by Bill Beranek
On June 27, 2014, the U.S. Army Corps of Engineers (USACE) issued its final Record of Decision (ROD) and approved the Westfield Boulevard Flood Wall as the preferred option to complete its 300-year flood plain protection project with the City of Indianapolis. This is the end of the multiyear formal federal decision process.
The Westfield Boulevard alignment protects the 300-year flood plain from Broad Ripple to Butler-Tarkington but does so with damaging consequences that could be avoided by a different protection design. This is the proposal that was vigorously opposed by many neighborhood groups during the public comment periods in the summer of 2012 and again last summer. It is the option that proposes a huge floodgate across the Central Canal and splits the historic canal towpath in two.
This proposal places emergency responders and Rocky Ripple residents at risk because it requires the Department of Public Works (DPW) to block the 52nd and 53rd street entrances to Rocky Ripple with sandbag barriers whenever a large flood is anticipated. Instead of protecting the canal itself at the 56th Street bend of the river, this design directs the river floodwaters down the canal to Holcomb Gardens and beyond, which could cause substantial damage.
The Westfield Boulevard alignment uses a flood wall that would make ineffective any future 100-year flood wall protecting the Butler University/Rocky Ripple Flood Plain due to the potential of flooding from the canal into Rocky Ripple at 52nd Street.
The City of Indianapolis opposes this option but it has not yet supplied a sophisticated enough technical and economic analysis of the superiority of an alternative to convince the Corps. The City prefers the West Bank Alignment to reinforce the berm along the Central Canal’s west bank, which has none of the defects of the Westfield option and all of the benefits. This alignment would not have a tall flood wall and flood gate crossing the canal, would provide flood protection to the water supply, and would provide a sound base for extending reduced flood risk for the Rocky Ripple flood plain at some future date. It would also provide flood insurance benefits to all properties protected by the Corps’ Westfield Boulevard alignment.
Further, the City proposes to pay any extra costs if the West Bank Alignment is more expensive. Nevertheless, even if the City agrees to pay for a greater share of its preferred option, the Corps could not adopt it unless it meets the Corps’ technical and economic standards. In the ROD, the Corps said the City has presented neither an adequate engineering study to demonstrate that a reinforced berm would work nor sufficient cost/benefit information.
Mike Massone, a DPW project manager, said the City has proposed conducting a feasibility analysis on the West Bank alternative to the Corps. “We have a good relationship with the Corps,” he said. “Our goal is to provide protection from floods in the project area.”
A river bend/canal berm alignment terminating at the Butler campus was considered by the Corps from 1999 to 2006 but was not explored in depth, in favor of the more straightforward Westfield Flood Wall alignment. Its recent revival has been strongly endorsed by neighborhood associations from Broad Ripple to Butler-Tarkington. They want to preserve the cultural and recreational amenity that enhances and unifies Midtown neighborhoods. They do not want a large flood gate dividing the canal towpath into two separate recreational areas.
Butler University endorses the river bend/canal berm alignment, as does canal owner Citizens Energy Group. According to Daniel Considine, manager of corporate communications at Citizens, the utility has operational concerns about the proposed gate structure. “We believe the West Bank alternative is a better solution for protecting the area from flooding while also ensuring the operational integrity of the canal, which provides about 60 percent of the water supply for the downtown area,” he said.
Despite such widespread community support, it is uncertain how long it will take the City to convince the USACE to adopt the West Bank alternative and whether the City has both the money and the commitment to undertake its construction.
Tree Removal Recommended
The ROD also made recommendations for proposed tree-clearing actions that would complete the Phase 3A/Warfleigh and Phase 3C/Monon–Broad Ripple sections. The USACE rejected an option to leave conditions as they currently are and opted instead to require clearing of vegetation 15 feet from either the toe of the levee or the face of the floodwall.
