This will be my third post about this study, officially called the Buffalo Bayou & Tributaries Resiliency Study.

My first post included a copy of the comments I helped prepare for the Houston Branch of the American Society of Civil Engineers in response to the U.S. Army Corps of Engineers’ (USACE’s) request for public input.

My second post was about how difficult it will be to devise a storage and conveyance project that will have a sufficiently favorable benefit cost ratio (BCR) to secure federal support.

This post is about why I don’t support the Buffalo Bayou Community Plan proposed by Houston Stronger. I have two main reasons, but first, I want to provide a short summary of the Community Plan.

The Buffalo Bayou Community Plan includes the following proposed elements:

Tunnel: 23 miles long and about 40 feet in diameter. Estimated to cost $4.2 Billion by Houston Stronger.

Addicks Excavation: Excavate and relocate 166,000 acre-feet of soil to increase storage capacity. The Astrodome is about 965 acre-feet, so the plan would be to remove 172 Astrodomes of soil and find a place to put it that won’t cause flooding elsewhere. Estimated to cost $1.35 Billion by Houston Stronger.

Barker Excavation: Excavate and relocate 191 Astrodomes of soil. Estimated to cost $1.10 Billion by Houston Stronger.

Cypress Creek Storage: Add storage and conveyance in Cypress Creek area. Estimated to cost $700 million by Houston Stronger.

The total cost, as estimated by Houston Stronger is $7.35 Billion. A diagram of the plan is presented below, from Houston Stonger’s website.

My first reason to oppose the plan relates to who pays for it. Put simply, we will never get the federal government to pay for it. As I explained in my prior post, low BCRs for conveyance and storage, the key elements of the Buffalo Bayou Community Plan, were calculated because the existing risk of flooding in the watershed is already very low.  Since spending $7.35 Billion to implement the plan will only slightly reduce an already very low inundation risk – the value of avoided damages is very small compared to the project cost. This means that the United States Congress will be very unlikely to authorize the work and very unlikely to appropriate any federal funding to conduct the work.

If we have to pay for it ourselves I think we should invest in other portions of the county that have a lower prior investment in flood risk reduction projects, a higher risk of flooding, and where people with higher vulnerability live. More on these points in a bit.

Since my post in November 2020, Harris County Commissioner Precinct 3 and Harris County Commissioner Precinct 4 allocated $1.68 million in local funding to assist the USACE to conduct additional studies of the Buffalo Bayou, Addicks, and Barker watersheds. These funds were unanimously approved by Harris County Commissioner Court on May 11, 2021. In addition, the Assistant Secretary of the Army for Civil Works, Michael Conner, approved the USACE Galveston District’s request for additional time and funding to expand the study. According to the website of U.S. Congresswoman Fletcher (TX-7), this approval was obtained in January 2022 and the total cost of the additional work is $3.367 million.

I don’t think the additional funding will be able to uncover any new projects that will result in a more favorable BCR. 

Now you are probably thinking: Michael, you always talk about how projects can deliver better social, environmental, and economic outcomes — maximizing the so-called ‘triple bottom line,’ – won’t the additional study funding allow the USACE to estimate the value of these benefits (those other than avoided damages)? Won’t that allow the USACE to generate a benefit value greater than the proposed $7.35 billion cost?

If the USACE uses current policy and procedures, benefits other than the value of avoided structure and property damage won’t be included. This calculation will not magically find more than $7.35 billion in benefits, especially, when the very low likelihood of the extreme storm event is considered (even if the likelihood is increased somewhat to account for climate change).

Even if the USACE can create updated guidance on how to consider all triple bottom line benefits in accordance with this January 2021 “Comprehensive Documentation of Benefits in Decision Document” memorandum from the former Assistant Secretary of the Army for Civil Works and if the Buffalo Bayou Community Plan is evaluated using the new guidance, I still don’t think the project will generate a benefit value greater than the $7.35 billion project cost.

Harris County is pushing as hard as it can to secure federal support for some type of additional investment by increasing the estimated benefit value. On October 26, 2021, the county hired Lowry Crook of the BBK law firm to help with this effort. According to his biography, Mr. Crook served as counsel in the White House and oversaw the Army Corps of Engineers.

My second reason for opposing the Buffalo Bayou Community Plan is based on fairness and equity. The maps below illustrate the situation.  The first map illustrates all Harris County watersheds. 

The second map illustrates the existing flood risk areas identified by the National Flood Insurance Program, mapped by Harris County Flood Control District, and approved by the U.S. Federal Emergency Management Agency (FEMA), mostly around 2017. Most of the blue zone — which shows areas with greater than 0.2% annual chance of inundation — will be expanding after the completion of the MAAPNext project which is using the updated rainfall statics included in Atlas 14.  Notice how narrow the blue zone is along Buffalo Bayou? While the blue area is very large in Addicks and Barker, there are no structures in most of that area because the federal government owns most of the land and prohibited development. Areas outside of federally owned land did see development, but virtually all of those structures are outside of the 1% annual chance flood zone.

The third map illustrates the 2018 Social Vulnerability Index (SVI) scores in all mapped flood zones. SVI scores are calculated for all U.S. Census tracts nationally by the Centers for Disease Control using U.S. Census data.  SVI scores range from zero to one and indicate how susceptible a population is to the harms and disruption caused by flooding.  An SVI of zero means extremely low vulnerability (dark green in the map below). An SVI of one means extremely high vulnerability (red in the map below).  For example, a homeowner with a car, an annual salary, and four weeks of personal time off is less vulnerable than a renter without a car, an hourly wage, and no time off.

SVI scores in the Buffalo Bayou watershed range from 0.0 to 0.50 – indicating a very low level of vulnerability.  SVI scores inside Halls Bayou, Hunting Bayou, and Greens Bayou, just to name a few, range from 0.50 to 1.00, with many areas greater than 0.75.

These maps illustrate that the Buffalo Bayou Community Plan is the opposite of equity. The plan suggests we spend $7.35 billion in a watershed that is one of the least vulnerable of all Harris County watersheds and one with the smallest number of homes and structures exposed to a greater than 0.2% annual chance of inundation.

As a member of the Harris County Community Flood Resilience Task Force (CFRTF)* I have to ask:

With over $50 billion in identified flood risk reduction needs across the county and a limited amount of public investment dollars to spend, why would we want to invest $7.35 billion in an area with a very low risk of flooding and with a highly resilient population when we have citizens living in Greens, Halls, and Hunting Bayous with much higher flood risks and much higher vulnerability? 

*This post represents my own views and does not in any way represent the views of the CFRTF.