Revising the Plan for Protecting Galveston Bay
Public Workshop Wednesday, March 1, 2017
Or Send Comments
Feb. 20, 2017
The Galveston Bay Estuary Program was established in 1989 to implement a comprehensive conservation plan for Galveston Bay. Established by the federal government and administered by the Texas Commission on Environmental Quality (TCEQ), the program’s goal is to “preserve Galveston Bay for generations to come.” It is one of two estuary programs in Texas and one of 28 programs nationwide protecting estuaries “of national significance.”
An estuary is “a partially enclosed, coastal water body where freshwater from rivers and streams mixes with salt water from the ocean. Estuaries, and their surrounding lands, are places of transition from land to sea. … Estuarine environments are among the most productive on earth.”
As the Environmental Protection Agency points out, “what happens on the land affects the quality of the water and health of the organisms that live in an estuary. … For example, if a river or stream … passes urbanized and suburbanized areas, it gathers substances such as:
- fertilizers or pet waste that wash off lawns;
- untreated sewage from failing septic tanks;
- wastewater discharges from industrial facilities;
- sediment from construction sites; and
- runoff from impervious surfaces like parking lots.”
Buffalo Bayou is the main river flowing through the center of Houston and emptying into Galveston Bay. Numerous other creeks and tributaries, including Brays, White Oak, and Sims bayous, flow into Buffalo Bayou, which becomes the Houston Ship Channel.
Updating the Galveston Bay Protection Plan
The 22-year-old Galveston Bay management plan is being revised. The Houston Sierra Club is urging the general public to attend a Wednesday afternoon workshop in La Marque to “provide input on how we can have a cleaner and more ecologically intact Galveston Bay.”
State of the Bayou
Downed Trees. New Channel. New Riprap. Washed Out Sidewalks, Beavers, and Turtles
But Some Banks Naturally Rebuilding
Does It Make Sense to Repair?
Sept. 1, 2016
Updated Sept. 11, 2016
You could not step twice into the same river. Heraclitus
We finally had a chance recently to float down beautiful Buffalo Bayou to see how things have changed. Our trip took us past Memorial Park in the middle of Houston. We also biked along the bayou through Terry Hershey Park far upstream in west Houston below the dams to see what was happening there.
The good news is that some of the high banks that had slumped in Memorial Park and the Hogg Bird Sanctuary during the Memorial Day 2015 flooding are naturally rebuilding.
The bad news is that the River Oaks Country Club has added more riprap to the south bank, hard armoring the bank with ugly, damaging concrete rubble, including where it should not be.
Nature’s Miraculous Way of Restoring. For Free.
Houston has had multiple record-breaking rains and flooding since the spring of 2015. When Buffalo Bayou overflows its high banks, as it did in the Memorial Day flood of 2015, the banks in places sometimes slump or slide away. This happens when the overflowing water seeps through the ground and saturates layers of sandy clay that liquefy, sometimes causing the bank to give way. Buffalo Bayou is 18,000 years old, and this has been happening for a very long time.
This natural tendency to slump is one reason why we think attempting to engineer these banks as proposed by the $6 million Memorial Park Demonstration Project won’t work. It’s also the reason why we think building and repeatedly repairing sidewalks at the bayou’s edge is wasteful and foolish.
It’s for the Birds
Report on Plans for the Hogg Bird Sanctuary on Buffalo Bayou
May 11, 2016
First the positives about the presentation Monday evening, May 9, by the Houston Parks Board about plans for the little-known 15.56-acre nature preserve on Buffalo Bayou known as the Hogg Bird Sanctuary.
The sanctuary at the end of Westcott Street south of Memorial Drive is probably better recognized as the mostly impenetrable woods next to the parking lot for the Houston Museum of Fine Arts’ Bayou Bend Collection and Gardens, located across the bayou, accessible by a footbridge. Bayou Bend is the former home of the Hogg Family, who developed River Oaks and in 1924, along with partner Henry Stude, sold at cost to the city the 1,503 acres that became Memorial Park. (The Hogg Brothers also sold to the city at cost 133.5 acres of land intended to be part of Hermann Park. In 1943 the city sold that land for the establishment of the Medical Center, which provoked the continuing ire of their sister, Ima Hogg.) Ima Hogg, a cultural and civic leader and one of the city’s most revered philanthropists, donated the family house and gardens to the museum in 1957 and then donated to the City of Houston the woods on the north side of the bayou as a nature preserve.
