Proposed List of Best Management Practices for Certain Operational Issues at Aggregate Production Operations

Comment From: Kevin Montes

1/24/25 @ 4:44 PM

RE: APO BMP List Proposal
TCEQ's proposed list of Best Management Practices for Aggregate Production Operations completely ignores mining issues that contribute to flooding in the Houston area.

Most mines on the East and West Forks of the San Jacint...↓

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Comment From: Wendy Turner

1/24/25 @ 4:33 PM

RE: APO BMP List Proposal
TCEQ's proposed list of Best Management Practices for Aggregate Production Operations completely ignores mining issues that contribute to flooding in the Houston area.

Most mines on the East and West Forks of the San Jacint...↓

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Comment From: Fabio Terasaka

1/24/25 @ 4:32 PM

TCEQ's proposed list of Best Management Practices for Aggregate Production Operations completely ignores mining issues that contribute to flooding in the Houston area.

Most mines on the East and West Forks of the San Jacinto were inundated last year...↓

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Comment From: David Fletcher

1/24/25 @ 4:14 PM

To Whom It May Concern,

I David N Fletcher (an affected member) am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate for the proposed Vulcan Quarry. For starters, they do not ad...↓

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Comment From: Michael SPANO

1/24/25 @ 4:08 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices (BMPs) for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption i.e. the quarrie...↓

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Comment From: Mark Zuzanek

1/24/25 @ 3:29 PM

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. They do not address practices to minimize water consumption, noise, and light pollution, as was directed to by the Texas Leg...↓

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Comment From: Dawn Houston

1/24/25 @ 3:02 PM

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollution, as was directed to by...↓

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Comment From: Rich Paces

1/24/25 @ 2:43 PM

Please see the attached letter on behalf of the Kerr County Aggregate Production Operations Community Advisory Council in response to TCEQ's request for comments on their proposed list of Best Management Practices for the Aggregate Production Operati...↓

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Comment From: Terry Duncan

1/24/25 @ 2:32 PM

To the TCEQ,
As a current resident of Round Mountain, and former life-long resident of the Galveston Bay community, I believe that the TCEQ does valuable and effective work. Currently, however, your draft for Best Management Practices for Aggregate ...↓

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Comment From: Mary Grace Kuehne

1/24/25 @ 2:01 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is inadequate to address concerns regarding aggregate operations. For starters, they do not address practices to minimiz...↓

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Comment From: Brad Beneski

1/24/25 @ 1:45 PM

TCEQ,
The proposed Best Management Practices (BMPs) for Aggregate Production Operations are critically flawed. They fail to address key environmental concerns mandated by the Texas Legislature, including water consumption, noise, and light pollution....↓

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Comment From: Leah Cuddeback

1/24/25 @ 1:39 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓tion, as was directed to by the Texas Legislature. The BMPs for the areas they do address — dust and water storage — also warrant serious improvement.

Our region is dealing with a historic drought and long term weather conditions are expected to be increasingly more arid. As heavy industrial APO businesses grow across the Hill Country region (particularly in Comal and Hays County, where I live) we are only increasing our demand for water - and in the case of these operations, extreme water waste.

The BMPs you share should have a focus on water consumption and management - it's ridiculous that they do not currently include such precautions, especially since there are known examples of better water management in APOs that could be shared. Texans for Responsible Aggregate Mining (TRAM) shared numerous examples of better, more specific recommendations which appear to have been ignored - and the below three recommendations regarding water especially should be added to your final draft.

1) Water quality: Vegetation is an inexpensive and effective way to protect soil from erosion and filter contaminants, protecting water quality in nearby streams and aquifers. It also protects air quality by holding dust down and filtering the air. Vegetative controls should consist of native plants appropriate for the Texas ecoregion where the site is located and must not include any noxious or invasive species.
2) Water use: Maximize the use of process wastewater, which cannot be discharged without treatment but can be reused in site operations. Managing fine tailings to reduce the amount of tailings in settling ponds with a tailings thickener system and/or flocculant and thickener are key BMPs that are understood, accepted and utilized by many APOs, These facilities can provide additional recycled water to reduce overall APO water use, water loss and reduce land use.
3) Riparian health and safety: The following is a list of suggested BMPs for riparian areas. Incorporating these practices into your operations will preserve the quality of the land and water and reduce the risk of catastrophic "pit capture" (when a river breaks through the riverbank or constructed levy and merges with the mine pit, as has happened countless times in Texas, due to poor mining practices):
a. Maintain undisturbed setbacks from at least 50 feet from the water's edge and preferably 200 feet.
b. Create a buffer between mining activities and the waterway.
c. Leave large woody debris in the floodplain.
d. Quarry above the water table only.
e. Minimize use of heavy equipment in riparian areas to protect vegetation and reduce soil compaction.

The TCEQ should further develop their list of BMPs, making sure to thoroughly address all of the issues that the Legislature directed them to address. As they currently stand, these are vague management practices, NOT best.

Sincerely,

Leah Cuddeback

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Comment From: Virginia Parker

1/24/25 @ 1:37 PM

To whom it may concern,
I am the Executive Director for the San Marcos River Foundation, and we are seeing more and more permit requests for rock quarries and gravel mines in our watershed. Unfortunately the public meeting process typically has no re...↓

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Comment From: Rachel Hanes

1/24/25 @ 1:35 PM

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Comment From: Jon Tipton

1/24/25 @ 1:28 PM

To: Jess Robinson, Office of Legal Services, TCEQ
Subject: Comments on "APO BMP List Proposal"

As a native Texan and 25-year resident of the Texas Hill Country, I am writing to provide feedback on the proposed Best Management Practices (BMPs) for Ag...↓

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Comment From: THOMAS JONES

1/24/25 @ 1:08 PM

I encourage you and your organization to adopt Best Management Practices that address the issues of minimizing water consumption, noise and light pollution--as the Texas Legislature has requested. We only have one Texas Hill Country. Allowing Aggrega...↓

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Comment From: Nicholas Valdez

1/24/25 @ 12:59 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Jennifer Greenwell

1/24/25 @ 12:29 PM

It's time to stop the destruction of our beautiful land. Suggestions attached.

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Comment From: Laura Hunt

1/24/25 @ 12:20 PM

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Comment From: Martha McHenry

1/24/25 @ 12:07 PM

After reading the submitted BMPs I believe they are deficient in that they do not address the full impact of their operations. Specifically, they do not it address water consumption and management. They do not address the light pollution that such ...↓

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Comment From: brende fuller

1/24/25 @ 11:50 AM

Dear Sirs,
As a resident of the Texas hill country, I am aware of the degradation of the environment. The legislature has directed many practices that are supposed to be helpful in management of our environment. The proposed list by TCEQ doesn't meet...↓

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Comment From: Anonymous Anonymous

1/24/25 @ 11:50 AM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. They do not address practices to minimize water consumption, noise, and light pollution, as was d...↓

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Comment From: Nancy Brady

1/24/25 @ 11:33 AM

January 24, 2025

Texas Commission on Environmental Quality
Jess Robinson, MC 175
Office of Legal Services
P.O. Box 13087, Austin, TX 78711-3087

RE: APO BMP List Proposal

Dear Mr. Robinson,

TCEQ's attempt at creating a usable list of Best Manageme...↓

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Comment From: Cheryl Schneider

1/24/25 @ 11:31 AM

January 24, 2025

Texas Commission on Environmental Quality
Jess Robinson, MC 175
Office of Legal Services
P.O. Box 13087, Austin, TX 78711-3087

RE: APO BMP List Proposal

Dear Mr. Robinson,

TCEQ's attempt at creating a usable list of Best Manageme...↓

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Comment From: MJ Anthes

1/24/25 @ 11:23 AM

To whom it may concern:

I'm concerned that the proposed BMP is grossly inadequate. Furthermore, they don't address directives by the Texas Legislature. The BMPs addressed warrant serious improvement.

TCEQ BMPs should be thoroughly addressed.

