25 Aria Isle Drive · Lot 4, Block 1, Lake Woodlands East Shore Sec 16 Replat No 1

Lot 4 Datum Investigation

An independent, neutral review of every elevation, datum, survey, plan, certificate, email and meeting in the project record that bears on vertical control, flood risk and plan coordination at 25 Aria Isle — with what is confirmed, what is only asserted, what conflicts, and what is missing.

Prepared27 Aug 2026, from the record as of ~3:45 pm CDT

MethodEvery document opened and read visually; external facts re‑verified at NGS, FEMA and Montgomery County on 27 Aug 2026

Not providedConstruction authorization, legal advice, or engineering conclusions — each open question names who must answer it

Full textdocs/2026-08-27-Lot4-Elevation-Survey-Control-Flood-Investigation.md

Labels:FACT verified in a document · STMT a person's statement · CALC my arithmetic · INFER my inference · CONFLICT evidence disagrees · MISSING not in the record

Each rod plots the values exactly as they appear in their source documents. The rods are drawn to one scale but deliberately not aligned: the record contains no surveyed tie between them. The red band is the FIS 0.2 %‑annual‑chance water surface at Panther Branch cross‑section Q (≈130.0 ft NAVD88, three readings 129.9–130.15).

1 · Executive summary

Three vertical reference systems are in use on this lot, and no signed document ties them together. Rod P ("brass disk found 130.95", Precision Surveyors 2023; no datum named) carries the arch R3 site plan (FF 133.5) and the Dunaway civil C1.0 (133.2 / garages 132.5). Rod D (NGS BL1169 = 121.76, "NAVD88 1991 adj") carries the DaRam 2025 topo and arch R2. Rod S (NGS BL1164 = 166.7, "NAVD 1988, 2001 Adjustment") is the STS elevation certificate signed 27 Aug 2026. FACT
The two cut‑X values, 127.56 and 129.69, are the same physical mark in two systems. The R2 sheet reproduces four of Precision's labelled points — cut‑X, manhole rim, gutter, top of curb — each exactly 2.13 ft lower: a uniform shift, not a re‑measurement. Whether the mark survived site clearing is unknown. FACT CALC MISSING
The recorded subdivision plat declares its own benchmark on an old datum: "3" brass disc … stamped 'ESL‑16 R1', ELEV. = 134.92' (NAVD 29, 64 ADJ.)" (Cab. Z Sh. 8621‑8623, recorded 24 May 2022). This is the first documentary support for the field claim that "Woodlands" control differs from current NAVD88. Whether the 130.95 disk is that monument is not established. FACT MISSING
The certificate's benchmark value and datum label do not match each other. NGS publishes BL1164 = 166.7 ft as its current GPS‑derived height (epoch 2010.00, with a land‑subsidence warning); NGS's 2001 value for the same mark is 51.05 m = 167.49 ft. FEMA's instructions say that where subsidence exists "the most recent reference mark elevations must be used" — so the value may be defensible, but the label, the 8.7‑mile transfer method, and any second‑mark check are undocumented. FACT CONFLICT
On the certificate's own numbers the flood margins are small and sit inside the datum uncertainty. Against a 0.2 % level of ≈130.0 (129.9–130.15), the certified floor (130.5) is 0.35–0.6 ft above, the garage slab (130.3) 0.15–0.4 ft above, and ground at the building (129.0) is below it. The county's 2‑ft‑above‑BFE condition (BFE 128.3 / 128.0) is met by the house by 0.2–0.5 ft and by the garage by 0.0–0.3 ft — valid only if the EC datum is the FIS datum. CALC
The implied offsets between systems disagree, so at least one number is not what it is assumed to be. Design‑to‑EC implies P − S ≈ 3.0 ft if the forms sit at "133.5 (P)"; road‑centreline comparisons imply 2.2–2.8; DaRam‑to‑EC road difference is only 0.4–0.6. Nobody has recorded which benchmark Keystone used to set the forms. CALC CONFLICT MISSING
No HOA / ESDC / Woodlands document disputes any survey elevation or states a required slab elevation. The written ESDC condition is "chimney must have a decorative cap" (3/9/2026); the guideline says "Slab elevation must be verified with lot grading plan" — a plan not in the record. Every "the HOA insists on its markers" statement traces to one builder, Steven Hanson (Ultimate Homes USA), describing his own project at 71 Aria Isle. FACT STMT
Plans still disagree with each other: arch R3 FF 133.5 vs civil 133.2; civil garage 132.5 vs no garage elevation on the arch site plan; both sit in the HOA‑approved package. No written reconciliation from Dunaway, Allen Bianchi or STS exists. Structural REV 4 (25 Aug 2026) carries no absolute elevation. FACT MISSING
The flood‑map classification is unambiguous: the building coordinate is in shaded Zone X (0.2 % area, not the SFHA); the AE / BFE‑128 polygon is ≈140 ft from the front‑centre coordinate and closer to the rear of the house; the county permit itself recites "Flood Insurance Zone AE, X SHADED" and the 100‑ft / 2‑ft condition. Whether that condition binds is the Floodplain Administrator's call. FACT
One instrument loop on one stated datum resolves this. An RPLS reads — in a single closed traverse — the STS TBM, the 130.95 disk, the cut‑X (if it survives), plat monument ESL‑16 R1 (if recoverable), the house form corners, the garage forms, the road centreline and the 71 Aria Isle curb X, with the benchmark PID, published value and epoch held, method and closure written on the sheet. Then three written determinations: surveyor, civil engineer, floodplain administrator.

2 · Evidence table — every reported elevation, point by point

Scroll sideways on narrow screens. "Status" is about the document: confirmed as drawn/certified does not mean the value is right for construction.

#	Issue	Value	Exact source	Physical point / meaning	Datum & benchmark stated	Existing / proposed	Status	Conflicting evidence	Missing	Who resolves
1	Cut‑X (R2)	127.56	Arch R2 A1.1 (ILA / Isaac Levy, 9/8/2024); same sheet in HOA forward 1/30/2025	Cut X at SW corner by Wind Whistle Path circle, next to capped iron rod at the P.R.C.; manhole 128.53, gutter 126.78, TC 127.06 beside it	"Based on NGS data sheet BL1169 elevation = 121.76 feet NAVD88"	Existing (2024 sheet)	confirmed as drawn R2 superseded	Same mark = 129.69 (row 2)	Survey R2 was traced from	Architect (ILA) + DaRam
2	Cut‑X (R3 / Precision / civil)	129.69	Precision Surveyors topo, Job 23‑01057, 2/24/2023 rev 3/23/2023, R. S. Willett RPLS 4615; arch R3 A1.1; Dunaway C1.0 "Elevation Information"	Same SW‑corner cut X (identical neighbours: manhole 130.66, gutter 128.91, TC 129.19)	"Elevations are based on brass disk found with elevation 130.95" — no datum	Existing (2023)	confirmed as drawn	127.56 — difference 2.13 at four identical points	Disk datum; whether X still exists	Surveyor (Precision / STS)
3	Brass disk	130.95	Precision topo note; STS Lot 11 survey 19661_survey_r1.pdf (Job 1638‑23, 10/31/2023, F. W. Lawton RPLS 2321) "TBM FND. BRASS DISK ELEV.=130.95" east of Aria Isle Dr. opposite Lot 11	Brass disk near the road several lots north of Lot 4; monument not described	None stated on either document	Existing	provenance unresolved	Plat benchmark ESL‑16 R1 = 134.92 (NAVD 29, 64 adj.) — different value; may be a different monument	Description, setter, stamping, datum	STS + plat surveyor (Jones\|Carter) / LJA
4	Plat benchmark	134.92	Recorded plat Sec 16 Replat No 1, Sheet 3 note (DOC# 2022067239; 3/1/2022, rec. 5/24/2022; Jones\|Carter, R. B. Tarasiewicz RPLS 6575) — sent by Steven Hanson 8/6/2026 with 3 phone screenshots of this note	3" brass disc in 6" concrete column 3' deep, flush with natural ground, stamped "ESL‑16 R1"; location not identified on sheets reviewed	"(NAVD 29, 64 ADJ.)" — apparently NGVD 1929, 1964 adjustment, wording as printed	Existing (2022)	confirmed as recorded tie to NAVD88 unknown	—	Location, recovery, NAVD88 value	RPLS (STS)
5	Road centreline (EC)	127.0	EC form p.3, Section D comments	Some point on the road centreline — location not stated	NAVD 1988 "2001 Adjustment"; BL1164 = 166.7	Existing	certified location unresolved	Precision C.R. 129.19–129.76; DaRam CL 127.36–127.59	Where shot	STS
6	Residence FF (civil)	133.2	Dunaway C1.0 Drainage Plan REV 0, sealed K. J. Breckon PE 73425, 6/11/2025; same sheet in HOA package 3/9/2026	Design finished floor	Implicit Rod P (TBM 129.69). The "(NAVD 1988, 2001 ADJUSTMENT)" line sits under Base Flood Information and describes the FEMA panel	Proposed	conflicts with row 7	Arch 133.5	Written reconciliation	Civil engineer (Dunaway)
7	Residence FF (arch)	133.5	Arch R3 A1.1 (Allen Bianchi Architects; "FOR PERMIT R3", 1/23/2026)	Design finished floor	Implicit Rod P ("brass disk 130.95")	Proposed	conflicts with row 6	Civil 133.2	Which governs; garage FF	Architect + civil
8	Garage FF (civil)	132.5	Dunaway C1.0 (both garages)	Design top of garage slab	Rod P (implicit)	Proposed	confirmed as drawn	Arch A1.1 shows none; EC garage 130.3 is 2.2 below (house: 3.0)	Arch garage elevation; what forms were set to	Architect + civil
9	EC top of bottom floor	130.5	EC p.3, C2.a	FEMA: "top of the bottom floor" (Diagram 1B); building "Under Construction" → in practice the top of form INFER	NAVD 1988 "2001 Adjustment"; BL1164 = 166.7	As‑built form (8/25 visit) or plan value converted — not stated	meaning unresolved	Design 133.5 / 133.2	What was shot; whether any value was "per plans"	STS (Fred F. Lawton RPLS 5530)
10	EC garage slab	130.3	EC p.3, C2.d	Lowest top of attached garage slab (form)	as row 9	as row 9	meaning unresolved	Civil 132.5 → 2.2; "133.5 − 2 in" → 3.0 (assumption)	as row 9	STS
11	EC LAG / HAG	129.0 / 129.3	EC p.3, C2.f / C2.g, "Natural" checked	Lowest / highest ground next to building at time of survey; lot was cleared and levelled by KGW in July	as row 9	Existing (graded)	"natural" doubtful	Precision NG 131.9–132.3; DaRam 130.0–130.4; KGW target ≈132.0	Pre‑ vs post‑grading	STS
12	71 Aria Isle curb TBM	127.99 / 128.68	DaRam survey of Lot 13 (B. D. Adkins RPLS 6137, 1/18/2026), from Steven Hanson 8/6/2026	X on curb in the 71 Aria Isle circular drive (≈1,100 ft from Lot 4 per Kanti; not measured here); X on wall	No benchmark or datum on the sheet; DaRam's Lot 4 topo used BL1169 / 121.76	Existing	confirmed as drawn	Compared by S. Hanson to the 130.95 disk ("2.98 ft") — different points	DaRam's written control statement (asked 8/6, 8/12; no answer)	DaRam (Chris / Barry Adkins)
13	Orange curb paint	130.05	Photograph cited in Kanti's 7/27 memo; quoted by S. Hanson 7/31	Unknown author, point, datum	None	Existing	unverified	—	Who painted it, from what	STS / Keystone / KGW
14	KGW pad target	≈132.0	KGW subcontract; Scott Lowe email 6/24/2026 ("FF 133.5, natural grade averaging 132.0, no pad needed")	Rough‑grade target	Rod P (implicit)	Proposed / as‑graded	confirmed as contracted	EC HAG 129.3	As‑graded survey	KGW / STS
15	BL1164 published height	166.7 (50.82 m)	NGS datasheet, retrieved 8/27/2026 16:19 EDT	Disk "L 1149 1959", 1.4 mi S of Conroe; 8.74 mi from the lot	NAVD88 current, GPS OBS, epoch 2010.00; "area of suspected vertical motion — validate before use"; superseded: 167.49 (12/03/2001), 166.99 (2021), 166.93 (2022), 167.80 (1991 leveling; NGVD29 1987)	—	confirmed	EC label "2001 Adjustment" ≠ 2001 value	Transfer method; validation	STS
16	BL1169 published height	not published	NGS datasheet, retrieved 8/27/2026 16:20 EDT	Disk in railroad culvert headwall 5.1 mi S of Conroe; 5.01 mi from the lot; last recovered 2005; stamping "R 88 1932 122.631"	Suppressed (SE Texas action, 2021); NGS "discourages" superseded heights	—	confirmed	DaRam / R2 use 121.76 "1991 adj"	Source of 121.76	DaRam
17	FEMA zone at building	X (shaded)	NFHL layer 28 at −95.476525, 30.1641083 (EC A5 converted), 8/27/2026	Front‑centre of house: "0.2 PCT ANNUAL CHANCE FLOOD HAZARD", SFHA_TF = F, no static BFE	NAVD88 (FIRM)	—	confirmed	—	Footprint‑level (rear) determination	RPLS / Floodplain Administrator
18	Nearest SFHA	AE, BFE 128.0	NFHL layer 28 with geometry CALC	Nearest AE edge ≈ 42.6 m = 140 ft from the coordinate; floodway ≈ 296 ft; rear of house closer	NAVD88	—	confirmed (GIS)	Permit lists "AE, X SHADED"	Surveyed distance from the footprint	RPLS
19	1 % WSEL (detailed)	128.3	NFHL layer 14; FIS Vol. 5 panel 316P — Panther Branch XS Q, station 35,154	Lake Woodlands reach	NAVD88	—	confirmed	FIRM label "EL 128"	—	Floodplain Administrator (which governs)
20	0.2 % WSEL	≈130.0	FIS profile 316P (graph reading ±0.2); DaRam note 130.15; Faisal Awad 129.9 (8/4/2026)	Water surface at XS Q	NAVD88 (FIS)	—	range confirmed; exact value needs an engineer	Three readings span 0.25 ft	Certified site‑specific value	Civil engineer / County
21	County condition	BFE + 2 ft	Development Permit SP‑0055704‑26, 3/26/2026, p.1	"If any portion of the structure falls within 100 feet of the Special Flood Hazard Area, the entire structure must be elevated 2 feet above Base Flood Elevation."	—	—	confirmed as printed	2014 regulation text online says one foot; county FAQ says two	Written applicability determination	Montgomery County Floodplain Administration
22	Permit clock	≈ 9/22/2026	Same permit p.1: "expires … if the actual start of construction (pouring of slab) does not occur within 180 days"	3/26/2026 + 180 days CALC	—	—	confirmed as printed	—	County's view of "start"	Permit Department
23	HOA condition	—	ESDC Form D5 (K. Anderson, 3/9/2026): "CONDITIONALLY APPROVED — Chimney must have a decorative Cap"; D7 "subject to already approved variance(s)"	—	—	—	confirmed	Kanti's 7/27 memo attributes a "top‑of‑slab … Aria Isle Grading Plan" condition — not found on the approval	The lot grading plan	ESDC / KAACM
24	HOA guideline	—	Aria Isle Supplemental Design Guidelines 4/12/2024 §2.5.B(2), §2.4.E, §4.3.C	"Slab elevation must be verified with lot grading plan"; pre‑concrete ESDC inspection ≥ 24 h notice; height "from natural grade to the highest point of the roof … shall not exceed forty (40') feet"	—	—	confirmed	—	The lot grading plan	ESDC / KAACM / Howard Hughes

