Money to Burn: Leaders Reject Cheaper, Less Damaging Alternatives
A Cascade of Increasingly Costly Mistakes
May 22, 2019
An elite private club on Buffalo Bayou has begun an $18-24 million “bank stabilization” project that will likely cause extensive damage to public and private property, including the club’s own property.
The River Oaks Country Club received a permit from the City of Houston Floodplain Management Office on May 6, 2019, to install over 1,500 linear feet of metal walls, concrete pilings, concrete rubble, wire baskets filled with rock (gabions), and other material in three locations on Buffalo Bayou below the edge of their golf course. The locations are opposite Memorial Park and the Hogg Bird Sanctuary, as well as private residential property.
This type of bank hardening has been specifically rejected by the Harris County Flood Control District and the Galveston District of the US Army Corps of Engineers, which governs the coast and southeast Texas down to the Rio Grande. Both agencies nevertheless appear to have given their approval, despite knowing that such unnecessarily costly projects often fail, damage nearby property, and even increase flooding.
Solutions Creating More Costly Problems
“Bank armoring at a single point of erosion has been shown to be ineffective along Buffalo Bayou,” noted the Corps in a 2014 publication specifically referring to this stretch of the river. “The isolated bank armoring installed to deflect the erosive shear stress at the point of failure, in most cases, is attacked at one or both of its terminal ends, resulting in eventual failure. This type of armoring redirects stream energy to a new spot location downstream, creating a new point of stress.” (p. 4)
The Federal Emergency Management Agency (p. 8), the Corps, and the Flood Control District recommend against bank hardening projects due to, among other reasons, the “lack of shear stress reduction” and “the erosive energy transfer it would place on the opposite bank of the bayou at a downstream location.” (p. 21)
The Corps and Flood Control specifically rejected bank hardening “on the outside of meander bends” for reasons that include, in addition to above, “the lack of habitat creation” and “lack of natural occurrence” on the bayou. All three locations for the “stabilization” project are on the outside of meander bends.
Damage to Others
The initial metal walls being pounded into the bank at the downstream end of the club’s golf course are opposite residential properties. A preliminary analysis showed that they will indeed “displace” the club’s “erosion consequences onto their neighbors,” and that the “displaced consequences will be more expensive than the ones [the club] seeks to avoid.”
The on-site analysis was conducted by a professional geologist working with Save Buffalo Bayou.
The project will similarly cause increased erosion of the forested banks of Memorial Park upstream, a 1500-acre public park currently undergoing $300 million worth of landscaping. Management of the park is under contract to the Memorial Park Conservancy. Of the 28 members of the Conservancy board, at least six are members of the River Oaks Country Club, including the chairman and vice chairman, as is a major donor.
Among other problems, the project maps use an outdated LIDAR topographic survey of the area, possibly from 2008, that shows an inaccurate path of the bayou channel.
The project maps also exaggerate the club’s property line, which only extends partially down the bank to the “gradient boundary.” The Port of Houston (the public) owns the submerged lands of Buffalo Bayou.
Less Damaging Alternatives
The club has other less damaging, less costly, and more effective methods of protecting its bank. In mid-April Save Buffalo Bayou contacted the club leadership with recommendations and information but received no response. The club is led by board chairman Randall B. Hale. Board member Steve Lindley has been in charge of the golf course and bank projects.
In mid-April Save Buffalo Bayou also contacted the Memorial Park Conservancy, the Houston Parks Department, City officials, including the Mayor and City Council representatives, among others, about its concerns for the park. There was no response.
The bank hardening project is in the stretch of the bayou that was the location of a controversial plan, known as the Memorial Park Demonstration Project, based on so-called Natural Channel Design, principles used by both the Corps and Flood Control. The club was participating in the $6 million project, which was promoted by Flood Control and the Memorial Park Conservancy, among others. The plan would have razed the trees on both sides of the bayou, including forest of Memorial Park and the Hogg Bird Sanctuary; dredged and rerouted the bayou along the entire length of the golf course. Taxpayers were footing $4 million of the estimated $6 million cost.
The plan was based on a faulty analysis of bank collapse on Buffalo Bayou and would have failed, leaving behind a wasteland after destroying one of the last publicly-accessible forested areas of the bayou, a historic nature area.
However, the club could still use some form of Natural Channel Design, which is in theory (if not always in practice) a form of bank restoration and stabilization based on mimicking nature, including anchoring large woody debris onto the bank. The club has already removed most of the trees along the three sections of the bank targeted for hardening, which is the main reason the club is having problems in these areas.
Save Buffalo Bayou believes it is incumbent on the property owner to use, and the City of Houston to require, the least damaging alternative. Our nonprofit organization has requested that the City revoke the club’s floodplain permit, issued under Ch. 19 of the City’s Building Code, and has asked for a hearing before the little-known Board of General Appeals. Building officials, however, have been adamant that the board only hears appeals of permits denied, not permits granted.
But City building officials, and the Board of General Appeals, can and should recommend new laws and regulations to City Council that prohibit these kinds of damaging projects on the bayou, which only force more and more property owners to harden their banks in response. The end effect will be more flooding and environmental degradation, and the loss of a valuable public resource.
Texas law prohibits the diversion of the natural flow of surface waters “in a manner that damages the property of another by the overflow of the water diverted or impounded.” (Sec. 11.086 of the Texas Water Code)
The project could also result in an increase in flood insurance policy premiums for Houstonians by damaging the City of Houston’s Community Rating under the National Flood Insurance Program. The Community Rating System rewards the protection of “the natural and beneficial functions of a community’s floodprone lands.” (p. 1)
Reportedly the Bayou Bend Collection downstream from the club is also now considering a similar sheet-pile method to harden its collapsing, irrigated bank. Irrigation worsens bank instability.
The club’s bank problems are largely self-inflicted.
The club’s property bordering the bayou was once heavily forested, a natural protection against erosion and drainage problems. The club was founded in 1923 among the tall “river oaks” of Buffalo Bayou, as was Memorial Park shortly after. Over the years the club has removed the forest to expand its manicured, watered golf course up to the edge of the bayou bank. This was done specifically in the three areas where the club is now spending millions to combat erosion problems.
Most recently the club removed a large expanse of mature trees in the middle of the course as part of its 2015 golf course renovation led by board member Lindley. This has led to increased runoff and slumping of the bank in the middle Area #2 where the club is now having problems, which it has attempted to remedy by pouring large amounts of broken concrete onto the bank.
This middle Area #2 was once a ravine with a small tributary flowing into the bayou. Likewise Area #3 was also the mouth of a small ravine with a stream emptying into the bayou. These small streams appear to have been filled in or buried.
Prior to that, in 2015 under the direction of Lindley, the club bulldozed trees and vegetation on the beach below problem area #1, a high bank where slumping, a form of vertical bank collapse, had formed the beach or terrace. This vegetation was protecting the bank. After razing the vegetation, the club placed heavy concrete rubble, known as riprap, on the bank.
Riprap is not recommended for slumping banks as the additional weight can actually aggravate the problem, as can sheet pile retaining walls.
The club also placed a large amount of riprap against the low bank in problem area #3 downstream. Both of these costly riprap projects have predictably failed.
Since then the club has been dumping trash, including parking lot debris, along the bank below the golf course. The Corps of Engineers forbids the use of broken concrete as fill in other parts of Texas.