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.
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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/01/20210101-RJR_4297.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-01-01 22:03:192021-01-02 21:05:18Guess Which Way to Colony Ridge
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.”
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.
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.
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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/10/Screen-Shot-2020-10-16-at-4.52.08-PM.jpg?fit=1200%2C942&ssl=19421200adminadmin2020-10-16 18:26:302020-10-16 18:36:06TCEQ Blasts Colony Ridge, Says Construction Practices Could Adversely Affect Human Health
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.
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
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/07/20200421-RJR_0898.jpg?fit=1200%2C800&ssl=18001200adminadmin2020-07-11 13:38:322020-07-11 14:37:37Details of SJRA Grant Application for Upper River Basin Sedimentation Study
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.
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.
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 Harveywhen 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!
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.
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).
This constant 20% contradicts numerous anecdotal reports from lakeside residents and boaters claiming that Harvey carried vastlymore 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.
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 nowwhere 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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2019/08/USGS.08069500.140334.00065..20170829.20170830..0..pres_.gif.png?fit=580%2C430&ssl=1430580adminadmin2019-08-20 16:14:592019-08-21 11:07:08Recently Obtained Documents Raise Questions about Amount of Sediment in Mouth Bar Due to Harvey
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).
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
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/06/SourceOfWater-e1529593516550.jpg?fit=1300%2C846&ssl=18461300adminadmin2019-04-15 19:52:052019-04-15 20:17:11Caution: SB 2126 Opens Door to Sand Mining in Rivers
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 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.
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
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.
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
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/03/Harvey-SanJac_41.jpg?fit=2000%2C1333&ssl=113332000adminadmin2018-12-17 19:38:252018-12-17 19:38:33How Sand Mines Increased Erosion Potential by 33X During Harvey
Last weekend, I posted about a statewide flood assessment by the Texas Water Development Board (TWDB) that will help shape public policy toward flooding. After reading the report, I became concerned by the lack of a serious discussion about the role of sedimentation in flooding. So I urged readers to send feedback before Wednesday at 5pm – the close of public comment.
If you haven’t had time to read the report yet…
Consider sending an adaptation of the email below.
First, thank you for an excellent report. I support all of your findings, but am concerned about one critical omission: sedimentation.
I live n the Humble/Kingwood/Lake Houston area. Sedimentation was and still is a major contributing factor to flooding here. The Army Corps of Engineers agrees. As a result, as taxpayers, we’re about to spend hundreds of millions of dollars on dredging. It could take a year or more to unclog our river and drainage ditches.
Here’s an example of a sand bar that largely formed during Harvey, blocks the San Jacinto West Fork where it meets Lake Houston. This giant bar elevated flood levels throughout the highly populated Humble/Kingwood corridor where more than 3300 businesses and 16,000 homes were damaged or destroyed.
Sadly, a large part of the sediment we received during Harvey was preventable. It came from sand mines upstream from us on both the East and West Forks of the San Jacinto. While this sand didn’t cause the flood, it exacerbated the flood.
Moving sand mines out of the floodway would be a simple way to reduce sedimentation and flood risk. Many states have minimum setback requirements in their permitting procedures and best practice guides. Texas has no such requirement. Neither does Texas require sand mines to:
Reclaim land when a mine is played out.
Slope banks to reduce erosion and strengthen dikes.
Avoid clearing land until it is ready to mine.
Post performance bonds to cover the cost of damage they cause.
Simply observing common-sense best management practices used in other states and countries could radically reduce the sediment escaping from sand mines during floods.
Additionally, I would point out that some counties (like Montgomery) may unwittingly encourage sand mining by giving miners timber exemptions on their real estate tax that they don’t qualify for.
For instance, one Montgomery County mine on the East Fork pays $288 a year in tax on 218 acres! All because of a timber exemption that hasn’t been valid for more than a decade!