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Comment From: Anastasia Petersen

1/24/25 @ 11:23 AM

We want concrete protections! As of right now Quarries leave toxic ponds to leech into the waterways and for cities to clean up once the quarry is done. We need limits on water usage! We can not have our springs and rivers running dry for the sake of...↓

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Comment From: Jennifer Jagger Johnson

1/24/25 @ 11:22 AM

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollution, as was directed to b...↓

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Comment From: Geary Hughes

1/24/25 @ 11:21 AM

Dear TCEQ Commissioners,

The current Best Management Practices for aggregate production operations require significant strengthening to protect Texas communities and natural resources:

1. Mandate continuous air quality monitoring at property bounda...↓

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Comment From: Dana Williams

1/24/25 @ 11:09 AM

To Whom It May Concern,
The proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollution, as was directed...↓

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Comment From: Eva Silverfine Ott

1/24/25 @ 11:04 AM

To Whom It May Concern,
I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollut...↓

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Comment From: Sharron Jay

1/24/25 @ 11:02 AM

To Whom It May Concern,
I Sharron Jay am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and ...↓

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Comment From: Gary HENDRIX

1/24/25 @ 11:01 AM

I have read the proposed list of Best Management Practices for Aggregate Production Operations. I find it rather skimpy and it completely ignores important issues such as noise, water consumption and dark skies best practices. Surely TCEQ can do be...↓

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Comment From: Gail Moncla

1/24/25 @ 11:00 AM

January 24, 2025

Texas Commission on Environmental Quality
Jess Robinson, MC 175
Office of Legal Services
P.O. Box 13087, Austin, TX 78711-3087

RE: APO BMP List Proposal

Dear Mr. Robinson,

TCEQ's attempt at creating a usable list of Best Manageme...↓

No attachments

Comment From: Kris Smale

1/24/25 @ 10:54 AM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

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Comment From: Melissa Gaskill

1/24/25 @ 10:34 AM

I am concerned about the proposed list of Best Management Practices for Aggregate Production Operations. These practices do not address minimizing water consumption, noise, and light pollution, as was directed to by the Texas Legislature. Even BMPs f...↓

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Comment From: Kenneth Welch

1/24/25 @ 10:26 AM

Public roads and streets outside quarry facilities MUST be kept free of aggregate dust and fine materials that create a safety hazard to vehicles traversing the roads. When wet, from rain or water drippings from the exiting trucks, the build up of d...↓

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Comment From: Julie Thomas

1/24/25 @ 10:13 AM

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Comment From: Prudence Guckian

1/24/25 @ 10:08 AM

Please take time to consider more reasonable and useful Best Management Practices for the aggregate production operation industry in Texas. The list you proposed is so vague it is completely ineffectual. It does not meet any standard of quality nor...↓

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Comment From: Jennifer Dewey

1/24/25 @ 10:03 AM

It is time for the BMPs to be made mandatory. The mess these places and the ruination of the land is atrocious. There is nothing to stop these quarries from using vast amounts of water, pollute the air and reduce the amount of noise they produce. I b...↓

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Comment From: Nancy M Dyer

1/24/25 @ 9:24 AM

To Whom It May Concern,

I Nancy Dyer am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and ...↓

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Comment From: James Doyle

1/24/25 @ 8:46 AM

Dear Sirs:

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. Rather than repeat the recommendations made by Texans for Responsible Aggregate Mining (TRAM), I will focus on t...↓hree additional points:

1. Require a comprehensive environmental impact review that addresses surface water, groundwater and dust contamination as well as light and noise. The evaluation should address the cumulative impact of the subject apo's addition to other sources in the area.

