction permit and the developer’s stormwater pollution prevention plan. Four investigations are currently swirling around this development. The contractor also cut down approximately 50 feet of trees in Edgewater Park along the entire boundary line and received a cease-and-desist letter from the Harris County Attorney. But the damage is done.

Balance Upstream and Downstream Interests

About 10% of all the water coming down the West Fork at the peak of Harvey came from Crystal Creek in Montgomery County. But the wetlands near the headwaters of Crystal Creek are currently under development. And the developer is avoiding building detention ponds with a “beat-the-peak” survey. This loophole allowed by Montgomery County says that if you get your stormwater to the river faster than the peak of a flood arrives, then you’re not adding to the peak of a flood and you don’t have to build detention ponds. So developers conduct timing surveys to reduce costs and maximize salable land.

What happens when upstream areas develop without consideration for the impact on downstream property owners.

Of course, speeding up the flow of water in a flood is the opposite of what you want to do. To reduce flooding, you should hold back as much water as possible.

The slide above shows part of a new development called Mavera at SH242 and FM1314 being built on wetlands near Crystal Creek.

The graph on the right shows what happened on Brays Bayou without suitable detention upstream. Floodwaters peak higher, sooner. Harris County has spent more than $700 million in the last 20 years to remediate flooding problems along Brays.

How much will we need to spend when more areas like Mavera get built upstream on the West Fork?

How Quickly We Forget!

FEMA’s Base-Flood-Elevation Viewer shows that in that same area, developers have already built homes that could go under 1-5 feet of water in a 100-year flood. These homes are actually in a ten-year flood zone. And yet more homes are being built nearby. On even more marginal land!

In recent years, the price of land as a percent of a new home’s cost has risen from a historical average of 25% to approximately 40% today. This puts pressure on developers to seek out cheaper land in floodplains, reduce costs by avoiding detention pond requirements, pave over wetlands, and reduce lot sizes resulting in more impervious cover. All contribute to flooding.

Of course, smart homebuyers would not make such risky investments. But few lack the expertise to gauge flood risk. Educating such homebuyers will be one of the major objectives of the book I hope to write.

Posted by Bob Rehak on 2/23/2022

1639 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.

San Jacinto Master Drainage Plan Uses Gage UPSTREAM from Sand Mines to Estimate West Fork Sedimentation

Appendix F of the San Jacinto River Basin Master Drainage Plan discusses the sediment contribution to Lake Houston of various tributaries. It asserts that Cypress Creek, Spring Creek, and West Fork sub-watersheds are the highest contributors of suspended sediment to Lake Houston, contributing an estimated 38.7 percent, 26.8 percent, and 13.0 percent of the total sediment load, respectively.

However, to measure sediment on the West Fork, the study team used a gage at I-45 – UPSTREAM from virtually all West Fork sand mines. This explains a huge disparity between measured data and visual observations. But the report never even acknowledges the visual observations.

I have previously posted about the 3600-page master plan. In many respects, it is a masterpiece that contains good and valuable information that will help mitigate flooding throughout the watershed. The comments in this post relate ONLY to Appendix F on sedimentation, which in my opinion contains a serious flaw.

Misleading Impressions

The problem with using the gage at I-45: it rules out certain contributions to sedimentation that the report barely acknowledges.

Cypress Creek and Spring Creek combine before merging with the West Fork. Thus, you would expect five times more sediment coming from Spring and Cypress Creeks than the West Fork, based on their findings. Yet almost every time I photograph the confluence of the West Fork and Spring Creek, I see more sediment coming from the West Fork, despite the fact that Lake Conroe blocks sediment coming from the upper part of the watershed. See below.

Confluence of Spring Creek and West Fork San Jacinto. Each shot taken in a different month and from a different angle. But the siltier stream in each case is the West Fork where virtually all the sand mines are.

Location of West Fork Gage Never Fully Specified in Report

The West Fork gage number is listed on page 114 of Appendix F. But the description says only, “W Fk San Jacinto Rv nr Conroe Tx, Gage #08068000.” At another point (page 115), it lists the gage near Lake Conroe. To find the exact location of the gage, one must go outside the report to a USGS site. Then to see where the gage sits relative to West Fork sand mines, one must back up to page 61 of Appendix F. Most readers will just assume, given the scientific nature of the report, that the authors used a gage at a representative location, not one that ruled out sediment from sand mines.

Even a careful reader of the report could conclude that the contribution of sand mines to sedimentation is minor in the grand scheme of things. TACA would welcome such a conclusion.

The report ignored thousands of photos posted on ReduceFlooding.com as well as TCEQ reports citing sand mines for non-compliance.

The implications of measuring sediment upstream from sand mines, overlooking visual evidence, and ignoring official reports calls into question some of the report’s recommendations. For instance, #2 suggests using “existing [emphasis added] stream gage data” … to “inform where higher suspended sediment is originating within each sub-watershed.”

Sorry, you can’t get there from I-45. And if sand mines are an issue, neither can you get there from LIDAR surveys taken every several years, which the report also recommends. Sand mine discharges happen frequently and sporadically, often under the cover of darkness.

Sand Mining Not Seriously Considered as Possible Source of Sedimentation

The report, for the most part, blames sedimentation on new development and stream bank erosion. It does not consider:

Un-permitted river mining and lax enforcement
Intentional pumping over dikes
Pipes buried under dikes
Breaches and pumping into surrounding wetlands that drain into the West Fork
Repeated breaches at the same location
Breaches in abandoned mines
Breaches into drainage channels just a few yards upstream from the West Fork
Intentional breaches. Note the backhoe tracks and sharp edges to the breach in this video.

Sedimentation Report Needs More Gages

You can’t document the volume of such breaches and illegal pumping from a helicopter. However, you can’t overlook such practices either.

What we really need is a sediment gage downstream from the sand mines just before the West Fork joins Spring Creek. A gage at that location would go a long way toward calculating the volume of sediment escaping from sand mines.

Report Also Needs Revision Before Legislative Committees Meet on Sand Mining

The authors also need to amend this report quickly. The amendments should highlight the location of the West Fork gage, the implications of that, and limitations on the use of the data – especially by the legislature.

My biggest fear is that sand miners will attempt to use this report to defeat reasonable legislative reforms of the industry. They have used similar reports in the past to do exactly that. I have personally testified in four House and Senate committee hearings about sand mines only to have TACA trot out figures from the 2000 Brown and Root Study. B&R drew similar conclusions because it used the same West Fork gage at I-45.

To protect the scientific integrity of its report and the validity of its recommendations, the authors need to act quickly. The legislature is considering new sand mining regulations at this instant. Such regulations could protect downstream residents from excess man-made sedimentation, huge dredging costs and potential flooding.

The Master Drainage Plan, including Appendix F on sedimentation, is intended to guide flood mitigation efforts for the next 50 years and help inform the expenditure of potentially billions of dollars during that time. The larger report has many good points. But Appendix F is seriously flawed. I hope the partners – City of Houston, SJRA, Montgomery County, HCFCD and their consultants – fix it before lasting damage is done.

Posted by Bob Rehak on 1/28/2021

1248 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.

House Committee Releases Report on Sand Mining

A House Interim Committee on Aggregate Production Operations (APOs, which include sand mining) just released a 77-page report focusing on the Hill Country and San Jacinto River Basin. The report validates many of the concerns ReduceFlooding.com has raised about sand mining for years.

One of multiple breaches at the Triple PG mine in Porter left open for months until the Attorney General sued the mine.

Purpose: To Balance Priorities While Addressing Concerns

Texas House Speaker Dennis Bonnen created the committee to help balance public protection, regulation and economic growth. Bonnen tasked the Committee with reviewing complaints about APOs and making recommendations to the 87th Texas Legislature. Issues include:

  1. Nuisance issues relating to noise and light
  2. Transportation safety and road repairs
  3. Air quality
  4. Blasting
  5. Reclamation
  6. Distance from adjoining properties
  7. Disruption of groundwater
  8. Water quality
  9. Sedimentation and flooding
  10. Municipal ordinances.

The report begins with a description of the balancing act regulators face. Sand and gravel used in concrete support economic growth. But they also impact surrounding property values, impact the health of neighbors, and lower quality of life when they cut corners and operate outside of industry best practices to lower production costs.

A number of bills in the last legislative session sought to resolve these conflicts and many, such as “best practices” will be reintroduced during the session which started this month. Pages 7-10 describe the legislation attempted in the last session.

Below, I summarize each issue listed above in order.

Noise Pollution

The main sources of noise from APOs come from the machinery used to move earth, process raw material and move product. Blasting is also a major consideration in the Hill Country.

The U.S. Mining Health and Safety Administration (MSHA) characterizes noise and one of the most pervasive health hazards in mining. Prolonged exposure to hazardous sound levels over a period of years can cause permanent, irreversible damage to hearing. Hearing loss may occur rapidly under prolonged exposure to high sound levels, or gradually when levels are lower and exposures less frequent.

Ways to reduce noise from moving equipment include use of strobes, alarms, camera systems and motion sensors that can trigger backup beepers as needed.

To mitigate noise from processing equipment, the report suggests chute liners and screens made of rubber or urethane to dampen the sound of the rock hitting the sides of the conveyors. Acoustical enclosures such as walls, berms and natural vegetation can also help protect neighbors.

APOs should monitor the noise exposure at their property line, keeping the noise level at their property line below 65 dB if the property line is within 880 yards of a residential area, school, or house of worship, and 70 dB if not.

Report Recommendation

Light Pollution

APOs create light pollution when the dust they generate scatters light and creates haze. Those that operate at night may require light for safety that keeps neighbors up.

APOs should be held to IDA and IES standards for outdoor industrial lighting, and fined when they don’t.

Report Recommendation

These standards provide operator safety yet shield neighbors from the most annoying effects of light pollution.

Transportation

The high volume of heavy trucks used to move product creates traffic safety issues near APOs and damages roads. TxDOT allows APOs to build 90-degree driveways. These are less expensive, but more dangerous than acceleration and deceleration lanes which provide massive safety benefits.

Dust and small rocks coming off of trucks cause windshield damage and obscure vision of nearby drivers. Placement of roadway bumps leading up to acceleration lanes would help shake off the dust and smaller rocks from the trucks before they make their way onto the highway.

