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Corps prohibits trees on levees; so where’s the state?


by Len Bahr, PhD*

On August 4 2012 Mark Schleifstein reported in The Times-Picayune that sections of the Mississippi River levee between the Corps New Orleans District headquarters on Leake Avenue and Audubon Park are being elevated by two feet, requiring temporarily closing some baseball fields and picnic areas known locally as “The Fly.”

Schleifstein reported that the elevated levee segments will conform to the new corps policy on levee vegetation. This caught my eye and reminded me of one of my favorite  subjects…the possible use of trees to stabilize and sustain hybrid levees for certain specific applications.

Virtually no one alive still blames Mother Nature for the August 29 2005 catastrophe spawned by Hurricane Katrina. Independent forensic analyses showed that the tragedy was the consequence of a levee system that failed under hydraulic forces weaker than its advertised design capability.

Levee failures in SE Louisiana took the lives of over 1,600 victims and incurred $150 billion in damages, which convinced the U.S. Congress to pony up almost $15 billion to upgrade levees, install pumps and build surge barriers.

The sordid Katrina episode called levee integrity into question throughout the country and prompted the corps to undertake a survey of the status and condition of all federal levees, from DC to Sacramento. This survey revealed that, notwithstanding a traditional corps blanket prohibition of woody vegetation on all federal levees, some ‘leftist’ California levees had become overgrown by trees.

These ‘forested’ levees had created wildlife habitat for ecologically significant migratory birds and contributed esthetic qualities that were locally popular. These and other attributes are not discussed in civil engineering schools. In my technical opinion, the intertwined roots of these trees probably greatly increased the integrity of the levee sediments as well, although to my knowledge this binding property has never been quantified.

Despite objections from the State of California, on April 10, 2009 the U.S. Army Corps of Engineers formally adopted a standard one-size-fits-all-policy prohibiting trees on levees. This policy goes under the rubric: Guidelines For Landscape Planting and Vegetation Management of Levees, Floodwalls, Embankment Dams, and Appurtenant Structures. The policy document was accompanied by a draft policy guidance letter: “Process for Requesting a Variance from Vegetation Standards for Levees and Floodwalls–25 Fed. Reg. 6364-08″ (PGL).

The State of California officially challenged the policy on environmental grounds. Here are some comments from a California review of that policy:

In the wake of Hurricane Katrina, the U.S. Army Corps of Engineers (Corps) embarked upon a process of reviewing and improving their levee standards with the goal of improving public safety. As part of this process, they reinvigorated and clarified national policy that would require the removal of all woody vegetation over 2 inches in diameter from levee systems throughout the country. This was done even though vegetation did not cause any of the numerous levee and floodwall failures in New Orleans.

On April 15, 2010, the California Department of Water Resources (DWR) and California Department of Fish and Game (DFG) submitted extensive comments on the ETL and POL, explaining how the Corps’ vegetation management policy will reduce public safety in California, result in extensive and unnecessary environmental damage, and remove the Corps’ responsibility to assist state and local maintaining agencies in ensuring the integrity of California’s levee system.

California agrees with the Corps that public safety is the highest priority for flood management. California also agrees upon the importance of appropriate vegetation management on levees. Despite these common goals, California asserts that the Corps’ strict enforcement of the ETL and PGL will adversely impact public safety. This unintended consequence is due in large part by attempting to address complex technical, financial, legal and institutional problems with a highly prescriptive, one-size-fits-all approach to vegetation management.

No comments on this blanket levee tree prohibition policy have ever issued from the Louisiana Governor’s Office of Coastal Activities (GOCS) or the Office of Coastal Protection and Restoration (OCPR) or the Coastal Protection and Restoration Authority (CPRA). During the current recovery period from Hurricane Isaac I hear a growing call for putting more of the limited coastal restoration ‘eggs’ into the traditional levee basket, i.e., to construct costly, high maintenance earthen levees, rather than expanding ecosystem restoration, as called for in the Louisiana Comprehensive Master Plan for a Sustainable Coast.

I have previously argued strenuously (and fruitlessly) for consideration in carefully selected areas of a modest cost ‘hybrid’ levee design, borrowing from the function of forested chenier ridges in SW Louisiana. These sustainable levees, called Chenieres Faux, would be smaller and lower than traditional earthen levees and purposely colonized with dense populations of native trees known to be extremely durable in the face of hurricane winds and water currents.

Chenieres Faux would be designed to be resistant, but not impervious to storm surge. In other words, overtopping by surge waters would be fully expected. Consideration of forested hybrid levees would of course require a special dispensation from the blanket prohibition on levee trees.

