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Common Nighthawk

Response to Corp of Engineers Buffalo Bayou Project

November 11, 2020

USACE Galveston District
P.O. Box 1229
Galveston, Texas 77553-1229
VIA E-mail:

Dear ACOE- Galveston District Project Managers:

Houston Audubon is a regional nonprofit with a mission to advance the conservation of
birds and positively impact their supporting environments. Over the past 50 years, we've
worked with regional and local partners and stakeholders to preserve our region's critical
habitats for birds and people.

Today, we write to express our deepest concern regarding the long-term ecological effects
the above referenced project will have on the region's important natural assets, especially
the bayou ecosystem, its riparian habitat, as well as critical endangered prairie habitat
that thousands of resident, nesting, and migrating birds depend on to survive. Habitat like
this has been destroyed over the years and loss of habitat like this has exacerbated the
flooding problems we are seeking to solve.

We recognize the urgency to address flooding in the greater Houston area, and we
support a robust, comprehensive process of evaluation, selection of alternatives, and
transparency. A robust and transparent process, which taxpayers deserve, includes
providing sufficient time for public review and releasing the supporting data and models
that were used to analyze the alternatives and that provide the basis of the study report.

We respectfully request release of this data and information and an extension ofthe
comment period to March 31, 2021.

Birds are an integral part of Houston's natural heritage and culture. With more than 400
bird species documented in the greater Houston region, preserving quantity and quality of
habitat is essential. Birds in the United States and Canada have declined by 29 percent
since 1970 and habitat loss is the most significant contributing factor.

In addition to requesting the USACE provide public access to all data and modeling before
eliminating alternatives under consideration, we also urge you to:

  • Focus on alternatives that preserve our natural assets and heritage and work with nature.
  • Provide for buy-outs, stronger building codes, restoration of habitats, acquisition  of buffer zones, and other benefits that are more sustainable and naturally resilient
  • If habitat preservation and restoration is determined to not be feasible, consider alternatives that provide quicker, scalable impacts but also ecological and social benefits.
  • Review whether the benefit-cost ratio (BCR) can effectively address flood risk on Buffalo Bayou.

We look forward to hearing from you regarding our requests and the comments we've provided to help
improve the long-term future of our region.


Signed by:
Helen E. Drummond, Executive Director
Sam Smith, Board President

Houston Chronicle article: Digging Buffalo Bayou deeper? Houstonians up in arms over Army Corps' 'old-fashioned' flood fixes.

Feasibility study: Buffalo Bayou and Tributaries Resiliency Study, Texas.

Reference link: USACE Galveston District releases Buffalo Bayou Tributaries Resiliency Study Interim Report.