3 · Numerical crosswalk — supported vs. not supported

A. Documented relationships (same physical point, two systems)

Point	Rod P (Precision / R3 / civil)	Rod D (R2 / DaRam)	Difference	Basis
Cut‑X, SW corner	129.69	127.56	2.13	R2 A1.1 vs Precision / R3 A1.1
Manhole rim by cut‑X	130.66	128.53	2.13	same sheets
Gutter by cut‑X	128.91	126.78	2.13	same sheets
Top of curb by cut‑X	129.19	127.06	2.13	same sheets
Natural ground at capped iron rod	130.6	128.5	2.10	one‑decimal values

INFER A four‑point identical 2.13 shift is the signature of a computed re‑basing, not independent re‑levelling. DaRam's own 3/23/2025 shots give a different picture nearby (road CL 127.36–127.59 vs Precision 129.19–129.76 → 1.6–2.4 ft; natural ground 130.0–130.4 vs 131.9–132.3 → 1.5–2.3 ft). The 2.13 is a drawing relationship; the field relationship P↔D has never been surveyed as such.

B. Implied relationships (different points, or unknown what was measured)

Comparison	Implied P − S	Caveat
Arch FF 133.5 vs EC top of bottom floor 130.5	3.00	Only if Keystone set the house forms at "133.5 (P)". Not documented.
Civil FF 133.2 vs EC 130.5	2.70	Only if forms were set to the civil value.
Civil garage 132.5 vs EC garage 130.3	2.20	Non‑uniform with the house — a datum offset should be uniform; either forms ≠ civil or the two EC readings are not both "top of form".
Arch garage (133.5 − 2 in = 133.33, an assumption) vs 130.3	3.03	Uniform with the house only under that assumption; not shown on A1.1.
Precision road CL 129.19–129.76 vs EC road CL 127.0	2.2–2.8	EC point location unknown.
DaRam road CL 127.36–127.59 vs EC 127.0	D − S ≈ 0.4–0.6	Of the order of a 1991‑adj vs current‑epoch difference (0.8 ft at BL1164), but not a measurement.

What cannot be converted from the record. 130.95 (disk) → NAVD88: no conversion exists; the disk's datum is unrecorded. 134.92 (plat monument, "NAVD 29, 64 ADJ.") → NAVD88: none; the FIS gives NGVD29→NAVD88 as only 0.007 ft in Montgomery County, but a 1964‑adjustment value also embeds ~60 years of site‑specific subsidence. 133.5 / 133.2 / 132.5 → NAVD88: not possible without a surveyed tie. The "3.0 ft" now circulating is an inference from the EC, not a surveyed offset, and it conflicts with the road‑centreline offsets (2.2–2.8). BL1164 label vs value: 167.49 (2001) − 166.7 (used) = 0.79 ft at the benchmark; whether the same difference applies 14 km away in a differential‑subsidence area is unknown.

4 · Vertical datum and survey benchmark

Datum named by each document

Precision topo (2023), STS Lot 11 survey (2023), arch R3 A1.1, Dunaway C1.0 / C2.0, KGW target, Keystone's "133.5 / 132.0" — none; all hang on "brass disk found 130.95".
DaRam Lot 4 topo (3/23/2025) and arch R2 A1.1 (9/8/2024) — "NGS BL1169, El. 121.76, NAVD88, 1991 Adjustment".
DaRam 71 Aria Isle survey (1/18/2026) — none; two TBMs only.
STS elevation certificate (8/27/2026) — "NAVD 1988, 2001 Adjustment"; benchmark "N.G.S. MONT. BL1164; 166.7"; B11 (FIRM datum) blank; "Conversion factor used? No".
FEMA FIS (2014) §3.3 — "Flood elevations shown in this FIS report and on the FIRM are referenced to the NAVD … TSARP … referenced to the NAVD (2001 adjustment). These flood elevations must be compared to structure and ground elevations referenced to the same vertical datum." §4.3 — "some or all of the benchmarks used to develop the BFEs on the FIRM have subsided … Releveling in the southern portion of Montgomery County was conducted in 1973, 1979, and 1987."
Recorded plat (2022) — ESL‑16 R1 = 134.92 "(NAVD 29, 64 ADJ.)".

"NAVD 1988, 2001 Adjustment" — precise meaning here?

In the Houston region it denotes the 2001 GPS/levelling readjustment of the subsidence‑affected network — the epoch of the FEMA/TSARP maps. For BL1164 the NGS line for that epoch is "NAVD 88 (12/03/01) 51.05 m … GEOID99 … GPS OBS" = 167.49 ft. The EC used 166.7 ft, NGS's current height (50.82 m, epoch 2010.00, "determined with an earlier geoid model"). Two readings remain open and the record cannot choose: (i) STS held the current value and mis‑labelled the datum; (ii) STS intended a 2001‑epoch value and mis‑copied the number. FEMA's C2 instruction — "For property experiencing ground subsidence, the most recent reference mark elevations must be used … the BFE should not be adjusted" — favours using the current value, but that is FEMA's rule, not evidence of what STS did.

Transfer over 8.7 miles: nothing in the record says whether STS levelled, used RTK/OPUS (FEMA asks for the CORS/RTN and an OPUS report), or carried through intermediate marks; no closure, no second‑mark check, no description of the on‑site TBM paid for on 8/24. MISSING

5 · Elevation certificate — field‑by‑field

FEMA Form FF‑206‑FY‑22‑152 (8/23). Instructions verified from the identical form mirrored by UCLS (fema.gov returned HTTP 403 to automated retrieval on 8/27/2026).

Item	Entry	Instruction / expectation	Finding
A1 Owner's name	blank	Required	incomplete Title holder is Arjun Shiva Investments LP.
A5 Lat / long	30°9'50.79"N 95°28'35.49"W NAD83	"centre of the front of the building"	= 30.1641083, −95.476525; matches the FEMA query point. Whether it is the front‑centre of the forms: unverified.
A6 Photos	Front 08/25/2026; rear / right / left 07/12/2026	"taken within 90 days … must show the foundation"	within 90 days but three of four predate the forms and show bare ground and silt fence.
A7 Diagram	1B	1A slab‑on‑grade; 1B raised slab / slab‑on‑stem‑wall‑with‑fill	Structural slab on 6" carton void forms over grade beams and helical piles. Certifier's call; revisit on the final EC.
A9.a Garage area	N/A	"Provide the square footage of the attached garage … If there is no attached garage, enter N/A"	inconsistent C2.d gives an attached‑garage slab elevation while A9.a says N/A (plans: 900 + 561 sq ft).
B1–B5, B7, B8	Montgomery County Uninc. 480483; 48339C0540H; 08/18/2014; X‑SHADED	—	consistent with NFHL
B6 FIRM index date	blank	Required	incomplete (8/18/2014)
B9 / B10 / B11	blank	BFE where provided; B11 = datum shown on the FIRM legend	Blank BFE is acceptable for shaded X, but B11 is required (NAVD88); given the county's 100‑ft condition the AE BFE (128.0 / 128.3) could be cited in comments.
C1	Building Under Construction	"include only those elevations that can be surveyed … Use the Comments area … to provide elevations obtained from the construction plans"	The product purchased was "Elevation Certificate per Construction Plans"; which values were field‑shot vs taken from plans is not stated.
C2 benchmark / datum	BL1164; 166.7; "NAVD 1988, 2001 ADJUSTMENT"; conversion: No	"must use the same datum on which the BFE is based … For property experiencing ground subsidence, the most recent reference mark elevations must be used"	label ≠ value; no OPUS / RTN / loop information.
C2.a / C2.d	130.5 / 130.3	Top of bottom floor; lowest top of attached garage slab	See evidence rows 9–10.
C2.e M&E	N/A — "no AC unit pad at time of survey"	Required at finished construction	Survey on the final EC: HVAC, electrical service, generator, pool equipment, elevator machine / sump.
C2.f / C2.g	129.0 / 129.3 "Natural"	"Natural grade means the undisturbed natural surface … prior to any excavation or fill"; for buildings under construction, LAG "at the time of the survey"	"natural" doubtful — lot cleared and levelled in July.
D	Fred F. Lawton, RPLS 5530, STSA, 8/27/2026, seal; Job 1596.26EC	—	properly executed Earlier STS work was by Fred W. Lawton (RPLS 2321).

To be re‑measured on the finished‑construction EC: top of finished floor (not form), garage slab, every M&E platform, finished LAG/HAG, deck/stair LAG, and — because the lot straddles AE and shaded X — the surveyed relationship of the footprint to the AE boundary; complete A1, A9.a, B6, B11 and reconcile the datum label with the value held.

6 · Flood mapping and the 0.2 %‑annual‑chance flood

Classification, precisely. The Special Flood Hazard Area is the mapped 1 %‑annual‑chance floodplain (Zones A/AE). Shaded Zone X is the mapped area between the 1 % and 0.2 % floodplains: outside the SFHA, inside the 0.2 %‑annual‑chance area. "Outside the SFHA" says nothing about being above the 0.2 % water surface; the FIS delineates the 0.2 % boundary "to indicate additional areas of flood risk" (Vol. 1 §4.1).

Effective mapping at the building (8/27/2026)

FIRM panel 48339C0540H, effective 8/18/2014, countywide; no preliminary panel pending.
Polygon at the coordinate: Zone X, "0.2 PCT ANNUAL CHANCE FLOOD HAZARD", SFHA_TF = F, no static BFE.
Nearest AE polygon (BFE 128.0): ≈140 ft from the front‑centre coordinate; AE floodway ≈296 ft; unshaded X ≈465 ft. The rear of the house is closer.
No LOMA points within 500 m; no LOMR polygons within 2 km. (Polygons cite source "48339C_LOMC2" — pre‑2014 map‑change geometry incorporated at the countywide update.)
Detailed study: Panther Branch, cross‑section Q (station 35,154), 1 % WSEL 128.3 NAVD88; profile panel 316P.
0.2 % water surface: shown graphically on 316P at ≈130.0 (rising 129.8→130.2 across the reach); no tabulated value. DaRam 130.15 · Dunaway 129.9 · this reading ≈130.0 (±0.2).

Elevations relative to that water — EC numbers, EC datum assumed = FIS datum CALC

Element	EC	vs 0.2 % (129.9 / 130.0 / 130.15)	vs 128.3 + 2	vs 128.0 + 2
Top of bottom floor	130.5	+0.6 / +0.5 / +0.35	+0.2	+0.5
Garage slab	130.3	+0.4 / +0.3 / +0.15	0.0	+0.3
LAG (ground)	129.0	−0.9 / −1.0 / −1.15	—	—
Lowest M&E	—	not yet surveyed	—	—

Safety margin: cannot be stated reliably. The margin (0.15–0.6 ft) is smaller than the unresolved datum uncertainty (0.79 ft at BL1164 alone; 2.2–3.0 ft spread in implied offsets). If the EC is on the FIS datum, the floor is inches above the 0.2 % level; if the EC is on a later, lower realization, the same floor reads ≈0.8 ft higher on the FIS datum. The surveyor's statement of the value/epoch held, plus a check on a second NGS "valid height" mark, separates the two.

Map location vs physical elevation vs insurance. Shaded X → no federal mandatory‑purchase requirement; NFIP Risk Rating 2.0 and private carriers rate on the building's actual first‑floor height, distance to water and the EC's numbers, not the zone label. A finished‑construction EC on the FIS datum is what an insurer reads — the datum question also affects premiums. County standard. Permit SP‑0055704‑26 prints the condition ("within 100 feet of the SFHA → entire structure elevated 2 feet above BFE"); the county FAQ says the same; the July‑2014 regulation text found online says one foot (apparently superseded). Applicability, the governing BFE (128.0 vs 128.3), and treatment of the garage are determinations for the Montgomery County Floodplain Administrator (501 N. Thompson, Conroe · 936‑539‑7836). The permit also requires the slab pour to start within 180 days of 3/26/2026 (≈ 9/22/2026).

7 · Plan coordination and construction control

Discipline	Set intended for construction	Elevation content	Datum	Status
Architectural	"FOR PERMIT R3" (Allen Bianchi, 1/23/2026; 12‑pp subset = Crown Exhibit D1)	A1.1: FF 133.5; brass disk 130.95; cut‑X 129.69	Rod P, unnamed	Final per project record; garage FF not on A1.1
Civil / drainage	Dunaway C1.0 / C2.0 REV 0, 6/11/2025 (in HOA‑approved package)	Residence 133.2; garages 132.5; TBM 129.69; inlets T/G 130.4–132.0	Rod P; "(NAVD 1988, 2001 ADJ.)" attached to the FEMA reference	No revision since; conflicts with arch by 0.3 ft
Structural	REV 2 (6/4/2026) being built; REV 4 issued 7/23 and re‑issued 8/25/2026 (sealed J. M. Gonzalez); sent to Keystone 8/26	No absolute elevation; "initial site grading shall be completed prior to setting forms"	relative	Confirm in writing which set governs
Grading	KGW: level to ≈132.0	—	Rod P (implicit)	As‑graded survey not in record
Foundation forms	Keystone; forms "ready" 8/24/2026	Set to ?	unknown control	missing the single most important gap
Survey	STS: building corners 7/8/2026 (horizontal only); EC 8/27; TBM purchased 8/24	130.5 / 130.3 / 129.0 / 129.3 / 127.0	Rod S	TBM description and field notes not delivered

