Lone Star Club-CS 971212 MEMORANDUM
FROM THE
DEPARTMENT OF ENGINEERING
To: Peter Smith, City Attorney
From: Ken Griffin, P.E., Director of Engineering and Public Works
RE: Lone Star Country Club/John Robinson property
Date: December 12, 1997
It was recently brought to my attention that fill dirt has been placed and is continuing to be placed
on property that was owned by KKR, Inc. This property is commonly referred to as the John
Robinson property/Zone Star County Club. As you are aware, there have been numerous
conversations with Mr. Robinson over the years about the proper approach on placing fill on his
property.
This week I visited the site and was fortunate enough to encounter one of the truckers and obtain
some intbrmation. On December 11, 1997, I received a call from Richard Jackson representing
himself as the attorney for the property owners. Mr. Jackson stated that dirt was being placed on
the property to rebuild Ledbetter Road. I explained to Mr. Jackson that our Floodplain
Ordinance has certain requirements that need to be complied with prior to placing any fill dirt in
the floodplain, whether that be for reclamation of property or for construction of roadways. Mr
Jackson operates as:
Richard Jackson and Associates
5115 McKinnev. Suite D
Dallas. TX 75205
(214) 522-5977
Mr Jackson would not provide any information about the owner of the property. When I
referred to it as the Robinson tract, he did state that the property had changed ownership recently
He would not tell me if Mr. Robinson was still involved with the property. The only name he
would provide to me is that the property is owned by a company called Afghan Emerald, Inc Mr
Jackson would not divulge if John Robinson, Kamwell, Inc. or KKR was still involved with the
property Chad Beach has checked with the County and discovered that about two months ago
KKR conveyed the property to Rostam Development Limited. A copy of the deed was faxed to
Bruce Stockard.
Because of the long histoD' of City involvement with this property, Jim Witt has suggested that
this be passed directly to vou
It is my opinion that the placement of the dirt on this property is a violation of Ordinance 94639
which is referred to as the "Floodplain Management Ordinance".
In the ordinance the definition for "Development" states "any manmade changes to improved or
unimproved real estate including ... filling.., within the floodplain management areas of the City'
In the same section, the definition for "Floodplain Development Permits" states "a permit which
must be obtained by any person before any development begins on land within a floodplain"
Article 3, Section D of the Ordinance states that "no structure or development of land shall
hereafter be constructed, located, extended, converted or altered without full compliance with the
terms of this ordinance and other applicable regulations". Section D also establishes penalties for
noncompliance..-~"ticle 4, Section B, paragraph 11 states "floodplain development permits are
required for all new development in floodplain management areas of the city" and that prior to
floodplain development permits being issued, conditional approvals must be obtained from
FEMA. To obtain the additional approval from FEMA, obviously, technical information needs to
be provided showing the impact of the fill on the floodplain and the properties both upstream and
downstream This is typically done with technical information commonly referred to as a I4_EC II
study. None of this information has been provided to the city.
In addition to the noncompliance to the Floodplain Management Ordinance, it is my opinion that
the placement of this dirt is also a violation of Ordinances 93634 and 97814. These ordinances
refer to the Trinity River Corridor Development Certification. Because this property is in the
floodplains of the Trinitv River, not only does it need approval from the City of Coppell and
FEMA it also requires notification to the following: City's of Arlington, Carrollton, Dallas,
Farmers Branch, Fort Worth, Grand Prairie, Irving and Lewisville; the Counties of Dallas.
Denton and Tarrant: and also the Tarrant County Water Control Improvement District ,e 1. Trinity
River Authority of Texas; United States Aa-my Corps of Engineers; and the North Central Texas
Council of Government Anyone of those entities can voice objections to the development.
however, the ordinance is very clear that the final granting of any permits rest with the city in
which the development originates.
My goal in this situation is to bring about the removal of the fill that has been placed on the
property and to insure compliance with not only the Floodplain Management Ordinance but the
Corridor Development Certificate..Any assistance you can provide the city in helping to facilitate
the removal of the dirt will be greatly appreciated.
If you should need additional information or clarification please contact me as soon as possible so
this issue can be resolved
cc Jim Witt, City Manager
Clay Phillips, Deputy City Manager
Lone Star file