The Benefits of Flood Mitigation Must Be Considered


Thank you for your attention to this issue so dear to myself, my neighbors & my community. Until recently I have remained cautiously optimistic concerning both added fresh water supply and much needed structural flood mitigation. It’s no secret that recent water supply forecasts are cause for alarm, demanding a regional effort to increase our sources of fresh water for both household and agricultural use.

The most logical solution, in my mind, involves capturing water during periods of severe excess, allowing the periodic deluges to fill our aquifers, rather than flood our homes and businesses. Efforts have been made in the past to mitigate the damaging effects of rare, yet catastrophic, flood events. In 1984, a dam feasibility study was conducted, which proved that while taking into account only the protection afforded to Comfort, 78% of the benefit requirement was met for a multi-purpose structural project to move forward. Not only did that study fail to quantify the significant potential water resource, which would be so welcomed now, but the study did not include the protection afforded to Sisterdale, Spring Branch, Bergheim, Canyon Lake and even New Braunfels.

The Hill Country missed out on a surplus supply of fresh water for decades since 1984 because the benefits of a multipurpose flood mitigation structure on Cypress Creek were not fully examined, resulting in a mere 22% shortfall of expected return. Three years later ten young campers tragically lost their lives to the very same waters that should be a boon, not our bane. A few years ago my friend since childhood lost his mother near Canyon Lake to the same waters flowing from our hills. What was so sadly missed in 1984 was the realization that every ounce of flood mitigation performed here at the headwaters benefits every community and family all the way to the Gulf of Mexico. Every opportunity missed puts them in danger.

My hope, and the hope of the Comfort Floodplain Coalition, is that the benefits of added water supplies and the benefits of flood mitigation are not considered separately as they were in 1984, but instead viewed as an overwhelming whole, demanding the same mutually beneficial solution. Multipurpose structural flood mitigation will spare our families thirst and shield our communities from drowning.

Comfort has been drowned not only by water but by the economic effects of strict FEMA regulation, as well. Property values, and therefore county revenue, have suffered greatly by the inability of property owners to maintain or improve their homes in the floodway. The floodway stretches nearly 4 blocks wide from the Cypress Creek, only to be met by another flood zone encroaching from the north, leaving a one block sliver of unregulated land in downtown. According to the Flood Insurance Rate Map (FIRM) there is nearly no flood plain, as this boundary is often less than 10 feet wide along Main Street, relegating most affected properties to be designated “no-build” zones.

The Cibolo Creek, a similar water course that bisects Boerne along Hwy 46, possesses a floodway that reaches a mere thirty feet, barely crossing the road. Comfort’s floodway, on the other hand, stretches up a twenty foot rise, covering the distance of two city blocks and consumes the entire football stadium at which I participated in so many scholastic events. Why are the areas affected by strict regulation so drastically different between these similar watercourses? The answer is Boerne Lake, combined with three smaller flood mitigation structures, affording the residents of Boerne the protection we all deserve. Revision of the broad floodway designation in Comfort would naturally follow any significant mitigation project on Cypress Creek, just as Boerne benefited from such structures.

The special meeting of the Kerr County Commissioners Court held on June 18th, 2013, was very encouraging to those who would like to see a solution to both water shortage and periodic flooding. The grant awarded to Kerr County, Kendall County, Upper Guadalupe River Authority, Headwaters Groundwater Conservation District, Cow Creek Groundwater Conservation District, and the Kendall County W.C.I.D. Number 1 of $69,400 by the Texas Water Development Board is a welcome sign of progress. Even more heartening is that these governmental entities are working together to finally address these issues. From my understanding, this is the first time a collaborative regional effort has been made on a project such as this in the Hill Country.

Kerr County Commissioner Letz stated, “The current grant is a ‘Regional Water Facility Planning Grant’. This study is not specifically looking at flood mitigation. It is unfortunate that grants are usually limited in scope. We requested the ability to look at potential flood mitigation projects as part of this grant and were told that this would not be funded under this grant. This grant will look at potential sites for water retention and it may be possible to later join the projects. A specific flood control study / grant needs to be done and I believe Kerr County would support this study. I also think that Kendall County will need to be involved as Comfort is in Kendall County.” Letz continued, “I am very excited about this initial planning grant as it is the first regional study done for Eastern Kerr County and Western Kendall County. We need to partner with all the governmental entities to come up with a regional solution. While the current grant focusses on water supply and water facilities, we can hopefully obtain another grant to re-look at flood mitigation. Hopefully, a feasible solution can be found that will solve both issues.”

The study funded by this grant will examine what options will best fulfill the needs of the project at a given cost. My concern, as stated earlier, is that the goals of the ultimate project must include flood mitigation, improving the safety and wellbeing of everyone lucky enough to live in the green, healthy environment near our many waterways. The recent efforts and subsequent progress made by our elected officials, proactive citizens and civil servants has nourished my optimism regarding the future of Comfort and strengthened my confidence in our greater community of the Texas Hill Country.


Emmanuel Flatten

Minutes of 6-18-13 Commissioners Court: 

Video Comparing the Boerne and Comfort Floodway boundaries: