Are Flood Planners Ignoring Legal Requirement To Consider Environmental Impact?
Stormwater Tunnel Inlets: No Environmental Impact On Streams, Says Flood Control
Dec. 23, 2022
Update Dec. 24: President Biden signs authorization for Galveston Bay Surge Protection Plan. Funding not included
Freeze? Drought? Holiday lights went out? Flood planning goes on.
A regional planning group has voted to send the state a flood plan while expressing concern that failure to assess its environmental impacts could be illegal.
Members of the San Jacinto Regional Flood Planning Group noted at a recent meeting that there were numerous public comments objecting to the environmental impact of projects included in the plan. Many were lodged against channelizing natural streams, among them wooded Spring Creek on the northern border of Harris County, parts of which are under conservation easement.
Conservation easements are actually a flood management strategy. Channelization, or dredging, altering, and straightening streams can increase downstream flood risk and lead to erosion, sedimentation, maintenance, and environmental issues. (pp. 154-155)
Criticisms also focused on the abundance of structural or engineering projects compared to nature-based projects and nonstructural strategies. The state’s technical guidelines require a balance of structural and non-structural projects, with an emphasis on natural systems and functions. (pp 87-88)
Nature-based approaches, or green stormwater infrastructure, slow and absorb stormwater runoff before it enters our pipes and streams. (Also improves property values, cleans the air and water, improves biodiversity, makes life better, and more.) Scientific studies have shown that nature-based flood management – using trees, plants, wetlands, prairies, etc. — is cheaper and more effective than structural engineered projects. (See here and here.) And here is Save Buffalo Bayou’s previous comment to the flood planning group outlining what other cities and states are doing in this regard.
The planning group, known as Region 6, is one of fifteen localized groups set up by the Texas Water Development Board to develop continuing flood plans to be funded by the state. The regional plan includes numerous projects and strategies proposed by governmental or public entities. These are cities, counties, districts draining the watershed emptying into the San Jacinto River, an area extending from Galveston to Huntsville.
The group had not yet posted the final approved plan on its website as of publication time. The final plan is to be sent to the state board by Jan. 10, 2023. Here is a link to the meeting presentation.
Most of the comments received on the draft plan objected to the emphasis on structural or engineered projects, the lack of nature-based projects, and the failure to consider the impacts of proposed channelization of streams and coastal surge protection projects.
The planning committee’s general response to these complaints is that they are “not endorsing” but just “including” the projects in their plan.
However, group member Gene Fisseler pointed out at the recent meeting Dec. 8 that it was important to make sure that the group adhered to its statutory requirement to evaluate environmental impact under Ch. 362 of the Texas Administrative Code.
The group members approved changes to the plan, including adding four City of Houston projects in Kashmere Gardens, Fifth Ward, Sunnyside, and Pleasantville. (pp. 19-22) They discussed how to answer environmental concerns.
Here is an explanation of the draft flood plan before it was updated.
The next planning meeting is scheduled for Feb. 9, 2023. The next plan update is due July 14, 2023. There will be further opportunity for the public to comment, Megan Ingram of the Texas Water Development Board said at the hybrid meeting held at the Houston Advanced Research Center in the Woodlands. A recording of the meeting is here.
The flood plan is an ongoing project, to be updated every five years.
Reaction of Conservation and Environmental Groups
Conservation groups, including Bayou Land Conservancy and the Coastal Prairie Conservancy, as well as numerous individuals, objected to plans to strip, dredge, and channelize natural streams, including those under conservation easement, specifically Spring Creek. They urged the flood planners to drop the San Jacinto River Regional Watershed Master Drainage Plan which includes those plans.
A coalition of environmental groups, including Save Buffalo Bayou, urged the flood planning group and the US Army Corps of Engineers to reconsider the environmental impact of the $34 billion coastal barrier and gate system recently approved by the House of Representatives. The draft flood plan claimed there was no environmental impact from the Corps’ Galveston Bay Surge Protection plan (known as the Ike Dike). (p. 2050)
Referencing the potential damage to the bay’s oyster, fish, shrimp, and crab populations, the coalition letter urged the Corps to “address gaps in its analysis” and consider non-structural alternatives to the gate system with greater cost support from the multi-billion-dollar industries needing protection.
Noting also the decades it would take to build the barrier system, the letter asked for solutions that can be implemented on a more rapid timeline such as storm-proofing homes, helping communities retreat, strengthening building regulations, and preserving wetlands, prairies, and floodplains.
There were also, however, numerous identical letters in support of the Ike Dike.
Technical consultant Mariah Najmuddin with Hollaway Environmental told the group about an interactive story map explaining the flood plan. However, the story map had not yet been added to the group’s website at the time of posting.
County, City Officials Address Community Flood Resilience Task Force
Later that afternoon members of the Harris County Community Flood Resilience Task Force met and heard updates from the Harris County Flood Control District and the City of Houston about flood resilience plans and projects.
Ryan Slattery, the new director of flood resilience planning for Flood Control, said that the district was moving “beyond traditional planning” into more nature-based projects including floodplain preservation.
Scott Elmer, assistant director of operations for Flood Control, gave a presentation on the results of research into the potential for a massive $30 billion, 133-mile underground stormwater tunnel system. The district is just beginning Phase 3 of its investigation which will look at “how tunnels can synergistically work together,” said Elmer.
“We’re not at a point where I can say it’s a must-go option for Harris County.”
Elmer claimed that the deep tunnels would not degrade the natural environment of Buffalo Bayou or other streams because the intakes built into the banks would be set at base flow. However, it would seem that preventing the flow from rising above the very low base level would deprive the vegetated banks and floodplain of necessary watering and collection of sediment and seed for replenishment.
Bob Rehak of Reduce Flooding Now and member of the task force asked Flood Control Director Tina Peterson why spending on flood bond projects had slowed. Peterson responded that the district was on schedule.
Johana Clark, director of stormwater operations for the City of Houston and a member of the task force, gave an update on the Resilient Houston Plan as well as multi-use park guidelines for improving stormwater drainage. She touched on other topics including the massive amount of stormwater infrastructure that the city must inspect and maintain, the Adopt-A-Drain neighborhood volunteer program, and how stormwater projects are recommended by city council members based on feedback from the community.
Here are the minutes of the meeting. The next meeting of the Community Flood Resilience Task Force is Feb. 23, 2023.