The Future of the Storm Protection Levees in Brazosport and Why FEMA’s Accreditation System lacks Historical Perspective

Incognizant Speculation:

Andrew S. Terrell

Dr. Joseph Pratt and Dr. Mark Young Public History Readings - Fall 2009 Department of History University of Houston

Introduction Since the catastrophic levee failures at New Orleans in 2005, the Federal Emergency Management Agency (FEMA) accelerated their accreditation program for levees. The accreditation system “allows FEMA to continue the congressional mandate to update the Nation’s flood insurance maps while allowing levee owners time to obtain documentation” necessary in keeping their levees on the new maps. However, FEMA failed to issue a target date for their map update. At the close of 2009, the only target of any kind is a twenty-four month Provisionally Accredited Levee (PAL) agreement that gives levee owners two years to meet private certification standards. What this means is that after a PAL extension is given, the levee owner must contract a surveyor, overhaul the levees to meet standards, obtain private certification, and then apply for FEMA accreditation or have their levee removed from the flood maps. This is an enormous problem for a levee system in the Brazosport area of Southeast Texas as it has a fifty-three mile levee which would require more than two years in any event to update the levee in whole.1 While the accreditation system is an example of a federal agency implementing proactive policy against future levee failures, FEMA fails to recognize the cost and labor limitations of the Velasco Drainage District (VDD) who oversee the Freeport HurricaneFlood Protection Levee. The VDD believes their levee system has withstood tests against floods since its inception in 1908-1909. History shows that the Freeport Levee protected the cities of Lake Jackson, Clute, Freeport, and Oyster Creek first from riverine floods out of the Brazos River in the earlier half of the 20th century, and hurricane storm surge in the latter half of the century through the present. Drainage districts such as the VDD must use engineering models that are
1 U.S. Department of Homeland Security, Federal Emergency Management Agency, Provisionally Accredited Levee Process, Powerpoint Presentation, Accessed 8 December 2009, Velasco Drainage District Public Documents. 2

based on historical storms when measuring their levees success. The engineering models also use variable changes of historical storm systems to estimate what could occur thus ensuring the security of the levee system against future events. In this light, FEMA’s accreditation system protects the citizens and businesses located behind levee walls. However, in the case of the Freeport Levee, a recent survey by the Army Corps of Engineers (USACE) already concluded that no additional work was recommended in May 2005.2 What has changed since May 2005 that would require FEMA to threaten the elimination of the Freeport Levee system from their flood insurance maps in 2009-2010? The 2005 hurricane season which devastated the levees in New Orleans. It is important to remember that Hurricane Rita in the same 2005 season hit the Freeport area, and the area faired well largely due to the proficiency of the levee system. The debate between FEMA and the VDD is a situation where history influences public policy. If FEMA erases the Freeport Levee from their flood maps, insurance premiums on the businesses and residential properties in the area will increase exponentially. The Brazosport area is home to roughly 66,000 inhabitants, and the largest basic chemical complex in the world. To build up fifty-three miles of levee walls even six inches will take longer than the two year extension offered by FEMA in their PAL agreement. Additionally, the estimated cost for any such work is between $700,000-$1,000,000 per mile. Such funding does not exist in the tax base therein.3 Thus, no matter what happens, the people of the Brazosport area must pay an exorbitant amount of money to continue living in the area. FEMA does not seem to understand what the

2 U.S. Army Corps of Engineers, Galveston District, Freeport and Vicinity, Texas Hurricane-Flood Protection Feasibility Report, May 2005, Velasco Drainage District, Office of Mel McKey. 3 Welcome to the Brazosport Area, Brazosport Area Chamber of Commerce. On-line. Available from internet,, accessed 17 October 2009; Melinda Luna, T. Lynn Lovell, Joe T. Barrow, John Ivey, and Jack Furlong, “Levees in Texas: A Historical Perspective,” Halff Associates, Inc, 2009; Texas Water Conservation Association, TWCA Supports Federal Funding for Levee and Dam Safety Floodplain Management. 27 October 2009. Velasco Drainage District Archives. 3

implications of such forceful policies are; the levee is either built up beyond what the USACE determined necessary in 2005, or the levee is erased from flood insurance maps. History is a tool for both sides of the debate. FEMA does not want to see a repeat of the levee failures at New Orleans in 2005. VDD, however, believes their levee system’s historical successes, a 2005 risk assessment report from Texas A&M University, and the 2005 Feasibility report by the USACE serve as adequate evidence that they should be granted FEMA’s accreditation and remain on the flood maps in 2010. The 2005 Hurricane Katrina is the prime reason for FEMA’s aggressive policy implementation. As such, this paper will explore the impact of the New Orleans scenario as a historical event that shaped FEMA’s drive to modernize the nation’s flood maps. Additionally, this paper will examine the feasibility of historical events in creating public policy in the case of the Freeport Hurricane-Flood Protection Levee.


