Incognizant Speculation:

The Future of the Storm Protection Levees in Brazosport and Why

FEMA’s Accreditation System lacks Historical Perspective

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 Hurricane-

Flood 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.

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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, http://www.brazosport.org, 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.

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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.

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 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,
http://www.asce.org/files/pdf/ERPreport.pdf.

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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.

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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,
http://www.associatedcontent.com/article/1058038/freeport_texas_residents_concerned.html?cat=17; 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, www.pattersonpumps.com/PDFs/velasco.pdf.

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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.

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 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.

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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.

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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-fits-

all 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.

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 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?

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Bibliography

American Society of Civil Engineers. The New Orleans Hurricane Protection System:
What Went Wrong and Why. Hurricane Katrina External Review Panel 2007.
http://www.asce.org/files/pdf/ERPreport.pdf.

Associated Content. 2008

Brazosport Chamber of Commerce Online. “Welcome to Brazosport.”

http://www.brazosport.org.

Houston Chronicle, The. 2001.

Patterson Pumps Online. “Patterson Manufactures Massive Pumps for Levee Protection.”
http://www.pattersonpumps.com/PDFs/velasco.pdf

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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