It’s a pattern. In 53 out of 53 Montgomery County sand mine properties the ReduceFlooding.com examined, not one was appraised as a sand mine! More than 90% were appraised as vacant land or ag/timber even though they were not vacant and they had no trees. So, my suggestions are to:
Recognize the contribution of sedimentation to flooding
Document sources of sedimentation
Encourage legislation that reduces sedimentation from the sources we can control.
Thanks.
Sincerely,
(Your Name and contact info)
Posted by Bob Rehak on 10/2/2018
399 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/03/15.NewSandBarAtEntrytoLkHouston.jpg?fit=2000%2C1333&ssl=113332000adminadmin2018-10-02 17:09:022018-10-02 18:30:14Have You Given Feedback Yet to TWDB on State Flood Assessment?
Sand mining best practices throughout the country and the world urge operators to leave vegetation in place until they are ready to mine an area. The reason: to reduce erosion. However, approximately 60 acres of the sand mine below on the East Fork of the San Jacinto where it meets Caney Creek and White Oak Creek was cleared but not mined – just in time for two 500-year floods.
Approximately 65 acres of this mine were cleared before two five-hundred year floods, contributing to downstream sedimentation in the East Fork, even though only about three acres of the area was mined.
The cleared area lies totally in the 100-year flood plain and was inundated. Satellite images of the area downstream from the cleared land show a sudden buildup of sand. While the sand did not all come from the cleared area, one wonders how much sedimentation could have been prevented by following best practices.
The following sequence of images shows the rapid removal of vegetation.
The white outlined area will be totally cleared before Harvey. On April 8, 2014, it was all dense forest.
By March 3, 2016, most of the area was cleared.
By January 23, 2017, just before Harvey, the area was entirely cleared.
Risk from Flooding
This FEMA flood hazard map shows that the entire area lies within with 100-year flood plain (aqua) and adjacent to the floodway (cross-hatched area).
Before and After: Results
This image from 2014 shows the area in question when it was still forested. Note how little sand is in the river downstream from the mine.
Here’s the same view after vegetationwas cleared and the area was inundated by Harvey in 2017. Note all the sediment in the river downstream.
Much of the sand and sediment washed downstream is invisible to satellite photos because it’s under dense forest canopy. This area (downstream the sand mine being discussed) was once wetlands. A boardwalk through those wetlands had to be excavated from several feet of sand after Harvey.
Here’s what part of the same trail looked like before it was excavated. Approximately 30 acres of the park were blanketed with dunes up to 10 feet tall after Harvey. Every trail in the park required repairs. Total cost: approximately $200,000 to Kingwood residents.
A bird’s nest that was ten feet up in a tree is now knee high. Many of the trees along the Eagle Point trail in East End Park are buried under so much sand that they are dying.
An Ounce of Prevention
It’s impossible to tell how much of the sand above resulted from the removal of vegetation? Previous posts showed how the mines stockpile also eroded. The river itself contributed sediment. However, if the mine were not in the flood plain and if the miners had not removed so much vegetation so far in advance of mining, we wouldn’t be having this discussion.
So why do miners favor the floodplains and floodways? Why to they remove vegetation years before it will be mined? Is it all about the relentless pursuit of efficiency at the expense of safety?
Tomorrow, we will look at economics, taxation and how some well-intentioned laws passed in the late seventies to protect family farms helped fuel a boom in sand mining.
Posted September 24, 2018
391 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/09/Harvey-SanJac_374.jpg?fit=2000%2C1333&ssl=113332000adminadmin2018-09-24 02:26:442018-09-24 07:46:37Sand Mining Best Management Practices: Vegetation
This morning, I received a press release announcing that the Texas Commission on Environmental Quality (TCEQ) had approved the joint decision by the City of Houston and the San Jacinto River Authority to temporarily lower the level of Lake Conroe during the peak of hurricane season. The lake will be lowered by two feet from 201 mean feet about sea level (msl) to 199 msl between mid-August and the end of September. This will provide buffer against flooding while the Army Corps of Engineers removes excess sediment from the West Fork deposited by Hurricane Harvey that is exacerbating flooding. Because this has legal implications and the Lake Conroe Association fought the lowering, I’m reprinting the entire text of the press release below…with special thanks to Houston City Council Member Dave Martin, Mayor Sylvester Turner, and SJRA Board Members Kaaren Cambio and Mark Micheletti who lobbied long and hard for this. Also to all the Lake Houston and Lake Conroe residents who made the trek to testify about this issue to the SJRA board.
