Cutting, Removing Fallen Trees on Bayou Banks is Wrong
Brush Creates New Banks and Needs to Stay
We were afraid of this.
Big floods are powerful. Anyone who has lived on or spent any time on a river in the wild knows that a river can rearrange its banks with an awesome, even frightening force. Yet floods in nature are necessary.
Buffalo Bayou is an 18,000-year-old river, our Mother Bayou. We are privileged to have a forested stretch of the bayou passing through the middle of the city in our great public Memorial Park. But during the Memorial Day flood and the record-high water released by the Army Corps of Engineers from the upstream dams during the days that followed, the rushing bayou took down trees and shrubs in Memorial Park, the Hogg Bird Sanctuary and elsewhere. The bayou was reordering its banks, replenishing and reseeding the floodplain, adjusting to the changing flow, as it has done for a very long time.
Not all of this was erosion exactly. Our geologists explain that some of it was slumping caused by the overflowing of the banks. The overflowing floodwater saturated the high ground and seeped into the internal layers of clay soil that turned to pudding and slid out, creating the concave look that you see on some of the banks. This particular slippery geologic makeup of Buffalo Bayou is one reason why we believe the Harris County Flood Control District’s costly and misguided $6 million “stabilization” project, known as the Memorial Park Demonstration Project, won’t work on the high banks of our untamed Buffalo Bayou, a rare natural asset to have and learn from in the middle of the city.
Our Muddy, Maligned, Mistreated Bayou Knows Better
But trees and brush falling onto the banks (and into the water) is part of a natural process, an important natural rebuilding process. The brush collects sediment from the waters of the bayou, building up new banks that the bayou replants with stabilizing and colonizing native vegetation. Yes, amazingly, our muddy, maligned and mistreated living bayou does that, with its own superior intelligence and life force. The bayou restores itself, replenishing its important ability to filter pollutants, neutralize bad bacteria, cleanse the water, protect against further erosion and provide aquatic habitat, among many other important functions, including trapping our trash and plastic debris before it ends up in the bay and oceans.
The Piles of Concrete Came Down
Country Club Armors High Banks with Chunks of Rubble
For months we watched with suspense the towering piles of concrete riprap. They hung heavily over the edge of a high bank on the south side of Buffalo Bayou near the downstream end of one of the loveliest natural stretches of the bayou in the city. It’s a long stretch of the bayou that the Harris County Flood Control District wants to bulldoze and “restore” to a “more natural state,” so we were apprehensive.
A row of small telltale colored flags had first appeared near the waterline here and upstream at the upper limit of the area targeted for flood control’s highly destructive Memorial Park Demonstration Project.
The south bank of the nearly 1.5 mile project area is owned by the River Oaks Country Club, which is a one-third partner in the $6 million public project initiated and promoted by the Bayou Preservation Association. The club, which has nearly completed a renovation of its golf course on the bayou, had long threatened to armor its banks with riprap if the “stabilization” project didn’t go through.
And now the club has carried through on its threat, laying down black plastic sheeting on the steep banks at those two locations downstream and upstream, distributing chunks of concrete on the slopes, and covering the blocks with dirt. Club member Steve Lindley, who is overseeing the riprap work as well as the golf course upgrade for the club, said that the plastic sheeting is porous and biodegradable and that club plans to seed the dirt with grass to keep it from washing away and eventually to plant it with native vegetation such as chili pequin.
Crazy Widespread Disappearance of Wetlands around Houston
Wetlands in Buffalo Bayou Threatened Too
The Army Corps of Engineers is not keeping track of whether developers are replacing tens of thousands of acres of wetlands lost to development in the Houston region as required by law.
Wetlands, according to the Environmental Protection Agency, “are part of the foundation of our nation’s water resources and are vital to the health of waterways and communities that are downstream. Wetlands feed downstream waters, trap floodwaters, recharge groundwater supplies, remove pollution, and provide fish and wildlife habitat.”
Under the federal Clean Water Act, the Corps of Engineers is charged with protecting our wetlands.
A study by the Houston Advanced Research Center (HARC), reported by the Houston Chronicle Friday, July 31, 2015, found that “more than 38,000 acres of wetlands vanished in greater Houston over the past two decades despite a federal policy that ‘no net loss’ can be caused by encroaching development.”
While We Wait
The Flood Control District’s Failing “Natural Channel Design” Projects
Well, the comments are in to the Army Corps of Engineers. The comment period that ended June 5 was not extended. So now we wait to find out what the Corps will do next about a permit for the Harris County Flood Control District’s controversial $6 million Memorial Park Demonstration Project. The flood control district wants to destroy one of the last natural stretches of Buffalo Bayou as it flows past Memorial Park in the middle of the city so that engineers can “build it better,” thus demonstrating exactly the wrong thing to do for erosion control and bank stabilization on the bayou.