Studies have also shown that the level of damage to the integrity of roads by heavy commercial vehicles far outpaces the funding they contribute through gas taxes. Such vehicles pay $.03 per mile, but cost $.26 per mile.

Recommendations:

  • Change TxDOT protocols to allow for an agreed upon change to a driveway should traffic conditions change.
  • Require that new APOs have enough right of way purchased to construct acceleration or decelerations lanes.
  • Commission a study to establish a Pricing Model for Pavement

Air Quality

Suffice it to say that the health risks of breathing APO dust are voluminous.

Short-term exposure can result in coughing, shortness of breath, tightness in the chest and irritation of the eyes.

Long-term exposure can result in reduced lung function, and respiratory diseases such as asthma, chronic obstructive pulmonary disease (COPD), diabetes, emphysema, impairment of brain development, low birth weight, lung cancer, stroke, aggravation of existing lung disease, and death.

OSHA, MSHA and other agencies responsible for worker health continue to reduce allowable exposure levels for labor; these same reduced exposure levels should be applied to the general population as well, says the report.

Testimony from those living near APOs who have been affected by the decline in air quality demonstrates that regular regional air-quality monitoring is insufficient. So, TCEQ does not know what the actual, real-time particulate concentrations are in the air near APOs.

Recommendations:
  • Require APOs to set up onsite monitoring.
  • Commission a study to determine cumulative effects of adjacent mines, each outputting a compliant level.
  • Modify the TCEQ permitting process to include county commissioners, municipal authorities and others.

Blasting

This is a bigger problem in the Hill County than Houston. So I will skip it here.

Reclamation

APO’s can suddenly cease operation for a number of reasons: bankruptcy, depleted assets, decline in demand, etc. While sites can never be returned to their original condition, they CAN be restored for safe, alternative uses.

At a minimum, this means removing hazardous materials and industrial equipment, and sloping walls to avoid leaving dangerous collapses.

Recommendations:
  • Require APO to file a reclamation/restoration plan.
  • Require operators to post a Surety Bond to cover all reclamation costs in the event the operator fails to reclaim disturbed lands.
  • Address all potential future safety and environmental problems (fugitive dust, erosion, etc.) in reclamation plans.

Distance from Adjoining Property

Current regulations depend on the type of facility and the type of equipment in use. This makes regulations complex and difficult to interpret.

Recommendations:
  • Revise permits to define setbacks by the distance from the APO property line rather than the specific piece of equipment.
  • Require a setback of 880 yards for concrete batch plants.
  • Establish setback rules for all APOs that treat platted subdivisions as residential areas.

Groundwater Disruption

The committee found inconsistent groundwater conservation rules around the state. Many counties did not even have Groundwater Conservation Districts, or if they did, they could not assess the cumulative regional impact of APOs on water supply. Historic APO water use data is not readily available to the public.

Recommendations:
  • The Texas Water Development Board should complete an in-depth assessment of APO water use.
  • Study future water supply, especially for the Houston area, where sedimentation threatens Lake Houston.
  • Require APOs to recirculate groundwater to conserve groundwater resources.

Water Quality

The committee found that TCEQ regulations for APOs are less rigorous than for other types of surface mining enforced by the Railroad Commission.

APOs construct ponds based on their preferred ‘best management practice,’ often without rigorous engineering or regulatory inspection. Testimony from neighbors indicated sediment-laden discharge damaged property. TCEQ found that nearly half (42%) of APO enforcement actions (not related to registration) were due to noncompliance with water-quality rules.

Groundwater pollution by APOs is also a legitimate concern.

Recommendations:
  • Require Texas APOs to comply with requirements for Texas coal and uranium mines.
  • Improve rules and regulatory processes to provide a higher level of protection from pollution by APOs.
  • Provide more robust and frequent groundwater inspections.
  • Perform dye-trace studies to determine groundwater flow-paths in areas close to major water wells.

Sedimentation and Flooding

The committee found sand mining along the San Jacinto River to be one of the contributors of excess sedimentation. It also aggravated flooding issues in Montgomery and Harris Counties during and after Hurricane Harvey.

Also, “The result of partitioning large areas of the floodway from rising floodwaters by levees and dikes can result in increased flooding of adjacent areas. Flood-induced breaches in levees can also add to the problems of flooding and sedimentation downstream.”

Unfortunately, breaches and unauthorized discharges are sometimes left unreported and unrepaired unless citizens file reports to the TCEQ. Even when violations have been documented by the TCEQ, fines have been minimal, averaging ~$800/violation from 2013-2017. Worse, the TCEQ inspects mines only once every two years for the first six years, and then once every three years thereafter.

The committee also found that in-river mining has continued along the West Fork of the San Jacinto even though no permits have been granted by TPWD. TPWD enforcement appears to be lax. “Thus, it is likely regulations will have little or no effect on in-river mining.”

Recommendations:

Municipal Ordinances

The report found that municipalities (as opposed to counties) already have the power to require minimum buffers in Public Health and Safety requirements and nuisance abatement ordinances. The committee specifically cited the City of Houston. But much mining remains outside of municipalities. So it recommended granting authority to counties to establish setbacks between incompatible land uses and to regulate water wells to avoid possible groundwater contamination.

Lack of Industry Cooperation

This report began by acknowledging the need for balance. However, it ended by complaining about the lack of industry cooperation.

For instance, TACA claimed that pushing facilities father from where products are needed will “add a tremendous amount of cost.” When the committee tried to investigate such economic claims, TACA refused to document them. The committee then reached out to trade groups in other states to substantiate TACA’s claims. However, all those groups refused to respond or simply ignored the requests.

That led to one final recommendation. Should concerns about the potential economic consequences become substantiated by reputable data, the legislature should institute a “Best Practices Compliance Incentive Program.”

It would require TCEQ to certify that all APOs trying to do business with the state comply with industry best practices.

To read the entire report, click here.

Posted by Bob Rehak on 1/26/2021

1246 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.

Guess Which Way to Colony Ridge

This is the confluence of Caney Creek (left) and the San Jacinto East Fork (right) one day after a New Year’s Eve storm dumped two inches of rain on the area, including Plum Grove and Colony Ridge. The rain turned Colony Ridge, to the right, into a river of mud again.

Looking north at the confluence of Caney Creek and the San Jacinto East Fork (right). The sediment coming from Colony Ridge is a man-made disaster in the making. Photo taken 1/1/2021.

Where the Pollution Came From

Picture courtesy of Michael Shrader, Plum Grove Resident, of Maple Branch near his home on 12/31/2020 as rains ended. Colony Ridge drainage ditch in Camino Real subdivision enters into Maple Branch and then into East Fork.
Colony Ridge Drainage Ditch. Photo taken 1/1/2021. Note lack of sediment controls such as grass, backslope interceptor swales, and silt fences. TCEQ has previously cited the development for piling dirt next to ditches like this and for lack of sediment controls, but has done nothing about it.
See caption above.
Likewise.
And note how the piles of dirt on the left have almost completely eroded away. Photo 1/1/2021.

How Long?

TCEQ continues to be a toothless tiger. Liberty County Commissioners Court sees no problem and refuses to look at the evidence. The developer saves the money. Downstream residents continue to pay the price. Business as usual.

Posted by Bob Rehak on 1/2/2021 with thanks to Michael Schrader

1222 Days since Hurricane Harvey and 471 since Imelda

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

TCEQ Blasts Colony Ridge, Says Construction Practices Could Adversely Affect Human Health

A seven-month-long TCEQ investigation of Colony Ridge construction practices resulted in a 184-page report that confirmed allegations of erosion and silt flowing uncontrolled into ditches and streams. The investigation resulted in a “notice of enforcement.”

TCEQ Alleges Permit Violations Affecting Human Health

TCEQ found the Colony Ridge developer in violation of its Construction General Permit for failure to install even minimum controls such as silt fences and vegetative buffer strips.

As a result, the report says the developer failed to prevent discharges that “contribute to a violation of water quality standards” and that have “a reasonable likelihood of adversely affecting human health or the environment.”

Investigators found unstabilized and unprotected drainage channels connecting 3,678.69 acres of disturbed land to unprotected streams and creeks. Sediment now almost completely fills some of those streams. They lead to Luce Bayou and and the East Fork San Jacinto River, which empty into Lake Houston, the source of drinking water for 2 million people.

Lack of Construction Best Management Practices

Colony Ridge’s Construction General Permit does not authorize discharges into Texas surface waters. Yet investigators found:

  • Drainage ditches with unstabilized soil on their sides
  • A drainage ditch with completely destabilized sides
  • Sediment deposition in multiple creeks
  • One creek channel almost completely filled by sediment
  • Culverts blocked with sediment
  • A washed out road
  • Water samples with elevated levels of dissolved and suspended solids as high as 1370 milligrams/liter (suspended) and 6360 (solid)…
  • ...All tied to inadequate or non-existent best management practices

See photos below.

Self-Reports in Stark Contrast to TCEQ Report

In contrast, the construction superintendent’s own inspection checklists (pages 51-78) rated virtually all erosion-prevention measures that the company did employ as “acceptable.” However, he also indicated that the company did not use most common protective measures, such as vegetation, sod, silt fences and detention basins; claiming they were “not applicable.” His report on 2/19/20 contained a note indicating the construction site “Looks good.” His last weekly report before the complaint that triggered the investigation found no “action items.”

Get the Picture

Pages 139 to 159 of the report (Attachment 13) and pages 167-171 (attachment 17) show photographs of almost five dozen violations that contradict the construction manager’s reports.

Below is a sampling of ten photos from the report. The TCEQ investigator took them all on 6/16/2020. He also provided the captions. Page numbers refer to the full TCEQ report.

