For residents of flood-prone areas such as Northpark South, only the National Flood Insurance Program (NFIP) stands between a river and ruin.
But ironically, efforts to staunch financial hemhorraging are making NFIP flood insurance unaffordable for many with low incomes. That creates an uncertain future for developments and people in or near floodplains.
Moreover, Congress must reauthorize NFIP before midnight on Feb. 2, 2024, to avoid a lapse in authority to sell flood insurance and borrow funds.
Approximately six million homes sit in special flood hazard areas nationwide. The National Association of Realtors estimates that should a lapse in the NFIP’s authorization occur, it threatens 1,300 property sales each day.
Hurricane Harvey inundated the area below with approximately eight feet of floodwater. Now, Century Land Holdings of Texas is clearing this risky area bordering the San Jacinto West Fork to build more than 230 homes.
This 50-acre patch of dirt is a symbolic battlefield in a growing debate over NFIP, which Congress must renew or reform next year.
Jobs vs. Jitters
A coalition of developers, home builders, realtors and mortgage lenders sees the NFIP’s nationally subsidized insurance rates as a tool to sustain employment, grow the economy, and enlarge the tax base of communities.
Others believe the subsidies encourage dangerous development in flood-prone areas by giving homebuyers a false sense of security.
Finding the right balance between encouraging responsible development and mitigating flood risks is a complex task for policymakers. Perhaps nowhere do the issues come into sharper focus than in Northpark South. Even the entrance to the subdivision was under eight feet of water. That would make evacuation difficult for anyone caught napping when the waters rise.
Contradictory Lawsuits Against FEMA
Contradictory lawsuits symbolize the two sides in this debate. An article in Government Executive noted that FEMA is being sued for making flood insurance too expensive AND too cheap!
The second lawsuit alleges taxpayer-subsidized, discounted coverage encourages floodplain development in high-hazard areas by providing insurance policies that obscure risk to property owners.
“This FEMA-incentivized development puts people in danger, harms communities, and destroys ecosystems.”
The contradictory allegations in the lawsuits underscore the need for careful policymaking around flood insurance.
Battle over Risk Rating 2.0
What triggered these lawsuits? FEMA has tried to navigate these dangerous waters by introducing a new system called Risk Rating 2.0. Risk Rating 2.0 reflects risk to individual properties from multiple sources of flooding, instead of aggregating people in broad flood zones. It also takes into account factors such as building codes and elevation that can mitigate flood risk.
Risk Rating 2.0 is an attempt to eliminate the subsidy aspect of flood insurance by quoting rates on an actuarial basis. Reportedly, some homeowner’s flood insurance rates have fallen, but others are rising and will continue to rise for years to come as risk becomes fully priced into policies. Texas and other Gulf Coast states are in the highest premium increase group, according to GAO.
Right now, law caps annual rate increases under Risk Rating 2.0. But the Congressional Accounting Office says caps only perpetuate an unfunded premium shortfall. GAO estimated it would take until 2037 for 95 percent of current policies to reach full-risk premiums, resulting in a $27 billion premium shortfall by then.
GAO also believes that discounted premiums hide fiscal exposure, address affordability poorly and hinder private-market growth.
In the meantime…
People who buy homes in Northpark South may find insurance affordable today and then find themselves quickly priced out of the market because of risk.
Higher premiums give policy holders a greater incentive to mitigate flood risk. But they’re also causing many homeowners to cancel policies.
One Congressional aid I talked to worried that if not enough people buy flood insurance, places like Northpark South will become “instant slums” after the first time they flood.
The reality: those who most need flood insurance can least afford it.
The GAO report comes as close to riveting reading as any government document I have ever read. Among other things, it points out how FEMA’s Community Rating System may send contradictory risk signals to potential buyers.
Approximately 236 homes and an 11.2 acre detention basin will be nestled between sand pits and occasional raging floodwaters.Northpark is the divided street in the background.Kingwood is beyond.
When Congress takes up NFIP next year, debate could lead to additional reforms. Watch closely. No one can predict the outcome at this point. Lobbyists are choosing up sides … between property rights and protection. Between a river and ruin.
Posted by Bob Rehak on 12/14/23
2298 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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2023/12/20231213-DJI_0385.jpg?fit=1100%2C733&ssl=17331100adminadmin2023-12-14 13:08:102023-12-14 13:42:45Between a River and Ruin
The Texas Water Development Board is seeking public comment on its plan to allocate $375 million in funding from the State’s flood infrastructure fund for the 2024-25 state fiscal year.
