Per the request of area residents, beginning May 5th, 2015, TIRZ 17  opened a 30 day public comment period ending June 6, 2015, for the Memorial Drive Drainage and Mobility Improvements project. People can go to the home page of the TIRZ website and post their comments at  All questions and comments from the Town Hall Meeting and public comment period will be addressed and posted on their website within 60 days of closing date.  This post presents some concepts that we would like to see incorporated in the Memorial Drive reconstruction project.  Please feel free to borrow in whole or in part for your own comments.

For those that missed the TIRZ 17 Memorial Drive Town Hall Meeting April 14th, 2015, you can find the Power Point slide show here.  The Memorial Drive reconstruction project will extend from Beltway 8 east almost to Tallowood and will add a sidewalk, a median, a 10-foot mixed-use shared hike and bike way, and over 10 acre-feet of underground detention.  We applaud TIRZ 17 for designing a Complete Street, and for us a complete street includes improving the underground infrastructure when the less expensive opportunity presents itself, as during reconstruction.   TIRZ plan for Memorial Drive Below is a cross section of the planned roadway.  Click on the drawing to open a clearer version.

Even though we consider this to be an improvement, we would like to offer some suggestions.  First, it is important to consider what the priorities are for the roadway.

Our priorities are:

  • Safety – the road must be safe for motorists, bicyclists, and pedestrians;
  • Mobility – the road must convey through traffic smoothly while providing easy access to area homes and businesses, but it should not promote excessive speed;
  • Stormwater – this roadway must store excess stormwater runoff in an area known to have serious flooding problems;
  • Infrastructure – the roadway must have underground infrastructure installed capable of supporting expected future Chapter 42 residential density and continuing expansion of commercial interests;
  • Quality of Life – the roadway should mirror the lush landscape and amenities for which the Memorial area is known.

From a safety standpoint, it’s best to separate pedestrians and bicyclists from the roadway by trees – better to hit a tree than a person.   As the trees grow, their canopy not only provides shade, air filtration, and noise reduction, but the presence of a canopy also encourages drivers to slow down and psychologically conveys the impression of a higher quality of life to an area.  Perhaps equally important, as trees grow it becomes increasingly more difficult and expensive to widen the road because the trees must be replaced by trees with girth equivalence.

Traffic studies of Memorial Drive do not justify widening the roadway to more than four lanes, however, inserting a 24 foot median easily allows the roadway to be widened at a later date.  When the TIRZ raised the possibility of taking the Gessner esplanade for underground detention, even if it was to be replaced and replanted, neighbors vociferously objected – and rightfully so.  The esplanades along Gessner and other Memorial roadways are one of the reasons the area is such a desirable place to live, but they are always vulnerable to road widening (see Project ID 12282).

If that is so, then why create an esplanade as a placeholder for a future road widening?  Lane widths for a major Houston thoroughfare are generally defined as 11 feet wide.   A 24-foot esplanade therefore allows two lanes of 12 feet each with only stripe separation or two 11-foot lanes with a 2-foot raised separator.  If it is desired that the esplanade never be removed, then it needs to be too narrow to create two lanes; that is, it needs to be 20 feet or less.  Combined with trees between the street and sidewalks, a 20-foot esplanade would make it difficult to remove the median or widen the roadway.  Ostensibly, a two way left turn lane (affectionately called suicide lanes) could be added, but it seems unlikely.  Suicide lanes are a serious source of accident fatalities, so should be avoided whenever possible.

A 20 foot esplanade also frees 4 feet of the 100-foot Right of 2015-05-17  - Memorial Town Hall Mtg_04142015_Way (ROW) that can be used elsewhere.  We have elected to use the 4 feet to expand the 6-foot sidewalk into another 10-foot mixed-use shared hike and bike way on the north side.  The graphic shows the widened sidewalks, a 20-foot median, and trees placed between the street and sidewalks.  Hopefully, our reasons for these changes will become more obvious.  Again, clicking on the graphic opens a larger version.

Porous concrete has begun to make inroads into some areas of building.  Rice University has paved many of their sidewalks with porous concrete and it is used in the parking lot at Frostwood Elementary.  So we asked ourselves, why not make the 10-foot sidewalks of porous material and install underground retention?  If the soil quality was sufficient at Frostwood to support2015-05-17  - Memorial Town Hall Mtg_04142015 double a similar underground system, certainly it would also be expected to work less than a mile away.  The graphic to the right indicates how this would work.  These systems are finding their way into design manuals in many communities, including Houston, where they are being used in lieu of surface detention systems.

Below is a quote that we presented to the Houston City Council’s  Transportation, Technology, and Infrastructure (TTI) Committee when the City proposed replacing sidewalks for homeowners.  This system costs approximately the same that then Public Works and Engineering (PW&E) Director, Dan Kruger, testified before the Committee that the City would charge to install a sidewalk.  A permeable sidewalk is not a detention system and does not need continuous connections so pipes and communication lines don’t interfere.   Because it is an open bottomed pipe, it also recharges the aquifer and water eventually percolates into the soil, reducing the possibility for mosquito breeding.  Concrete pipes are notorious breeding grounds for mosquitoes.   Puddling is eliminated with porous sidewalks, so bicyclists can use the sidewalk just after the rain without spraying “rooster-tails” over themselves and everyone else.S29 System under a porous walk and standard details page 1

We got a quote from Triton because they happened to answer the phone when we called and were willing to provide this information.  Residents Against Flooding has no affiliation whatsoever with Triton.  Moreover, there are numerous other companies producing similar systems [1][2], [3] so this technology clearly works and is readily available.  It’s useful to note that if the ground is deemed to have a poor water infiltration rate, then this system can serve as more flexible normal detention, although the chambers would then need to be interconnected.

In the PowerPoint presentation, LAN states that over 10 acre-feet of detention can be achieved using dual underground 10-foot by 10-foot rectangular culverts.  In a 100-foot ROW, more than two rows of culverts can be installed.  Can we add more?  Is it a matter of construction difficulty or the cost of the culverts?

Suppose that additional 10-foot by 10-foot pipes extending from W153 were placed under the permeable sidewalk drainage system.  These would not be used to convey water, but would be used to add capacity to W153.  Therefore, they would be closed at one end and fully open to W153 at four places where it crosses under Memorial Drive underneath the north and south sidew2015-05-17  - Memorial Town Hall Mtg_04142015 double with boxesalks: two would connect under the bridge underneath the southern 10-foot sidewalk with one extending east and the other extending west; and two more underneath the northern sidewalk – again, one east and one west.  The graphic to the right shows the concept.  Since they add capacity, they would dead-ended some practical distance east or west of the W153 bridge and need to be sloped so that water would drain back into the channel after a rain event.  A 1% slope is probably sufficient, meaning that the elevation of top of the pipe rises 1 foot for every 100 feet of pipe.

To the right is a picture of W153 at Memorial Drive.  There is a 9-foot by 9-foot channel under the roadway; the smaller pipe was added to compensate for lost capacity due to bisection of the main channel by a large water line and reconnects into the main pipe under the roadway.  Hopefully, much of this will be corrected in the MePicture 015morial Drive redesign.  For reference, nearby residents measured the distance from the bridge surface to the channel bottom at 23 feet, so there should be sufficient space under the sidewalk drainage system, which takes about 5 feet, even if the roadway is lowered.    For every 217 feet that a pair of these pipes extend, one acre-feet of detention is added.  Since elevations rise more to the west, it’s expected that more capacity can be added in that direction.  During construction, fill dirt around the pipes can be selected to complement operation of the sidewalk drainage system. Again, these pipes are in addition to the drainage systems currently planned by the TIRZ.

In summary, Residents Against Flooding recommends:

  • A median less than 20 feet wide;
  • Two 10-foot mixed-use permeable concrete sidewalks and underground open-bottom drainage systems;
  • Trees planted between the roadway and the sidewalks;
  • Additional large box culverts to expand detention capacity of W153.
  •  The culvert size under Memorial Drive should be increased  during reconstruction to be whatever is needed if more W153 water is allowed in Buffalo Bayou.


The RAF Annual Meeting:
Will be held on APRIL 8th, 2015 in the auditorium at Spring Branch Middle School, 1000 Piney Point Drive. Our speaker will be Mr. John Rickel, a TIRZ 17 Board Member & Citizen-Appointee to the Board.

John Rickel is resident and citizen-appointee within the Spring Branch / Memorial District, appointed by the District G Council Member Oliver Pennington to serve on the TIRZ Board.

Mr. John C. Rickel has been Senior Vice President and Chief Financial Officer of Group 1 Automotive Inc. since December 2005 and also serves as its Chief Accounting Officer.  Mr. Rickel served as Chief Executive Officer of Group 1 Automotive Inc.  Previously, he held a number of executive and managerial positions with Ford Motor Company.  He has served as Controller of Ford Americas, where he was responsible for the financial management of its western hemisphere automotive operations. Immediately prior to that, he served as Chief Financial Officer of Ford Europe, where he oversaw all accounting, financial planning, information services, tax and investor relations activities. From 2002 to 2004, Mr. Rickel served as Chairman of Ford Russia.  He received his BSBA in 1982 and MBA in 1984 from the Ohio State University.
This Meeting will explain current, past, and upcoming development & infrastructure projects, & consider the means necessary to avoid or remedy impacts on area properties.


The “Residents Against Flooding” dba was adopted in April 2012, reflecting infrastructure impacts that exist throughout the City of Houston.

Update 11/6/14: Chapter 9 released

The Public Works and Engineering Department has released the long awaited Chapter 9 revisions of the Infrastructure Design Manual.  Most of our requests were ignored, although the City did add back text stating, “The combined system is intended to prevent Structural Flooding from extreme events up to a 100-year storm.” This was necessary to maintain Houston’s extraordinarily good FEMA rating and discounted flood insurance rate.  

PW&E didn’t remove “Grandfathering” (see below) and significantly decreased detention requirements for lots 15,000 square feet or less, which represents the vast majority of residential properties (94%).  Detention requirements for these properties have been reduced to 7% from 10% proposed earlier this year.  Compare this to 50% detention required to develop on virgin properties over 2 acres.

The new Chapter is still not harmonized with Chapter 42 of the City’s Code of Ordinances, which designates the entire incorporated City as urban.  For example, runoff coefficients still reflect suburban densities, meaning that new road construction need only assume 55% runoff rates in areas with residential lots of less than 1/4 acre (10,890 square feet).  Given that Chapter 42  allows up to 90% concrete coverage on properties this size and that Chapter 9 only mitigates for 7% of the runoff, this discrepancy will produce street and structure flooding in the extreme event.  There is clearly a disconnect between the claim of preventing structural flooding up to a 100-year event and its Chapter 9 implementation.

Super Neighborhood Alliance (SNA) Chapter 9 Comments

•  What’s at Stake?

  • Increased Risk of Flooding
  • Reduced Detention and Drainage Capacity
  • Rising Insurance Rates
  • Decreasing Economic Competitiveness

•   What Needs to Change?

•     Chapter 9 should be revised to insure consistent and transparent enforcement and eliminate unwarranted variances (§ 9.02.A.2).

  • Chapter 9’s standards for evaluating the storm water impacts should be revised to reflect both increased amounts of impervious cover and time of concentration.
  • Raise and reduce number of run-off coefficients (§ 9.05.B.3)
  • Protect existing development from increased risk of flooding (§ 9.05.D.5)
  • Specify more than two Manning numbers for roadside ditch design (§ 9.05.F.2.d)

•     Chapter 9 should be revised to eliminate “grandfathering” and require full mitigation for the storm water impacts of all types of new development

  • “What is Grandfathering?”
  • Off-Site Mitigation (§9.05.H.3.b)
  • On-Site Mitigation (§9.05.H.3.d-e)

 •    Chapter 9 should be reorganized or harmonized with City Code of Ordinances.

  • Chapter 19
  • Chapter 42

•     Chapter 9 should be revised to improve city records by require maintenance of public records showing the location and capacity of detention on private property so that capacity is not lost during redevelopment (§ 9.07).

•     What Should City Council Do?

  • Provide resources needed to enforce standards consistently and transparently
  • Demand compliance with Chapter 19 of the City Code
  • Educate and inform
    • Schedule presentations
    • Call special meetings
    • Summon witnesses


What’s at Stake?

•    Increased Risk of Flooding

  • Amendments to Chapter 42 of the City Code of Ordinances passed in 2013 expanded “urban” standards for residential development from the Inner Loop to the entire city.
  • The amendments to Chapter 42 increased allowable density of single family housing outside Loop 610 from roughly 8 to 27 units per acre without requiring corresponding increases in supporting infrastructure or full mitigation for storm water impacts.
  • Local watersheds already have tens of thousands of properties in existing floodplains. Unless Chapter 9 is amended to require full mitigation for storm water impacts of new development, more properties than ever will be at risk of flooding.
  • Harris County Flood Control has recently changed its mitigation requirements from 1/2 acre-foot per acre of increased impervious cover to 1/3 acre-foot per acre.