133.2 and 133.5 are both design finished‑floor elevations on Rod P; the 0.3 ft is a civil (June 2025) vs arch R3 (Jan 2026) coordination error never reconciled in writing.
132.5 is the civil design top‑of‑garage slab; the arch site plan gives no garage elevation. The EC's 130.3 sits 2.2 below 132.5 but 3.0 below a hypothetical "133.5 − 2 in" — so the forms appear not to follow the civil garage elevation, or the two EC readings are not equivalent. INFER
130.5 / 130.3 are almost certainly the tops of the house and garage forms as they stood on 8/25 on Rod S — but STS has not said so, and Murat's 8/27 question ("is this the EC per construction plan … an approval of the form survey?") is unanswered.
Known conversions: REV 2 shows a 6" slab over 6" carton void forms; Kanti's 7/3 email asked Keystone whether the pad should be 132.5 (= 133.5 − 6" − 6") — no reply in the record. The 2" house‑to‑garage step is an assumption. No form‑board offset or architectural zero is documented.
Field vs plans: unknown — the only field numbers are on a different system from the plans, and the offset is unmeasured. Written reconciliation: none from STS, Dunaway or Allen Bianchi; Faisal Awad's 8/14 email is an opinion pending survey results; Kanti's 8/24 request for "one final written direction" is open.

8 · Who said what, on what basis

Speaker (role)	Statement (quoted)	Where	Basis	Supporting / contradicting evidence	Responsible for the subject?
Steven Hanson, Ultimate Homes USA / The Paragon Place (GC of record; building 71 Aria Isle) — "Speaker 3" identity inferred from "Thank you Stephen" and Murat's 7/31 & 8/13 emails	"The elevation that they show … is one thirty point oh five … ours is like one thirty point ninety six up the street. The reality is that it's actually right at three feet below … The Woodlands … claim to use monuments … and they no longer exist … they stipulated it in their paperwork that anything … on the island, the elevations have to follow their … monuments or their temporary benchmarks."	Plaud 07‑31, 0:00:36–0:02:26	His own project's surveys; belief	Plat benchmark note (134.92, "NAVD 29, 64 ADJ.") supports "older control exists"; 130.96 vs 127.98 is disk‑to‑curb at different points; no ESDC document stipulates elevations	No — builder, not RPLS/PE
Steven Hanson	"… the Woodlands … will not accept ours … if you have something showing too low Montgomery County won't accept it either." / "one thirty three point five is going to be the minimum finished floor … just right at [the 500‑year]." / "bring your elevation up to at least … one thirty four point five."	07‑31, 0:06:14, 0:07:11, 0:13:59	Experience; recommendation	No rejection letter in record; no document sets 133.5 as an HOA minimum; 0.2 % ≈130.0 on the FIS datum	No
Scott Lowe, Keystone Concrete	"The finished floor elevation is 133.5 and the natural grade is averaging 132.0. You will need Kenny to just remove the vegetation and level the lot."	Email 6/24/2026	Read from the site plan (Rod P)	Consistent with arch R3 and Precision	No (contractor)
Danielle Noah, STS operations manager	"We previously set the building points for this property, not elevation work."	Email 7/21/2026	Firm records	Consistent with Quote 35857 trip 1	Not the RPLS
Jennifer Zimmermann, Dunaway (structural PM)	"Precision Surveyors provided the topographic survey, not STSA." / (08‑06) "they just have temporary benchmarks … you have to tie it back to measurable datum and it's not."	Email 8/4/2026; Plaud 08‑06 0:13:00	Firm file; reading the surveys	Confirmed by this review	Structural — statement is factual
Faisal Awad, PMP, Dunaway (civil PM; C1.0 is sealed by K. J. Breckon PE)	"500‑year flood elevation based on fema is set at 129.9' … should still be above the 500 year flood elevation even with −3.0 drop (133.2‑130.2)."	Email 8/4/2026	FEMA website screenshot	FIS profile ≈130.0; the arithmetic in the email is garbled	Civil firm — yes
Faisal Awad (Speaker 5, inferred)	"if it's off by three feet, the surveyor can just lower everything by three feet, and we can update the plans … even if you drop it three feet, we will still be … roughly nine inches above the five hundred year."	Plaud 08‑06, 0:07:36	Calculation	CALC 133.2 − 3.0 = 130.2 vs 129.9 → 0.3 ft ≈ 4 in; 133.5 − 3.0 = 130.5 → 0.6 ft ≈ 7 in — not 9 in	Civil
Faisal Awad	"there is no actual BM nearby … I personally do not see any issues based on the 2 surveys we already have … 129.7' and the other bm … 127.99' … only 1.7' off and not 3.0' … Worse case … your finish floor will still be above the 500‑year elevation."	Email 8/14/2026	Two surveys on different datums at different points	Precision CR 129.19–129.76 (P) vs DaRam 71 Aria curb 127.99 (D?) — not the same datum; the EC later gave 127.0 (S)	Civil
Kanti Bansal (owner side)	"I have not found evidence that the homeowners association … has rejected or disagreed with an elevation supplied by South Texas Surveying Associates."	Memo 7/27/2026	Document review	Consistent with this review; the memo's "Aria Isle Grading Plan" condition could not be located on the approval	Not a licensed party
Ken Anderson, ESDC / KAACM	"The ESDC nor KAACM, Review or Approve Foundations designs."	Email 4/30/2026	HOA policy	—	HOA reviewer
Murat Ozevin	"Could you let me know if this can be used as the Elevation Certificate Per Construction Plan as well? … is this an approval of the form survey, so the concrete crew can come back?"	Email 8/27/2026 2:43 pm	Question	Unanswered	—

What "the HOA does not agree with the survey elevation" could mean — evidence for each, no choice made. (1) Disputing datum or measurement — no ESDC/KAACM/Woodlands document says so. (2) A separate architectural requirement — the guideline says "Slab elevation must be verified with lot grading plan" and measures the 40‑ft height limit from natural grade; the lot grading plan is not in the record. (3) Comparison with nearby houses — only Steven Hanson's remarks. (4) A neighbourhood benchmark — the plat carries ESL‑16 R1 at 134.92 on "NAVD 29, 64 ADJ."; nothing shows the ESDC requiring its use. (5) Appearance / drainage / permitted floor height — pre‑concrete inspection and the height rule are documented; any elevation check at that inspection is not. (6) An informal statement repeated — the entire "HOA position" enters the record through one builder's account of his own project.