FEMA uses Hurricane Katrina as its prime example of how susceptible communities are to faulty levee construction and maintenance. However, the cities of Freeport and New Orleans present different challenges to flood protection. The hurricane protection levee system of New Orleans began construction following Hurricane Betsy in 1965 and was not scheduled for completion until 2015. The New Orleans hurricane levee was a piecemeal construction project; smaller levees joined larger ones and little detail was given to the meeting places of the different walls. Additionally, pump stations were outdated and the force of the rising storm surge breached their walls. Gates were missing and some were inoperable allowing for additional floodwater to breach the levee system as a whole. Of most consequence, was the failure of the USACE to adapt the New Orleans levee system to the 1979 National Weather Service standard project hurricane parameters. Instead, the levee was only built to withstand a storm surge associated with 101-111 miles per hours which was the 1959 estimated strength of a storm that could hit New Orleans. The 1979 probable maximum hurricane value was between 151 and 160 miles per hour.4 One believes these causes for the New Orleans levee failures are the reason why FEMA seeks to implement their accreditation system. However, using only one historical event overlooks the possibility that other levee systems might have different circumstances. Because of Hurricane Katrina, the new levee accreditation system appears to be a one size fits all policy. FEMA wants to insure businesses and people behind levees that their protective walls will hold. This is a large shift in FEMA policy, from reactive management to proactive requirement. In both New Orleans and Freeport, the levee systems are composed of riverine and coastal barriers. FEMA requires riverine levees to have a freeboard--extra height added on top of minimal heigh--at least “3 feet above the water-surface level of the base flood.” For coastal
4 American Society of Civil Engineers, The New Orleans Hurricane Protection System: What Went Wrong and Why, Hurricane Katrina External Review Panel, 2007, On-line, Available from Internet, 5

levees, the freeboard must not be less than “2 feet above the 1-percent-annual-chance stillwater surge elevation.” Freeboard for coastal levees essentially are present to catch waves above expected surge height.5 Because New Orleans was not updated to combat against newer estimates of storms, the surge overtopped many points exacerbating storm erosion. Whether or not such a scenario can repeat itself depends on the preparedness of individual levee systems. In the case of Freeport, the VDD implements its own proactive adaptation to new models and scientific estimates for future storms. Budget limits and a responsibility to the community likely require the VDD to stay ahead of changing recommendations. In essence, it makes no sense to spend $53,000,000 to increase levee height and support only four years after investing in a lengthy risk assessment by Texas A&M University and a feasibility report by the USACE itself. That Velasco sought such a survey before Katrina should speak for the VDD’s compulsion to maintain the levee system. Who will pay for another survey, private certification, and eventual work on the levee? The problem for any large scale project like levees is funding. However, levee owners must balance expenses with communal obligations. Misconceptions feed paranoia, especially when discussing natural disasters. The entire nation was troubled by the levee failures in New Orleans. Joshua Pierce wrote an article after Hurricane Ike in 2008 missed Freeport that revealed how distrusting citizens were with their levee system. According to Pierce, the residents were concerned because the “only protection they have from a major hurricane here is a 20-foot dirt protection levee.” Understating the amount of engineering involved in the development of the Freeport levee was a blunder to the VDD. Being a former resident of the area, one recalls many instances where hypothetical conversations about water disasters filled the air at supermarket check out lines and the mall food
5 U.S. Department of Homeland Security, Federal Emergency Management Agency, Requirements for Mapping Levees: Complying with Section 65.10 of the NFIP Regulations, November 2008, Velasco Drainage District Public Files. 6

court. The threat is real, but the protection given by the levee is too. Pierce cited a long time resident of Freeport who said, “We are not that well protected here as you can see. Just drive out to the levee.” This too is another misconception of the vast levee system that protects the Brazosport area. The levee system is more than fill dirt as seen by the public at a popular intersection heading to Surfside Beach, it is a complex system of floodgates, dams, enormous pump stations, and a large tidal gate in Freeport Harbor. Every mile of the levee system is designed to work in conjunction with each other. This is completely opposite of the New Orleans levee system which was built piecemeal and never joined adequately.6 Pierce overlooked the differences in construction and maintenance of the two levee systems. History shows the flaws in the New Orleans’ levee system and exemplifies that of the VDD. As part of the VDD’s proactive stance to optimizing the efficiency of the levee system, it increased the proficiency of most pumping stations in 2006. Six Patterson Axial Flow Pumps were installed, each capable of moving 250,000 gallons of water per minute (gpm). The pump systems could then move 3,000,000 gpm, twice as much as 2005 levels.7 Excessive precipitation that joins tropical storms is little match for the pumping stations within the Freeport levee system. This again shows how the VDD acts proactively when updating the levee. FEMA’s Provisionally Accredited Levee (PAL) system is the only recourse for levees like Freeport. The two year extension to complete work required for certification is simply not enough for the VDD. Furthermore, FEMA has yet to release a fixed target for when the new digital flood insurance rate maps will be released. Until such time, levee systems without proper
6 Joshua Pierce, “Freeport, Texas, Residents Concerned about Levees,” Associated Content, 23 September 2008. On-line, Available from Internet,; U.S. Senate Committee on Homeland Security and Government Affairs, Testimony of Raymond B. Seed, Ph.D. University of California at Berkeley, 2 November 2005. 7 “Patterson Manufactures Massive Pumps for Levee Protection,” Patterson Pumps PDFs. On-line, Available from Internet, 7

funding to meet the accreditation requirements have to wait to apply for the PAL extension. From FEMA’s perspective, the flood maps are dated (last updated in 1982). The effort to accredit levees is part of “the need to accurately show the risk of flooding behind levees.”8 However, the threat that the Freeport levee could be erased from the flood insurance maps forces the VDD to wait on FEMA to establish a release date, essentially putting a hundred year old drainage district at the mercy of a thirty year old federal agency with its own questionable history. The PAL system is exploitative of many other levee systems, even within Texas. An inter-local agreement is in the works as of December 2009. The agreement is between Matagorda County Conservation and Reclamation District, Jefferson County Drainage District, and the Velasco Drainage District. The coalition aims to get legislation passed to reverse FEMA’s timeline in removing levee systems from the upcoming flood insurance maps. Their case cites the increase in flood insurance premiums that will appear without a levee on the map, the timetable necessary to meet FEMA’s standards as being more than two years, a decline in property value and tax base as people move along with businesses, and expected public outcry to restore flood protection. Additionally, the coalition seeks--as do other districts--federal funding for recommended improvements. The VDD has a legitimate case in requesting federal funding as the levee is classified “federal” because the USACE constructed the coastal levee portion of the Freeport system.9 Nonetheless, lobbying campaigns do not always work. Should the coalition fail to get federal aid for levee improvements, the burden falls to property tax increases.

8 U.S. Department of Homeland Security, Federal Emergency Management Agency, Provisionally Accredited Levees, 3 October 2006, Velasco Drainage District Public Files. 9 “Interlocal Agreement Between Matagorda County Conservation and Reclamation District No.1, Jefferson County Drainage District No. 7, and Velasco Drainage District, Brazoria County,” December 2009, Velasco Drainage District, Office of Mel McKey. 8

The VDD has a history of private construction of its riverine levees that date back to 1909, but the part of the levee that is likely envisioned by the public is the coastal levee. The first report by the USACE of the Velasco-Freeport levee system appeared in May 1956. Up to 1956, local agencies assumed responsibility for the maintenance of the levees, mostly through funding from DOW Chemical. The Brazosport area had a sound economy, doubling by most measures from 1950-1955 as Dow Chemical, Phillips Petroleum, and Sulphur Companies expanded. Major storms forced the VDD to expand the levee, namely the 1915 unnamed storm that cause $50,000,000 in damages, and two more hurricanes that crossed the coast at Freeport in 1941 and 1949 totaling $13,000,000 in further damage. The City of Velasco (now part of Freeport) was already surrounded by levees in 1955 and dependent on pumps to dispose of storm water. VDD wanted the USACE to help in obtaining two 15,000 gpm pumps and improving the storm protection levee that was constructed in 1950. The request to the USACE concluded saying the forecasted economic growth in the area warranted the improvements. Thus, the USACE built a more sound coastal levee system and left the maintenance to the Velasco Drainage District.10 The 1950 construction of the first coastal levees was in reaction to the devastating 1949 unnamed hurricane. Also, the 1962 improvements were in reaction to Hurricane Carla in 1961 that was the worst storm to hit the Texas coast since the storm of 1900 at Galveston. Again with Hurricane Alicia in 1983, the Brazosport area faced $2,000,000,000 in damages. The area has a history of tropical storm landfalls, as such the VDD constantly improves the condition of the levee system as new studies and figures recommend. In the current debate with FEMA, however, the VDD has a prepared system according to the USACE, but not well enough for
10 Brazoria County Drainage District No. 2, report to Corps of Engineers U.S. Army on Required Storm Protection in the Velasco-Freeport, Texas Area, 29 May 1956, Velasco Drainage District Archives Public Files. 9