Downstream view of Rocky Branch Creek. Washed out road in background. Photo 2 out of 57. Page 141.
Destabilized banks along Long Branch Creek and sediment deposition in creek channel. Note: the creek channel almost completely filled in by sediment. Photo 17 of 57. Page 146.
Unstabilized drainage channels in Section 7 that are tied into Long Branch Creek. Photo 20 of 57. Page 147.
Area surrounding Long Branch Creek destabilized with no BMPs installed around the creek. Note unstabilized sediment piles next to the creek. Photo 30 of 57, Page 151.
Area surrounding Long Branch Creek destabilized with no BMPs installed around the creek. Note unstabilized sediment piles next to the creek. Photo 32 of 57, Page 151.
Sediment and debris in cement culvert that allows Long Branch Creek to flow underneath Section 5 entrance road. Photo 40 of 57. Page 154.
Sediment and debris in cement culvert that allows Long Branch Creek to flow underneath Section 5 entrance road. Photo 41 of 57. Page 154.
Inadequate BMPs in drainage ditch that leads to Long Branch Creek. Note: Undercut silt fence. Photo 44 of 57, page 155.
Sediment deposition in unnamed creek channel right before Long Branch Creek. Note sediment line on cree. Sediment line is demarcated by pocket knife in red circle. Photo 48 of 57. Page 156.
Sediment in a drainage ditch that is tied into an unnamed creek. Note over-capacitated silt fence. Photo 53 of 57. Page 158.

Personal Observations Corroborate Report

Based on personal observations, I don’t think the investigator exaggerated. On the contrary, he may not have captured the full scope the hazards. Some can only be seen from the air. As luck would have it, I flew a helicopter over Colony Ridge on the same day the investigator captured his photos. Here are two from the air and one from the ground.

Washed out ditches abounded.
The developer was clearing more land before previously developed areas could be stabilized.
Silt fence being propped up to allow raw sewage to flow underneath it into Luce Bayou, which empties into Lake Houston.

Other Strangeness

Colony Ridge hired Merit Professional Services in Flower Mound, a Dallas/Fort Worth suburb. Merit obtains stormwater pollution prevention permits and also provides stormwater inspection services. However, according to the complainant in this case, Merit claimed they only provided the permit, but not inspection services. Lack of local oversight may have been a large part of the problem.

Page 182 of the TCEQ report contains an August 12, 2020, memo from Landplan Engineering to the investigator. It states that, “Going forward, Colony has switched to Double Oak since they are headquartered in the Houston Area.” Double Oak provides the same services and then some. Their website shows they offer construction, erosion control and stormwater management.

Ironically, Double Oak Construction is a defendant in the Elm Grove lawsuits against Perry Homes and its contractors on the Woodridge Village project in Montgomery County. That case involves many of the same issues involved in both the TCEQ report and the City of Plum Grove’s lawsuit against the developer of Colony Ridge. The report does not mention exactly when Double Oak started working for Colony Ridge.

For the full TCEQ report, click here. Caution: large download, 28 megs, 184 pages.

Posted by Bob Rehak on 10/16/2020

1144 Days after Hurricane Harvey and 393 After Imelda

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

Details of SJRA Grant Application for Upper River Basin Sedimentation Study

SJRA has applied for a $375,000 grant from the Texas Water Development Board’s (TWDB) Flood Infrastructure Fund to study sedimentation in a six county area:

  • Liberty
  • Waller
  • Grimes
  • San Jacinto
  • Harris
  • Montgomery

The City’s of Conroe and Houston also support the effort.

Sedimentation Known to Limit Floodway Conveyance

Sedimentation in the Upper San Jacinto River Basin says the SJRA, “…is known to impact floodway conveyance capacity.”

SJRA Grant Application

In order to create a plan for implementing potential sediment solutions, this study will develop “sediment budgets” by evaluating the input, output, and storage of sediment for the entire basin, as well as for sub-watersheds within the basin.

Identifying Largest Problem Areas

This process will identify which sub-watersheds in the basin:

  • Produce the most sediment
  • Store the most sediment.

With this information, the SJRA says it can prioritize locations for improvements, mitigate loss of floodway conveyance, and develop best management practices. In regard to the latter, changes of regulations could be considered.

Much Has Changed Since Last Study

KBR conducted the last study on this issue in 1998. Since then, we’ve seen exponential growth of sand mining and development in this watershed. Both have the capacity to change conclusions from the KBR study. So a new study is highly warranted.

Confluence of Spring Creek and West Fork. TCEQ alleges that Liberty Mines discharged 56 million gallons of white waste water into the West Fork.

What’s Included in Study?

Specific tasks anticipated to be included in the scope of work include, but are not necessarily limited to:

  • Upper San Jacinto River Basin watershed characterization
  • Inventory of available existing data
  • Annual sediment output determination
  • Annual sediment storage determination
  • Sediment transport modeling
  • Individual sediment source or storage locations determination
  • Individual site investigations
  • Key stakeholder and permitting agency coordination
  • Development of conceptual solutions and overall implementation strategy
  • Development of Upper San Jacinto River Basin sediment management plan

If approved, the grant would also include development of cost estimates, preliminary exhibits, and preliminary permitting requirement evaluation.

All identified projects, efforts, and practices will be ranked and included in an implementation plan. Ultimately all information will be compiled into a regional sediment management plan, which can guide mitigation efforts in the future.

Building on Other Recent Efforts

The project will take advantage of data and tools developed recently as part of the San Jacinto Regional Watershed Master Drainage Plan project (SJRWMDP) now nearing completion.