Ima Hogg a Defender of Nature and Public Parks
Ima Hogg, who died in 1975, was also an ardent conservationist, early civil rights activist, mental health activist, and defender of park space for the public, in particular Memorial and Hermann parks. In her letters to city officials over the years, available in the archives of the Museum of Fine Arts, she described her firm belief that woodland parks should be kept as natural as possible and criticized in a 1964 letter to then Mayor Louie Welch, who famously thought public parks unnecessary, the “alarming situation” of rapidly diminishing park areas in Houston and “throughout America,” including through construction in the parks by “worthy institutions” that really ought to look for building sites elsewhere, she wrote. Miss Ima was still angry that the city had “relinquished so much of the acreage” in Memorial Park for highways and a golf course and in an earlier letter to then city director of public works, Eugene Maier, demanded that the money the city received from the state for the highway land be used to acquire and improve additional park sites. Let’s guess that probably didn’t happen.
Proposed Roads to Damage Katy Prairie Preserve
Urgent Notice of Public Meeting and Comment Deadline
May 1, 2016
Updated May 3, 2016
The Katy Prairie Conservancy has announced that the Harris County Engineering Department has corrected the email link for commenting on proposed changes to the Harris County Major Thoroughfare and Freeway Plan that will damage the Katy Prairie.
The correct email address is:
Update May 8, 2016
The comment period has been extended until May 13.
The Katy Prairie Conservancy has sent out an urgent notice of a Harris County plan to build new roads in and around the Katy Prairie Preserve. The preserve is a nonprofit land trust project to restore and protect historic wetland prairie in Waller and western Harris counties.
Buffalo Bayou originates in the Katy Prairie. Prairie wetlands, rapidly being destroyed and paved over by development, are vital for clean water and flooding mitigation, as are forested riparian zones along the banks of streams such as Buffalo Bayou and its tributaries.
When, Where, and How
The Harris County Engineering Department is holding a public meeting Monday, May 2, 2016, on proposed changes to the Major Thoroughfare and Freeway Plan (see particularly pages 25 through 29) that will “degrade the Katy Prairie Preserve System,” according to the conservancy.
The meeting takes place from 5:30 to7:00 pm at the Hockley Community Center, 28515 Old Washington Road, in Hockley, Texas.
The conservancy urges that if you cannot attend the meeting, please submit your comments in writing by May 13, 2016, via email to firstname.lastname@example.org or by mail to:
Harris County Engineering Department
10555 Northwest Freeway, Suite 120
Houston, Texas 77092
Attn: Fred Mathis, P.E.
The conservancy says that while Harris County is proposing to dispense with parts of the one-mile road grid through some of the preserves, the county also recommends constructing new roads in sensitive and/or inappropriate areas.
Here are some of the conservancy’s main objections:
- In general, the plan does not effectively take into consideration the importance of the Katy Prairie preserves in reducing flooding, improving water quality, providing wildlife habitat, and offering recreational opportunities for the residents of the Greater Houston area. Roads should go around the Katy Prairie preserves and not through them. Roads can move, nature cannot.
- KPC does not support the new proposed east-west road through the upper third of the Warren Ranch; it will cause fragmentation and impair ranch operations.
- KPC does not support the new proposed north-south road through the conservation easement lands owned by KPC’s conservation easement donors; this land provides sensitive habitat and flood protection as well as other environmental benefits. It should be protected.
- A number of the proposed new roads, if built, would be under water during flood events if the most recent flood event is any indication of where floodwaters go on the prairie.
For more information visit http://www.katyprairie.org/
Reminder: The Threat is Still Alive
Operation Save Buffalo Bayou II
March 14, 2016
Okay, so we harshed the mood a little with our small, silent reminders that regatta contestants were paddling through a historic natural area still threatened with destruction.