That prompted me to compare the TWDB and Harris County plans for ranking flood projects. The differences remind me of how the scoring systems favor certain projects in some areas and not others.
Harris County and the Texas Water Development Board (TWDB) use distinctly different priorities when considering which flood-mitigation projects to fund.
The biggest differences have to do with the weights given to severity of flooding, protection of infrastructure, social vulnerability and maintenance costs.
The state also uses “benefit/cost ratios” much like the federal government. The county, however, uses a measure called “project efficiency,” which is related but slightly different.
Let’s look more closely at each plan and then examine their differences.
Harris County Prioritization Framework
Harris County examines:
Project Efficiency…
Using People Benefitted
Using Structures Benefitted
Existing Conditions
Social Vulnerability Index
Long Term Maintenance Costs
Environmental Impacts
Potential for Multiple Benefits
Each project is assigned a score for each criterion below ranging from 0 to 10. A score of “10” indicates the project fully met the criterion and a score of “0” indicates that it did not.
Summary of ranking matrix from page 4 of Harris County Framework. For explanations of scoring on each measure, see full document.
Proposed TWDB Matrix
The TWDB scoring matrix measures more factors and gives them different weights.
The first thing you notice is that the table above is much wider and deeper than the County’s matrix. That’s because it lists evaluation criteria for different categories. And criteria sometimes change depending on the category.
Comparison of Differences
Social Vulnerability
Harris County gives 20% of all projects’ weights to social vulnerability. But the TWDB only gives it 5% weight. TWDB also uses social vulnerability as a tie breaker (see page 22).
Equity
Harris County has organized its flood-mitigation priorities since 2019 around equity. The proposed TWDB plan does not mention the word.
Efficiency
Harris County measures the efficiency of removing people and structures from the 100-year floodplain. The County defines efficiency as the cost of the project divided by the number of people or structures benefited. It gives them 45% weight within the final score.
TWDB also measures the number of people and structures removed from the 100-year floodplain. But unlike the county, it factors in critical facilities, the number of low water crossings, and miles of roads removed from the 100-year floodplain. Combined, they represent 55% of the weight. TWDB does not weigh cost against these measures at this point in its scoring matrix. However, it separately gives 2.5% weight to benefit/cost ratios.
Flood Risk
Harris County does not directly incorporate flood risk in its evaluations. It uses a proxy called “Existing Conditions” and gives it 20% weight. Existing Conditions measures the level of service provided by a detention basin or a channel. For instance, one with a 2-year level of service floods in a 2-year storm. One with a 25-year level of service floods in a 25-year storm, etc.
TWDB does not directly measure flood risk either. Rather it measures the number of structures, people, critical facilities, low-water crossings and road miles inside the 100-year floodplain. It’s a measure of what is “at risk.” These measures collectively add up to 100% of the score for a flood-management evaluation and 60% of the score for a flood-management strategy.
Severity
Harris County gives no weight to the severity of flooding. TWDB does. TWDB measures both the average depth of flooding in a 100-year storm and the percentage of a community’s population exposed to a 100-year flood. Together, they can account for 10% of a project’s total score.
Critical Facilities
Harris County does not differentiate among structures removed from a 100-year floodplain. But TWDB recognizes critical facilities. Such facilities could include sewage and water treatment plants; bridges; schools; hospitals; police and fire stations; and more. These affect entire communities, not just individuals.
Maintenance Costs
Harris County projects maintenance costs and gives them 5% of the weight. TWDB does NOT consider costs associated with current or future operations and maintenance activities.
No Right or Wrong Way
Neither the TWDB plan, nor the County’s plan is right or wrong. Their weights reflect the needs of different people and different organizations in different places. For instance, the state is not involved in maintenance, but maintenance historically has consumed as much as 50% of Harris County Flood Control District’s budget. So it makes sense for the county to prioritize low maintenance costs.
However, I would observe that Harris County could borrow some ideas from the state, such as incorporating measures for severity of flooding, protection of life, and protection of critical facilities. The areas that had the deepest flooding and the highest loss of life during Harvey have received little flood-mitigation assistance from Harris County compared to poor areas.
What happens when 240,000 cubic feet per second, 20-foot-high floodwaters tear through your home.When sewage-contaminated floodwater invaded Kingwood High School to the third floor,4,000 students had to study in shifts at another high school an hour away for a year.