Harris County Flood Control District (HCFCD) leads that project. It utilizes Atlas 14 rainfall. The project will also utilize data developed by the U.S. Army Corps of Engineers (USACE) and Harris County while dredging sediment from the mouth of Lake Houston.

SJRA feels the proposed project will increase benefits gained from state and federal dredging efforts which total approximately $125 million.

Finally, this project will also build on a sand trap development project currently being performed by SJRA in coordination with HCFCD along the West and East Forks of the San Jacinto River. SJRA already submitted a separate abridged application for the next phase of the sand trap development project.

FOUR YEARS to Complete!@#$%

SJRA anticipates that this study will take 4 years to complete! It says the work will only take 18 months or less, but budgeting uncertainties related to COVID-19 will delay the start of the project. With seven partners, the matching funds demanded from each would only about to about $50,000.

However, this delay, says the SJRA, will allow completion of the sand trap preliminary design study so that the SJRA can use that information as input for the sedimentation study.

While this grant application covers only planning and study, it will identify sedimentation solutions, and guide future sedimentation reduction projects, efforts, and practices.

Helping Preserve Water Storage Capacity in Lake Houston

Any sedimentation reduction activity in the Upper San Jacinto River Basin (Lake Houston watershed) should reduce the sediment load entering Lake Houston. That would help preserve volume for water storage. Lake Houston is the main water supply reservoir for approximately 2 million people.

Until SJRA identifies sedimentation solutions, it cannot quantify sedimentation reduction benefits. One of the main goals, however, would be to restore, maintain, or expand storm flow capacity, which could potentially remove structures from the floodplain.

Flood mitigation provided by these future projects/efforts/practices could benefit areas impacted by Hurricane Harvey and Tropical Storm Imelda as well as other major storms such as Hurricanes Ike and Rita, and storms in 1994, 1998, 2015, and 2016.

To review the full application, click here.

To review related applications submitted by SJRA to TWDB, click the Reports page and scroll to the bottom of the SJRA tab.

Four Years Is WAAAAY Too Long

The only thing I don’t like about this study is the three year delay due to COVID. It’s already been three years since Harvey.

Of five recent grants that SJRA applied for, this is the only one that mentions such a delay.

If six counties, the Cities of Conroe and Houston, and the SJRA can’t come up with $50,000 each in matching funds, something’s seriously wrong. It would take more than that to repair ONE flooded home in each of those municipalities and counties. And that makes me wonder whether hidden hands are intentionally delaying this important study.

West Fork Sand Mine cited by TCEQ for unauthorized discharge of 56 million gallons of sediment-laden waste water into West Fork San Jacinto.

If you get in a helicopter and fly around for a day, it’s pretty obvious where the problems are.

Posted by Bob Rehak on 7/11/2020

1047 Days after Hurricane Harvey

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

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

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

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

History of Controversy

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

Corps Demands then Rejects Stockton Protocol

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

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

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

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

Corps Produces Own Analysis

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

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

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

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

Corps Analysis Requires Explanations Never Supplied

Why did the Corps:

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

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

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

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

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

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

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

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

Corps Rules Out Extremes for Extreme Event

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

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

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

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

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

Quantum Leap in Erosion Not Factored In

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Taxpayers Deserve Independent Scientific Review

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

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

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

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

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

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

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

Corps Plans Still Being Kept from Public

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

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

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

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

Others Scrambling to Pick Up the Pieces

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

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

Posted by Bob Rehak on 8/20/2019

721 Days after Hurricane Harvey

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

Caution: SB 2126 Opens Door to Sand Mining in Rivers

Senate Bill (SB) 2126 is well intentioned. However, in my opinion, its present wording could have disastrous unintended consequences.

What Bill Does

SB 2126 would allow a “conservation or reclamation district” to take sand from the West Fork and its tributaries in order to “restore, maintain, or expand the capacity of the river and its tributaries to convey storm flows.” The district would not need a permit and could deposit sand anywhere as long as it’s on private land. What’s a “conservation district?” The San Jacinto River Authority (SJRA), which supports this bill.

Image showing proximity of sand mines to the West Fork of the San Jacinto. If approved, SB2126 would allow miners into the river, too.

How It Started

The SJRA, concerned about sediment in the river, met with miners to see if they could find a public/private solution. The feelings were:

  • The river had too much sand
  • Dredging is very expensive
  • Miners had the expertise and equipment to remove it at no cost to the public.

Great in Theory But…

It’s hard to argue with any of those points and the cost savings are appealing. But this bill ignores the fact that river mining is actually outlawed in many countries. They include England, Germany, France, the Netherlands, and Switzerland. Others strongly regulate river mining including Italy, Portugal, and New Zealand.

Scientific literature abounds with examples of how river mining frequently increases sedimentation downstream. Some causes include:

  • Loss of riparian vegetation that stabilizes river banks
  • Channel incision (lowering or widening of river beds)
  • Lowering of flood plain water tables, which kills more plants on river banks and increases erosion
  • Disturbance (resuspension) of sediment on the river bottom that gets carried downstream
  • A reduction of “bedload” that contributes to head cutting and downstream erosion, as seen in this video.
  • “Sediment starvation” which causes downstream water to pull sediment from banks and beds, often resulting in the loss of private property downstream.
  • Upstream changes in channel geometry that cause beds and banks to erode downstream, for instance, when rivers go from wide (near sand mines) to narrow (downstream).

