Harris County Changing How It Will Choose Which Flood Projects to Support; Welcome to the "Equity Bias"

Imagine you pull up to a stoplight and two needy people approach you for a handout. You want to help, but have only $1 in your pocket.

Do you give the dollar to the person who has not eaten for the longest time? Or to the person from the zip code with the highest percentage of minorities and lowest average household income?

As you may have guessed, the people at the stoplight are a metaphor for flood victims.

More Needs than Dollars

Harris County doesn’t have enough dollars to build every flood mitigation project that everyone needs. Flood mitigation requires tough choices.

So the County is setting up a supposedly unbiased task force to decide whom to help. But its composition will be biased toward people who believe flood bond money should favor low income, minority neighborhoods, i.e., the constituents of the three politicians pushing the task force (Judge Lina Hidalgo, Precinct 1 Commissioner Rodney Ellis, and Precinct 2 Commissioner Adrian Garcia).

Stacking the Jury

Look at the proposed overview and bylaws for the Community Resilience Task Force. You will see that they embed the concepts of equity, social justice, and social vulnerability into every recommendation the task force will make. For flood mitigation. Housing. Health. Construction. Urban planning. And more. For the next 30 years!

Proposed bylaws for the task force explicitly state that the members MUST demonstrate:

An interest in “equitable” flood mitigation.
Interest in socioeconomic and demographic factors that affect resilience.

So they are baking “equitable” into the job descriptions.

Difference Between Equitable and Equal

“Equitable” treatment sounds like “equal” treatment. But it’s not.

Treating people equally means treating them identically. Treating people equitably means treating them differently, but fairly.

For instance, handicapped people get to park closer to the door. That’s fair…based on need.

But what happens when you start making flood mitigation decisions on the basis of race, income, and social vulnerability? Is that fair to more affluent communities destroyed by flooding?

Flood Spending Based on Race and Income?

Ms. Hidalgo, Mr. Ellis, and Mr. Garcia define “equitable” so preference goes to the “socially vulnerable.” Their argument goes like so.

Because poor people have a harder time recovering from floods, they should get more protection from flooding. They can’t afford to flood (…as if anyone can).

Hidalgo, Ellis and Garcia all advocate the use of a CDC social-vulnerability index and LMI (low-to-moderate-income) data to prioritize flood projects.

They argue in meeting after meeting that FEMA bases grant decisions on a benefit/cost ratio (BCR) that favors neighborhoods with more expensive homes. That’s true, but…

Socially Vulnerable Neighborhoods Already Receive Preferential Treatment

They never mention that Department of Housing and Urban Development (HUD) Community Development Block Grants for mitigation (CDBG-MIT) and disaster recovery (CDBG-DR) already favor poorer (LMI) neighborhoods.

Nor do they mention that the County has already received a BILLION dollars in CDBG-DR funds. Or that the Texas General Land Office is sitting on top of approximately $4.2 billion in CDBG-MIT funds that it’s trying to distribute. The vast majority of those funds must go toward LMI/socially vulnerable neighborhoods. (The exact percentages vary by storm and type of grant. But they often range up to 70%.)

Problems With Basing Flood-Mitigation Decisions on LMI Data

There are two more problems with basing flood-mitigation decisions on racial and LMI data.

First, it ignores need. Shouldn’t projects that help the largest numbers of people or the worst flooding be mitigated first?
Second, LMI data only comes by zip code. Zip codes can mask huge disparities in wealth. So even if you feel poor people deserve more flood protection than the middle class, it’s hard to ensure that result with zip code data. Elm Grove, for instance, is an LMI neighborhood embedded within an affluent zip code.

Mr. Ellis argued that his Precinct One constituents, who are 76% African-American and Hispanic, would not get their projects because money they deserved more was being spent in affluent Kingwood.

He did not mention Army Corps of Engineers grants to HCFCD for work on four bayous in his precinct. Nor did he mention that in the entire history of Harris County Flood Control (which dates back to 1937), not one federal dollar has ever been funneled through HCFCD by the Corps for work in the Lake Houston Area.

4 Out of 5 Flood Bond Projects in SVI Neighborhoods

How much have Ellis, Hidalgo and Garcia skewed flood bond spending to date?

During the Commissioners Court meeting on June 30, 2020, Harris County Flood Control was asked to prepare a report to document the status of flood bond risk reduction projects in socially vulnerable neighborhoods. See Item 2E on Tuesday’s Commissioners Court Agenda. It shows a startling fact.

Out of the 145 active bond projects, 79% are located in high or moderately high SVI areas.
Letter from HCFCD to Commissioners Court

The distribution looks like this.

*79% of Flood Bond Projects are located in the **most** socially vulnerable neighborhoods; only 21% in the **least** socially vulnerable neighborhoods. Source: Memo to Commissioners Court from HCFCD.*

If you live in a “socially vulnerable” neighborhood, you’re 4X more likely to have a flood bond project near you.

And those are just the projects based on Flood Bond money. The Flood Control District is also pursuing additional CDBG grants and Army Corps funding to help fund even more projects in socially vulnerable areas. Those projects are not reflected in these percentages.

Rushing Through Public Comment Period

One measure of how much Ellis, Hidalgo and Garcia want to institutionalize their own definitions of equity is that they’re giving only six more days for public comment with little public warning.

You can bet that the commissioners court meeting on the 28th will be packed with surrogate speakers for Ellis, Hidalgo and Garcia who favor the “equity bias.” They’ve shown up in Commissioners Court for months.

Why wouldn’t they? It’s worked. They now have 4 out of every 5 flood bond projects going into their neighborhoods and they could get even more if this task force goes through in its current form.

Meanwhile, the San Jacinto watershed, says the Greater Houston Flood Mitigation Consortium, received 0% of the mitigation budget prior to Harvey, yet had 14% of the region’s damages during Harvey.

How Do We Decide What’s Fair?

So, should projects go to neighborhoods that:

Had the fewest flood mitigation projects?
Flooded the worst?
Help the greatest number of people for the dollars invested?
Are the poorest?

Or should the money be split equally or on some other basis?

Personally, I think decisions like these should be left in the hands of engineers, not partisan politicians.

Register Your Opinion

The County Judge’s office is inviting the public to share their thoughts and ideas on the proposed draft bylaws of the Task Force. You can register your opinion from now until July 30th, 2020, via one of the following methods:

Email CRTF@cjo.hctx.net and submit comments digitally, beginning July 21
Join a virtual focus group via Zoom. After registering, participants will receive a confirmation email containing information about joining the meeting.
- Register here for July 29rd at 12pm
- Register here for July 30th at 10am
Offer input during the July 28th Commissioner’s Court
- Sign up to speak here

Posted by Bob Rehak on July 24, 2020

1060 Days since Hurricane Harvey

For more information on the “equity bias,” see this series on “Where Flood Mitigation Dollars Have Really Gone”

Or this series on “The Equity Flap”