Recently, the Houston Sierra Club (Sierra Club) provided input to the General Land Office for the Texas Coastal Resiliency Master Plan (Plan). The Plan currently focuses on ecological restoration projects for the entire Texas Coast. Additional human infrastructure projects will be added in the future.

The Sierra Club stated in its comments that it appreciated the effort that went into the preparation of the Plan and that the Club’s intent is to provide comments that make the Plan a better document for the future. Since the Sierra Club did not have an opportunity to provide input during the preparation of the Plan, these comments provide an “initial assessment” and may change over time.

The Sierra Club stated that the Plan does not clearly document that “infrastructure” can be the cause of or cause additional natural and human-induced disturbance impacts. So “resiliency” of “infrastructure” may cause a weakening of “resiliency” of coastal ecosystems.

The Sierra Club expressed a concern that the root-causes of many Issues of Concern, are not addressed. Instead, the symptoms are addressed, like for example, shoreline erosion, instead of ship traffic and land development that cause the erosion. The Plan is reactive and not proactive. By addressing the symptom and not the actual cause the Plan will often cost taxpayers more money, require forever care, and will not resolve eternal problems.

The Sierra Club was not invited to assist the planning team and was not appointed to the Technical Advisory Committee. The Sierra Club has been involved with coastal issues almost from its inception, about 50 years ago. The Sierra Club is part of the public and is a stakeholder for the protection and careful use of the Texas Coast. We want to be involved. It is important that there be more input from the general public on the Plan.

The Plan states that “Pressures exerted on the coastal system (such as tropical storms, hurricanes, depletion of freshwater inflows, sediment deficits, infrastructure and development) … stem from social, economic and natural Drivers.” It is important to note, that there is no problem on the Texas Coast when people and their structures are “kept out of harm’s way”.

It is the behavior of people who place themselves in “harm’s way” and then want to interfere with and change natural ecosystems, processes, and their functions that cause problems for the environment and humans. It is important to address these behaviors via education, persuasion, and regulation so that both people and coastal ecosystems are safe.

The Plan states that “an enhanced focus on storm surge defense and flood risk reduction” is needed. The Sierra Club is concerned that instead of implementation of prevention measures, so that people and their structures are not put in “harm’s way”, and instead of personal responsibility being advocated as a driving force to keep people out of “harm’s way”, that large, costly, and ultimately perpetual structures that cause significant environmental damage, will be advocated for and constructed.

This solution requires defense of these structures and more reliance on further structural solutions. This is a no-win solution that will bankrupt economically and environmentally the Texas Coast. Flooding, storm surge, erosion, and sedimentation will continue (it is their dynamic nature) on the Texas Coast no matter what we do as climate changes, sea level rises, rains increase, and storms appear. It is not clear how the Plan can fully fund, enforce, and in perpetuity continue forever such social, economic and environmental changes via structural solutions or ecosystem restoration. The population and development pressures that drive problems on the Texas Coast must be addressed as the primary forces that put people and the environment in “harm’s way”.

The Sierra Club agrees that “The high rate of erosion in this region can be partly attributed to a naturally sand-starved setting; exacerbated by engineered structures such as the dredged channels and jetties … that interrupt the longshore transport of sediments”. However, the Plan does not address these specific human causes of erosion, dredged channels and jetties, as the drivers of erosion and thus treats the symptoms and not the causes of human-caused erosion.

The Sierra Club believes that the causes of erosion that are human-caused must be addressed. The Plan discusses the effect Hurricane Ike had on the dune system along the Galveston Seawall but then does not state that the dune system originally eroded away due to the “Seawall”, that it continues to erode way due to the “Seawall”, and that the “Seawall” causes further erosion down the shoreline from its location. The construction of the “Seawall” was the cause and driver of this erosion but the Plan does not discuss this or what can be done about this cause.

The Sierra Club is concerned that the Houston Region has had 14% of the land area developed and 13.4% of the Gulf beaches and 21% of the bay shorelines armored. The problems that these structures cause and the solutions for these problems should be a major focus of the Plan but are not. The Plan must focus on root-causes and not symptoms of problems.

Many extreme weather events and sea level rise are caused by human actions, the release of greenhouse gas air pollutants like carbon dioxide and methane. Therefore, the Plan should not be afraid to say that global warming is caused by human actions which burn or release greenhouse gases. The actual rate of sea level rise has been higher than we thought for several decades. The figures used by the Plan for sea level rise are out-of-date and are not the best scientific information available.

The Plan should define how it envisions “longevity” for coastal resiliency. 100 years is a short-term horizon in the age of “climate change” and “sea level rise” and that at least this horizon should be used for all projects, proposals, policies, programs, and plans. While the Plan wants to “protect our valuable coastal resources and habitats from changing conditions” this will not occur. The changes have occurred and will continue to occur. The best we can do is plan ahead and be strategic about how we respond to those changes. We cannot stop the changes that will occur to the coastal ecosystems over time.

The Sierra Club is concerned that the Plan proposes to dredge sand from the mouth of the Trinity and Sabine Rivers. The destruction and degradation that will occur from this proposal to Galveston Bay and Sabine Lake is ignored. The Plan should state clearly how this can be done and not degrade these two bay systems.

The Sierra Club is concerned about Follets Island erosion control. Already Brazoria County has requested that the Corps of Engineers allow it to dredge San Luis Pass so that sediment can be put on Follets Island. The protection of State Highway 257 is dubious as a road due to its 2-foot elevation and its continued erosion by normal wind, wave, and current actions.

The Plan should state why “increased harvest pressure” and “over-harvesting” has been allowed to degrade oyster reefs and what will be done in the future to reduce this pressure.

From the Galveston Seawall to San Luis Pass much of the land is private. The Plan should state how much of the cost for projects will be paid by private landowners who benefit from them. This is only right since the public should not have to pay the full cost of projects that significantly benefit private landowners.

The Sierra Club plans to monitor and provide input for the Plan in the future.

Brandt Mannchen