It’s the wrong thing to do because the specially adapted trees and plants on the bayou (known as the riparian zone) protect the land from erosion, slow storm water and runoff, filter pollution and bacteria (and trash) from the water, provide shade and habitat, among many other vital functions. Razing the riparian buffer, as this project would do, digging up and running heavy equipment over the banks and bayou bottom are all contrary to Best Management Practices and the policies of virtually every federal and state agency charged with protecting the health of our waters, our wildlife habitat, and our soil.
What Are the Options?
So what are the Corps’ options?
Flood Control Project Would Destroy Vital Wildlife Habitat
Buffalo Bayou protects diverse wildlife and acts as corridor
Predators help control control diseases by consuming rodent and insect pests
Mosquitoes more dangerous than coyotes
The Houston Chronicle recently published an informative article about wildlife in the city. It has special relevance to Buffalo Bayou at a time when the Harris County Flood Control District, supported by the City of Houston, the Bayou Preservation Association, the Memorial Park Conservancy, and the Buffalo Bayou Partnership, is planning to destroy nearly 1.5 miles of one of the last natural stretches of Buffalo Bayou as it flows past Memorial Park and the Hogg Bird Sanctuary.
Wild animals in the city: It’s time to stop being surprised
Gray Matters, the Houston Chronicle, July 1, 2015
Several times this spring, coyotes made national headlines when spotted roaming the streets of New York, from Manhattan to Queens.
In recent years, a host of charismatic wild species, the coyote being only the most famous, have returned to American cities in numbers not seen for generations. Yet the official response in many areas has been, at best, disorganized, and people’s responses varied. The time has come for us to accept that these animals are here to stay, and to develop a new approach to urban wildlife.
Most big American cities occupy sites that were once rich ecosystems. Large parts of Houston, Chicago, and New Orleans rest atop former wetlands. New York and Boston overlook dynamic river mouths. San Francisco and Seattle border vast estuaries, and even Las Vegas sprawls across a rare desert valley with reliable sources of life-giving fresh water, supplied by artesian aquifers the nearby Spring Mountains. All of these places once attracted diverse and abundant wildlife.
Read the rest of the story in the Houston Chronicle.
Permeable Paving Can Help Save Us and Our Bayous
Impervious Surface Is A Major Cause of Flooding in Houston
Yes, porous paving does work in Houston. We need to use more of this, on our hot, sunbaked parking lots, on our sidewalks, driveways, patios, and more. (It’s cooler too!)
Storm water runoff is a major problem for our bayous (especially those that have had protective trees and plants stripped from their banks). And impervious surface is the major cause of flooding and contributes to water pollution too. Instead of soaking into the ground (or being deflected by trees and leaves), filtering naturally and slowly through the soil and being cleansed of pollutants, storm water runoff gathers quickly, racing through toxic streets and highways, into drainage systems and pouring all at once into our bayous and creeks.
Here is an interesting and timely article in the Houston Chronicle by the founder of Houston-based TrueGrid, a permeable paving company that even creates permeable grass parking lots.
(Note to Houston park and street planners: we don’t need to have ugly, hot impermeable concrete or asphalt sidewalks to accommodate wheelchairs and runners. TrueGrid makes ADA compliant, permeable sidewalks.)
There is, in fact, also a permeable asphalt, recommended by the Environmental Protection Agency (EPA).
But here’s another interesting fact: in a typical urban residential area, rooftops account for 30-40 percent of the total impervious area. What can you do about that? Individuals can do a lot!
As the EPA says, “Slow it down, spread it out, soak it in.”
We don’t need to keep flooding and destroying our bayous, making them into bigger, uglier drainage ditches.
Leave It Alone: Buffalo Bayou Will Naturally Repair Itself
Opponents of the Memorial Park Demonstration Project Say Buffalo Bayou Is Fine Post-Flood
By Dianna Wray, Houston Press, Wednesday, June 10, 2015
After the rains started coming down on Memorial Day weekend, geologist Bill Heins, an ardent opponent of the Memorial Park Demonstration Project, couldn’t stop thinking about what was happening as the waterway continued to swell and slop over its usual banks along the last natural stretch of Buffalo Bayou that exists in Houston.
