On July 26, 2024, the Houston Sierra Club (HSC) submitted a public scoping comment letter to the U.S. Army Corps of Engineers, Galveston District, about the proposed revision of the Addicks/Barker Reservoirs (ABRs) Master Plan (MP), Buffalo Bayou and Tributaries, Fort Bend and Harris Counties, Texas.  Some of the comments made by the HSC include:

1.  Non-native invasive plant and animal species (NNIPAS) must be controlled to reduce the negative impacts they have on natural ecosystems, native plants and animals, and human structures.  The Corps should put together a list of NNIPAS, the problems they create, and how they will be controlled for the draft MP and solicit input from the public about this issue.

The Sierra Club is concerned that obvious NNIPAS, like Chinese Tallow … and urges the Corps to have an active, visible, NNIPAS control and reduction program.   

Feral hogs, nutria, crazy ants, and fire ants must also be controlled.  The Corps should cooperate with other agencies … to come up with a regional plan to reduce the numbers significantly of feral hogs, nutria, crazy ants, and fire ants.  This can be done but requires patience and dedication.  Control of NNIPAS should be a pillar of the MP.

It’s important that the Corps prevents the introduction of NNIPAS by keeping restricted and prohibited lists updated, insuring enforcement actions at the boundaries, cleaning equipment and vehicles to reduce NNIPAS spread, and cooperating with … administrative officials.  NNIPAS will also be reduced in numbers if the Corps focuses on the maintenance, restoration, and protection of healthy terrestrial and aquatic ecosystems. 

The Corps should recruit and train citizens so they can assist with the protection of ecosystems via identification of NNIPAS in ABRs. 

2. Climate change, and its effects, like more frequent and intense rainfalls, sea level rise, more frequent and intense storms, and greater temperature heat effects must be addressed.  Buffalo Bayou and its tributaries and the ABRs will be significantly affected by climate change.  There must be an acknowledgment of this and how the ABRs will be managed for this in the MP.

The best thing to do is to ensure that ecosystems are healthy so that the natural processes they perform function, and they can adapt to climate change.  This includes buffers to allow bottomland hardwood forested wetlands and other ecosystems to be protected from other uses so that they remain healthy.

The Corps needs a plan … “Management for the long-term” is a key philosophy along with “work with Nature, not against”, and “keep people out of harm’s way”.

The Corps should address the increase in temperature and heat due to climate change with safety information and shade structures (small and integrated into the landscape) so that people are protected and forewarned about this danger.

3. Environmentally sensitive areas are important.  What is equally important is the level of protection from human action and activities that these areas receive.  It’s very important that there be adequate personnel to conduct patrols to ensure that illegal uses, actions, trespassing, and damaging activities are limited, minimized, and avoided.  The Sierra Club agrees that maintenance, protection, and restoration of wetlands in ABRs is a high priority.

Some of this protection can be done with public education but we need strong enforcement and compliance rules and the personnel to implement these.  This includes interactions with landowners and ensuring that they don’t trespass or attempt to use federal public land to enhance themselves economically or personally.  Development has closed in on the ABRs.  The Corps must plan for more intense pressures from development and its environmental impacts on the ABRs.  Boundary marking and enforcement is very important for the MP to address.

There is a need to protect and restore more native coastal prairie in the ABRs.  Buffers are needed between areas to ensure that environmentally sensitive areas don’t have spillover effects from recreation areas.

ABRs is one of the largest and last public land sites where prairie restoration can be implemented and practiced.  There needs to be more prairie dedicated to sensitive areas and protected from multiple uses that reduce prairie ecosystem benefits.

The Corps should recruit and train citizens so they can assist with the protection of terrestrial and aquatic ecosystems in ABRs.  The Corps should aggressively protect terrestrial and aquatic ecosystems and consult and communicate with the public and relevant agencies about these efforts.

4. Water instream flows are paramount to the health of the ABRs.  These flows help maintain the bottomland hardwood forested wetlands and riparian woodland ecosystems and the floodplains that they contain.

5. Any recreation allowed in the MP should be low impact and compatible with the protection of ecosystems and management (light-handed management) of natural ecological systems and processes.   The Sierra Club doesn’t support the use of motorized vehicles, except on existing roads.  No public recreational off-road vehicle use should be allowed.

6. Mountain bike use should occur on a separate system of trails from hiking/walking/running trails because the speed and experiences are different for these two trail users.  There are matters of safety, compatibility, and user conflict between these two users that need to be addressed and reinforced by the MP.

7. Terrestrial trails must be compatible with the ecosystems where they are found.  Since the ABRs consist primarily of riparian and aquatic ecosystems, flooded reservoirs, and wet prairie ecosystems, terrestrial trails should be limited to areas that can withstand these wet conditions.

Operation, maintenance, repair, and rehabilitation of terrestrial trails is difficult in such wet ecosystems without permanent soil erosion, compaction, rutting, puddling, sedimentation, and other problems.  Additional rainfall due to climate change will make the use of trails more difficult. 

8. The Sierra Club, in general, doesn’t support commercial concessions and quasi-public development of any of ABRs in the MP.  Making money shouldn’t be the reason that any activity is on public lands in the ABRs.  Low Density Recreation should be emphasized because it’s cheaper to construct, maintain, can be lower in impact, and more compatible with other management of the ABRs.

9. The Sierra Club recommends that certain areas should be designated as Fish and Wildlife Sanctuaries with restrictions so that fish and wildlife species have places where they can rest, migrate, feed, nest, and spawn.  Expansion of and the restoration and maintenance of native prairies is an important element that should be addressed in the MP.

10. The Sierra Club opposes maximizing the use of limited public lands.  This leads to land degradation on a landscape scale and overcrowding and will be detrimental to the enjoyment of solitude, natural sounds, natural dark, and other important public land features and values including the spiritual renewal that natural lands provide and a low noise environment.  The Corps should include the protection of solitude, quiet, natural sounds, natural dark, and spiritual renewal in the MP.

The Corps should encourage people of all ages and abilities to experience the outdoors; educate the public about the importance of environmental protection; expand outreach to increase awareness and participation in the conservation of natural and cultural resources; and increase citizen awareness of the value of urban ecosystems.  Face-to-face meetings should be emphasized because of the importance they have in providing social meaning for environmental protection.

11. The Sierra Club doesn’t support logging forests under “Vegetation Management”, “Wildlife Management”, or any other land classification.  It’s one thing to cut down Chinese Tallow or other NNIPAS.  But logging other trees isn’t justified in the ABRs.  There is no need for it.  The Sierra Club urges the Corps not to allow logging of forests in the MP.  Prescribed burning should be used to control woody plants.

12. The Sierra Club agrees that utility corridors should be used as much as possible to reduce fragmentation of the ABRs.  The Corps should discuss mineral rights and the ABRs and how their management fits in with management of other uses in the MP.  Utility corridors could be places where native prairies can be restored. 

The HSC will follow the preparation by the Corps of the Addicks and Barker Reservoirs Master Plan and provide additional comments in the future.