2. In RG-500, best management practices stipulate that the minimum quarry-base elevation be set 25 ft above a highest-estimated aquifer elevation at the site based on historical aquifer records. The BMP should be modified to stipulate that the estimate be based on records of the shallow aquifer underlying the proposed quarry site. The Edwards Aquifer Recharge Zone is environmentally sensitive, and in some areas, the shallow aquifer is the Upper Trinity Aquifer. Contaminants introduced in those areas pass from the Trinity Aquifer to the Edwards Aquifer via cross-fault flow. The Edwards and upper Trinity aquifers differ in recharge area and recharge sources; they don't necessarily move in concert. The BMP in RG-500 is illustrated only using data from the Edwards Aquifer and includes the statement, "The TCEQ will accept the water-table elevation measured in December 2007 either on-site or in the nearest off-site well as the elevation from which the 25 ft separation applies." As an example of the problem that creates, in the recently-approved WPAP for the Comal Vulcan Quarry that phrase was accepted as justification for a quarry depth for which data from the underlying Upper Trinity Aquifer clearly show the minimum required standoff has been repeatedly exceeded.

3. BMP should be added for the process of blasting to minimize nitrate contamination of groundwater in limestone aggregate quarries. Quarries are a source of nitrate pollution in groundwater resulting from the use of Ammonium Nitrate fuel oil (ANFO) mixtures (a). Loss of nitrate to groundwater is variable depending on details of the blasting operation (b). Specifically for the Edwards Aquifer, historical water-quality data from the Texas Water Development Board show that nitrate levels began rising in the 1950s coincident with the large-scale introduction of ANFO as a commercial explosive. In the Edwards, nitrate levels have generally reached a level harmful to some freshwater aquatic species. The highest observed levels are clustered near quarries indicating some owners of wells unfavorably situated near quarries may experience degraded water quality (c).

(a) ALBERTS, N., 2016, Tackling nitrate contamination of water in mines: Mining News Digest, August 11, Electronic document, available at https://www.mining.com/web/tackling-nitrate-contamination-ofwater-in-mines/

(b) BROCHU, S., 2010, Assessment of ANFO on the Environment, Technical Investigation 9-01: DRDC Valcartier TM 2009-195; Defence R&D Canada, Valcartier, Canada, 38 p.

(c) DOYLE, J. D., 2024, Quarries as a Source of Nitrate Pollution in Karst Aquifers: Case Study, the Edwards Aquifer, Texas: Environmental & Engineering Geoscience, Vol. XXX, No. 4, November 2024, pp. 173–191.

Sincerely,

James Doyle

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Comment From: Frances Lovett

1/24/25 @ 8:35 AM

Mr. Robinson:
I am a member of the Kerr County APO Advisory Council and a stakeholder involved in establishing the Kerr County Voluntary Guidance Document for Aggregate Production Operations. I am submitting feedback on TCEQ's proposed BMPs for the s...↓tate's Aggregate Production Operations. The following is submitted as a private citizen only and I do not speak for any organization.
Overall, this proposal underestimates the desire and potential for the industry and their neighbors to solve dust and water issues. Health issues are relegated to a "nuisance." Some other problems are not addressed including hours of operation, noise, lighting, and reclamation. All should be necessary components of any industry BMPs because they can be mediated as noted in Kerr County's agreement.
Dust control addressed as a nuisance in the proposal relies on "water sprays, sprinklers, mists". The outcome is airborne aerosols, migration of runoff into groundwater and streams, and threats to local surface and groundwater availability and quality. Air systems, covered screens, conveyor belts and drop points, and building enclosures are the desirable means of dust control. This includes all conveyor belts, not just those "longer than 300 ft." In addition, limitations in water supplies during drought and accepted conservation efforts put this document's use of water for dust control into question. Inclusion of expectations for recycling pond water would be helpful.
Foams, roofing shingles, and wettened tire chips for dust control present questions of environmental contamination. Calcium chloride is an environmentally friendly dust suppressant for bare ground and stockpiles. One gallon used saves three gallons of water. Haul road paving is a significant deterrent to fugitive dust, but is not suggested as a solution. Herbicide guidelines are missing even though many operations use them as a method of weed control.
Failure to address reclamation in the BMP document is worrisome. Citizens understand the need for aggregate materials to support our Texas growth. Any meaningful BMPs should address restoration of the land to its previous condition, supportive of property values, development potential, and wildlife, when site operations cease.
Best Management Practices set forth in this proposal lowers expectations for the APO industry, thus threatens our state's resources. There is a high likelihood that this proposal could be marketed as a superior performance by some APOs, thus undermining the good intentions of our state's operators who are already implementing meaningful BMPs. An example is the mix of international corporations and local independent owners who have implemented and are continuing plans for inclusion of the Kerr County's Voluntary Guidance Document for Aggregate Production Operations i.e. Kerr County Commissioners' Court Order #39892.
Hopefully, the TCEQ will revise this BMP proposal to reflect minimum standards for the industry in the interest of protecting our state's natural resources.
Respectfully,