The flood waters haven’t fully receded yet, but both those in favor of the project and those against it have been out on the bayou looking for anything to back up their arguments. Project proponents point to signs of erosion on the soggy banks as evidence that we need this project. Those against it, including Heins, argue that the banks are showing signs of only minor erosion and that the evidence so far shows the natural system of the bayou — even during a record-setting flood — is working perfectly, meaning the Memorial Park Demonstration Project is unnecessary.
What Flood Control Is Not Telling Us
“Maintenance” Road Planned Along Bulldozed Bank
Updated June 8, 2015. See below.
Updated June 7, 2015. See below.
The Harris County Flood Control District is planning to create a 12-foot wide pathway for maintenance vehicles along the graded bank of Buffalo Bayou in Memorial Park.
The maintenance road parallel to the bayou is not included in the plans to “restore” the wild banks of the bayou submitted to the Army Corps of Engineers by the flood control district.
The district revealed the plan for what it is calling a “Monitoring Access Zone” at an invitation-only meeting Tuesday, June 2, 2015. The meeting was one of a series to develop a planting plan for the $6 million “erosion control,” “bank restoration,” “water quality improvement,” “flood conveyance” project known as the Memorial Park Demonstration Project. Apparently the planting plan is not progressing well, as at the meeting the district proposed planting tall fescue, an invasive exotic almost impossible to control. Tall fescue has been the scourge of Texas prairies for several decades at least.
“Tall fescue forms a near-monoculture and is responsible for the loss of otherwise undisturbed prairie remnants throughout Texas and the Midwest,” reports one of our landscape ecologists.
Well, so much for the district’s native plant expertise and commitment to a native-only riparian forest.
No trees, no “better than ever” riparian forest
Little is known about the previously undisclosed but long-suspected “Monitoring Access Zone.” According to a source who was at the meeting, the 12-foot wide pathway will be planted with some sort of seed mix for several years until the district is certain the “restored” banks will hold. They won’t hold, of course, so this grassy, flat “access zone” is likely to be permanent.
Which means no trees, no “better than ever” riparian forest and wildlife habitat, banks bulldozed and leveled even through the so-called “no-work zones.”
What is Federal Jurisdiction
The district explained at the meeting that it was not required to reveal the “monitoring” road to the Army Corps of Engineers because it does not impact federal waters, presumably because the road will be above the Ordinary High Mark, which is the lateral limit of federal jurisdiction.
But it will not be above the OHWM, which in a significant section of the park extends deep into the forest as part of the flood plain, a natural detention area, including swales and wetlands, all of which are under federal jurisdiction. The road and the “bankfull bench” upon which it will sit will also fill and block at least two tributaries, which also are under federal jurisdiction, although on its plans the district labels both tributaries “gullies,” thereby attempting to remove the tributaries from federal jurisdiction. (See sheets 16 and 18.) Gullies are classified as an “erosional feature” by federal law. An actual gully leading from the South Picnic Loop parking lot is oddly labeled a “tributary.” (See sheet 16.)
So far we don’t know the length of “Monitoring Access Zone,” whether it extends along the entire north bank of the project area, including private property, or whether a “Monitoring Access Zone” will also be built on the south bank of the project, land which belongs to the River Oaks Country Club.
Guess we’ll have to ask the flood control district. And object to the Corps.
What else is the flood control district not telling us?
Update June 7, 2015
There is no “road” planned for maintenance vehicles on the wild banks of Buffalo Bayou targeted for “restoration” by the Harris County Flood Control District.
Jason Krahn, manager for the district’s controversial $6 million project to “improve” one of the last natural stretches of Buffalo Bayou, wrote in an email to Save Buffalo Bayou on June 5 that “there is no road proposed for the post construction monitoring activities associated with MPDP [Memorial Park Demonstration Project].”
Participants in the district’s Vegetation Advisory Workgroup for the dredging and channelizing project had been told that for several years after “restoration” there would be a grassy 12-foot wide “Monitoring Access Zone” for maintenance vehicles to access the bulldozed and reconstructed banks of what is now a perfectly healthy historic natural area in need of no monitoring or maintenance whatsoever–other than picking up the trash and mitigating runoff from trails and parking lots.
This “Monitoring Access Zone,” workgroup participants were told, would remain in place until there was no longer any need for monitoring, replanting, watering, removal of noxious invasive vegetation, or repairs to failing “stabilized” banks, etc. Presumably removal of noxious invasive vegetation would not include the tall fescue, a noxious invasive plant, described above, that the district earlier this month was contemplating planting. Responding to objections, the district reportedly has changed its mind about the tall fescue.