•    Reduced Detention and Drainage Capacity

  • Most of our drainage system is designed for low density suburban development with low discharge flows.
  • Unless Chapter 9 is amended to require the calculation of detention and drainage needs using coefficients that assume high density development with higher peak discharge flows than currently exist, city engineers will continue to evaluate detention and drainage needs using calculations that incorrectly assume low density development with low discharge flows.
  • Calculations that incorrectly assume low density development with low discharge flows where density and discharge flow is increasing will reduce detention and drainage capacity.
  • High density development increases demand for street and parking capacity that is often satisfied by filling-in roadside ditches that further reduces detention and drainage capacity.
  • New roads need to be constructed assuming full urban density since it is impossible to know where very dense development will occur.  Likewise, roads reconstructed under Rebuild Houston should also have drainage systems assuming runoff from fully developed urban density.

•    Rising Insurance Rates

  • Biggert-Waters Flood Insurance Act of 2012 mandates rates based on actual risk of flooding.  Even though the Affordable Homeowner Flood Insurance Affordability Act of 2014 rolled back or slowed many rate increases for homeowners, businesses are still impacted fully.  All rental and vacation homes will all have a yearly $250 surcharge to help subsidize at risk homes.
  • Flood maps are being revised to capture true costs of structural flooding.  55% of homes flooded in Houston are not in a FEMA floodplain compared to 33% nationwide.  A 100-year rain event occurs on-average about every 5 years, and a 500-year rain even occurs about every 8 years.  Under Biggert-Waters, FEMA will need to capture these anomalies.  As a result, the floodplains will continue to grow.
  • Revisions to flood maps are increasing the size of the city’s 100-year flood plains and the number of structures at risk of flooding.
  • PW&E is removing references to meeting a 100-year Level of Service (LOS) from Chapter 9.  FEMA has publicly stated that without this verbiage, Houston will loose its extraordinarily good FEMA Community Rating System (CRS) rating of 5.  For each point lost, Houstonian’s flood insurance premium will increase 5%.  For reference, the national average is 7.6 and Harris County is an 8.  Only 4 communities of 872 are better than Houston’s CRS rating .

•    Decreasing Economic Competitiveness

  • Reduced drainage and detention capacity, increased risk of flooding, and rising insurance rates will threaten economic competitiveness.


What Needs to Change?


  • Chapter 9 needs to retain references to meeting a 100-year level of service and rather than giving up on achieving it, PW&E needs to rework Chapter 9 in order to achieve it and stop worrying about hurting development.
  • Chapter 9 should be revised to insure consistent and transparent enforcement and eliminate unwarranted variances (§ 9.02.A.2). Section 9.02.A.2 allows the city engineer to grant site-specific variances that result in annual increases to 100-year flood plain. Site specific plans should be considered openly and have stringent requirements
  • Chapter 9’s standards for evaluating the storm water impacts should be revised to reflect both increased amounts of impervious cover and time of concentration
    • Raise and Reduce Number of Run-Off Coefficients (§9.05.B.3): Chapter 9 should be revised to reflect higher run off coefficients because drainage from all types of new development will have higher flow than from existing development. And now that high density development can occur throughout the city, the number of run-off coefficients should be reduced to two, e.g., (e.g., 75% for residential development and 100% for roadways).
  • Protect Existing Development from increased risk of flooding (§9.05.D.5): Roadways are designed to capture water in excess of two-year events up to 100-year events, but emergency routes are not allowed to flood even in 100- year events. Absent full mitigation for all types of new development, existing neighborhoods are wrongfully forced to serve as de facto detention ponds.
  • Specify two Manning numbers for roadside ditch design (§9.05.F.2.d): Using a large Manning number (e.g., 0.045) when replacing an earthen ditch with a concrete conduit will result in a channel that does not have as much conveyance capacity as the original ditch and thus increased flooding.
  • Chapter 9 should be revised to eliminate “grandfathering” and require full mitigation for all new development
    • “What is Grandfathering?” Chapter 9 allows property that either has impervious cover or had impervious cover in the past to be fully redeveloped without any on-site mitigation for storm water impact. Exemptions and/or reductions in detention and drainage requirements for redevelopment on such  properties is referred to as “grandfathering.” “Grandfathering” needs to end because it shifts the cost of flood damage and reduction from developers to neighboring landowners, public agencies, and taxpayers.
  • Off-Site Mitigation (§9.05.H.3.b): When drainage from new development is directed to public right of way (ROW), Chapter 9 should require infrastructure to receive and convey water into storm sewer system and not redirect water to neighboring properties as occurs when roadside ditches are filled-in or curb and gutters don’t work properly. SNA has proposed that developers be allowed to install underground detention for lots smaller than 15,000 sq.ft. in the ROW to allow for maximum development and adequate detention.
  • On-Site Mitigation (§9.05.H.3.d-e): Chapter 9 requires detention as a % of existing impervious cover as follows: up to a maximum or 4% of the property size for lots of 1-10 acres, and up to a maximum of 7.5% for lots of 10-50 acres. Use of equations to determine the amount of detention are difficult and expensive to police. The best action is to eliminate the equations and require 0.5 acre-feet per acre for all types of new development.
  • Chapter 9 should be reorganized and harmonized with relevant chapters of the City Code of Ordinances.
    • Chapter 19: Chapter 19 of the City Code governing floodplains embodies a “No Adverse Impact” policy that should require full mitigation for all impacts of new development.
  • Chapter 42: Standards for storm water detention and drainage on private property should be moved out of Chapter 9 of the Infrastructure Design Manual and into Chapter 42 of the City Code of Ordinances to insure that  (1)  development standards are approved by City Council; (2) variance requests will be considered and approved the in open meetings, e.g., by the Planning Commission; and (3) variance requests will be subject to public comment.
  • Chapter 9 should be revised to require maintenance of public records showing the location and capacity of detention on private property so that capacity is not lost during redevelopment (§9.07). Parking lots can be used for detention, but such does not need to be recorded. Because analysis for new development assumes no detention, such properties are treated as “grandfathered,” and as a result run off increases.