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Comment From: Richard Stewart

1/24/25 @ 8:16 AM

Our home at the above address was flooded with 4 feet of water from Harvey, we support Texans for Responsible Aggregate Mining and Bob Rehak's input.

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Comment From: Scott Miller

1/24/25 @ 7:55 AM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Travis Simmons

1/24/25 @ 12:04 AM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

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Comment From: Patrick Mullin

1/23/25 @ 11:59 PM

I am concerned that the BMP for Aggregate Production Operations are inadequately specific in detailing any metric for when sediment and erosion control facilities are adequate. They merely indicate that certain control facilities "can" be provided. ...↓

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Comment From: Bekah Woodard

1/23/25 @ 10:50 PM

I do not think these are adequate- they do not address issues that I'm facing in my neighborhood with noise pollution and air quality issues. More needs to be done to protect people who live nearby

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Comment From: Kathy Hasten

1/23/25 @ 10:46 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

I have attached a PDF that shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Susan Davy

1/23/25 @ 10:36 PM

And why should "best practices" such as "Securely storing chemicals, paints, solvents,..." using "Setback Distances and Buffer Zone(s)" and "Perimeter Controls", covering "vehicle cargo with tarpaulin," and being "sure your stockpiles are only as hig...↓

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Comment From: Anne Trapani

1/23/25 @ 10:21 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

I have attached a PDF that shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Shawn Troxell

1/23/25 @ 10:11 PM

I, Shawn Troxell, am deeply concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. They do not address practices to minimize water consumption, noise, and light pollution, as was dire...↓

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Comment From: Wendy Gonzales

1/23/25 @ 10:01 PM

For a more environmentally friendly and conservation-focused approach, the Best Management Practices (BMPs) for Aggregate Production Operations (APOs) can emphasize long-term sustainability, habitat preservation, and community well-being. Here's a pr...↓

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Comment From: Rebecca Drummond

1/23/25 @ 9:43 PM

My home flooded in 2017 and I believe the proposed best management practices do very little to help control sediment pollution from mines in the Lake Houston area. The proposed practices do not address the discharge of sediment laden
Water that leads...↓

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Comment From: Timothy Edward Duda

1/23/25 @ 8:58 PM

I am very concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. They do not address practices to minimize water consumption, noise, and light pollution, as was directed to by the Te...↓

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Comment From: Francisco J Garcia

1/23/25 @ 8:23 PM

Whom It May Concern,

I Francisco J Garcia am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise,...↓

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Comment From: Anne Goj

1/23/25 @ 8:03 PM

RE: APO BMP List Proposal

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that ...↓reduce water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

No attachments

Comment From: Candy Cargill

1/23/25 @ 7:53 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

No attachments

Comment From: Lyann Kramer

1/23/25 @ 7:37 PM

PLEASE PROTECT OUR FORESTS AND OUR RIVERS

RE: APO BMP List Proposal

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated ...↓by the legislature, as well as others that reduce water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Sheri Gray

1/23/25 @ 7:31 PM

In truth I would venture to say that generally speaking, Gillespie County doesn't invite government programs into their management practices because I have seen similar wording written in the county's business operational plan available on the county...↓

No attachments

Comment From: Jerry Forey

1/23/25 @ 7:24 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

No attachments

Comment From: Philip Wickes

1/23/25 @ 7:20 PM

To whom it may concern, I Philip Wickes am concerned that your Best List of Practices for Aggregate Production Operations is inadequate for our Hill Country rivers and streams. It does not address issues of water consumption, noise and light pollutio...↓

No attachments

Comment From: Elizabeth Bowerman

1/23/25 @ 7:09 PM

Attachments:

