Posted on January 15, 2025
The Texas Commission on Environmental Quality has proposed new Best Management Practices (BMPs) for mining in response to a mandate from the 2023 session of the Texas Legislature. However, in my opinion, the recommended BMPs will do little to nothing to help control sediment pollution from mines in the Lake Houston Area.
The BMPs feel like little more than a half-hearted attempt on the part of a reluctant regulator to create the illusion of environmental protection.
You can find the proposed BMPs at this page on the TCEQ website. You may submit comments on them electronically. To be considered, TCEQ must receive your input by 11:59 p.m. on January 24, 2025. Your email should reference “APO BMP List Proposal.”
Please let the TCEQ know what you think even if you disagree with me.
Notable Omissions
The TCEQ’s recommended BMPs do not really address the biggest mining issues we have in the upper San Jacinto watershed.
I urge you to urge TCEQ to develop BMPs that address:
- Discharge of sediment-laden water
- Pit capture (when a river starts flowing through a mine)
- Periodic flooding.
The proposed BMPs do not cover these issues at all.
The final report of a TCEQ investigation into a West Fork pit capture last year didn’t even mention the phrase. Do they not consider it a problem? I sure wish the TCEQ could enlighten us on this issue. I documented seven instances of pit capture in the Lake Houston watershed last year alone. There may have been more; many mines are in remote, difficult-to-access locations.
Sediment Pollution Reduces Water Quality, Increases Flood Risk
All three of the bullet points above add up to a big problem called “sediment pollution.” Dredging costs for the City of Houston and Army Corps approached $200 million dollars as of October 2023. Better BMPs would likely have reduced or delayed that expenditure of public funds.
At an October 2023 town hall meeting in Kingwood, Mayor Pro Tem Dave Martin presented this summary showing dredging costs totaling $186 million.
But those costs paled in comparison to the damages to 13,000 homes and businesses that flooded in the Lake Houston Area behind giant sand bars that formed sediment dams at the mouths of the East and West Forks of the San Jacinto.
Nor do the costs reflect extra water filtration at the City’s Northeast Water Purification plant.
To be fair, nature causes some erosion. The question is whether local mining practices accelerate it.
Photos of Sediment Pollution Related to Discharges, Pit Capture and Flooding
See the pictures below. I will submit these as part of my comments on the draft BMPs. Feel free to submit them as part of yours, too.
too.
Hallett sold the San Jacinto West Fork sand pit below to a real estate developer. Within months, the river captured the pit.
River Speed During Floods High Enough to Stir Up and Carry Even Largest Particles of Sand
Now, let’s discuss the speed of floodwaters and whether it’s sufficient to entrain sand in pits and carry it downstream.