What Should City Council Do?

•    Provide resources needed to enforce standards consistently and transparently

Recent amendments to Chapter 42 of the City Code of Ordinances and proposed revisions to Chapter 9 of the Infrastructure Design Manual necessitate additional inspectors and engineers. Failure to provide adequate staffing to support these changes further exposes the city risk of flooding.  Clarifying the standards will simplify the enforcement.


•    Demand compliance with Chapter 19 of the City Code.

  • Sec. 19-1.b states: “The provisions of this chapter shall take precedence over any less restrictive conflicting laws, ordinances, codes, or official determinations.”
  • Chapter 19 also states in several places that the city engineer must use the strictest interpretation regarding conflicting provisions when interpreting provisions relating to flood control. Among these is the express obligation of the city engineer regarding the use of data provided in Sec. 19-4.b.1: “To the extent of any inconsistencies between the study data and the effective FIRM, the more restrictive base flood elevations and special flood hazard areas shall be controlling.”
  • Sec. 19-11 provides that no permit, plat, or variance in the affected areas shall be granted unless it is shown to comply with this chapter.
  • Educate and inform
    • Schedule presentations: Chapter 2, Sec. 2-2 of the City Code of Ordinances, rules of procedure for meetings and proceedings of the city council, Rule 2.a.3 governing presentations to the city council by persons, groups, or organizations allow presentations to be scheduled by council members through the office of the mayor pro tem. Presentations on the issue of flooding and drainage could be scheduled to educate council and the public on these issues.
  • Call a special meetings: Article VII of the City Charter, Sec. 3 titled “Meetings” provides: “Special meetings shall be called by the City Secretary upon the written request of the Mayor or three Council Members.”
  • Summon witnesses: Article VII of the City Charter, Sec. 5 titled “City Council May Summon Witnesses” provides: The City Council shall have power to summon and compel the attendance of witnesses and the production of books and papers before it whenever it may be necessary for the more effective discharge of its duties, and shall have the power to punish for contempt . . .”

Since May, the Super Neighborhood Alliance and the City of Houston were supposed to be discussing changes to Chapter 9 of the City’s  Infrastructure Design Manual.  We haven’t been.

Instead, we have been discussing one small part, a “fee in lieu of detention” for development and redevelopment of properties less than 15,000 square feet.  For reference, that’s approximately a third of an acre and detention is already required by Chapter 9, so a change in this requirement can affect 94% of single family residences.  As an elevation challenged city, Houston needs all the detention that it can get, and it needs to be where the new density is occurring, but land to build large regional detention ponds where needed for  maximum benefit is often unavailable.

We have proposed an alternative,  a single paragraph to the existing wording that permits a fee to be used for under sidewalk detention of up to 15 cubic feet per linear foot of sidewalk.  The fee would be paid to the City who would subcontract one of several companies who do this sort of thing.  A phone call to the company at the top of a search list resulted in an estimated cost of $5.50-$6.75 per cubic foot of detention.  The proposed “fee in lieu of detention” was to have been $7.50 per cubic foot of required detention as calculated by a formula in the City’s Infrastructure Design Manual and didn’t include the cost of a sidewalk.  The maximum fee for “under sidewalk detention” would be $5000 for a 15,000 square foot lot.  For the City’s average lot of 5,000 square feet, the cost would be $1667.

Under the sidewalk detention provides an immediate solution to rainwater runoff when construction occurs, rather than delaying to gather enough funds to build a regional detention pond.  Distributed detention can provide surprising large amounts of detention and it’s located where the detention is needed, so doesn’t need to be piped to the lowest cost land when, and if, it becomes available.  And the open bottom system drains water into the aquifer, rather than letting mosquitoes breed as they do in regular storm sewers.

If you think “under sidewalk detention”  is a more reasonable alternative than a “fee in lieu of detention” for single family residential properties under 15,000 square feet, please contact your City Councilmember.


Update (3/29/14) CM Larry Green has put Chapter 9 on his Agenda for the TTI Committee meeting on Tuesday April 1st, 2014 in City Council Chambers at 9:00AM.

Update (10/8/13): The City has refused to release Chapter 9 of the Infrastructure Design Manual to the public or to the TTI Committee Chair for review.  As a result, TTI Chair Melissa Noriega is not calling a Public Meeting.

Update (9/25/13):  Our meeting with CM Costello regarding “fee in lieu of detention” was a waste of time.  His position was that either we agree to a fee in lieu of detention or he would march across the street and have the Mayor sign it anyway.  He refused to consider our proposal for under sidewalk retention at all. 

Update (7/10/2013): The  5-year look-back has been tabled.  Now they are exploring no look-back, but instead using the current drainage fee area as the existing impervious cover for new construction; i.e., if no fee is paid now, the land is permeable so detention is required.  I asked that in addition to this, the clause adding some detention for existing impervious cover also be kept.  In the future, sites that have been fallow for a long time can no longer use grandfathering to eliminate detention requirements; for example, under these rules the Heights Walmart would have required detention.

Update (7/9/2013):  The TTI Committee meeting on Chapter 9 will be delayed once again by approximately 60 days, now meeting sometime in September.  The delay is to allow CM Costello and Andy Icken to advocate for a fee in lieu of detention for smaller lots and to address the look-back time for the “grandfathering” clause added by CM Costello that requires a small amount of detention for preexisting concrete.

Update:  The public meeting on Wednesday, June 12th was cancelled.   It has been rescheduled for July 17th at 5:00PM.  Although the City promised final revisions by July 1st, they are only required  to make them available 1 week prior to the meeting.  Consequently, revisions will be available July 9th at 5:00PM.

The public comment period for revisions to Chapter 9 of the City of Houston Infrastructure Design Manual closes on May 24, 2013.  Comments must be submitted to no later than that date.  The draft of the revisions for Chapter 9  was released prior to the final City Council vote on Chapter 42 (which deals with urban development) of the municipal Code of Ordinances.  Please note that these two manuals, the municipal Code of Ordinances and the Public Works and Engineering (PW&E) Infrastructure Design Manual (IDM), are distinct but different.  The Code of Ordinances are voted upon by City Council after public hearings, while the IDM is approved by a PW&E Standards Committee not subject to a vote or hearings.

Here’s a link to our comments on proposed revisions to our red-lined copy of Chapter 9.