9 · Contradictions, ambiguities, incomplete fields

Cut‑X 127.56 (R2) vs 129.69 (R3 / civil / Precision) — same mark, uniform 2.13 shift; datum of the 130.95 disk unrecorded.
Residence FF 133.5 (arch) vs 133.2 (civil) — both in the HOA‑approved package.
Garage: civil 132.5 vs arch (not shown) vs EC 130.3 — implied offsets 2.2 vs 3.0.
EC benchmark value 166.7 vs its label "2001 Adjustment" (NGS 2001 value 167.49).
Implied P − S: 3.0 (house forms) vs 2.2–2.8 (road) vs 2.7 (civil FF).
EC C1 "Building Under Construction" vs the product purchased ("Elevation Certificate per Construction Plans"; STS: "pre‑construction … per plans").
EC LAG / HAG marked "Natural" after mechanical clearing and levelling.
EC blanks: A1 owner, B6 index date, B9 / B10 / B11, A9.a garage area (N/A while C2.d is filled).
Three of four EC photos are dated 7/12/2026 — before the forms; foundation not shown.
"(NAVD 1988, 2001 Adjustment)" on civil C1.0 sits under Base Flood Information (describes the FEMA panel) but has been read as the survey datum.
County freeboard: permit and FAQ say 2 ft; the July‑2014 regulation text online says 1 ft (probably superseded — obtain the current ordinance).
0.2 % water surface: 129.9 (Dunaway) / 130.0 (this reading) / 130.15 (DaRam). 1 % BFE: 128.0 (FIRM) vs 128.3 (FIS XS Q).
Distance between the two compared markers: "roughly 200 ft" (Faisal 8/14) vs "approximately 1,100 feet" (Kanti 8/6).
Speaker identities in both Plaud transcripts are inferred, not stated.
The DaRam Lot 4 topo (3/23/2025) is in the project folder, but the delivering email and who commissioned it were not identified.
Kanti's 7/27 memo attributes to the ESDC approval a "top‑of‑slab … Aria Isle Grading Plan" condition that does not appear on the approval form found; the sentence exists in the guideline instead.
The plat benchmark reads "NAVD 29" — presumably NGVD 29; wording as printed.
Fred W. Lawton (RPLS 2321) vs Fred F. Lawton (RPLS 5530) — two licensees at STS; the EC is by the latter.
Quote 35857 (6/25/2026) already included "2nd Trip – Form Survey and Under Construction Elevation Certificate ($700)"; the 8/17 EC ($385) and 8/24 TBM ($600) were bought in addition. Which trip the 8/25 visit and 8/27 certificate discharge, and the credit position, are unresolved.

10 · Findings consistent across independent sources

Lot identity and legal description — plat, EC, Precision, DaRam, STS Lot 11 survey, county permit.
The lot straddles Zone AE (lakeward) and shaded X (building area) — DaRam, Precision (AE), county permit ("AE, X SHADED"), NFHL, plat.
FIRM panel and date 48339C0540H / 8/18/2014 — NFHL, EC, civil C1.0, DaRam, Precision, plat.
1 % BFE near the lot 128 (FIRM) / 128.3 (FIS XS Q) — NFHL, FIS, DaRam ("128.4"), FIRM excerpt.
0.2 % water surface about 130 ft NAVD88 (129.9–130.15) — FIS profile, DaRam, Dunaway.
Natural ground at the building area is ≈1.2–1.5 ft below the design floor on every system — Precision 131.9–132.3 vs 133.2/133.5; EC 129.0–129.3 vs 130.3/130.5; DaRam 130.0–130.4 vs (133.5 − 2.13 = 131.4).
STS set only horizontal building points in July — STS 7/21, Quote 35857 trip 1, Jennifer 8/4.
Arch R3 and civil C1.0 both derive from the Precision topo — identical TBM and ground shots.
No LOMA / LOMR affects the lot; no preliminary map pending — NFHL 8/27/2026.
BL1164 is a Height‑Modernization station recovered in good condition in 2023, in an NGS "suspected vertical motion" area.
The ESDC does not review foundations (K. Anderson); its only written condition is the chimney cap (Form D5).

11 · Chronology

1932 · 1959NGS marks BL1169 (R 88) and BL1164 (L 1149) monumented
2014‑08‑18FIRM 48339C0540H and countywide FIS effective (NAVD88; TSARP data on 2001 adj.)
2022‑03‑01 → 05‑24Sec 16 Replat No 1 prepared (Jones|Carter / LJA) and recorded — benchmark ESL‑16 R1 = 134.92 (NAVD 29, 64 adj.)
2023‑02‑24 / 03‑23Precision Surveyors topo of Lot 4: brass disk 130.95; cut‑X 129.69
2023‑10‑31STS survey of Lot 11 (63 Aria Isle) using the 130.95 disk
2024‑09‑08Arch R2 A1.1: BL1169 = 121.76 NAVD88; cut‑X 127.56
2025‑01‑30R2 set + Lot 11 survey forwarded "for the HOA"
2025‑03‑23DaRam topo of Lot 4 (BL1169 121.76, NAVD88 1991 adj.; TBM 127.78; 500‑yr WSEL 130.15)
2025‑06‑11Dunaway civil C1.0 / C2.0 REV 0 — residence 133.2, garages 132.5, TBM 129.69
2025‑07 → 2026‑04‑06Structural revs A, B, C (HOA permit set 8/15/2025), 1 (issued for construction 4/6/2026)
2026‑01‑23Arch "FOR PERMIT R3" issued — FF 133.5; brass disk 130.95; cut‑X 129.69
2026‑01‑18DaRam survey of 71 Aria Isle — curb X 127.99; wall X 128.68
2026‑02‑12 → 03‑09ESDC application received; conditionally approved (chimney cap)
2026‑03‑26County permits SP‑0055704‑26 ("AE, X SHADED"; 2‑ft / 100‑ft condition; 180‑day start) and NS‑0055705‑26 (pool)
2026‑04‑30ESDC: does not review foundations
2026‑05‑12 / 13Murat requests STS quote; Quote 35857 (3 trips)
2026‑06‑04Structural REV 2 (helical piles, void boxes)
2026‑06‑24 / 25Scott Lowe: "FF 133.5, NG ≈ 132.0, no pad needed"; Quote 35857 signed; Invoice 963298
2026‑07‑03Kanti asks Keystone for the pad elevation in writing (no reply in record)
2026‑07‑08 / 15STS sets 4 building points (one over the 10' BL → shifted 1"); re‑stake
2026‑07‑13Keystone contract signed
2026‑07‑21STS: "building points … not elevation work"; offers a TBM
2026‑07‑23Structural REV 4 first issued (grade‑beam fix pending)
2026‑07‑27Kanti's internal memo on elevation control
2026‑07‑31Phone conversation with Steven Hanson (Plaud 07‑31)
2026‑08‑04Kanti emails Dunaway and STS; Faisal: 500‑yr = 129.9; Jennifer: topo is Precision's
2026‑08‑06Dunaway Google Meet (Plaud 08‑06); pre‑read with 71 Aria survey; Steven sends plat + screenshots; Faisal writes DaRam
2026‑08‑12Faisal follows up with DaRam and Fred Lawton
2026‑08‑149:00 "Elevation Discussion" (Faisal, Kanti, Steven Hanson; no recording); Faisal's "no actual BM nearby / 1.7' not 3.0'" email; Murat orders "Construction Elevation Certificate (Phase I)"
2026‑08‑16 / 17Quote 35857‑01 "Elevation Certificate per Construction Plans" $416.76 signed; Faisal "Yes this is good"; Invoice 963680
2026‑08‑20Wire received; STS: "We can be one August 25"
2026‑08‑24Murat: "form is ready"; Quote 35857‑01‑01 "Set TBM and 3 elevations" $649.50 signed & paid; Kanti's written instructions to STS and Faisal
2026‑08‑25STS crew on site; structural REV 4 re‑issued (sealed 8/25)
2026‑08‑26Murat sends REV 4 to Keystone; reports surveyor visited for both products
2026‑08‑27 14:22STS delivers 29361_ElevationCert_r1.pdf — C2.a 130.5, C2.d 130.3, LAG 129.0, HAG 129.3, CL 127.0
2026‑08‑27 14:43Murat asks whether it is the "EC per construction plan" and an approval of the form survey

12 · Follow‑up requests, by recipient

Surveyor — STS (Fred F. Lawton RPLS 5530 / Fred W. Lawton RPLS 2321)

State which published value and epoch of BL1164 was held (166.7 current vs 167.49 "2001"), the transfer method (level loop / RTK network / OPUS report), the closure, and whether a second NGS "valid height" mark was checked. Correct the C2 label or value.
Describe the on‑site TBM set 8/25 (location, description, elevation, photo) — the deliverable paid under Quote 35857‑01‑01.
For C2.a and C2.d: state exactly what was shot, or whether any value was taken from plans and converted.
One closed loop on the stated datum: 130.95 disk; cut‑X (or "destroyed"); plat monument ESL‑16 R1 (or "not found"); all house form corners and both garage forms; a described road‑CL point; the 71 Aria Isle curb X. Signed point table with offsets.
State whether the 130.95 disk and the plat monument are the same object, and the origin of 130.95.
Complete A1, A9.a, B6, B11; revisit the "Natural" LAG/HAG and photo coverage; confirm which contracted trip 8/25 discharges and the credit.