“Thanks for polluting my day,” yelled one paddler in the crowd of hundreds of Buffalo Bayou boaters playing loud music and stopping to pee in the woods. We were watching from the sandy bank of the lovely middle meander, forested with young willows and box elder that would all be cut down, the meander filled, graded, and planted with grass.
The event was the 44th Annual Buffalo Bayou Regatta on Saturday, March 12. And once again we hung our beautiful Save Buffalo Bayou banner (Night Heron by Houston artist Frank X. Tolbert 2) from the railroad bridge and set out small white signs alerting participants to the fact that the wild stretch they were passing through would all be bulldozed under a plan proposed by the Harris County Flood Control District and the Bayou Preservation Association (BPA).
The project, known as the Memorial Park Demonstration Project, demonstrates exactly the wrong thing to do. (See Buffalo Bayou Park and Fonteno Park.) It would raze most of the trees and vegetation along more than 1.25 miles of the 18,000-year-old bayou as it passes by Memorial Park and the Hogg Bird Sanctuary. These trees and vegetation and even the sand are part of the riparian zone, essentially wetlands, that hold the banks together, cleanse and filter the water, slow and absorb storm runoff, provide wildlife habitat, among many other important ecological functions. The $6 million “natural channel design” project, financed with $4 million in county and city taxpayer funds, would dredge and reroute the bayou and plug tributaries, obliterate ancient cliffs, destroy 250,000-year-old sandstone formations, and fill in our lovely meander (a natural detention area). Killing the bayou’s ecosystem in the name of “restoration.” And landscape design.
And no, contrary to rumors, the project, although holding its breath, is not dead. The Army Corps of Engineers is still deciding whether to issue a permit for the project, which is otherwise a violation of the federal Clean Water Act.
The Bayou Preservation Association first formulated the plan for the project in private meetings in 2010 and former BPA president Kevin Shanley, then a principal with the landscape architecture firm SWA Group, was the primary promoter. SWA Group is the design firm that is also responsible for the landscape design of Buffalo Bayou Park downstream east of Shepherd.
So this is why we had signs up warning of landscapers lurking. In Buffalo Bayou Park downstream, we set out a few signs pointing out that landscaping has washed away (several times actually) and that removal of vegetation has caused erosion problems, and that repairs were $$$$ (paid with City funds). Yes, we were bad! Those signs did not last long, however.
Upstream around Memorial Park and the Hogg Bird Sanctuary our signs pointed out where beavers live, where banks were being naturally rebuilt by the bayou, and the Pleistocene bluffs that would be graded into a slope. Interestingly, the bayou, during and after the Memorial Day flood in 2015, has already graded the lower banks of those steep bluffs into a slope.
The River Oaks Country Club is theoretically a one-third partner in the demonstration project and owns the entire south half of the project reach. But in the meantime the club in two places has armored its banks with ugly concrete riprap, one of the most environmentally destructive methods of erosion control (pdf), and also, we allege, in this case illegal, as we contend that much of the riprap was placed in public waters, also a violation of the Clean Water Act.
The club, unfortunately, is having erosion problems on its high banks in those places because it cut down a lot of trees and extended the mowed and watered grass of its golf course up to the edge of the banks.
We put out signs pointing out that riprap damages the ecosystem and is part of the problem, not the solution.
But we’re glad people had fun, enjoyed the bayou, and picked up some of trash.
Maybe they’ll think about the future of the bayou.
And special thanks to river guide Tom Helm and to Richard Hyde for extra long duty putting out and picking up our banner and picking up our signs.
Fighting For Our Public Forests on Buffalo Bayou
On the Radio
Forests Work for Us
Oct. 28, 2015
Listen to Susan Chadwick of Save Buffalo Bayou and Landrum Wise of Save Our Forest talk about community campaigns to protect public forest along some twelve miles of Buffalo Bayou in Houston.
They spoke with Pat Greer and H.C. Clark on Eco-Ology on KPFT 90.1 Tuesday, Oct. 27, 2015, about efforts to keep the City of Houston and the Harris County Flood Control District from destroying woodlands on Buffalo Bayou in Memorial Park in the center of Houston and in Terry Hershey Park in far west Houston.