Comment From: Suzanne Martin

1/23/25 @ 7:08 PM

TCEQ's attempt at creating a usable list of Best Management Practices for the Aggregate Production Operations Industry in Texas is completely inadequate. The BMP list, three years in the making, only weakens TCEQ's effort to protect public health an...↓

Attachments:

Comment From: vaughn eifler

1/23/25 @ 7:04 PM

I am deeply concerned that the proposed list of Best Management Practices (BMPs) for Aggregate Production Operations falls significantly short of addressing critical environmental and operational issues. The current list fails to include any meaningf...↓

No attachments

Comment From: Martha Richardson

1/23/25 @ 7:03 PM

I feel TCEQ has done an inadequate job of proposing Best Management Practices for Certain Operational Issues at Aggregate Production Operations. I submit TCEQ should take the job seriously in order to devise BMP's for Aggregate Production Operations ...↓

No attachments

Comment From: Bonnie Ward

1/23/25 @ 6:56 PM

To Whom It May Concern,
I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. First, they do not address practices to minimize water consumption, noise, and light pollution, as...↓

No attachments

Comment From: Alan Smith

1/23/25 @ 6:28 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Becky Breazeale

1/23/25 @ 6:26 PM

To Whom It May Concern,

I Becky Breazeale am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise,...↓

No attachments

Comment From: Austin Nikel

1/23/25 @ 5:51 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

No attachments

Comment From: Lucas Mancuso

1/23/25 @ 5:51 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Madison Lozano

1/23/25 @ 5:43 PM

To Whom It May Concern,

I am deeply concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and ligh...↓

No attachments

Comment From: Dara Zoboroski

1/23/25 @ 5:42 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

No attachments

Comment From: Samuel Nunnally

1/23/25 @ 5:40 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

No attachments

Comment From: Rhonda Brown

1/23/25 @ 5:29 PM

To Whom It May Concern,

I'm very concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light p...↓

No attachments

Comment From: Michael Cummings

1/23/25 @ 5:20 PM

I and my family are concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollution, as was...↓

No attachments

Comment From: Lisa Swint

1/23/25 @ 5:08 PM

I'm a City Council Member from Garden Ridge actively working to minimize the impacts of APOs on our community. My views are my own. I support TRAMS suggestions for meaningful solutions which I have copied here. They are all important but I'd like to ...↓

No attachments

Comment From: James Stepter

1/23/25 @ 5:01 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. Where are the papers and research on our water shortage and what the plants use? what are the e...↓

No attachments

Comment From: Ira Yates

1/23/25 @ 4:55 PM

To Whom It May Concern,
I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is not good enough. Facilities along the Pecos River have a unique consequence on the river that need to be considered. F...↓

No attachments

Comment From: Sydney Beckner

1/23/25 @ 4:48 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production
Operations is grossly inadequate. For starters, they do not address practices to minimize water
consumption, noise, and light polluti...↓

No attachments

Comment From: Schuyler Wight

1/23/25 @ 4:48 PM

To Whom It May Concern,

I, Schuyler Wight, am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise...↓

No attachments

Comment From: Brooke Small

1/23/25 @ 4:46 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Cliff Kaplan

1/23/25 @ 4:44 PM

I am submitting the attached PDF of comments regarding TCEQ's APO BMP List Proposal on behalf of the Texans for Responsible Aggregate Mining (TRAM) coalition.

Attachments:

Comment From: Ellen Scott

1/23/25 @ 4:33 PM

To Whom It May Concern,

I Ellen Scott am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and...↓

No attachments

Comment From: Stanton Calvert

1/23/25 @ 4:28 PM

I believe that the proposed list of Best Management Practices for Aggregate Production Operations is inadequate. For example, they do not address practices to minimize water consumption, noise, and light pollution, as was directed to by the Texas Leg...↓

No attachments

Comment From: Lauro Martinez

1/23/25 @ 4:27 PM

To Whom It May Concern,

I am concerned that the proposed list of Best Management Practices for Aggregate Production Operations is grossly inadequate. For starters, they do not address practices to minimize water consumption, noise, and light pollu...↓