Civil engineer — Dunaway (K. J. Breckon PE 73425 / Faisal Awad)

Written reconciliation of 133.2 vs 133.5 and the garage elevation, stating which governs and on which datum.
Certify the site‑specific 0.2 % water‑surface elevation and the controlling BFE (128.0 vs 128.3) on the FIS datum, and the freeboard adopted above each.
After the loop: a sealed memorandum placing FF, garage, LAG, storm inlets and M&E on the FIS datum, stating whether the project complies without change.
Confirm the 100‑ft SFHA relationship of the footprint for the county.

Architect — Allen Bianchi / Isaac Levy (ILA)

State the intended garage slab elevation and its relation to FF 133.5 (the 2" step is an assumption).
Confirm the datum intended by "brass disk found 130.95" on A1.1, and the source of R2's BL1169 note and the 2.13 shift.
If any raise is contemplated: confirm the 40‑ft‑from‑natural‑grade check and the approved variance basis.

Structural engineer — Dunaway (J. M. Gonzalez PE 122348 / Jennifer Zimmermann)

Confirm which set (REV 2 6/4/2026 or REV 4 8/25/2026) is the construction set and that REV 4 changes nothing at the foundation datum.
State the slab / void‑form / grade‑beam offsets from FF so pad and form checks can be expressed numerically.

Floodplain Administrator — Montgomery County (501 N. Thompson, Conroe · 936‑539‑7836)

Written determination whether the 2‑ft‑above‑BFE / 100‑ft condition applies, which BFE governs (128.0 or 128.3), and whether the attached garage slab is subject to it.
Whether a pre‑pour (form) EC is required and what datum statement the county accepts given FIS §3.3 / §4.3.
Confirmation of "start of construction" status relative to the 180‑day clock (≈ 9/22/2026).

Homeowners association — ESDC / Ken Anderson & Associates

Provide the "lot grading plan" referenced in ESDG §2.5.B(2) for Lot 4, and any Aria Isle grading plan or benchmark instruction, with its datum.
State whether the ESDC requires any numeric slab / finished‑floor elevation or benchmark, and what is checked at the pre‑concrete inspection.
Confirm the approved height variance terms and the reference grade used.

Insurance professional

Advise which EC datum statement NFIP and private carriers accept, and how the final EC's first‑floor height and distance‑to‑water will be rated in shaded X.
Confirm whether any lender requires an EC on the FIS datum before closing.

13 · Conclusions with confidence

Conclusion	Confidence	Evidence
127.56 and 129.69 refer to the same physical mark on two vertical systems.	high	Identical location and neighbours on R2 and R3/Precision; four identical 2.13 differences.
The 2.13 shift is a drawing‑office re‑basing, not an independent field measurement.	medium	Uniformity to 0.01 ft; DaRam's own field values differ by 1.6–2.4 ft.
The plans being built (arch R3, civil C1.0) rest on an unnamed datum.	high	Notes on both sheets; no datum anywhere.
The recorded plat's benchmark is on an old (1929 / 1964) datum, documenting a "Woodlands" control system that is not current NAVD88.	high that the note exists · low that the 130.95 disk is that monument	Plat Sheet 3; no monument description for 130.95.
The EC's datum label and benchmark value are inconsistent with each other.	high	NGS datasheet (2001 = 167.49; current = 166.7) vs EC text.
The EC values are field readings of the forms on the STS datum.	medium	C1 "Under Construction"; visit 8/25 after forms were ready; STS has not confirmed.
On the EC's numbers, margins above the 0.2 % level and the county condition are a few tenths of a foot.	high as arithmetic · low as a statement about the real house	Depends on the label/value question being resolved.
The implied inter‑system offsets are mutually inconsistent (3.0 vs 2.2–2.8).	high as arithmetic	Crosswalk table B.
No HOA / ESDC / Woodlands document disputes a survey elevation or sets a numeric slab elevation.	high (for the record reviewed)	Approval form, guideline, Ken Anderson email; absence across all searches.
The building coordinate is in shaded Zone X, not the SFHA; AE is ≈140 ft from the front‑centre point.	high	NFHL, 8/27/2026.
The county condition (2 ft above BFE within 100 ft of SFHA) is on the face of the permit; whether it binds is the county's call.	high	Permit p.1.
Nobody has recorded which benchmark Keystone used to set the forms.	high (absence)	All threads searched.

14 · The smallest set that resolves the matter

Measurement — one RPLS, one day, one datum

A single closed loop reading: STS TBM; 130.95 disk; cut‑X (or "destroyed"); plat monument ESL‑16 R1 (or "not recovered"); four house form corners; both garage forms; a described road‑centreline point; the 71 Aria Isle curb X — with the benchmark PID, the published value and epoch held, the method and the closure written on the sheet.

Documents

STS's written answers: what was held, how transferred, what was shot.
The ESDC "lot grading plan" for Lot 4 (or a statement that none exists).
DaRam's written statement of the control behind 127.99 / 121.76.

Written professional determinations

Civil engineer (sealed): controlling FF and garage elevations, the 0.2 % WSEL and BFE on the FIS datum, the freeboard adopted, and whether construction may proceed unchanged.
Montgomery County Floodplain Administrator: applicability of the 2‑ft / 100‑ft condition, the governing BFE, treatment of the garage, and the pre‑pour EC requirement.
Architect (letter): garage slab elevation and datum intent of A1.1; structural engineer (letter): the construction set and slab / void offsets.

With items 1–7 in hand, every number in this report can be placed on one line, and the "3 ft" question closes either way.