In addition to their great social value and benefit to our health, well-being, and quality of life, the trees and vegetation that grow naturally along the bayou perform vital ecological services and are a key part of the bayou’s living system. Known as riparian zones or buffers, these specially adapted trees and plants cleanse and filter pollutants from the water. They protect the banks from erosion, absorb and slow storm water runoff and provide natural flood detention. They shade us and cool the stream, and provide wildlife habitat.
Legally Required to Conserve Harris County Forests
The Harris County Flood Control District, according to its 1937 charter, is charged by state law with conserving forests in the county. (See page six.) But for decades the district has been razing forests to build storm water detention basins on our bayous, creeks, tributaries, and elsewhere, and to re-engineer channels and banks. Detention basins are used to hold or slow temporarily surface runoff or high flows in a stream during storms.
The flood control district’s project on Buffalo Bayou in Memorial Park, known as the Memorial Park Demonstration Project, would raze some 80 percent of the trees and vegetation along more than 1.25 miles of the bayou and its tributaries in Memorial Park and the Hogg Bird Sanctuary. The Army Corps of Engineers, which enforces the federal Clean Water Act, is currently considering whether to issue a permit for the controversial $6 million project, which is described by flood control as an “erosion control” and “bank stabilization” project. The project violates Best Management Practices for riparian areas. Virtually every federal and state resource agency has policies and regulations protecting riparian zones, which perform essentially the same function as federally-protected wetlands.
Recent Success for Save Our Forest
The City of Houston recently withdrew a project to cut down the majority of trees and understory on some 42 acres of public forest and excavate up to six large detention basins on the south bank of Buffalo Bayou in Terry Hershey Park between Beltway 8 and Wilcrest Drive. The Capital Improvement Project was to have cost the taxpayers between $3.5 and $8.5 million.
However, the flood control district appears to be continuing with its widely-opposed “Charting Buffalo” study that proposes as many as 24 storm water detention basins along some 10.7 miles of both banks of Buffalo Bayou in the forests of Terry Hershey Park between Beltway 8 and Highway 6 at Barker and Addicks dams. On Nov. 12, 2013, despite public opposition, Harris County Commissioners Court approved flood control’s request for $250,000 for a vegetation and topography survey in the park.
The headwaters of Buffalo Bayou are on the Katy Prairie west of Houston, and the 18,000-year-old “mother bayou,” fed by numerous tributaries, flows for some 53 miles east through the city and the ship channel into Galveston Bay. Buffalo Bayou, unlike major bayous like White Oak and Brays, which join Buffalo Bayou just west and east of downtown, has never been covered with concrete, though parts of it have been channelized.
Update on Puzzling Project to Bulldoze Wild Buffalo Bayou
Damaging, Expensive, Contradictory Plan Still Threatens
Conflicts Still Apparent, Purpose Still Unclear
No Permit Yet
October 8, 2015
The Harris County Flood Control District has responded to largely critical public comments to the Army Corps of Engineers about Flood Control’s misguided project to destroy one of the last natural stretches of Buffalo Bayou in Houston, a most remarkable asset to have in the middle of a city. The Corps is reviewing the Flood Control District’s responses, says Jayson Hudson, who has been the Corps’ Galveston District project manager for the permit application.
Flood Control must apply for a permit from the Corps of Engineers because the Clean Water Act requires the Corps to ensure that projects on federal waters do not damage the health of our waters. Federal waters are defined as navigable streams (Buffalo Bayou) up to the Ordinary High Water Mark, their tributaries and adjacent wetlands, all of which form the great living veins and arteries of our limited water supply. Some studies argue that all riparian areas , the highly biologically diverse natural gardens and forests along stream banks so vital for clean water, should be considered protected wetlands .
Crazy Widespread Disappearance of Wetlands around Houston
Wetlands in Buffalo Bayou Threatened Too
Aug. 3, 2015
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
July 11, 2015
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?
What Flood Control Is Not Telling Us
“Maintenance” Road Planned Along Bulldozed Bank
June 4, 2015
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.”