Commissioners Approve New Formula for Scoring Future Flood Projects

Harris County Commissioners Court approved a motion on 1/10/23 that will change the formula for scoring future flood projects. It gives two thirds of a potential project’s score to population density, building density and social vulnerability, but only 20% to flood risk and nothing to actual flood damage.

Stacking the Deck

The new formula could be used both to compare and eliminate projects. With only 20% of a project’s score determined by flood risk, fixing minor flooding inside the Beltway could soon take precedence over fixing severe flooding outside the Beltway. The formula provides only the illusion of transparency and fails to ensure fairness.

During Hurricane Harvey, the highest flooding in the County occurred outside the Beltway along the San Jacinto River, Spring Creek and Cypress Creek.

Regardless, despite being the largest watershed in the county and one of the most heavily damaged, few flood-mitigation dollars have come to the San Jacinto Watershed.

Brays is the county’s most populous watershed. It’s also where Commissioner Ellis lives. Could that have anything to do with the factors and weights in the new formula for scoring future flood projects? They include:

• 45% Project Efficiency
  • 15% Resident Benefits 
  • 30% Structure Benefits 
• 20% Existing Conditions 
• 20% Social Vulnerability Index 
• 5% Long Term Maintenance Costs 
• 5% Minimizes Environmental Impacts 
• 5% Potential for Multiple Benefits 

This new formula omits consideration of damage, risk reduction and partnership funding. Partnership funding has provided approximately one third of all Flood Control District funding since 2000. The new formula gives the most weight to building and population density incorporated in the Project Efficiency formula (project cost divided by # residents and structures benefitted). This 15-page PDF explains how projects are scored within each category above.

Other Problems with Formula

The formula for scoring future flood projects, proposed by Precinct 1 Commissioner Rodney Ellis has many other problems. It also:

1. Does not differentiate between types of structures while giving them almost a third of the weight. Thus, a mobile home counts for as much as a hospital or college. 
2. Gives no weight to protecting critical infrastructure such as bridges, hospitals, grocery stores, wastewater treatment plants, etc. 
3. Omits actual damage from consideration, which “ground-truths” risk assumptions (see Existing Conditions, Page 6).
4. Eliminates consideration of partnership funds, which have provided almost one third of HCFCD funding since 2000. 
5. Gives 20% weight to social vulnerability, but ignores the severity of flooding. Thus a low-income home with one inch of flooding counts as much as an entire condo complex swept away by 22-foot deep floodwaters. 
6. Makes awards more subjective because HCFCD has no way of estimating how many people live in apartment buildings or homes. HCFCD can count buildings in satellite photos, but the number of residents benefitted will always be a guess. Census tracts do not follow floodplain boundaries. 
7. Undermines efforts to prevent flooding, as opposed to correcting it after people are damaged. Prevention, such as HCFCD’s Frontier Program, is always more cost effective in the long run. 
8. Places 45% of the weight on cost data that has not yet been determined when deciding whether to explore projects further.

Ellis’ proposal passed 3-1 yesterday. Commissioners Rodney Ellis, Adrian Garcia, and Lesley Briones voted for it. Commissioner Tom Ramsey voted against. County Judge Lina Hidalgo was absent. Commissioner Ellis ran the meeting.

To see the discussion on Ellis’ proposal, click on “Departments 2 of 2” in the meeting video and scroll forward to 3:03:53. The discussion lasts 16 minutes. Below is a summary of key points and their time codes.

Summary of Debate with Video Timecodes

Ellis positions his proposal as a “transparency measure.” 3:04:10

Dr. Tina Petersen, head of the Flood Control District describes it as a “clear, consistent and equitable basis” for comparing projects that the flood control district is undertaking. 3:04:53

Precinct 3 Commissioner Tom Ramsey says “criteria and frameworks are not necessarily a bad thing,” but then expresses a list of concerns about the proposal, none of which are addressed later in discussion. 3:06:19

Petersen responds that it’s “not perfect.” She says, “there’s no reason we can’t continue to refine this tool.” It’s very “general.” It let’s us “use what we have as a basis for comparison and continue to look forward to opportunities to refine” the tool.

Precinct 2 Commissioner Adrian Garcia asks whether the proposal will add costs or time to projects. 3:11:00

Petersen says no. “The framework should not require additional costs as long as we don’t look back.”

New Precinct 4 Commissioner Asks Probing Questions

New Precinct 4 Commissioner Briones then asks “how often will it be updated?” 3:13:20

Petersen replies, “We’re not considering making any changes to the framework.” She describes the primary uses as: comparing projects and determining which are eligible for funding from the Flood Resilience Trust.

Briones asks whether the framework incorporates “severity of flooding.”

Petersen points to the “efficiency” metric as the closest thing because it incorporate the number of people and structures benefitted. But Petersen sidesteps the point of the question about “depth of flooding” raised by Ramsey earlier. 3:14:25

Briones questions why partnerships are excluded.

Petersen responds that the framework was designed for use with the flood resilience trust, on projects where partnership dollars were no longer considered a possibility. “It was intended to be a backstop for projects that do not have partnership funding.” Petersen does not mention $750 million in HUD/GLO dollars pending final approval.

Briones next asks whether the framework will provide a threshold for making go/no-go decisions on projects. 3:15:40

Petersen replies, “I want to be clear. It will be used for determining whether a project is eligible for flood resilience trust funds.”

At 3:19:30, Ellis quickly closes debate before someone asks for clarification. The measure passes.

Debate Filled with Unresolved Contradictions

Petersen sidestepped Brione’s tough questions about severity of flooding and the eliminating projects. At one point, Petersen said it was “only a point of comparison.” Later, she said it would determine project “eligibility.”

She also equivocated in her response to Ramsey’s concerns. At first she implied the framework was a first step. Later she said that she didn’t plan to change it. Even though the framework is intended for future projects, most of Petersen’s answers related to the past.

Bellwether Vote

Only one thing is certain.

We’re in for four more years of fog described as transparency!

Posted by Bob Rehak on 1/11/2023

1961 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.