Off the Kuff Rotating Header Image

Your feedback requested on Chapter 9

From the Inbox, from CM Noriega:

Council Member Melissa Noriega announces a Special Called Transportation, Technology & Infrastructure Committee meeting Wednesday, June 12, 2013 at 5:00 p.m. TTI committee members will review the changes to Chapter 9, Stormwater Design Requirements, Chapter 13, Stormwater Quality Design Requirements and receive public comments.

The Standards Review Committee (SRC), Department of Public Works and Engineering (PWE) was established to review, revise, and update PWE’s Standards and Documents. The Public is invited to provide their input and to participate by the submittal of proposals for suggested changes, comments, recommendations and other information. The deadline is Friday, May 24, 2013.

In this year’s review cycle, SRC has reviewed Infrastructure Design Manual Chapter 9, Stormwater Design Requirements and Chapter 13, Stormwater Quality Design Requirements and the associated design specification and details on the basis of comments received from all interested parties.

The SRC’s draft versions of the recommendations are posted at this link.

All the interested parties are asked to please review the recommended changes and provide comments for the final review by no later than Friday, May 24, 2013. After that time the committee will review all the final comments and authorize the City Engineer to publish the 2012-2013 version of the Infrastructure Design Manual by July 1, 2013.

You can provide your comments two ways:

For more information contact Rajiv Arya at 832.394.9131or at email:

Also from the inbox, via Ed Browne:

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 key 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 9.01.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 subregional 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.)
  • Subregional (huge) detention ponds have been touted as the City’s savior by several Houston Mayors, but they are not.  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 subregional detention ponds, each of about 640 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, and 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 subregional 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 subregional 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.  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.H.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 for the June 12th meeting or to send comments to the City (

Finally, the Planning Department will hold numerous community meetings to discuss the recent changes to Chapter 42:

Thursday, May 23, 2013, 10:00 a.m. to 11:30 a.m.
Sunnyside Multi-Service Center
9314 Cullen
Houston, Texas 77051

Thursday, May 23, 2013, 6:30 p.m. to 8:00 p.m.
Northeast Multi-Service Center
9720 Spaulding
Houston, Texas 77016

Wednesday, May 29, 2013, 6:00 p.m. to 8:00 p.m.
Briar Grove Elementary School
6145 San Felipe
Houston, Texas 77057

Wednesday, May 29, 2013, 6:00 p.m. to 8:00 p.m.
Avenue CDC Home Ownership Center
707 Quitman
Houston, Texas77009

Thursday, May 30, 2013, 6:00 p.m. to 8:00 p.m
Garden Villa Community Center
6720 South Haywood Drive
Houston, Texas770612

Monday, June 3, 2013, 6:00 p.m. to 8:00 p.m
La Fontaine Reception Hall
7758 West Tidwell
Houston, Texas 77040

Thursday, June 6, 2013, 6:00 p.m. to 8:00 p.m.
Freed Community Center
6818 Shady Villa Lane
Houston, Texas 77055

Tuesday, June 10, 2013, 7:00 p.m. to 8:30 p.m.
Willowridge High School
16301 Chimney Rock Road
Houston, Texas 77053

Thursday, June 10, 2013, 6:00 p.m. to 8:00 p.m.
Jefferson Davis High School
1101 Quitman
Houston, Texas 77009

Tuesday, June 18, 2013, 6:00 p.m. to 8:00 p.m.
Memorial Drive United Methodist Church
12955 Memorial Drive
Houston, Texas 77024

To learn more about this program and download applications, visit

Related Posts:

Comments are closed.