Houston (July 24, 2020): Residents Against Flooding (RAF) is pleased that the City of Houston’s Planning and Development Department has issued new requirements for developers within our metropolitan area:

“To mitigate and reduce the risk of flood loss for future development, the 100-year, 500-year floodplains and floodway will be required to be identified on all General Plans submitted to the Department with the Plat Tracker application. Applicants will be required to graphically depict the location of the floodplains and or floodway on their General Plans and provide related note.”

Nevertheless, RAF urges homeowners around these tracts to check for recent Letters of Map Revision (LOMR’s) used to revise floodplain maps related to the new development. More importantly, homeowners should be able to identify where the City of Houston or Harris County Flood Control District has allowed or plans to allow fill dirt to be trucked in that will elevate that property above surrounding properties. RAF also suggests that application requirements to identify the locations of floodways and floodplains should NEVER be subject to waivers or variances. And detention and conveyance plans and financing must be established BEFORE permits are granted.

RAF continues to see LOMR’s along Houston’s bayous where large plats are being engineered out of the floodplain so that they can be developed. As the local Cooperative Technical Partner for FEMA, Harris County Flood Control District (HCFCD) has the responsibility for checking the accuracy of developer’s applications. As RAF has shown previously, HCFCD sometimes fails to merit the public’s trust by passing LOMR’s that have used computer modeling tricks to engineer properties out of the floodplain for the benefit of a developer.

Likewise, some of these LOMR’s have been originated by the City of Houston and/or have been signed off by the City Floodplain Manager. FEMA has recently issued new guidance which should enable HCFCD to push back against bad floodplain management.

Using engineering to change a property’s flood designation in order to remove it from the 100-year floodplain creates several problems: 1) Properties are often elevated with trucked-in fill dirt before building, causing stormwater run-off onto lower properties; 2) Areas that were once absorbent get covered with concrete and roofs that flow stormwater run-off into pipes that rapidly empty into bayous, creating surges of water downstream; 3) Properties located in or adjacent to floodways are useful for expanding the flow capacity of bayous or for providing overflow detention during major rain events. Once developed these properties are likely lost forever for flood prevention; 4) Displaced water from new developments will often cause flooding in adjacent properties built to older standards. Although these communities may not be in any currently mapped floodplain, homeowners will likely find their property subsequently remapped into one, diminishing their home’s resale value and putting them at risk. This is what RAF considers preventable man-made flooding.

Residents Against Flooding urges the City of Houston and Harris County to act proactively to preserve property in floodplains and adjacent to floodways and to strongly resist developers’ efforts to remap these. Furthermore, once a property has been bought due to repeat flooding, RAF believes that it should never be remapped or sold to a developer.

While our organization is pleased with the change to Chapter 19, we think it is only a small step in the right direction and urge the City to act more aggressively to prevent future flooding.

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ABOUT RAF: Residents Against Flooding is the oldest 501(c)3 nonprofit in Houston focusing on policy matters to make the area more resilient to flooding. Chair and founder Ed Browne and advisory board member Cynthia Neely represent RAF and Houston as founding members of Higher Ground, the largest flood survivor network in the U.S.


Cynthia Neely
RAF Communications Director

Ed Browne
RAF Founder & Chair

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