On Tuesday this week, Harris County Commissioners Court erupted into heated discussion over flood-mitigation funding for Halls and Greens Bayous. Construction delays had to do with the length of time for awarding grants from the U.S. Department of Housing and Urban Development (HUD). Then, in a cosmic coincidence, yesterday, the Texas General Land Office (GLO) sent out a press release announcing $135 million in HUD flood mitigation grants – for 2016 floods that happened under President Obama.
Ironically, the GLO press release pointed out that 2016 grants were for repetitively damaged areas. And in the five years since the 2016 floods, we’ve also had Hurricane Harvey, Tropical Storm Imelda, and a record-setting 2020 hurricane season.
Reading the release felt like getting hit by three buses while waiting for the ambulance to arrive. That prompted a call to the GLO, which administers HUD grants in Texas. I asked a simple question.
“What Takes So Long?”
When I asked the GLO “Why does flood-mitigation funding take so long”, they referred me to this page. Key takeaways include:
- Congress didn’t appropriate money for Disaster Declarations in 2015, 2016 and 2017 until February 9, 2018.
- Texas received $4.3 billion from the U.S. Department of Housing and Urban Development for all those years.
- Before the GLO could distribute those funds, it had to wait for HUD to develop and publish rules in the Federal Register governing the distribution of those funds. That took 1.5 years.
- Then the GLO had to develop a state action plan. That required developing another set of rules, holding public meetings around the state, soliciting public comments, responding to the comments, and getting HUD approval of the plan. HUD finally approved the state action plan on March 31, 2020.
- Then GLO had to translate the plan into Spanish, Chinese, Arabic, Vietnamese, and Korean before publishing it.
- To be fair to everyone across the state, GLO then holds a “competition” to find the most worthy projects. The criteria for “worthiness” include multiple factors. But the biggest in HUD grants are: percentage of low-to-moderate income families being helped, how economically distressed an area is, and total expected benefits for dollars invested. For instance, when comparing applications for a $10 million grant that will help 1,000 families to a grant for the same amount that will help a 100,000 families, the latter would win.
- But to determine that kind of information, applicants need to conduct preliminary engineering studies before they can even file applications.
- The GLO must wait for all applications to be submitted, evaluate the applications, rank order them, and see how many will fit within available funding. In the case of the grants just announced, the GLO received requests for almost TWICE as much funding as they had available. The average over the years exceeds 3X. For Harvey, it was 5X.
- HUD must then review and approve the grants.
- GLO distributes the money.
- Finally, mitigation projects can begin.
Are All These Steps Necessary?
When you look at the list above, each step sounds reasonable. But there may be ways to collapse steps and speed up the flood-mitigation funding process. Why, for instance, do you need 1.5 years to publish rules specific to these floods in the Federal Register? Why not have a generic set of rules for all floods and adapt the boilerplate as needed?
I also asked if a way existed to shorten the process by eliminating the competition. After all, its easier to approve one application than compare it to hundreds. Their reply: “Competitions are the only fair way to do it.”
Should We Go Back to Earmarks?
The current competition system replaced an earmark system whereby Congress directly allocated funds to certain projects in certain districts. Earmarks sped up construction, but had many problems of their own. For instance, unnecessary projects often went to the districts of congressional leaders. That sometimes deprived other areas with greater needs.
However, the competition system for flood-mitigation funding has obvious problems, too. It has spawned whole industries of grant writers, project managers and people who know how to navigate traps in the convoluted application process.
Hopefully, that doesn’t happen often. But when it does, we have proof that bureaucracy has become more important than the taxpayers it serves.
More about GLO/HUD Grants Announced This Week
For the record, out of the $135 million in grants announced yesterday, Harris County received $10 million for cloverleaf drainage improvements in Carpenters Bayou. City of Houston received $8.2 million for flood mitigation in the Alief Forest Area. Baytown, Freeport, Sweeny, and Jacinto City also received grants.
This table shows where the money went.
Hurricane Harvey Competition Results Not Yet Announced
Winners of the first round of the Hurricane Harvey Mitigation Competition are expected to be announced in late spring or early summer. The GLO received 220 extensive applications totaling more than $5 billion in requests for the $1 billion in available funding (Round 1).
The Hurricane Harvey State Mitigation Competition for flood-mitigation funding is open to cities, counties, COGs, state entities, and special purpose districts. Examples of projects include flood control and drainage improvements, infrastructure improvements, green infrastructure, public facilities, and buyouts. Each proposed project must have a total proposed cost between $3 million to $100 million.
What We Need
Getting disaster relief 5-10 years after the fact is the largest disaster of all. We need Congress to reform the process to speed up the delivery of flood mitigation funding. How many homes and businesses that flooded in 2015, flooded again in 2016, 2017, 2019 and 2020? And what were the associated costs? Did repeat-flooding damages for these years due to funding delays cost more than the amount of mitigation funds appropriated by Congress? Somebody, somewhere has that information.
Posted by Bob Rehak on 3/12/2021
1291 Days since Hurricane Harvey