Krahn said that monitoring activities would take place on both the north and south banks of the bayou in the project area, which includes Memorial Park and the Hogg Bird Sanctuary on the north and the River Oaks Country Club on the south.
He also wrote that “no work zones” on the bayou were in fact “no work zones,” despite the fact that heavy equipment would be driven over the banks, according to the district’s plans. However, above the Ordinary High Water Mark these “no work zones” would not be graded into bankfull benches, wrote Krahn, because “these are portions of the project area that already have the necessary geomorphic characteristics for a sustainable, stable channel.” A bankfull bench is a flat or sloping area above the bank of a stream that slows overflowing floodwater.
Asked to clarify the “Monitoring Access Zone,” Krahn has not yet replied.
But it’s not a “road,” Krahn insisted. So we won’t call it a “road.”
How about sendero?
Updated June 8, 2015
Project Manager Jason Krahn has clarified the “monitoring access zone.” In an email to Save Buffalo Bayou Monday morning, Krahn wrote:
“To provide for the monitoring access as outlined in the Atkins report [the post-construction monitoring plan included in the revised permit application], the District is working to define the appropriate spacing for vegetation within a portion of the flood plain planting zone. A spacing of 12-foot in width is currently being considered to allow for this access, or ‘monitoring access zone’ as you’ve referenced it in your previous email correspondence.”
Immutable Plan. Invisible Rocks.
“Revised” plan to destroy Buffalo Bayou not really “revised” at all.
Project manager says no significant changes to much criticized original plan.
No sandstone in project area, says flood control, contradicting itself.
Despite the hundreds of comments criticizing the purpose, methods, impact, cost, benefit, and harm of Harris County Flood Control District’s proposed “erosion control” project on Buffalo Bayou in and around Memorial Park, the district has made no significant changes to the plans recently re-submitted to the Army Corps of Engineers.
Jason Krahn, project manager for the controversial Memorial Park Demonstration Project, told Dianna Wray of the Houston Press that the district was “simply following the guidelines” and that there were “no significant changes” to the original project plan.
Indeed, many of the “revised” plan sheets posted by the Army Corps of Engineers on its website appear to have been simply relabeled with new dates, though there are some with new details.
The public has until June 5 to send comments to the Corps about the district’s “revised” permit application and the district’s responses to previous comments. There is no limit on the number of comments one can make. So if you’ve already made a comment, make another!
Revised plan to destroy Buffalo Bayou announced: Public has till June 5th to comment
Updated May 15, 2015.
Today, May 5, 2015, the US Army Corps of Engineers posted a new public notice announcing a revised permit application from the Harris County Flood Control District to destroy nearly 1.5 miles of one of the last natural stretches of Buffalo Bayou in Houston. The flood control project, called the Memorial Park Demonstration Project, is in a historic natural area with high cliffs and sandstone formations hundreds of thousands of years old.
Comments must be submitted by June 5, 2015.
The Flood Control District’s first application was announced in a public notice last April, and public comments were received through June 30. The comments were overwhelmingly negative. The revisions to the permit application are in response to those comments.
The Corps is now soliciting comments from the public, governmental agencies and officials, and other interested parties in advance of making a determination about the permit application. The Corps requests that comments be limited to the clarifications and updates made by the Flood Control District to the Memorial Park Demonstration Project plans, monitoring plan and planting plan, as well as the District’s responses to comments received by the Corps and made by the Corps. The summary of updates and clarifications are contained in the following document under the “Response to Comments” tab on the Corps’ website:
You can read the revised plan here.
Houston and Harris County taxpayers are funding $4 million of this destructive “restoration” project, which would shorten, reroute, dredge, and channelize the bayou, eliminating a healthy riparian zone and rebuilding it using “natural, stable, channel design” methods prone to failure. The River Oaks Country Club, which owns the entire south bank of the “restoration” project, is paying $2 million. Riparian zones are crucial to the cleanliness of our waters, and are generally protected by policies and programs of our state and federal governments.
The north bank of the project is mostly Memorial Park and the Hogg Bird Sanctuary, with some private property in between.
All comments and requests for additional information should reference file number, SWG-2012-01007, and should be submitted by June 5 to:
Regulatory Branch, CESWG-RD-P
U.S. Army Corps of Engineers
P.O. Box 1229
Galveston, Texas 77553-1229
And send a copy of your comments to the Texas Commission on Environmental Quality. The TCEQ, which asked critical questions about the project in its comments to the Corps, must certify that the project complies with state water quality standards.
Texas Commission on Environmental Quality
Water Standards Team
401 Coordinator, MC-150P.O. Box 13087, Austin, Texas 78711-3087