There are several points that are particularly important to note:

  • This sentence was removed in the new version of Chapter 9: “Drainage criteria administered by the City of Houston and complemented by Harris County and the Harris County Flood Control District (HCFCD) for newly designed areas provides protection from Structural Flooding from a 100-year storm event.”   We hope that the City doesn’t quit trying to provide protection from a 100-year storm event and that FEMA and commercial insurers don’t abandoned Houston to our floods.  Removing a sentence does not remove the City’s responsibility to protect its citizens from preventable disasters. (see Section 9.02.A.1)


  • Chapter 9 is not harmonized with Chapter 42.  Recent Chapter 42 changes include increasing development density for single family residences  dramatically (from 7 to 27 homes per acre) and designating all of incorporated Houston as urban.  Urban density means more concrete and more concrete means more water runs off of properties.  The stormwater runoff coefficient, C, that percentage of a property that is impermeable, needs to be changed in Chapter 9 to reflect an all urban City.  Any roadways being reconstructed by Rebuild Houston need to assume stormwater runoff of 90% or higher. (see 9.05.B.3.a.1)


  • Chapter 9 allows fees in-lieu-of detention (see Section 9.05.H.2.a.).  Section 9.02.J. says that payments in-lieu-of detention will be allowed only if deficit drainage systems are improved to sufficient capacity to convey new and existing runoff.  If conveyance systems are being asked to carry all the runoff, then they need to have been designed using urban stormwater runoff  (C>90%)  that assumes all the water will be carried by the roadway conveyance and have capacity in excess of this.  If Rebuild Houston intends to install sub-regional detention ponds, then all conveyance routes must be designed and built to handle more than the 100-year event; i.e., C >100%.   Any fee paid in-lieu-of providing detention needs to go to a Rebuild Houston fund earmarked to build subregional detention in the subregion where the fee was paid.  It should not go towards the General Fund, nor to be used on any road project anywhere within the City.


  • Attempts by the City to deal with “Grandfathering” will cause more confusion than anything.  Inspectors will be unable to discern the small amount of new detention added when redeveloping properties with existing impervious cover (concrete).  Enforcement would be virtually impossible.  Our suggestion is that all development or redevelopment install the same amount of detention.  Inspectors could very easily tell whether detention was installed or not and requiring everyone to install the same detention would reduce, if not eliminate, creative ways to avoid detention.  We also recommend that elevating properties would require mitigating for 100% of runoff due to the elevation. (see Section 9.05.H.3.)


  • Sub-regional (huge) detention ponds have been touted as the means to save us from flooding by several Houston Mayors, but that’s misleading.  It will be years (if ever) before Rebuild Houston funding begins to accumulate enough funds for these detention ponds.  Back-of-the-napkin math suggests that we would need approximately 600 sub-regional detention ponds, each of about 320 acre-feet (huge), if we want to do away with requiring local detention.  This would cost tens of billions and land available for purchase may not be optimally placed for detention; moreover, land will become scarcer as Chapter 42 is implemented.  Clearly, we’ll need to build some anyway, even if local detention is used, because we’re only mitigating for half the runoff produced.  A more subtle problem is our insistence that our roadways are designed to convey excess water in heavy rains, so the roadways will need to carry the water to the sub-regional detention ponds.  Trouble is, major thoroughfares that need to carry emergency vehicles, or provide an evacuation route, must not flood even in an extreme event.  Theoretically, all neighborhoods will have access to emergency and evacuation routes, so the question becomes, “How will the need to convey water to sub-regional detention ponds and the need for safe passage be reconciled?”  The answer is that they cannot unless major thoroughfares are designed with much larger drainage systems than currently used, and that costs even more money and adds more delay.  Chapter 42 densification will not wait for Rebuild Houston money to accumulate, so we strongly advocate for local on-site detention with no in-lieu-of payments. (See section 9.05.D.5)

Please refer to our other pages for more information about the relationships between Chapter 42 and Chapter 9.  Use whatever comments you wish to get your own talking points or to send comments to the City (

Previous Chapter 9 comments were written to show what would be necessary if Houston wants to improve flood protection to a 100-year level of service.  Those comments are at Can We Stop Houston Flooding?

Interspersed in the last bullet are pictures of detention ponds being installed along Brays Bayou by HCFCD as part of Project Brays, which will remove about 60,000 homes from the 100-year floodplain.  Some of the detention ponds are quite large, for example, Eldridge Detention Pond is 4500 acre-feet and Arthur Storey Park detention pond is 3500 acre-feet, yet Bellaire Boulevard at Beltway 8, very nearby to Arthur Storey Park, floods during relatively small rain events.   If the water cannot get to the pond, it doesn’t matter how large it is.  In spite of the numerous detention ponds (picture – Brays at 610 Loop), home flooding in SW Houston occurred along Brays Bayou  for a bad but not unusual event.  This should be some indication of how bad the situation really is.

Comments of Bob Schwartz, President of Brays Bayou Association

Comments of Carol Caul, Attorney, Advocacy Chair of Citizen’s Transportation Coalition

Chapter 42 was passed

April 24, 2013

Chapter 42 of the City of Houston, Code of Ordinances passed as proposed by the Mayor’s administration with minor amendments at the April 24, 2013, Houston City Council with only three votes against: CM Andrew Burks, CM Helena Brown, and CM Jerry Davis.  It is now the law.  As a consequence, our Chapter 42 discussions have been removed.  If you have linked to them, please let me know and we’ll work something out.

CM Laster’s two amendments passed as well. CM Laster’s amendment to reduce from 60% to 55% the level of support needed to complete an application for minimum lot size protection passed with only one vote against (Bradford), and his amendment to allow development on less than an acre of land outside of existing neighborhoods had unanimous support.  CM Brown’s two amendments (1) to keep most of District A “suburban” and, alternatively, (2) to refer Chapter 42 back to the administration, both failed.

Houston & ETJChapter 42 extends the “urban” density formerly found only inside Loop 610 to all of incorporated Houston; i.e., inside the City limits.  Suburban density now only applies to the extraterritorial jurisdiction (ETJ).

What should homeowners do?  You should begin scheduling somebody from COH Planning to come explain how to adopt minimum lot size criteria for those neighborhoods that don’t have provisions in your deed restrictions.  If you haven’t started already, you should also begin the process of modifying deed restrictions to add protection verbiage.  You cannot start too soon.

Also, plats not associated with any neighborhood are eligible for redevelopment instantly, so drive through your area to see if you can identify any that don’t seem to be a part of any subdivision; for example, abandoned utility ROW or abandoned drainage ROW.   Likely it’s too late to do anything about these, since developers have had 6 years to identify these odd parcels, but it may not be too late to begin planning for denser development.

