Item #123 on the Harris County Commissioners Court Agenda for 6/28/22 is a request to tap the County’s Flood Resilience Trust Fund to help finance 16 flood-bond projects in the coming year. The request also seeks approval for a method of allocating future funds that weighs projects using a social vulnerability index.
A Backstop for Partner Funds
The introduction to the request states, “Although the Harris County Flood Control District (HCFCD) continues to aggressively pursue partnership dollars … substantial amounts of anticipated partner funding remain unrealized.”
Of the roughly $5 billion in 2018 Flood-Bond Projects, officials hoped that Federal, State and local partners would supply roughly half the money. But it hasn’t all materialized yet. So last year, Commissioners created a flood-resilience trust fund to create backstop funding. Until now, the county has not needed it. But now the county does…for the sixteen projects listed below.
To date, Harris County has secured $1.275 billion in partnership funding for 2018 Bond Program projects from Federal, State, and local partners. Of the $2.5 billion in partner funds originally anticipated, “the county has not yet identified $754.2 million. This gap includes projects for which grant applications were submitted to various Federal and State programs such as CDBG-MIT, FEMA-BRIC, and others but not awarded,” says HCFCD.
Ironically, the backup documentation provided to commissioners by HCFCD makes no mention of the $750 million allocated by the U.S. Department of Housing and Urban Development (HUD) and the Texas General Land Office (GLO) to Harris County. More on that below.
The document provided to commissioners by HCFCD contains information about the Trust, its history and intent, projects that need funding help now, and a methodology for ranking projects.
After ranking all flood-bond projects that are short of funding using the proposed matrix below (Appendix B), the county began whittling away from Trust funds. HCFCD started with the top-ranked project and proceeded to the lowest until the money ran out, i.e., the balance in the trust fund went negative. Only two projects from the entire San Jacinto Watershed made the “eligible” list: one near the ship channel and another below Highway 90. But neither of those is part of the group of 16 above.
Weighting Factors in Proposed Matrix
The scoring matrix used by the County includes evaluations of:
- Cost per person (15%)
- Cost per structure (30%)
- Non-structural benefits (45%)
- Existing conditions (20%)
- Social Vulnerability Index (20%)
- Long-term maintenance (5%)
- Minimizing environmental impacts (5%)
- Ability to deliver multiple benefits, i.e., flood mitigation, social and environmental (5%)
As additional partnership funding sources are identified, money remaining in the Trust may cover additional projects…assuming inflation doesn’t eat it all up.
For this exercise, HCFCD analyzed all projects with partnership funding gaps. However, that doesn’t mean that those projects will necessarily receive Flood Resilience Trust funds. When and if HCFCD identifies funding partners, some projects could drop off the list of those needing help. That could make funds available for lower ranking projects. See Appendix B, last page.
If approved, HCFCD will return to Commissioners Court twice each year with additional requests from the Flood Resilience Trust. Each of those requests will include an updated analysis of partnership and contingency funding needs, Trust funds remaining, and eligible projects.
$750 Million HUD Allocation Not Discussed
The County’s Community Services Department is currently developing a Method of Distribution (MOD) for the $750 million designated earlier this year for Harris County by HUD. A MOD is a plan for distributing the $750 million. Where and how will the county use the money? Who will benefit?
HUD and the GLO require that at least 50% of the money benefits Low-to-Moderate Income neighborhoods.
At the time the GLO and HUD dedicated $750 million to Harris County, they also dedicated $488 million to the Houston Galveston Area Council (HGAC).
HGAC has already submitted its MOD to the GLO and received preliminary, conditional approval. Conditional approval requires:
- Validation of all calculations
- Meeting HUD requirements
- Verification that all recipients are still interested in participating.
According to a GLO spokesperson, HGAC began developing its MOD when the GLO submitted its action plan to HUD. However, Harris County reportedly delayed planning until AFTER HUD approved the GLO’s recommendations.
That delay could mean spending more local money. And that could penalize Harris County watersheds farther down on the Trust Fund priority list that don’t currently meet SVI and other requirements. Will there be money left for the Lake Houston Area by the time we work our way further down this list? Only time will tell.
Posted by Bob Rehak on 6/28/2022
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