FEMA’s new accreditation requirements. At the risk of sounding cliché, it is fair to say that the history of one storm in 2005 is greater than a century of recorded storms and actual landfalls at Freeport. When history becomes a tool in policy debates, it should be approached from all angles pertinent. In the case of Freeport, FEMA overlooks the specialty and historical success of the Hurricane-Flood Protection Levee in favor of extreme what-if scenarios that cost small districts more money than they have.11 Who is going to pay the $53,000,000 estimate, what engineering force can build up a fifty-three mile levee system in two years?

11 “Looking Back: Carla brings death, destruction to Texas coast,” The Houston Chronicle, 11 May 2001; “Texas Hurricane History,” USA Today, 2000. 10

Conclusion The 2005 Hurricane Katrina breached the levee system in New Orleans. In response to the catastrophic failure, FEMA implemented levee accreditation. Even though the necessity for accreditation of some sort is warranted, the implemented timeline and consequence for not reaching the standards is deplorable. From FEMA’s point of view, the new flood maps expected in 2010 must adequate portray property’s likelihood for flooding, even if behind an existing levee. They use Katrina and speculative future storms as evidence that such large, one-size-fitsall levees are necessary to have levees drawn on the flood insurance maps. However, they do not supply funding for required improvements. Thus, the conclusion is one of two scenarios that eventually lead to the same end after much strife. FEMA can draw their maps without the Freeport Hurricane-Flood Protection Levee forcing flood insurance premiums to increase exponentially, or the VDD can force overspending in their budget and increase property taxes to compensate over the next few years. Neither scenario is cheap, nor efficient. The VDD has an established history of proactively improving the Freeport levee without external pressure. A Risk Assessment by Texas A&M University as well as a feasibility report by the USACE in 2005 both concluded that the levee was sufficient. The extent to which Katrina changed the function of FEMA from a reactive agency into a proactive policy implementer requires a much larger study than allocated herein, however, one believes such an exploration may appear as a turning point in how history can be a tool of public policy, especially for emergency agencies such as FEMA. It is not accurate to say Katrina gave FEMA a blank check to impose what it will because FEMA cannot support or finance the necessary improvements to levees nationwide, and as locally as Freeport, TX.


Historical evaluation is essential to decision-making in public policy. However, when one chooses to overlook some historical events in favor of others, one misses the opportunity to learn from the past. Instead, a situation of incognizant speculation manifests itself in the decision-making process. Such practices are prone to be overly expensive and infused with misconceptions. The panic from the American public after Katrina is warranted, but when does paranoia eclipse confidence in engineering? Failures of man-made structures are inevitable, and no accreditation system will change the history of natural disasters’ ability to damage land and structures. Since the VDD is constantly improving and maintaining the Freeport levee system, one believes they will comply with accreditation standards, hopefully through the lobbying effort to obtain federal aid. Whatever the future of the levee system, the VDD has a solid century of construction, maintenance, and adaptation history to support its claims that the levee and its ancillary water management system is more than sufficient for 21st century storms. The removal of the Freeport levee system from the flood maps will devastate the area far more than a category five hurricane would. History shows that the Brazosport area was among the growing localities of Texas throughout the twentieth century. Flood insurance premiums hikes and utter consternation will be the result of a Brazosport without an accredited levee. Is it worth implementing such demanding stipulations if it will bankrupt a small, yet prosperous area of Texas?


Bibliography American Society of Civil Engineers. The New Orleans Hurricane Protection System: What Went Wrong and Why. Hurricane Katrina External Review Panel 2007. Associated Content. 2008 Brazosport Chamber of Commerce Online. “Welcome to Brazosport.” Houston Chronicle, The. 2001. Patterson Pumps Online. “Patterson Manufactures Massive Pumps for Levee Protection.” U.S. Senate Committee on Homeland Security and Government Affairs. Testimony of Raymond B. Seed, Ph.D. Professor of Civil and Environmental Engineering, University of California at Berkeley. On behalf of the NSF-Sponsored LEvee Investigation Team before the Committee on Homeland Security and Government Affairs. 2 November 2005. USA Today. 2000. Velasco Drainage District Archives. U.S. Department of Homeland Security. FEMA Files. Office of Mel McKey, Superintendent. Public Files.


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