Heart-Breaking Violation of County, City Mandates. Appropriate Use of Federal Funds?
Sept. 30, 2020
We were hoping they wouldn’t do it. That Harris County Flood Control would see it wasn’t necessary. The bayou banks were healthy and stable, lush and green.
But the private consulting engineers had planned it. So Flood Control did it: scraped away the young trees and deep-rooted native plants holding the bank together, bulldozed what nature had successfully engineered, built, and planted in Buffalo Bayou Park.
They left bare dirt, disturbed, compacted, dead. Violated every established principle of good management of a riverbank, as noted by one of the federal agencies funding the project. (p. 14)
And the bare dirt washed away in the rains that followed.
Without the anchor of the surrounding network of deep-rooted plants, the remaining lone trees on the banks likely will soon fall, as happened as a result of Flood Control’s previous work.
They did it with public funds, spending over $2,000 per linear foot, claiming the purpose was to “contain erosion and bank failures caused by Hurricane Harvey.”
These particular banks weren’t failing. We know because we climbed out of our canoes and up that gently sloping bank through the tall goldenrod and horseweed below the Dunlavy a couple of times in recent months. Flood Control’s federal grant was supposed to be used to “reshape and protect eroded streambanks.” But none of these areas was eroded. The bank shape was fine. Maybe steeper after bulldozing, with less of a beach, but pretty much the same. Though bare and unprotected.
Designed to Fail? Do It Anyway
Not even the private contractors paid to scrape it all away thought it was a good idea. In response to the observation that the denuded bank would fail as a result, one worker commented, “That’s what we told them.” He added, “But that’s the way Flood Control wanted it.” We responded that Flood Control had just destroyed a healthy bayou bank. The guys nodded.
Like Harris County Flood Control’s previous bank projects, this one seems almost designed to fail, requiring more public funds, more maintenance and repairs, more contracts to be let.
Jason Krahn, Flood Control’s former project manager for Buffalo Bayou Park, said in a phone call that the purpose of scraping the banks was to remove sediment accumulated from floods and take the “bankfull bench back down to the design elevation.” He was referring to Flood Control’s original 2010 plan, based on Natural Stable Channel Design, for the channel and banks in the park.
But the bank elevation of those sections looks pretty much the same. Floodplains naturally collect sediment, a reason they are so fertile, and a reason why artificially landscaping a park on a riverbank is complicated and costly. The huge amount of sediment deposited by Harvey on the upper banks had long ago been removed. We did see piles of sediment scraped together just before Storm Beta. We also saw backhoes spreading out sediment and packing it down.
The banks scraped of deep-rooted native plants will be planted with turf grass for now, said Krahn. He added that the district together with the Buffalo Bayou Partnership, the private nonprofit organization that manages the park, is studying what else to plant on the banks.
Perhaps they could have saved some public funds and simply noted what was growing there before they scraped the banks. The bayou, a living river, has perfected a landscaping plan, purposefully planting a succession of functional plants at appropriate times.
And while some people think that these tall, deep-rooted riparian plants can block the flow, note how they bow to the force of the stream during high water. And yes, they stand up again.
Contrary to County Instructions, City Floodplain Management Plan
This particular bulldozing of healthy bank in three lengthy sections of the north and south bank above Waugh Drive was the last phase of a controversial $9.7 million project in Buffalo Bayou Park begun in August 2019. On August 27, 2019, Harris County Commissioners’ Court passed the Harris Thrives Resolution instructing Flood Control “to emphasize an approach that respects, reclaims, and restores floodplains; preserves undeveloped prairies and forests that detain stormwater; and encourages the use of nature-based solutions, natural infrastructure, and cutting edge technological methods where possible in public and private projects …”
Apparently those instructions from Flood Control’s bosses didn’t apply to this project. Or they think these methods are “nature-based.”
Most of the 4,540 linear feet of bank “repaired” by Flood Control in the popular city park between Allen Parkway and Memorial Drive was bulldozed and covered with tons of concrete riprap and dirt extending far into the channel.
The nearly $10 million in public funds for the project comes from grants from the Natural Resources Conservation Service (NRCS) and the Federal Emergency Management Agency (FEMA).
NRCS Emergency Watershed Protection Recovery grants can be used to:
- Remove debris from stream channels, road culverts and bridges;
- reshape and protect eroded streambanks;
- correct damaged or destroyed drainage facilities;
- establish vegetative cover on critically eroding lands;
- repair levees and structures;
- repair conservation practices.
Program funds cannot be used “to install non-essential restoration work that will not reduce or eliminate adverse impacts from the natural disaster.”
As for the FEMA funds, FEMA also emphasizes the benefits of natural floodplains for protection against erosion and flooding, among other things. How well local authorities manage their floodplain and floodways determines how much local residents will pay for their federal flood insurance through FEMA’s National Flood Insurance Program. To participate in the program, both the City of Houston (p. 6) and Harris County are required to have floodplain management plans that emphasize protection of the natural and beneficial functions of floodplains.
Those many beneficial functions include absorbing, slowing, cooling, and cleansing stormwater and polluted runoff, collecting and holding sediment, reducing peak flows and dissipating dangerous energy in the stream, protecting against erosion and bank failure, promoting groundwater recharge and preventing subsidence, and more.
Floodplains and floodways include what is known as the riparian zone, buffer, or corridor, which is the vegetated area adjacent the stream, anywhere from 15 feet to 100 feet wide on each side. Particularly important for water quality in urban areas, riparian buffers have been shown to be more effective at cleansing water than even water treatment plants.
The Environmental Impact
Riparian areas are also essential for wildlife habitat. The bayou in this section and up and downstream is home to threatened alligator snapping turtles, beavers and other creatures that make their home in and on the bank. Jones Carter, the engineering firm that designed the project, claimed to have consulted with Texas Parks and Wildlife about the environmental impact of the bank work.
We do know that the contractor, James Construction Group, LLC, made arrangements to avoid working around Waugh Bridge during hours when the popular bat colony there would be feeding. According to the permit issued in 2019 by the Corps of Engineers for the project, “This work activity has no effect on threatened or endangered species or their habitat, cultural or historic resources, or rookeries.” (p. 1)
Stormwater Pipes Left in Place to Block Flow, Increase Turbulence and Bank Erosion
We asked Flood Control’s Krahn about why, when they were spending so much money and going to so much effort to repair again repairs they had already made in a constantly eroding channel, they didn’t replace the numerous stormwater drainage pipes (outfalls) that point directly across the stream, blocking high flows, causing turbulence and erosion. Drainage outfalls at angles of greater than 45 degrees violate the District’s own guidelines (p. 136) as well as its federal permit from the Corps of Engineers. (p. 3)
Krahn explained that the stormwater pipes in Buffalo Bayou Park were not installed by the district.
Last of the Endless Repairs
The initial bank project that Flood Control did in the park in 2010 was a demonstration of their controversial Natural Stable Channel Design method. These are the banks that Flood Control has now been repairing at great expense for almost ten years. One would have to conclude that Natural Stable Channel Design failed. (And they wanted to do it to the forested banks of the bayou flowing past Memorial Park.)
But Flood Control continues to rip out trees and bulldoze the banks of our few remaining natural streams in order to rebuild the bank using the failed principles of Natural Stable Channel Design. In fact, according to Krahn, they focus these design projects on natural areas rather than previously channelized streams.
For a recent example, see Pillot Gulley, a tributary of Cypress Creek at the edge of the Kickerillo-Mischer Preserve in northwest Harris County, where Flood Control removed the stabilizing trees to stabilize the bank with Natural Stable Channel Design.