For more background and explanation, see:

Proponents Say…

The SJRA says that it would provide the necessary oversight to reduce negative environmental impacts of river mining. The bill’s authors cite the need for “continuous dredging” on the West Fork. Further, they say that the bureaucracy for contracting dredging is overly burdensome and that this bill will cut red tape. Here is the analysis of the bill prepared for the Senate’s Water and Rural Affairs Committee.

Opponents Say…

Many environmental groups and scientists see river mining as far more destructive than flood-plain mining. Historically, the shift to flood-plain mining across the U.S. was largely a response to the dangers and excesses of river mining.

Also, the bill makes no mention of any oversight provisions, limitations or public comment. Sponsors even argue that the bill’s purpose is to eliminate the red tape associated with current oversight.

The Bayou Land Conservancy, one of the leading environmental groups in the Lake Houston Area, is sending the following letter to members of the Senate Water and Rural Affairs Committee as well the group’s own members.

Bayou Land Conservancy’s Letter on SB 2126

“On behalf of Bayou Land Conservancy, I urge you to vote NO on SB 2126 when the Water & Rural Affairs 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, primarily 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. 

“SB 2126 would allow operators that are now currently limited to mining away from the river to remove sand and gravel from within the river itself. The river belongs to the citizens of Texas, and the contents of the river do as well. SB 2126 allows operators to remove sand, gravel, and other natural products that belong to the taxpayers of Texas without acquiring a permit or paying a fee. 

“Not only would passage of this bill set a dangerous precedent, only a casual understanding of the science is necessary to know it would make sedimentation and flooding on the San Jacinto River even worse. “

“Because of the sandy soils along the San Jacinto, river banks are especially prone to collapse. Furthermore, while dredging in the still waters of a lake or bay can have benefits, mining within the flowing portion of a stream catastrophically destabilizes the river channel, speeding up erosion. Far from the imagined result of less sediment moving down the river, this dredging within a flowing river leads to much more sediment ending up in Lake Houston.

“This watershed-wide disruption of regional stream dynamics could also potentially create a tremendous liability for mining operators. Worst of all, this action would send much greater volumes of water even faster downstream, threatening communities like Kingwood, Humble and others. 

“Without prior careful and deliberate study by an independent research organization long before any legislation, this practice should not be allowed. There are too many risks to downstream communities. We urge you to keep the life, health, safety, property of these downstream communities in mind and vote NO on SB 2126.”

This Bill Scares Me

The lack of language pertaining to oversight, methods and limitations in SB 2126 scares me. I was at a meeting in Austin last November when the subject of this bill came up.

I asked a simple question: “What would the solution look like?” I got three different answers from the SJRA, legislators and sand miners. Since then, I have met with all three groups again and still have no consistent answer.

Worse, the bill does not encourage them to find one. I can imagine years down the road (when all the good intentions are long forgotten) how the purpose of this bill could be subverted. Imagine a developer like Romerica saying, “I have a flooding problem. Take more sand out of the river and put it on my property. We don’t need any pesky oversight or public comment. Let’s get on with it. Who cares about flood plains when you can just expand the river?”

While I would like to see flood mitigation speeded up, I recognize that removing regulation can sometimes solve one problem only to create others. In addition to increasing sedimentation, this bill could fuel ceaseless and careless development along river banks that contributes to flooding. Despite its good intentions!


Posted by Bob Rehak on 4/15/2019

594 Days since Hurricane Harvey

How Sand Mines Increased Erosion Potential by 33X During Harvey

Yesterday, I posted about how major storms transport the vast majority of the sediment that flushes down rivers. That’s a major reason to have wide buffers between mines and rivers, and to get the mines out of the floodway. One major event, as we have seen, can alter a river and people’s lives forever. However, in Texas we allow sand mining right up to the edge of the river, increasing the potential for erosion.

Scalping 20 Square Miles of Forest Increased Erosion Potential

We all know from science classes that when you remove ground cover, you increase the potential for erosion. That’s exactly what the sand mines upstream from the Humble/Kingwood area have done. They have removed about 20 square miles of ground cover to expose sand. And because virtually all of the mines are in the floodway, they effectively increase the riverbed width during floods by an average of 33X. Here’s the basis for the calculation. 

Exposed Sand in Floodwater is 33X Wider than Natural Riverbed

Between I-45 and I-69 on the West Fork, a distance of 20 miles, we have approximately 20 square miles of sand mines. So we have one square mile of mines per mile.

If you lined all mines up, end to end, you would have a swath exactly one mile wide.

But the river is, on average, only .03 miles wide. Thus, mines widen the effective riverbed width by average of 33X.

By removing all the surface vegetation, miners also increased the potential for erosion during extreme storms, such as Harvey, by 33X. 

To put a mile-wide riverbed in perspective, that’s twice as wide as the muddy Mississippi … in the Delta region. 