Text of Press Release
CITY AND SJRA RECEIVE APPROVAL TO MOVE FORWARD WITH TEMPORARY FLOOD MITIGATION PROPOSAL FOR LAKE HOUSTON AND LAKE CONROE
Texas Commission on Environmental Quality will use “enforcement discretion” if flood mitigation releases for Lake Houston and Lake Conroe exceed annual water rights
HOUSTON, TEXAS – Hurricane Harvey deposited tremendous amounts of silt in the West Fork of the San Jacinto River. The silt physically changed the river’s ability to safely pass flows during storms and created the need for a significant dredging project to restore the river’s capacity. As a temporary flood mitigation solution, the City of Houston and the San Jacinto River Authority (SJRA) proposed a temporary, joint reservoir operations strategy for Lake Houston and Lake Conroe. The temporary flood mitigation would be in place for up to two years or until the dredging project is completed.
The proposed strategy involves the pre-release of water from Lake Houston immediately prior to certain storms and the seasonal lowering of Lake Conroe’s water level during the Spring and Fall.
A significant hurdle to final consideration of the proposed temporary strategy was a decision by the Texas Commission on Environmental Quality (TCEQ) on how releases of water from the two reservoirs would be “accounted for” by the state. TCEQ issues permits that limit how much water can be diverted each year from water supply reservoirs like Lake Houston and Lake Conroe.
The proposal from Houston and SJRA highlights the difficulty of balancing the state’s long-term need for reliable water supplies with the short-term goal of protecting public health and safety while emergency measures are implemented to reduce flood risks.
In a letter to the City of Houston and SJRA on Friday, June 15, 2018, the TCEQ expressed its intent to use enforcement discretion to allow the two agencies to move forward with finalizing their temporary flood mitigation strategy.
The letter states that “if flood mitigation releases . . . result in an exceedance of the annual permitted amounts for diversion or release by SJRA of the City of Houston, the TCEQ Executive Director will exercise enforcement discretion with respect to such exceedance.” The TCEQ’s decision acknowledges the importance of accounting for all diversions from the state’s water supply reservoirs, but it also recognizes the emergency nature of the flood mitigation work being conducted in the San Jacinto River.
The City of Houston and SJRA express their sincere appreciation to the leadership and staff at the TCEQ for their thoughtful consideration of the unique flood challenges that our region is facing. We look forward to finalizing the details of our proposed joint reservoir operations strategy. Additional details on the project including a timeline will be provided as they become available.
ABOUT HOUSTON PUBLIC WORKS
Houston Public Works (www.HoustonPublicWorks.org) is responsible for streets and drainage, production and distribution of water, collection and treatment of wastewater, and permitting and regulation of public and private construction covering a 627-square mile service area. Houston Public Works is accredited by the American Public Works Association. Facebook & Twitter:@HoustonPWE
ABOUT SAN JACINTO RIVER AUTHORITY
Created by the Texas Legislature in 1937, the San Jacinto River Authority is a government agency whose mission is to develop, conserve, and protect the water resources of the San Jacinto River basin. Covering all or part of seven counties, the organization’s jurisdiction includes the entire San Jacinto River watershed, excluding Harris County. SJRA is one of two dozen river authorities in Texas, and like other river authorities, its primary purpose is to implement long-term, regional projects related to water management and development. For more information, visit www.sjra.net.
00adminadmin2018-06-17 10:16:372020-01-17 10:05:27TCEQ Approves SJRA and City Plan to Temporarily Lower Lake Conroe