If you are building a new home or rebuilding on an existing site, consider pier and beam construction.  Construction costs may be slightly higher, but ultimately the serviceability and flexibility offered over the life of the home will make up any difference.  If water shows signs of rising in the neighborhood, it’s relatively simple to raise the house higher and install more porch steps.  Despite the fact that Rebuild Houston doesn’t credit pier and beam as being permeable, it does allow water to flow under the house and provides less surface area to flowing water.  Piping is accessible and less prone to stress cracking as the ground shifts during Houston’s periods of torrent and drought.

Finally, Chapters 9 and 13 of the City of Houston Infrastructure Design Manual that deal with Stormwater are up for revision.   With the increased density that Chapter 42 will provide will come increased stormwater runoff.  This is particularly problematic in areas where flooding is already prevalent and may migrate to areas that are marginal.  Chapter 9 deals with the “grandfathering” of existing permeable surfaces.  Currently, if a property has existing concrete, mitigation of on-site detention need only be done for increased imperviousness, but only at 50% of the impact rate for properties above 1 acre in size.  Smaller properties are mitigated at 20% with properties below 15000 square feet only requiring 10% of increase impervious cover.

Because of objections by homeowners, minor changes to these requirements have been made already, but these are insufficient to prevent an increase in flooding.  Instead, we recommend complete elimination of any special provisions for already developed areas because many were originally installed without adhering to detention requirements, so should not be grandfathered. Arguments that it is unfair to burden new developers with the transgressions of the past don’t seem logical.  We think that it is unfair to developers of virgin properties to have to mitigate stormwater runoff while those of older properties are allowed to remove existing concrete to elevate their property without any mitigation.  It is also unfair to adjacent property owners.

Please help us protect Houston from future flooding.  Please join us to get these provisions updated.

On Wednesday April 24, 2013, the Houston City Council will vote on Chapter 42.  Citizens will have one last opportunity to raise their concerns at the pop-off session before City Council on Tuesday afternoon.

I think that I can speak for the Super Neighborhood Alliance (SNA), when I say that everyone agrees that the City needs to grow and densify, but there are good ways to grow and bad ways.  Tomaro Bell, President of the SNA, and Jane Cahill West, its Vice President, have experienced the negative aspects of Chapter 42 inside Loop 610 where it has been the law for over 10 years.   They and others inside the Loop decided that the rules need to be cleaned up before subjecting the entire City to them.  SN 22, along the Washington Avenue corridor, has been a test case for a lot of these issues.  Jane gave a tour for City Council members and SN leaders in her area of problems created by Chapter 42 and although many have been addressed by the City, some of the more important ones still need attention.

We had been told by the Mayor and developers that the main thrust for Chapter 42 was to redevelop run-down apartments and strip centers, but no sooner had the SNA removed its objections, then the Mayor started backpedaling – offering to reduce the wait time for neighborhoods to establish minimum lot sizes and setbacks from 2 years for lots under an acre to 1 year for lots under 1/2 acre.  Small lots like this are not run-down apartment complexes.  They are neighborhoods like yours.  Fortunately, with help from CM Costello, SNA leaders were able stop these changes from going forward.

Underground street infrastructure for most of Houston is old and antiquated, so we want to be sure that high density building does not occur where the streets have inadequate storm sewers, water lines, and sanitation sewers. When the toilet flushes next door, will you get scalded?   But Jane pointed out that high density also makes every detail more important.  Where are trash cans stored? Where are mailboxes? Air conditioners?  With a requirement of one guest parking spot for every 6 homes, where do guests (and homeowners) really park?  In Cottage Grove, emergency vehicles cannot access many homes because too many vehicles are parked on narrow streets.  Ladder trucks needed for the 3 or 4 story homes need a place for support pads so they don’t topple over.  These were Fire Marshall concerns, too, not just Jane’s.

Average lot size can be as low as 1400 square feet, but there is no minimum lot size.  Permeable ground can be no less than 150 square feet on a 3500 square foot lot – tiny.  Chapter 42 and Chapter 9 are not harmonized; i.e., they contradict one another.  Chapter 42 requires green space which increases as the lot sizes reduce until at 1400 square feet 600 square feet of green space is required, but there is no minimum lot size .   More about that later.

Very dense development makes sense in areas that have good mass transit because then people can do without a car.  People who fondly remember brownstones in Chicago or New York forget that both cities have excellent mass transit and until recently, neither had the flooding concerns that Houston does.   Multiple small shared driveway developments scattered throughout a neighborhood creates a parking mess, increases traffic, and would probably remove the trees and shade that define the neighborhood’s character.  That doesn’t matter to somebody who only wants to make money, but it does matter to people who’ve searched for the perfect house for their family and have committed to a multi-year mortgage to realize it.

From the drainage perspective, neighborhoods in my area have been dealing with redevelopment of commercial tracts that have not adhered to City ordinances for detention or were granted unwarranted variances to do without.  We approached CC well before these properties were completed seeking help, but found none.  In a meeting on April3, 2013, CM Costello told SNA representatives that homeowners in my area were victims of a lack of enforcement. Had it been one instance, I would agree, but it was worse that – it was multiple occurrences of systematically ignoring ordinances that continues even now.  So unless we want recurrences of what happened in my area, before Chapter 42 is passed, we need legislation setting up oversight committees, clearly written enforcement criteria, and personnel dedicated to enforcement.  Keep in mind, though, that the area to service increases by 8.4 times that inside Loop 610, so this is not a small requirement.  All present politicians will be gone when this experiment is in full swing, so all uncodified promises are meaningless.

City Council has been told by Mayor Parker that the City needs density to generate funds, but it may be false economy.  Presently, growth is primarily in the extraterritorial jurisdiction (ETJ) around new activity centers of The Woodlands, Sugarland, Katy, the Energy Corridor, etc.,  so I expect that much of the new development will continue to be near these centers.  Chapter 42 affects the ETJ as well.  The further away infrastructure is, the more it costs.  Our water comes from Lake Houston.  Pumping that water across the entire City while maintaining flow and pressure is expensive. And if a development explosion occurs in a previously undeveloped area, providing the infrastructure may consume most of, or more than, the increased revenues generated.