No attachments

Comment From: Robert Harrison

1/23/25 @ 4:25 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

I have attached a PDF that shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Gary Yepsen

1/23/25 @ 3:58 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: B Warr

1/23/25 @ 3:58 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Lauryn LeClere

1/23/25 @ 3:41 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Leslie LeClere

1/23/25 @ 3:35 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Lindy Hernandez

1/23/25 @ 2:37 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Kay Anonymous

1/23/25 @ 2:10 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

No attachments

Comment From: Donna Walton

1/23/25 @ 2:08 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

https://reduceflooding.com/2025/01/21/only-4-days-left-to-comment-on-new-tceq-sand-mining-bmps/

No attachments

Comment From: Krystal Boutwell

1/23/25 @ 1:54 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

No attachments

Comment From: NICOLE RILEY

1/23/25 @ 1:33 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.
The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.
In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.
Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.
The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.
Addressing these issues requires building mines on higher ground, farther from rivers.
I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.
I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.
Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.
The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.
I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

No attachments

Comment From: Blaise Millican

1/23/25 @ 1:27 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and in...↓crease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Lynn Bradshaw-Hull

1/23/25 @ 1:22 PM

What happened to common sense management of the San Jacinto River? As late as the '70s and '80s, counties had various dragline operators who removed sand/silt after Texas "gully washers" for the "price" of keeping and marketing the sand/silt.....prob...↓

No attachments

Comment From: Cathy Gist

1/23/25 @ 1:07 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Richard Thomas

1/23/25 @ 12:53 PM

RE: APO BMP List Proposal
TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that r...↓educe water quality and increase flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

I have attached a PDF that shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Attachments:

Comment From: Jamie Turner

1/23/25 @ 12:47 PM

TCEQ's attempt to create a helpful list of Best Management Practices for Aggregate Production Operations is an exercise in willful blindness. It completely ignores issues mandated by the legislature, as well as others that reduce water quality and i...↓ncrease flood risk.

The issues you do address are addressed in a vague and/or self-evident manner that render them inadequate.

In addition to more specificity, I would like to see BMPs that help mines in the Houston region avoid inundation and pit capture.

Most mines on the East and West Forks of the San Jacinto were inundated last year. Floodwaters swept industrial waste downstream into Lake Houston, the drinking water supply for two million people.

The rivers also broke through the dikes of at least six of those mines. The rivers now run through pits instead of around them. This flushes sand and sediment downstream, where it reduces conveyance, blocks drainage and contributes to flooding.

Addressing these issues requires building mines on higher ground, farther from rivers.

I recommend doubling the minimum setback from 100 to 200 feet for mines in the San Jacinto watershed. That will put the mines on higher ground, farther from the floodway.

I also recommend leaving forests undisturbed in the widened buffer zone. That will reduce the velocity of floodwater and, with it, the volume of sediment carried downstream. It will also decrease the likelihood of pit capture, by increasing the amount of time that it takes a river to migrate into a mine. The forest will also help capture sediment that may escape a mine.

Finally, the wider buffers will give rivers more room to spread out during floods. Right now, dikes are supposed to protect mines from a hundred-year flood. But when mines build tall dikes on one side of a river, they double the volume of water flooding the other side. And when they build tall dikes on both sides of a river, water has no room to spread out without invading the mines. The tall dikes effectively eliminate ALL floodplains and turn rivers into erosive firehoses.

The attached PDF shows visual proof of the need for BMPs that address our main sand-mining concerns in the San Jacinto Watershed.

I also support the concerns and list of alternative BMPs supported by Texans for Responsible Aggregate Mining.

Links: https://reduceflooding.com/2025/01/21/only-4-days-left-to-comment-on-new-tceq-sand-mining-bmps/?fbclid=IwY2xjawH_XN9leHRuA2FlbQIxMAABHdEIAllB4VsytTXQFWX4pKyWDwWRERwbGo8afMNw5cWc4efnw3BYavHj0g_aem_9TPWASiWk2zQfWUCPIoD7w

Attachments:

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