Sediment Dams Increase Flood Levels

That helps explain how so much sand piled up virtually overnight during Harvey. The flood was wide enough to inundate the mines. Afterwards, a nearly continuous trail of sand along both shores of the West Fork led directly to the Humble/Kingwood area as the pictures in my gallery show. In many places, this trail was more than 5 feet deep. Here’s what it looked like onshore in River Grove Park.

Note height of sand in River Grove Park relative to parking sign in background.

Plus there was far more sand in the river after the flood than before.  

If the river AND both shores were ALL higher after the storm than before, then it stands to reason that most of that sand had to come from somewhere other the river itself. 

Looking at a satellite image, the barren sand mines dominate the landscape like no other feature in the watershed. The obvious conclusion is that much of the sand came from mines like this …

West Fork Mine Complex one day after the peak of Harvey when floodwaters were already receding. Exposed sand surface increased the potential for erosion.
West Fork Mine Complex day after peak of Harvey when floodwaters were already receding. Exposed sand surface increased potential for erosion relative to river which snakes diagonally through photo. Image courtesy of Google Earth.

… and wound up in places like this.

Sand left behind by Hurricane Harvey on both flanks of the west fork of the San Jacinto River. Looking northeast toward Forest Cove where apartment buildings or townhomes were destroyed. Note sand in treetops in foreground.

Or places like those below, where it formed sediment dams, which the Army Corps says contributed to flooding.

A drainage ditch (center left) that empties the entire western third of Kingwood at River Grove Park was virtually closed off by a sandbar approximately 10 feet high and 1500 feet long. It was deposited during Harvey. An estimated 500+ homes above this point flooded.
A six foot high dune not present before Harvey virtually blocks the West Fork just south of Kingwood Country Club.
A giant sand dune has formed at the mouth of the west fork of the San Jacinto. It is not being addressed by the Army Corps dredging project but should be. Thousands of homes upstream from the blockage flooded during Harvey.

Huge Pre/Post Increases in Deposition Rates Since Sand Mining

In its final report on Hurricane Harvey, Harris County Flood Control District confirms the enormity of the deposition. It says, “Large amounts of debris and heavy sedimentation upwards of 4.0-8.0 ft in some locations have been noted especially along the West Fork of the San Jacinto River.” (See Page 7.)  But how does this compare to the deposition rate before Harvey?

Sedimentation Rate Much Higher than Before Sand Mining 

In 1983, Turner Collie & Braden, an engineering consulting firm, estimated the loss of lake capacity due to sedimentation at 311 acre-feet per year. (See page 9.)

Large-scale sand mining on the West Fork began shortly after that and has grown ever since. On the East Fork, sand mining began in the early 2000s.

The Texas Water Development Board created the difference map below by comparing data collected in 2011 with data collected from March through June of 2018. Remember, three or four of those years were drought years when very little sediment came down river. Virtually all of what you see below happened during the last three years. We can also see from satellite photos  that most of that happened during Harvey.

West Fork Difference Map. Red/orange/yellow/green areas represent decreases in sediment since last survey. Blue, violet and white represent increases.

The map above shows we gained 1.0 to 5.5+ feet of sediment in most of the 3400 acre area between the mouth bar and FM1960. 

Assuming we gained on average about 3 feet per acre, that means the City lost approximately 10,000 acre-feet of storage in this ONE SECTION of the lake in only three years.

Current Rate Estimated 22X Higher

That’s about an 11X increase per year compared to the Turner Collie & Braden study which measured the ENTIRE lake. However, we can also roughly adjust for the difference in lake and sample sizes shown above. Page 9 of the Brown & Root report in 2000 says that the area shown above collects a little less than half (42%) of the sediment flowing into the lake. So we can assume that 11X at least doubles to 22X. (Because there’s more in the bottom portion of the lake than the top.) 

22X is less than 33X, but consistent with earlier observations when you consider that much of the sand was deposited on shores, as you saw in the River Grove photo. 

Caused by Mining or Nature?

Some of this sand also came from urban runoff. And some undoubtedly came from other tributaries, such as Spring and Cypress Creeks, which have fewer mines. Some also came from the East Fork watershed, where there is a huge active sand mine on Caney Creek.  Regardless, 131,000 cfs cut across that statistical mile-wide swath of sand on the West Fork during Harvey. 

Analysis of satellite and aerial photos leads me to believe that the river carried millions of cubic yards of sand and sediment downstream from the mines, including their stockpiles. That sand, I believe, helped to create the blockages shown above, which contributed to flooding throughout the heavily populated Humble and Kingwood areas.

Let’s Get Sand Mines Out of the Floodway

Miners claim that the currents in Harvey were not strong enough to carry sand out of their mines. Several world-leading hydrologists that I have talked to claim the opposite. As one said, “Of course it could.”

That’s why we need to pass legislation moving mines back from the river. We can’t reduce natural sedimentation, but we can reduce man-made sedimentation by putting sand mines out of the reach of rushing floodwaters.

As always, these are my opinions on matters of public policy. They are protected by the First Amendment of the United States Constitution and the Anti-SLAPP statute of the Great State of Texas.

Posted by Bob Rehak on December 17, 2018

475 Days since Hurricane Harvey