Section 42-182 clearly shows that minimum lot sizes in the ETJ can also be reduced to 1400 square feet, although each lot of that size must have 720 square feet of compensating green space versus the 600 square feet required in the urban zone.  Compensating green space can be replaced by a recreational center, so clearly this is not to prevent flooding.  Normal lot size in the urban area without requiring green space is 3500 square feet and is 5000 square feet in the ETJ.  Plats in the urban area can be less than 1400 square feet as long as the average is 1400, yet under no circumstance can ETJ plats be below 1400 square feet.   The upshot of this is that if the City’s reason for doing Chapter 42 is to increase density inside the City limits in order to generate new revenue, then why are they increasing density outside the City to almost the same levels?  It makes no sense.

All this may not stem the migration to the suburbs either.  That’s being driven by jobs (Exxon, Noble Drilling, etc) moving to the ETJ and the construction of the Grand Parkway and its induced development.  Better schools, more property at a lower cost, newer construction, lower taxes, lower insurance, less traffic, etc., also affect the transition, not to mention that the size of the ETJ is more than double the existing City limits.  Why is it a surprise that there’s explosive growth?

High density developments in Jane’s area started as high-end properties drawing empty nesters looking to simplify their lives.  The aforementioned issues became apparent – parking, noise, traffic, etc.- so they soon became rental properties and the values began to slide.  It should not come as a surprise that many are inhabited by multiple singles splitting the rent, nor should it surprise that Jane’s neighborhood is the test bed for new parking ordinances, noise ordinances and who knows what’s next.

Common sense says that Chapter 42 should not be sprung on all 4 million people at once with most not understanding what it’s all about, particularly since so many people are unaware of its ramifications.  Just three days before the CC vote the Houston Chronicle wrote an OpEd about Chapter 42, but said that it applies to the area inside Beltway 8.  That’s wrong.  If the Chronicle Editorial Board doesn’t know what’s going on, why would City Council expect the rest of the City’s citizens to be any better informed?  At least give the Chronicle time to catch up.  Common sense says implement the changes inside Loop 610 immediately, test the results, then plan a staged roll-out into areas that have been identified as being served by adequate infrastructure or where infrastructure has newly been added in anticipation of densification.  Stage it with expansion of mass transit and commercial revitalization, improved drainage and detention.  But common sense does not seem to hold sway.

Chapter 42 and Growth

April 17, 2013

This is part of a continuation of a series of articles about Chapter 42 and its effects on the city of Houston.

After the City Council hearing on Chapter 42 on April 10th, 2013, it became clear that removal of the Super Neighborhood Alliance’s objections had paved the way for its passage.  Unfortunately, concerns about flooding were not abated and I’m not sure if the well-meaning City Council members understand that Chapter 42 will likely increase flooding and not stem the disparity between growth in the City and its extraterritorial jurisdiction(ETJ).  Depending upon which expert is cited, growth in the ETJ is somewhere between 5 and 10 times the growth in the City.  Developers used this argument to convince Mayor Parker to change the City from and urban/suburban City to a completely urban City – the largest urban-only City in the country; i.e., uncharted waters.  Herein we’ll attempt to shine a penlight into the murky waters.

The growth in the ETJ has been driven by many factors: lower housing costs, jobs, lower insurance rates, planned communities, less risk of flooding, less density, and better schools.  Historically, what prevented moving to the ETJ was the bad commute to downtown jobs, but jobs are leaving the City to relocate in the ETJ so the disincentive is now an incentive.   It should be no surprise.  No matter how big a slab of concrete was poured, within 5 years or so it was almost as clogged as it had been before with  the SW Freeway and I-10 being good examples.  Had Houston pursued commuter rail to give an alternative to the frustrating freeway delays, perhaps the situation would be different.  In the meantime the Grand Parkway (GP or NAFTA Highway, as insiders know it) is being built in the ETJ to service the increasing number of residents.  The GP has already induced growth along it’s planned route as new housing developments spring up to service the new jobs.

Can Chapter 42 bring the jobs back to Houston?  Maybe some, but the Mayor needs to find a way to sweeten the medicine.  Her “because I say so” approach is doing little, except helping her political opponents.  The issues raised by the SNA are real issues that deserve better answers.  Everyone knows that the drainage is defined in a different manual, and parking is in a different chapter, and noise is still undefined, but the reality is that they are all related to increased density, so all need to be addressed before moving forward.

It’s difficult to believe that the City spent 6 years on this one chapter and never considered the need to deal with related issues.  Now we are.  Chapter 42 and Chapter 9 need to be harmonized – right now they don’t agree.  It shouldn’t take six years, but it certainly should be given more than two weeks.


Bad experiences with Chapter 42 redevelopment inside Loop 610, convinced the Super Neighborhood Alliance (SNA) to mount a sustained effort to improve Chapter 42 of the City Code of Ordinances prior to it’s extension from its current limit of within Loop 610 to encompass the entire City and the extraterritorial jurisdiction (ETJ).  The SNA has been concerned that the increased density will require additional infrastructure, including additional stormwater drainage, so had recommended changes to “grandfathering” clauses in Chapter 9 of the Public Works and Engineering (PW&E) Infrastructure Design Manual.

As a result of the SNA request, Mayor Parker asked that CM Costello engage the engineering community to suggest revisions to  Chapter 9 regulations associated with “grandfathering” detention; i.e., the regulations that say that if a property is already paved, then no detention is necessary when the property is redeveloped.  One week before the hearing before City Council about the latest Chapter 42 revisions (held on Wednesday, April 10th, 1013), members of the SNA met with CM Stephen Costello to discuss changes that his group had recommended be made.  On Friday, April 5, PW&E released their latest Chapter revisions, which included parts of the requested revisions,  so the SNA called an emergency meeting on Monday, April 8, to try to disseminate the information to as many Super Neighborhoods as possible. CM Costello was asked to be the keynote speaker and graciously accepted.Houston & ETJ

Chapter 42 will have an impact on all of the City of Houston and the extraterritorial jurisdiction (ETJ), not just the area inside Loop 610 that’s arbitrarily defined as urban.   That’s a very large area – much much larger than the area inside Loop 610.  To see just how large, click on the map to the right.  Not all requirements apply to the ETJ, but enough do that the not yet annexed areas should be aware.  From Chapter 42:

Sec. 42-2. Scope.
This chapter shall apply to all development and subdivision of land within the city and its extraterritorial jurisdiction. This chapter establishes the general rules and regulations governing plats, subdivisions and development of land within the city and its extraterritorial jurisdiction to promote the health, safety, morals and general welfare of the city and the safe, orderly and healthful development of the city.