According to the USACE, approximately 6.9 acres of vegetation along the Warfleigh segment will need to be removed along the White River for approximately 1,140 linear feet (or 15 percent of its total length) with erosion control blankets installed there. In the Broad Ripple section, approximately 0.62 acres will require clearing. A total of more than 7 acres of mature bottomland hardwood forest will be removed and three wetland areas totaling 0.45 acres will be affected by vegetation removal.
To mitigate what it terms “unavoidable impacts” the Corps will work with the City to plant similar bottomland hardwood tree species within the watershed in order to minimize impacts to the endangered Indiana bat. The area will cover approximately 81 acres. Few residents will live to see these seedlings mature to the height of the trees that are slated for removal.
“We know there will be consternation over vegetation management,” Massone said. “This has been no secret. The Corps has made it clear that if vegetation is not removed the safety officer will not certify the project.” No certification means no removal from the flood plain and no elimination of the need to carry flood insurance.
Meanwhile, additional stress and uncertainty for property owners continues as the Federal Emergency Management Agency (FEMA) responds to congressional pressure to reduce the federal subsidy for the flood insurance mandated for borrowed money on structures in the 100-year flood plain. FEMA is now proposing to change the flood maps, which will add a few more properties to the 100-year flood plain. The Indiana Department of Natural Resources has posted the draft maps for the state here.
Simultaneously, the City is in discussions with FEMA to request that many Broad Ripple properties receive partial or complete relief from flood insurance and flood plain building restrictions because of the existing flood levee from Broad Ripple to the Riviera Club. Without any further extension of the flood barrier beyond its current termination at the Riviera Club, the Broad Ripple flood elevation has already been reduced by seven feet. Because practically, if not legally, such property is already above the design flood levels, this would seem to be an appropriate request.
However, with the completion of the ROD, regulation time has run out. The federal government is ready to pay 75 percent of the $15 million joint City–Corps project to protect hundreds of structures from the 300-year flood plain. The City wants a different solution to protect those properties and the canal, but that will take time to design and to win federal approval. The Ballard administration must act decisively now, before the political pressure from property owners suffering the impacts of changing flood insurance policy results in agreement to the Corps’ already approved Westfield Flood Wall.
While there is no further formal opportunity for public comment required by law, individuals working alone or with neighborhood groups or government entities can still strive to achieve the following objectives as soon as possible:
- Convince the Corps to modify the Record of Decision for the Westfield Boulevard Flood Wall Alignment by using the West Bank Alignment Alternative. This requires hiring a national engineering firm experienced at providing technical, legal, economic, and policy information of high quality in order to convince the Corps to change the decision.
- File formal application with FEMA to obtain conditional certification that the existing levees protect certain Broad Ripple properties from being in the current 100-year flood plain.
- Work with active engagement of Rocky Ripple residents and Butler University to develop technically and economically feasible flood wall options and funding mechanisms to remove much of the land from designation in the Butler University–Rocky Ripple 100-year flood plain.
- Create an organization of property owners across the area to explore options to fund a conservation district for the purpose of eliminating existing properties from the 100-year flood plain regardless of degree of Corps assistance. Local funds will be needed to design the most cost-effective structures, to help build the structures, and to maintain them indefinitely to FEMA standards.
City government can lead a partnership of all affected parties with regular meetings to work out practical strategies. The next best option is for external organizations to provide the leadership to work with city, state and federal agencies to fund and develop feasible alternatives with as much Corps engagement as possible.
Where and how to build the final phase of the flood project are decisions that will determine the vitality of Midtown neighborhoods for the next century. It is too important to let happen without the best expertise of and careful deliberation by all affected parties.
Bill Beranek, an environmental mediator with a Ph.D. in chemistry, is a longtime northside resident. He has been actively engaged in analyses and discussions with all key government agencies and affected parties for two years to help find a solution to managing White River flooding in this area in a way that is of the greatest help and the least harm and cost to the greatest number of people. A version of this article appeared in the August/September 2014 issue of the magazine.