*Founding editor
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  1. The state of Louisiana has twisted this Corps guideline (guideline, NOT POLICY) into a premise to steal the private property along all levees in Louisiana. That Corps guideline calls for 15 foot vegetation free zones along new levee projects, where these zones would be purchased from private property owners as part of the property acquisition for the new project.
    The guideline for existing levee projects is that the Corps works with whatever the state’s existing rights of way are. The guidelines specifically call for NOT increasing the real estate interests on existing projects. The state lied and increased it’s claim to these properties to toe plus 15 feet. They also lied by threatening levee decertification if it wasn’t done. Attempts to have the state AG issue an opinion on the constitutionality were also blocked. Watch the state’s lies unfold before your eyes:

  2. I’m a freelance journalist doing a story on the leftist levees in California in Eastern Contra Costa County. I assume your Phd is relevant to the subject of flood control. Would you say trees make the levee stronger? The Board of Supervisors/Flood Control District is supporting changes to Federal law to make it easier to get variances to the Army Corps of Engineers policy of grass-only.

  3. Corps policy that requires 15 foot vegetation free zones along the toe of the levee are being enforced state wide. in 2011 Louisiana levee officials had the legislature increase the state law to 15 feet to match this Corps guideline. The only problem is…there is no such guideline.

    Here is what the Corps policy calls for:
    15 foot vegetation free zones are for new
    Existing projects whose existing real
    estate interest are less than the 15 feet
    shall operate within the maximum
    allowable width that the existing real
    estate (IE:right-of-way) allows. In some
    cases that existing real estate is ZERO
    distance from the levee toe. IE: none!
    1. There is no provision in Corps Policy
    for variances on these existing projects.
    2. Existing projects satisfy the
    guidelines because they are an “exception
    to the rule”.
    3. Also the provisions for variances to
    the vegetation guidelines are for new
    projects, not existing ones.
    4. Existing projects satisfy those
    guidelines by maintaining the VFZs to the
    maximum allowed by that existing real
    estate (rights-of-way) interest. They
    don’t require variances.
    5. The state undertook the increase to
    the VFZs in 2011 on it’s own. Anyone
    saying that the Corps requested this is
    lying. Just as they are if they are
    claiming that these smaller than 15 foot
    zones threatened the certification of the
    levees. Not true, see link to document

    Here is the page from the Corps
    guidelines that most of my comments refer

    Picture this; if the Corps even
    considered a variance on land where the
    existing real estate interest was less
    than 15 feet. The Corps would actually
    be making a decision to grant a variance
    (or not grant one) on property that by
    definition, is outside of the property
    that it has the authority to grant a
    variance on, and would be on property
    that is an exception to the guidelines
    and therefore is property where the
    guideline does not apply.

    The above article says that

    “No comments on this blanket levee tree prohibition policy have ever issued from the Louisiana Governor’s Office of Coastal Activities (GOCS) or the Office of Coastal Protection and Restoration (OCPR) or the Coastal Protection and Restoration Authority (CPRA).”

    But that is not accurate. The CPRA has been making all sorts of false claims in support of this. The first two statements in this video (link below) are from Mr. Garret Graves, chairman of the CPRA, and the second is from Mr. John Barry of the CPRA. Barry’s statement was made at the Feb. board meeting of the CPRA.

  4. It seems to me that the idea could at least be explored with some test chenier faux (sic italics) “outside” the levee system in fresh water swamp areas to see how various species and varieties of native plants respond.

    Studies such as this have never been made in Louisiana so no one
    really knows how successful or unsuccessful the concept of tree covered levees would be.

    Salix nigra (sic italics) long ago used to armor the Mississippi river ought to be the first species tested since this type of native tree has adventitious roots that sprout after being submerged with sand, silt and water moved clay.

    Also this species will sucker from the roots if cut to the ground one must wonder what might cause the tree to die other than wind storms. The answer there of course is to never let the species grow to a high center of gravity by keeping it cut low to the ground. It is the roots that are wanted, not the top of the tree.

    In addition, add a little vitiver grass (Vetiveria zizanioides)
    six italics, and Fakahatchee grass (Tripsacum dactyloides)sic italics around the base of the willows and you will have some vegetative roots doing some structural work.

    What is there to lose by at least test driving the concept?

  5. I agree that healthy trees nearly always take energy and momentum out of surge and help break waves. But it also true that if a tree growing on or near a levee topples due to wind effects and pulls the root ball up, then that could compromise the integrity of the levee. There needs to be a careful balance between the surge reduction benefits and the risks of compromised integrity.

  6. That trees slow storm surge was obvious in coastal parishes during the hurricanes in recent years. Planting trees is inexpensive relative to the alternative levee construction, and has all sorts of ecological benefits throughout the year.

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