Addendum A · Hard‑point test: Precision 2023 vs DaRam 2025 CALC

If two surveys differ only by their ruler, every point measured on both should differ by the same amount. Ten features that can be identified on both sheets (read at 400 dpi; Precision 1″=40′, DaRam 1″=20′; stations from the east parkway manhole near the P.C.):

Same physical feature	Precision 2023	DaRam 2025	Difference
Parkway manhole rim, west (just off the P.R.C.)	130.66	128.81	1.85
Parkway manhole rim, east (near the P.C.)	130.52	128.68	1.84
The "X" at the inlet / throat — Precision "cut X set"; DaRam "X on top of inlet"	129.69	127.78	1.91
Gutter at the throat, just east of the X	128.91	127.05	1.86
Curb ~10 ft NE — top of curb / gutter	129.50 / 129.11	127.67 / 127.27	1.83 / 1.84
Curb ~33 ft NE — top of curb / gutter	129.72 / 129.40	127.79 / 127.41	1.93 / 1.99
Curb ~78 ft NE — top of curb / gutter	129.88 / 129.52	128.12 / 127.70	1.76 / 1.82
Road centreline ~21 ft NE	129.47	127.52	1.95
Road centreline ~85 ft NE	129.76	127.99	1.77
Top of brick wall / top of bank, lake side (four shots)	131.0–131.1	129.2–129.3	1.7–1.9

Result. Ten independent hard points, two crews two years apart, all within 1.76–1.99 ft (centre ≈ 1.87). That is a constant datum offset inside ordinary two‑crew tolerance — a ruler difference, not a ground change or a blunder. Manhole caveat: DaRam's two rim labels sit between the rims; the pairing shown agrees with the other eight points (the alternative gives 1.98 / 1.71, which agrees with nothing).

Consequences INFER: (1) the R2 sheet's 2.13 shift was not DaRam's field value — DaRam read the X at 127.78, R2 shows 127.56; (2) Precision→DaRam ≈ 1.9 plus DaRam→STS ≈ 0.4–0.6 (road centreline only) implies Precision→STS ≈ 2.3–2.5, not 3.0 — so either the forms sit ≈ 0.5–0.7 ft below "133.5 (P)" or the EC's road point is not comparable; the loop ordered from STS on 8/27 (forms + curb marks, one instrument) decides which; (3) a constant offset says the rulers are offset — it does not say which one is the FEMA datum.

15 · Source appendix

Project documents (paths relative to the project folder)

29361_ElevationCert_r1.pdf — STS elevation certificate, 7 pp (form pp. 2–8), signed 8/27/2026; Gmail msg 1a044ac392238649 (2:22 pm CDT).
Current_Drawings/25 Aria Isle - Architectural Plans Only- For Permit R3.pdf — p.2 sheet A1.1.
Old_Drawings_to_be_deleted/Final Art plans/lot 4 Aria Isla - R2-A1.1 site plan.pdf — R2 A1.1.
tmp/pdfs/B012871.001-Lot-4-Aria-Isle-REV-0-2025-06-11.pdf — Dunaway civil C1.0 (p.1), C2.0 (p.2); also Current_Drawings/25 Aria Isle- DrainagePlan.pdf and pp. 3–15 of the HOA package.
Current_Drawings/26-0825 - 25 Aria Isle - Lot 4 - 12871.001 - REV 4.pdf — structural REV 4 (S1.0–S6.0), sealed 8/25/2026; tmp/elevation-review/26-0723 … REV 4.pdf — 7/23 issue.
Current_Drawings/19661_survey_r1.pdf — STS survey of Lot 11 (63 Aria Isle), 10/31/2023.
Precision Surveyors topo — lot 4 25 Aria Isla - FOR ENG-Model - TOPO.pdf (Faisal Awad 8/14/2026, Gmail thread 1a0010e6d8dcb6e6; the archived copy is encrypted at rest).
tmp/pdfs/revision_elevation_review/AriaIsle25Daram-Rev.pdf — DaRam topo 3/23/2025; tmp/pdfs/AriaIsle71-Rev6-Envelope-TC-DaRam.pdf — 71 Aria Isle, 1/18/2026.
Recorded plat "LWES, Section 16 - Replat No. 1 Recorded Plat.pdf", 3 pp — Open Archiver attachment a2a284e5‑… from Steven Hanson 8/6/2026 (msg 39162255‑…).
Montgomery County Permit.pdf — SP‑0055704‑26 and NS‑0055705‑26 (3/26/2026).
tmp/elevation-review/HOA Final Design Resubmittal - approved 2026-03-09.pdf — Form D5 (p.1), D7 (p.2), civil and structural sheets.
ESDG_Guideline.pdf — Aria Isle Supplemental Design Guidelines 4/12/2024 (§2.4.E p.8, §2.5.B p.9, §4.3.C p.31).
tmp/elevation-review/FEMA Montgomery County FIS Volume 5 2014.pdf — profile panel 316P; tmp/pdfs/48339CV005A.pdf — FIRM excerpt (Faisal Awad, created 8/4/2026).
tmp/elevation-review/plaud-transcript.md — verbatim 07‑31 transcript; Plaud file 2d9026ecb1523d59dacb6e55a443647e — 08‑06 meeting (via Plaud MCP 8/27/2026).
Emails — Open Archiver message IDs cited in the full report; live Gmail threads 1a044ac392238649 · 1a00c92d2e435727 · 1a035858aaae7be9 · 1a0010e6d8dcb6e6 · 1a001ea85dca9a21 · 1a0352903f6e5ced. STS Quotes 35857 (5/13, signed 6/25), 35857‑01 (8/16, signed 8/17), 35857‑01‑01 (8/24); Invoices 963298, 963422, 963680, 963739.

External sources (all accessed 27 Aug 2026)

NGS datasheet BL1164 — geodesy.noaa.gov/cgi-bin/ds_mark.prl?PidBox=BL1164 (retrieved 16:19:59 EDT).
NGS datasheet BL1169 — geodesy.noaa.gov/cgi-bin/ds_mark.prl?PidBox=BL1169 (retrieved 16:20:06 EDT).
NGS south‑east Texas valid orthometric heights — geodesy.noaa.gov/datasheets/southeastTXValidHeights/home.html.
FEMA NFHL REST service (layers 28, 3, 14, 34, 1, 16, 8, 20) at −95.476525, 30.1641083 — layer‑28 point query (reproduced; returns Zone X / 0.2 PCT ANNUAL CHANCE FLOOD HAZARD / SFHA_TF F).
FEMA Map Service Center, panel 48339C0540H — msc.fema.gov/portal/downloadProduct?productID=48339C0540H.
Montgomery County FIS Volume 1 (effective 8/18/2014; 214 pp) — cms1files.revize.com/montgomerycountytx/Volume 1.pdf — §3.3 (p.43), §4.1 (p.44), §4.3 (p.46). Volume 5 — Volume 5.pdf (panel 316P).
FEMA Elevation Certificate FF‑206‑FY‑22‑152 and instructions — fema.gov … fema_form-ff-206-fy-22-152.pdf (HTTP 403 to automated retrieval); text verified from the identical 20‑page form at ucls.org.
Montgomery County Permitting FAQ — mctx.org … permitting/faq.php ("elevated to at least two (2) feet above Base Flood Elevation"; final EC "if the home is in or 100' from the Area of Special Flood Hazard").
Montgomery County Flood Plain Management Regulations (July 2014 text, mirror) — reduceflooding.com … July_2014.pdf (residential lowest floor "a minimum of one foot above the base flood elevation"; likely superseded). County floodplain page — mctx.org … floodplain.php.
Plaud 07‑31 public share (from Murat's 7/31 email) — web.plaud.ai/s/pub_1273ebf3‑….

Access gaps

No recording or notes exist for the 8/14/2026 "Elevation Discussion" with Steven Hanson.
Not in the record: DaRam's reply on the 71 Aria Isle control; STS field notes / TBM description; Keystone's form‑setting reference; the ESDC lot grading plan; the county's current ordinance text; Keystone's answer to the 7/3 pad‑elevation question.

Prepared as a neutral record review. Nothing here authorizes construction or substitutes for the determinations of the licensed surveyor, the engineers of record, the East Shore Design Committee, or Montgomery County.