The equations that the engineers have defined may be based upon sound science, but they do precious little to prevent flooding in Houston.  In fact, for “grandfathered” areas of between 1 and 10 acres (100% concrete), developers would only need to add about 4% of the area in acre-feet of detention.  For “grandfathered” areas of between 10 and 50 acres (100% concrete), developers would need to add more, as defined by the equation, up to a maximum of 7.5% of the area in acre-feet of detention. For relative numbers, ground that has never been covered in concrete (and this is a necessary distinction) would need to add 50% of the area in acre-feet of detention.  If the ground has ever been covered in concrete, it is grandfathered, even if the concrete was removed and the land remained dormant for years.  PW&E should remove this onerous definition for several reasons, primarily because it is difficult to verify.  There are numerous examples where PW&E incorrectly claimed 100% impervious cover and allowed a developer to completely pave over the ground without the need to mitigate for any stormwater runoff.  Satellite photographs often tell a different story.

We’ve created a simple Excel spreadsheet that allows you to calculate the amount of detention for a property.  In the orange box, insert the development area in acres.  The percentage of new impervious cover (Aii = new concrete) is in the left column and the percentage of redeveloped impervious cover (Aei = old concrete) is along the top row.  The intersection of the row and column is the amount of detention reREAL 100 year floodplainquired.

Why are we so concerned about detention?  Lots of reasons, but perhaps the most important is that the City is very vulnerable to flooding.  In order to understand why so many people flooded in April, 2009, TIRZ 17 used a two dimension computer model in its Regional Drainage Study to determine stormwater sheetflow in the area around it’s boundary.  The image at the right shows the Study area north of I-10 and the actual 100-year floodplain (there’s a similar map south of I-10).  FEMA defines the 100-year floodplain as water that exits from a bayou or drainage ditch that floods the surrounding area.

What FEMA doesn’t define, and every hydrologist and civil engineer understands this, it that it is the water that cannot get to the ditch or bayou, the overland sheetflow, that causes the most flooding.  That’s the area in green in the picture.  The property that is outlined in yellow is a 46-acre property that failed to install detention and raised the property an average of about 1.5 feet.  Once the lowest property in the area, it’s now the highest, and as a result, many 50-year old homes that had never flooded, flooded in an event that was estimated to be between a 10 and 25-year event.   These are deed-restricted neighborhoods and residents recognized early on the problem and raised the issue with PE&E and the City, but were ignored.

This example is mirrored throughout the City and continues even inside TIRZ 17, despite our efforts to stop it.  Likely it has happened within your neighborhood, or will happen.  CM Costello says that it’s an enforcement issue because the regulations clearly say that sheetflow patterns cannot be interrupted.   If the City is unable to enforce regulations already in place, why should we expect them to enforce regulations when the new regulations are extended to an area many times the size of the existing urban area?  In these budget constrained times, should we expect that the City will multiply its staff many-fold? Probably not.

CM Costello said that the way to solve the flooding is with sub-regional detention ponds – huge detention ponds judiciously spaced throughout the City.  That could work, but there are several problems:

  • They need to be located where they can do the most good and be large enough to handle vast amounts of water – for a 100-year event, say a hurricane, consider something a few inches over a foot deep spread over several square miles.  How deep is defined by where in Houston you reside, but range from 13″ to 19″ in 24 hours.  Consider that the City of Houston encompasses 600 square miles, not including the ETJ, so if one sub-regional detention pond is placed per square mile, then 600 detention ponds would be needed with a capacity of over 640 acre-feet each.  One pond in TIRZ 17 is 44 acre-feet and costs $26 million.  That’s high.  Land cost was about $8 million and most of the rest was because residents weren’t listened to when they warned that the channel and the bridge would have to be rebuilt. Let’s consider a typical cost might be half that.   There are nearly 15 44-acre ponds per 640 acre pond, so one sub-regional pond might cost about $190 million.  One for each square mile would be over $114 billion dollars.
  • All City streets are supposed to be capable of handling a 2-year rain event under the street and a 100-year rain event within the street ROW.  Most cannot handle a 2-year event, much less a 100-year event, yet somehow all this water is supposed to be conveyed to a sub-regional detention pond perhaps a mile away.  For example, Arthur Storey Park surrounds a large HCFCD detention pond near Bellaire Blvd and Beltway 8 along Brays Bayou, yet the intersection routinely floods because the conveyance system cannot move the water the tenth of a mile, or so, to the pond.  Of course that detention pond wasn’t purposed as a sub-regional pond, but it illustrates that building the pond is only part of the cost.

This is back-of-the-napkin math, but the take-away idea is that the cost and time required to build such a system, even scaled to a tenth, would likely prohibit its completion and who would decide which tenth would be protected.  Houston has a history of not keeping its promises and a history of cronyism, so there will always be backroom deals and unwarranted variances.  Keep in mind, too, that the Rebuild Houston Developer’s Fee only provides $1.5 million per year.  At that rate, it would take over 125 years to build one developer-funded sub-regional detention pond.

The infrastructure required for the density proposed is much more than just drainage.  It is also water and sewer service, trash and maintenance, police, fire, power and lighting and the vast majority will be paid for by the taxpayer.  Even if the City is only responsible for those services that occur within the City limits, it still represents a sizable investment, and it’s not likely to keep pace with development.  In the meantime, streets that were designed for suburban use will need to carry more runoff water, and neighborhoods that haven’t flooded in the past will likely flood in the future.



Memorial Examiner article about Jim Blackburn’s presentation.

“A combination of actions by governmental entities and developers have exacerbated flooding problems in Memorial City and West Houston, environmental attorney Jim Blackburn said Wednesday.

Blackburn addressed the Memorial City District Drainage Coalition’s annual meeting on March 20, to a crowd of about 100 residents, including several Houston city council members and candidates for council positions, and representatives from Super Neighborhoods.

Blackburn said the flooding and drainage problems in West Houston aren’t isolated, that similar situations exist across the region.

But MCDDC is a unique group, he said. Blackburn used a presentation put together by members of MCDDC.

“This is one of the neatest collaborations I’ve worked with, and I’ve worked with a lot,” said Blackburn, who, besides being a partner in the law firm Blackburn and Carter also teaches at Rice University and is co-director of the SSPEED Center at Rice. “These citizens put together most of this information.”

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