Developers Plan to Improve Memorial Park By Cutting a Lot of Trees, “Re-establishing” Streams

Business Group Requests Federal Permit for Dredging, Filling Wetlands, Hardening Tributaries to Buffalo Bayou

Public Comment Due by April 4, 2019


March 13, 2019

A Galleria-area development group has asked for a federal permit to fill wetlands and dredge and armor streams in Memorial Park in order to build two “earthen land bridges” over Memorial Drive. The project, part of a controversial $200-300 million landscaping plan for the public park, requires the felling of hundreds of trees, including mature pines, digging up and lining the streams with concrete rubble and wire baskets of “rocks,” covering Memorial Drive with concrete tunnels, and relocating playing fields and picnic areas.

The Harris County Improvement District 1, otherwise known as the Uptown Houston District is a local government corporation composed of property owners and developers and funded by special property tax levies. Its members are appointed by the Texas Commission on Environmental Quality. In 2013 the boundaries of the Uptown District, which is also governed by the Uptown Development Authority or Uptown Houston Tax Increment Reinvestment Zone (TIRZ 16), though they have different boards, was expanded to include Memorial Park, a 1,500-acre semi-forested park on Buffalo Bayou in the center of Houston. The TIRZ uses local property taxes that would otherwise go to the City’s general fund.

Location of proposed concrete tunnels and “land bridges” over Memorial Drive and same location in 2017.


The park, formerly the site of a World War I-era military training camp, is also a State Antiquities Landmark. (See also here.) Parts of a small constructed channel connecting the two originally natural though partially altered tributaries appear to be walled with stone possibly dating from that period. The two tributaries flow through deep wooded ravines lined with lovely dirt paths and empty in Buffalo Bayou.

“Rocks,” other than ancient sandstone, are not natural to Houston’s streams.

  • Location of streams, marked in blue, within project area in Memorial Park south of Memorial Drive subject to Clean Water Act because they are tributaries to Buffalo Bayou. Image from p. 15 of permit application mitigation plan.
  • A 2013 topographic map of natural tributaries flowing from Memorial Park into Buffalo Bayou.
  • The 2013 topographic map focused on the area of proposed land bridges and "re-established" streams.
  • Overview of the so-called "main" and "west" tributaries within the project boundaries. Image from page 24 of the permit application mitigation plan.
  • Plans for armoring the two streams with rock, gabions, and toewood. From page 26 of the permit application mitigation plan.


Public Comment Period Until April 4

The Improvement District last week filed an application for a permit from the US Army Corps of Engineers, which enforces the federal Clean Water Act. The Corps is seeking public comment on the permit application, including on whether a public hearing should be held. The public has until April 4 to comment. See below for how to comment.

The application seeks, among other things, to alter wetlands and “re-establish” some 1,485 linear feet of streams on both sides of Memorial Drive. The plan is to remove hundreds of trees in the channel of these streams, along the banks, and in the adjoining floodplains in an area of about 108 acres.

Removing trees that hold the streambank together and help deflect and absorb rain and runoff is pointless and counterproductive.

  • Great egret among trees north of Memorial Drive marked for clearcutting for land bridge. Photo by SC Jan. 31, 2019
  • Mature pines felled north of Memorial Drive for land bridges. Photo by SC Jan. 24, 2019
  • Trees tagged for felling along constructed channel lined with stone apparently dating from era of World War I military camp in Memorial Park. Photo by SC, March 5, 2019, south of ball fields on south side of the park.
  • Trees to be clearcut along and in old rock-lined channel flowing east-west between tributaries south of playing fields. Photo by SC March 5, 2019
  • Pines marked for removal south of ball field on south side of Memorial Drive. Photo March 5, 2019
  • Trees along western channel marked for clearing.
  • Doomed pine along east west channel south of Memorial Drive. Photo March 5, 2019
  • Loblolly pines along path next to deep ravine draining Memorial Park south into Buffalo Bayou. Photo by SC March 5, 2019
  • Large ravine draining Memorial Park south of ball fields and emptying into Buffalo Bayou. Photo March 5, 2019
  • Great loblolly pine standing next to ravine (tributary to Buffalo Bayou) along trail through woods south of ball fields. Photo by SC March 5, 2019


The permit seeks to use in part a costly, damaging, and discredited stream “restoration” method called “natural channel design,” or “natural stable channel design,” as it is called by the Harris County Flood Control District. Despite widespread criticism, the system is still used by public agencies across the country.

In addition to lining the stream channels with “rock” (often concrete rubble known as riprap) (p. 153) and gabions or wire baskets filled with rock, the applicant plans to destabilize the bank by digging it up with heavy equipment in order to bury tree trunks with root wads sticking out into the stream.

Armoring or hardening streams in an attempt to stabilize them can actually de-stabilize them. (p. 29)

The City of Houston has entered into an agreement allowing the newly-formed Astros Golf Foundation to enlarge and remodel the public golf course in the park for use as a PGA Tour tournament course. The Mayor’s Office has refused a Public Information request from Save Buffalo Bayou for information about the golf course plans or terms of the agreement. However, sources report that the renovation involves (has already involved) the felling of trees.

Hundreds of trees have been taken down for the landscaping of the 100-acre Eastern Glades on the east side of the park north of Memorial Drive. In addition, the master plan for the park currently includes the removal of large swaths of trees on the west side of West Memorial Loop Lane north of Memorial Drive for the planting of a monoculture of rows of pine trees.

Comments about the plan (including a request for a public hearing) should reference file number SWG-2018-00549 and be sent before April 4, 2019, to the Galveston District of the Corps Engineers by either mail, fax, or email:

North Unit

Regulatory Division, CESWG-RDE

U.S. Army Corps of Engineers

P.O. Box 1229

Galveston, Texas 77553-1229

409-766-3869 Phone


409-766-3931 Fax

Or email: