Response to Concerns About Flood Mitigation Benefits Index (Part II)
The letter below expresses disagreement with two recent ReduceFlooding.com posts about a proposed Flood Mitigation Benefits Index. It is from Michael Bloom, P.E. While I disagree with almost all of his claims, I am reprinting his letter verbatim because I encourage healthy debate. Compare the posts and draw your own conclusions. – Bob Rehak, Host, ReduceFlooding.com.
This is Part II of my two-part article providing responses to concerns raised by my colleague on the Community Flood Resilience Task Force (CFRTF), Mr. Bob Rehak about the FMBI. If you missed Part I, you can read it here.
Why are we Using the Index When it Produces Inconsistent Results that are Not Intuitive? Mr. Rehak provides an example that holds the current population and current risk the same, but changes the total prior investment amounts, as illustrated in the table below:
(% Annual Chance)
Mr. Rehak looks at these results and writes: “So, spending more money to get the same results increases benefits? Shouldn’t it be the opposite? That’s both depressing and confusing. You spend 10X the money; flood risk remains the same; and the “benefit” increases!!!??? You would think spending less money to achieve identical results would be more beneficial. It certainly is for taxpayers.”
Everyone should be depressed and confused by this result if the FMBI was illustrating the results for the same location. Mr. Rehak appears to make that inference when he writes: “spending more money to get the same results increases benefits.”
But Area A and Area B are two different locations. The FMBI is just telling us what the current conditions are at two different locations in the county. One location had 10 times the prior investment than the other – but both locations still have the same current risk.
Worse, in this case, BOTH locations have risks that are ten times the current standard of care for new developments – which require structures to have less than a 1% annual chance of inundation. Clearly, both locations need more flood risk investment. The FMBIs of 2 and 20 both are extremely low, meaning they need help, regardless of the prior investments. A high FMBI indicates that no additional help is needed in that location. A low FMBI indicates that additional help is needed in that location.
The table included in the middle of my February 17, 2022, post entitled “How Should We Decide Where to Invest in Flood Risk Reduction?” presents additional examples showing how the FMBI changes from location to location with only one changed variable. It also provides narrative explanations of each sequence. Notice how the index values are greater than 3,000 (sometimes greater than 20,000 or 100,000) in locations where the current annual chance of inundation is less than 1%? Again, a high FMBI means we don’t need to make more investments in that location. A low FMBI means that location needs more help.
Isn’t the FMBI Trying to Prove Inequitable Investments in Flood Risk Reduction? To some extent, partially, yes, it is. This was always an important aspect of the FMBI, when it was originally proposed as the “Flood Benefits Index (FBI)” by Dr. Erthea Nance and Iris Gonzalez in May 2021. I have continued to advocate for its use as one of four input variables we should use to create our county-wide “heat map.” This is explained in more detail in my other article. Mr. Rehak is concerned about the taxpayer. I am also. I don’t think the taxpayers of Harris County should pay for flood risk reduction projects in areas that already have a high FMBI. Said another way, it is a waste of taxpayer money to invest in additional flood risk reduction projects in areas currently with less than a 1% annual chance of inundation.
Isn’t the FMBI Measuring per capita Investment Associated with a Certain Level of Flood Risk and Mistakenly Calling that a “Benefit?” Mr. Rehak writes: “The more people you help with any given sum, the more the benefit goes down. Voila! That makes it look as though the highly populated watersheds (that have received the overwhelming majority of prior investments) have received little benefit. And that may be the point of this formula. It will send even more money to those same areas.”
This interpretation again seems to stem, I think, from Mr. Rehak’s belief that the index will be used to compare the same location at different times – before and after various investments. This is not the proposed use of the index. The proposal is to use the index to describe the current conditions at all locations in the county at the same time.
I’m not sure I understand Mr. Rehak’s concern about the index being a per capita value. The more people in an area who benefit from prior investments the better. Wouldn’t we want to invest in areas that help the most people?
The blue-shaded area of the table in my earlier post illustrates how population differences between locations will change the index value among those locations. For convenience I’ve repeated the table below:
Mr. Rehak accurately notes that the index goes up in locations with fewer people and down in locations with more people; this will incentivize planners to direct future investments in those higher population areas. He writes: “The more people you help with any given sum, the more the benefit goes down.” This is true, but Mr. Rehak’s statement doesn’t connect it to the past and it omits how the index will be normalized by area size. Index values will be calculated for similarly sized areas. This will allow an apples-to-apples comparison of per capita investments. The index is intended to incentivize future investments in areas with more people in cases where risk and prior investments are equal because we want to help as many people as possible.
By Michael Bloom, P.E.
Posted by Bob Rehak on 7/10/2022
1776 Days since Hurricane Harvey
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