What Do You Think?
TWDB seeks public comment on its proposed plan by January 1, 2024. What do you think? Based on your flood experience, do you think TWDB could do something better? Let them know.
Their plan includes more information than shown above. For instance, it also includes information on eligibility, minimum standards, program timeline, and financial assistance categories.
If you wish to comment email FIF@twdb.texas.gov and specify in the subject line “FIF IUP Comments.” Should you have any questions, please contact the TWDB by emailing the same address.
Posted by Bob Rehak on 12/11/23
2295 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/01/KHS-e1702338318946.jpg?fit=1100%2C616&ssl=16161100adminadmin2023-12-11 17:47:242023-12-12 07:12:39Differences in Ways County, State Propose Ranking Flood Projects
In the 2023 runoff election for Mayor of Houston, John Whitmire won by a landslide. Kingwood voted for Whitmire at much higher rates than the city as a whole. He won 91.4% of the votes in Kingwood – a 10.6 to 1 margin of victory over Sheila Jackson Lee, compared to 1.9 to 1 for the City as a whole.
Most of Undecideds Sided with Whitmire
Whitmire enjoyed a 7% lead over Lee in early polls, but picked up most of the undecideds. He finished with a convincing 65.26% to 34.74% victory, not quite a 2:1 margin.
Citywide, Whitmire won by a margin of 60,275 votes. In Kingwood, he beat Jackson Lee by 8,734 votes – 14.5% of his citywide margin.
That’s remarkable for two reasons.
Kingwood has only 3% of the City’s population (about 70,000 out of 2.2 million).
Kingwood had 5% of the total voters in the runoff.
Among the City’s 1.2 million registered voters, turnout was a meager 16.92%. But among Kingwood’s 44,000 registered voters, turnout was 23.86% – 7 percentage points higher.
Ten of Kingwood’s 12 precincts had turnout in the top quintile of all precincts.
So, Kingwood had higher turnout than most areas and those who voted preferred Whitmire overwhelmingly.
Meaning of Whitmire Win
Whitmire ran a positive campaign focused on crime, the economy, drainage/infrastructure, city services and bringing Houston together.
Kingwood is traditionally Republican. Kingwood’s overwhelming endorsement of the moderate Democrat may herald a sea change in local politics. Here, in this election, in this place, at this time, voters buried partisan politics and reached across the aisle to support centrist viewpoints that benefit the majority.
Precinct-By-Precinct Rundown
Kingwood has 12 voting precincts.
Kingwood voting precincts. 948 is all commercial and had no registered voters.
Here are the totals for each candidate in each precinct from HarrisVotes.com. See how your neighbors voted.
Whitmire vs Lee in Kingwood
Precinct
J. Whitmire
S. J. Lee
Total
JW Win %
199
717
69
786
91.2%
340
620
74
694
89.3%
357
664
78
742
89.5%
459
1,029
106
1,135
90.7%
469
883
56
939
94.0%
546
833
39
872
95.5%
563
829
80
909
91.2%
590
668
43
711
94.0%
612
775
84
859
90.2%
635
530
77
607
87.3%
670
999
81
1,080
92.5%
758
1,094
120
1,214
90.1%
Kingwood Total
9,641
907
10,548
91.4%
Citywide Total
128,908
68,633
197,541
65.3%
Kingwood Tallies & Totals vs. Citywide in Whitmire/Lee runoff.
It appears to me that Sheila Jackson Lee’s winner-take-all politics of polarization backfired on her this time. I haven’t yet had time to check other Republican-leaning areas, but in Kingwood, it seems that Republican’s arms didn’t stretch to her extremes.
The Candidate Now Has a Mandate
While Whitmire could have won the City convincingly without Kingwood, he won it dramatically with Kingwood. He will start the job with a broad mandate.
Whitmire still has huge challenges to face. Now comes the hard part of governing a city saddled with debt.
Between a River and Ruin
For residents of flood-prone areas such as Northpark South, only the National Flood Insurance Program (NFIP) stands between a river and ruin.
But ironically, efforts to staunch financial hemhorraging are making NFIP flood insurance unaffordable for many with low incomes. That creates an uncertain future for developments and people in or near floodplains.
Moreover, Congress must reauthorize NFIP before midnight on Feb. 2, 2024, to avoid a lapse in authority to sell flood insurance and borrow funds.
