Expert Analysis of The Woodlands Township’s Incorporation Law Enforcement Plan Reveals Alarming Financial and Operational Deficiencies

THE WOODLANDS, TX -- The Howard Hughes Corporation® (NYSE:HHC) today released the findings of an independent analysis of the law enforcement portion of The Woodlands Township Board of Directors’ Incorporation Planning Study intended to provide a road map for creating a new police department should The Woodlands® vote to incorporate on November 2.

“In spite of repeated assurances from the Township Board of Directors that their plan provides a reliable blueprint for a new police department, independent experts have found it to be shockingly inadequate to ensure the public safety of The Woodlands,” said Jim Carman, President of the Houston Region at The Howard Hughes Corporation. “All of us as residents should be alarmed by the profound financial and operational deficiencies of this plan, which clearly demonstrate that a rush into incorporation would jeopardize the safety of our families and our community.”

The analysis was conducted by Tim Oettmeier, Former Executive Assistant Chief of Police, and Joe Fenninger, former Deputy Director and Chief Financial Officer of the Houston Police Department.

According to Fenninger, “The Township’s plan is remarkably deficient in many areas. It does not provide appropriate levels of funding for operations and processes that it does identify, and it fails to identify many other vital police operations that will incur significant costs. The plan’s financial projections are grossly understated.”

Oettmeier explained, “Our evaluation was based entirely on the accuracy and merits of the Township’s projections and descriptions of law enforcement options, agnostic to the prospects of incorporation. In our opinion, the plan falls significantly short of providing a reliable blueprint for ensuring public safety in The Woodlands.”

The expert analysis reveals that The Township's law enforcement plan:


• Grossly understates ongoing costs, primarily labor. For the first four years, cumulative costs are understated by $12.1 million to $14.5 million.

• Does not plan for inevitable cost increases of salaries, benefits, insurance coverage or pension plans. For example, the Montgomery County Sheriff’s Office is implementing a 5-percent across the board pay increase on October 1, 2021, which is not reflected in the Township’s numbers. These expenses will continue to grow over time.

• Ignores the transfer of accountability and liability to the new city and does not project costs for the settlement of claims and/or costs of liability insurance.

• Understates the cost of procuring patrol vehicles by approximately $6.1 million. The Township does NOT own any patrol vehicles. For a new city, they would have to be purchased.

• Does not address a federally mandated Criminal Justice Information Systems (CJIS) law that governs access to information contained within law enforcement technology systems and its costs.

• Fails to address the issues associated with collective bargaining and negotiating with a new police union, as well as issues of civil service.

• Provides insufficient and unreliable patrol and investigative staffing projections. No crime data was used to determine what investigative staffing should be for a new city.

• Fails to identify how financial crimes, special victims, gang activity, computer crime, juvenile crime and some vice offenses and regulatory offenses will be addressed or funded.

Carman went on to say, “The Woodlands is one of the safest communities in the United States, thanks to the men and women currently providing our law enforcement services. It is clear from this expert analysis that should the residents vote to incorporate on November 2, we would be eliminating our reliable law enforcement team and replacing it with an under-funded police department that is unprepared to ensure our public safety. These findings underscore the profound risks associated with this rush to incorporate.”

The full expert analysis can be found here.