UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
C5
1445 ROSS AVENUE, SUITE 1200
DALLAS, I X 75202-2733
July 11, 2017
Mark Wyatt Director, Program Administration Water Supply & Infrastructure Texas Water Development Board1700 North Congress Avenue Austin, Texas 78711-3231
Dear Mr. Wyatt,
Thank you for your inquiry regarding the City o f Houston's request to use the 'Texas Water Development Board's Clean Water State Revolving Funds (CWSRF) for channel modifications, bridge modifications, and construction o f regional stormwater detention basins as paid o f the Bayou Brays project We have determined that while there are many aspects of the Bayou Brays project that would be eligible for CWSRF funding, the bridge replacement and/or modification is not eligible under 603(e)(5) nor any other section o f Water Resources Reform and Development Act. Though the project description makes it clear that flooding, is causing a number of problems, the Brays Bayou project is more about reducing flood risks than water quality.
Other aspects of the Bayou Brays project are eligible for the CWSRF, such as the construction o f the stormwater detention basins, Regarding utilization of the CWSRF for channel widening, we have determined that Section 603(c)(7) is not the most viable resource to address increased resilience o f a treatment works system. We suggest that the City of Houston consider an alternative approach such as constructing berms around the treatment works system, to protect the system against, possible impacts of future flood events. We understand that sanitary sewer overflows resulting from flooding of the Brays Bayou is also a concern for the City o f Houston. While this may he a factor, a more pressing concern may be that sanitary sewer overflows are occurring due to inflow and infiltration during wet weather events. We suggest the City o f Houston consider the replacement o f impacted pipe to address this inflow and infiltration issue.
Because we have consulted with Sheila Platt, Team Leader o f the United States Environmental Protection Agency's CWSRF Program regarding the eligibilities o f various aspects o f this project, we are copying her on this response. If you have any questions, you can contact me at 214-665-3172 or hovvard.amber@epa.gov, or David Reazin of my staff at 214-665-7501 or reazin.david@epa.gov.
Sincerely yours.
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eCC: Sheila Piatt, EPA Sierra Club v. EPA 18cv3472 NDCA
Amber Howard Acting Chief Community Infrastructure Section Water Division
Tiers 8&9
ED 002061 00094910-00001