Serving Kerr County with a Conscience

Flood Protection Inadequate in Kerr County

If you are new to Kerr County, and even if you have lived here for some time, you may not know that you live in “Flash Flood Alley”—an area that has some of the worst flash-flood prone land in the world. In the past 83 years, Kerr County has had some truly horrifying floods. The one most remembered for our area, for the deaths and the property devastation, was the August 2, 1978 flood—but other major floods occurred in 1932, 1946, 1952, 1987, 1991, 1997, and, the last big flood, in 2002.

While most people believe that they won’t be affected by a big flood, the truth is, they are wrong; if anything, the chance of experiencing a disastrous flood in the Hill Country has increased. Global warming has created extremes in weather, resulting in more severe tropical storms sweeping in from the Gulf of Mexico. The drought that has plagued the Hill Country since 2006—with the terrible, worst year of 2011—has denuded terraces, and swept away topsoil, exposing the bedrock of the ancient seas. Water flows faster across these devastated landscapes.

There are many issues involved in floodplain management, and in the next few weeks we intend to explore these issues and explain why, at the current time, protection from killer floods is not being handled properly in Kerr County. (See “Old River Road RV Park Being Built in the Special Flood Hazard Zone.”)

Altering the floodplain of the Guadalupe River, as well as the floodplains of its major streams, changes the way that water flows and is allowed to drain. Under federal law, FEMA—the Federal Emergency Management Agency—is responsible to insure that citizens have protection from flooding. FEMA enters into contracts with local governments to carry out floodplain management. Kerr County’s floodplain management is carried out by Road and Bridge, and the county hires a part-time engineer, John Hewitt, as the “Flood Plain Administrator” (FPA.) The City of Kerrville has its own FPA, and manages the floodplain within its city limits. Even though there are many issues with floodplain management right outside the city—in the ETJ (Extra-Territorial Jurisdiction), these areas are managed by the county.

Today, more than ever before, the politics of floodplain management place people at risk. It’s all about money. Developers do not want to be told that they cannot build in the floodplain. Cities and counties don’t want to be told that they will not receive tax revenues from a particular land parcel because it is in the floodplain, and should not be developed. Private property owners do not want government interfering and telling them what to do with their land. Sadly, there are corrupt engineers that manipulate the floodplain to allow developers the maximum use of their property—at the expense of the public.

Do you live in an area that has flooded in the past? In the final analysis, you should find out. Subdivision developers won’t tell you, realtors won’t tell you, and most of the time, local government won’t tell you. The lives of your family, your pets, and your property may depend upon taking the initiative yourself and preparing for the next big flood.

Areas that we will be exploring:

  • Why does eastern Kerr County—the Ingram, Hunt, Kerrville, Center Point, and Comfort communities—experience such deadly flash floods? What climatic forces are at work that create record rainfalls in short periods of time?
  • Have we learned from the floods of the past? “Historic Floods in Kerr County”
  • Eyewitness accounts of flood survivors
  • Floodplain Administration: How are floodplains determined in Kerr County? FEMA requires that communities be involved in floodplain determination. This hasn’t happened in Kerr County.
  • As a citizen, what rights do you have, and what access to local government do you have, if you are concerned about flooding around your property?
  • Between Kerrville and Comfort, there are several major streams that flow into the Guadalupe River. In the past, these streams have contributed significantly to death and destruction by floods; yet most of these streams are unrecognized, not studied, and not taken into account when developers want to build in the floodplain.
  • Much of Kerr County has FEMA maps that are old, hurriedly put together in the first place, and are just plain wrong. What can we do to update these maps?
  • As a community, what can we do to insure that floods of the past will not be forgotten, and that newcomers are more aware of the dangers of living in “Flash Flood Alley?”
  • Without adequate scientific information, floodplain decisions cannot be made accurately. How can we all work to insure that confluence water rises, cresting heights, and water inflow from streams are gauged and recorded?

Mary Matthews

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​An Unsafe Septic System

The septic system under construction for Old River Road RV Resort bypasses safeguards for public health and safety. An onsite septic facility (OSSF) is being installed with tanks and drain-fields designated for servicing 25 people or less. OSSF’s are the usual residential systems.

The RV park’s septic system lies over the Guadalupe River’s recharge zone. Installing a septic system on the RV park site is not contraindicated. However, the Texas Commission on Environmental Quality (TCEQ) has specific rules and precautions for RV septic systems, they are more expensive than an OSSF. The Environmental Protection Agency refers to such systems as large capacity septic systems (LCSS). The TCEQ standards are based on the 5000-gallon rule—any project producing 5000 gallons of sewage per day requires a large capacity septic system application and oversight by the TCEQ. The RV developers evade this rule and TCEQ oversight by dividing the 240 unit development into three sections, each needing less disposal capacity than 5000 gallons.

RV parks present specific problems for septic systems. In addition to the higher volume produced by the convergence of people within a small area, the waste is more concentrated because less water is used in RVs. Toilet contents are made more caustic by strong chemicals and deodorants used to control tank odors. These conditions accelerate corrosion and septic system failures. The LCSS rules are designed to extend the life of a septic system from the usual 15 years to 30 years. Still, RV septic systems often fail prematurely.

The septic permit issued to the RV park compromises the health of the Guadalupe. The riverbank, adjoining terrain and fields serve as a sponge, absorbing water during wet weather. Referred to as riparian, its water continually migrates through the soil toward the river. Seeps and springs from riparian zones replenish the river during drought and are essential to its continuous flow and health.

