Sunday, January 21, 2024

Butler Landfill revegetated west zone: What exactly is the plan here?

The west side of the Butler Landfill was improved in the spring and summer of 2023. Irrigation was added, and pervious pavement installed to form a Y-shaped driveway for heavy vehicles over the landfill cap which is 5-6 feet of soil over trash.

Location of west side appears in brown/soil color:

The plans show the supportive driveway mats:

However, this photo shows that ACL parked over the entire revegetated zone in 2023:

The revegetated zone has been entirely damaged and the reseeding has begun from scratch.

Was this the intended use when the TCEQ approved these plans for the Butler Landfill "improvements"?

Parks Board members: Please help the general public understand whether ACL's use of this zone for staging will be a pattern of destruction that we can expect on an annual basis. Explain to us if this was the intended use pattern when the permit was approved by the TCEQ.

On January 22, 2024, I received this information from the TCEQ:

General Information

Texas Commission on Environmental Quality (TCEQ) rules require an authorization for any activity that disturbs the final cover over a landfill. If approved, the applicant can disturb the soil that makes up the final cover over a landfill, install permanent structures (ex. light poles, bleachers, fences, etc.), and install engineered structures (ex. sidewalk, roads, buildings, etc.). Engineered or design improvements over a closed landfill – like parking and staging areas in the case of Butler Landfill – are allowed but the applicant must ensure the final cover remains intact.


For Butler Landfill, TCEQ has approved several projects to disturb the final cover.


2018 - The July 2018 authorization allowed the City of Austin to remove existing crushed stone material that was above the final cover and replace that material with four additional inches of topsoil, then revegetate the area. Areas west of Mopac were not included as part of this project.


2020 – The December 2020 authorization resulted in the City of Austin conducting additional maintenance activities of the existing final cover for the development of the staging area. The maintenance included placement of crushed stone to protect final cover for use of the staging area, minor site improvements such as fencing, grading, and a temporary irrigation system. 


2022 – In the May 2022 authorization, the City of Austin revised the type of vegetation used and included revisions for fence foundations, irrigation systems, and stone surfacing over the final cover.


Specific Questions

Did the TCEQ approve the use of the revegetated zone for annual ACL staging?



Is it strong enough for trucks and vehicles to be parked for a month outside of the supportive mats? Is the gravel zone of the landfill of sufficient substrata depth to safely support parked heavy vehicles?

Applications for development over a closed landfill must be prepared and certified by a Texas licensed professional engineer. This engineer is responsible for ensuring that their proposed designs follow common engineering practices and conform to local building codes, along with meeting the TCEQ rule requirements. The engineer is also required to certify that the proposed development will not damage the integrity or function of a closed landfill. TCEQ’s review focuses on ensuring the application meets all TCEQ requirements for developing and disturbing final cover over a closed landfill.


Is the grass destruction, re-tilling and reseeding of the zone “routine maintenance” or should it require new TCEQ approval?

Additional authorizations are not required if the City of Austin is revegetating in the same areas and in the same manner as approved in their TCEQ authorizations.


Are inspections performed as a matter of scheduled routine, or on-demand? Are inspections made in response to citizen-inquiries like the one I am making today?  Does the TCEQ perform their own inspections of sites like this?


While active municipal solid waste (MSW) landfills have a three-year inspection cycle, closed landfills do not have a routine inspection cycle. Compliance investigations for closed landfills are completed by TCEQ as an on-demand activity when a complaint is received or when TCEQ deems an investigation is necessary.


Individuals may report suspected noncompliance with any TCEQ rules or authorization conditions to the TCEQ Region 11 Office at 512-339-2929, the toll-free Environmental Violation Hotline at 1-888-777-3186, or online at


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