The RV park’s septic tanks and drain-fields are embedded in this riparian sponge. We can expect the heavier than normal bacterial count and untreated caustic chemicals percolating from the septic system to mix with the naturally migrating water and seep into the adjacent Guadalupe. The predictability of early tank corrosion and system failure presents the risk of surface pollution draining directly into the river. The health and safety of RV park occupants is in immediate danger with such surface contamination.

Survival of the adjacent public recreation area, Brinks Crossing, is questionable. This Guadalupe swimming hole named the third best in the state in a 2008 edition of Texas Monthly and again hyped in 2012, receives the runoff, seeps and migrating water directly from the RV park’s septic system. Additionally, the river will carry any fecal and chemical contaminants the short distance downstream to Lions Park Dam, a busy swimming destination for children. Is it possible river contamination at this site could sacrifice the Guadalupe as a statewide recreational attraction?

There are no public safeguards such as inspections for breakdowns, measuring river contamination or ensuring repairs when failures occur. Kerr County’s Environmental Health Department who issued the OSSF permit is not staffed for such monitoring. The department depends upon the public and owners to self-report failures. Can we expect this owner who is avoiding the safety of an LCSS system and TCEQ oversight to self-report?

Many Texas counties have specific rules for construction of RV park septic systems. Kerr County has no guidelines, nor do we have a licensed sanitarian available to counsel our county employees tasked with issuing the RV park’s OSSF permit. Of course, the accepted path of following the 5000 gallon rule would assure TCEQ oversight of planning, construction and maintenance through an LCSS permit.

Our county officials spent untold time and energy plus $3 million on the Kerrville South Wastewater Project designed to replace failing residential septic systems polluting a Guadalupe tributary. A similar plan, the Center Point Wastewater Project, will cost an estimated $44 million to replace deteriorating OSSF’s threatening the river. Now county officials ignore the RV park’s immediate source of contamination—drain fields leeching into the riparian’s recharge. The septic tanks and connecting systems are at high risk for failure long before their 15-year lifespan is reached.

Elected officials are aware of the project’s health and safety issues. They also know that TCEQ oversight of this septic system could prevent much of the damage. Does it seem reasonable for authorities to ignore or perhaps support the creation of another site, sure to require taxpayer funding for cleanup, while the Center Point project is still in the planning stage? Is it possible the RV park site will need cleanup before the Center Point project is completed?

Frances Lovett

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​RV Park Safety

The beginning construction of the Old River Road RV Resort presents several public safety concerns. The most urgent is the predictability of lost lives during flooding. Yes, predictable, because this RV park is located within a dangerous portion of the floodplain. The project sits at the confluence of the Guadalupe River, Turtle Creek and Nowlin’s Hollow which assures rising water during heavy rains. Whether deluges occur in Turtle Creek’s watershed to the southwest, the Guadalupe’s from the west, or Nowlin’s Hollow from north of the airport, each presents the probability of life-threatening water rises. A rain event involving any two or all three of these watersheds assures walls of water and overwhelming flooding within minutes. The view from Highway 27, just east of the airport, explains why. The site is a small, bowl-shaped valley, surrounded by hills on three sides. The remaining boundary is the river. Drainage is limited to the southeast corner along the Guadalupe’s narrow outlet. The potential volume of accumulating water is far greater than emptying capacity.

Historically, there are two landmarks on the valley’s eastern ridge, a family home and an iconic oak tree marking the site of the Welborn family cemetery. Edward Wellborn lived there as a child and recalls the 1932 flood filling the entire valley. Only the house and cemetery oak were visible above water.

Debris in cypress trees confirmed that Turtle Creek crested at 42 feet at this convergence in the 1978 flood. Photos of the Monkey Island area, adjacent to the park, show huge Cypress stumps uprooted and deposited there during flooding. A naked eye observation reveals the RV site resting on lower ground than the Cypress stumps. One Center Point resident recalls working as a young man to remove cypress trees and stumps deposited in the valley’s field during floods . . . the same field the RV Park will occupy.

In a Hill Country flood the valley will fill rapidly with turbulent floodwaters. Evacuating the planned 240 RVs and their occupants becomes a public safety issue. The only exit is the steep uphill entrance in the southeast corner at the convergence of water from Turtle Creek and the Guadalupe. How much warning is needed to avoid the chaos of a bottleneck at this exit, because it is only wide enough for one RV at a time? How many RVs will be disabled by even a few feet of water flooding into the park?

Many of those fleeing will be retirees and elderly, unable to meet the physical challenge of escaping rushing water and climbing steep hillsides. Rainwater cascading down the hillsides would only diminish their chance of survival. Will a quarry bordering the northeast corner of the Park fill with water from Nowlin’s Hollow and add to the chaos?

Any RV fortunate enough to drive out in time faces the possibility of being swept away. A right turn out of the park runs into a flooded low water bridge at Brink’s Crossing. A left turn carries an RV along the narrow River Road sandwiched between Drymala Quarry berms and the Guadalupe. A ditch draining water from the berms increases the likelihood of water washing over the road and possible washouts.

Kerr County’s Flood Plain administrator has approved a no rise certificate indicating that the RV park’s presence will not obstruct the normal flow of water during river rises. The purpose is to protect upstream property owners from back-up and higher floodwaters. Who considers the safety of the RV Park customers facing the same floodwaters, especially if a flash flood occurs at night?

Frances Lovett

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RV Park Update

The RV Park plan proposed by Richard Colvin in 2009 did not materialize. Financial hardship entered the picture for Colvin. When he was unable to obtain financing, Victoria National Bank of Corpus Christi, Texas foreclosed. In June 2011 the bank held an auction on the site, but a sufficient bid was not obtained. In November of 2012, the property was purchased by William Sturges, also of Corpus Christi. He moved forward with plans for another RV park, called Old River Road RV Resort.

Frances Lovett

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