Approximately six million homes sit in special flood hazard areas nationwide. The National Association of Realtors estimates that should a lapse in the NFIP’s authorization occur, it threatens 1,300 property sales each day.
Texas Ranks #2 in States with Most Flood Damage
Texas ranks #2 in states with the most flood damage. More people live in Texas floodplains than live in 30 states, according to the TWDB. Northpark South is a good example why.
Hurricane Harvey inundated the area below with approximately eight feet of floodwater. Now, Century Land Holdings of Texas is clearing this risky area bordering the San Jacinto West Fork to build more than 230 homes.
This 50-acre patch of dirt is a symbolic battlefield in a growing debate over NFIP, which Congress must renew or reform next year.
Jobs vs. Jitters
A coalition of developers, home builders, realtors and mortgage lenders sees the NFIP’s nationally subsidized insurance rates as a tool to sustain employment, grow the economy, and enlarge the tax base of communities.
Others believe the subsidies encourage dangerous development in flood-prone areas by giving homebuyers a false sense of security.
Finding the right balance between encouraging responsible development and mitigating flood risks is a complex task for policymakers. Perhaps nowhere do the issues come into sharper focus than in Northpark South. Even the entrance to the subdivision was under eight feet of water. That would make evacuation difficult for anyone caught napping when the waters rise.
Contradictory Lawsuits Against FEMA
Contradictory lawsuits symbolize the two sides in this debate. An article in Government Executive noted that FEMA is being sued for making flood insurance too expensive AND too cheap!
One law suit – that includes the State of Texas as a plaintiff – alleges that high flood insurance rates put residents and communities at risk of economic ruin.
A second lawsuit alleges that low rates do too little to stop developments on at-risk land.
The second lawsuit alleges taxpayer-subsidized, discounted coverage encourages floodplain development in high-hazard areas by providing insurance policies that obscure risk to property owners.
The contradictory allegations in the lawsuits underscore the need for careful policymaking around flood insurance.
Battle over Risk Rating 2.0
What triggered these lawsuits? FEMA has tried to navigate these dangerous waters by introducing a new system called Risk Rating 2.0. Risk Rating 2.0 reflects risk to individual properties from multiple sources of flooding, instead of aggregating people in broad flood zones. It also takes into account factors such as building codes and elevation that can mitigate flood risk.
Risk Rating 2.0 is an attempt to eliminate the subsidy aspect of flood insurance by quoting rates on an actuarial basis. Reportedly, some homeowner’s flood insurance rates have fallen, but others are rising and will continue to rise for years to come as risk becomes fully priced into policies. Texas and other Gulf Coast states are in the highest premium increase group, according to GAO.
Right now, law caps annual rate increases under Risk Rating 2.0. But the Congressional Accounting Office says caps only perpetuate an unfunded premium shortfall. GAO estimated it would take until 2037 for 95 percent of current policies to
reach full-risk premiums, resulting in a $27 billion premium shortfall by then.
GAO also believes that discounted premiums hide fiscal exposure, address affordability poorly and hinder private-market growth.
In the meantime…
Affordability of Insurance Increasingly in Doubt
Rising costs are the number one insurance-related issue in many states, according to Realtor Magazine. Risk Rating 2.0 aligns premiums with risk, but jeopardizes affordability.
Some who buy homes in Northpark South will drop flood insurance because of its cost. GAO says nine percent of NFIP policy holders will see price increases greater than 300%.
Higher premiums give policy holders a greater incentive to mitigate flood risk. But they’re also causing many homeowners to cancel policies.
One Congressional aid I talked to worried that if not enough people buy flood insurance, places like Northpark South will become “instant slums” after the first time they flood.
The reality: those who most need flood insurance can least afford it.
The GAO report comes as close to riveting reading as any government document I have ever read. Among other things, it points out how FEMA’s Community Rating System may send contradictory risk signals to potential buyers.
When Congress takes up NFIP next year, debate could lead to additional reforms. Watch closely. No one can predict the outcome at this point. Lobbyists are choosing up sides … between property rights and protection. Between a river and ruin.
Posted by Bob Rehak on 12/14/23
2298 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.
Differences in Ways County, State Propose Ranking Flood Projects
The Texas Water Development Board is seeking public comment on its plan to allocate $375 million in funding from the State’s flood infrastructure fund for the 2024-25 state fiscal year.
That prompted me to compare the TWDB and Harris County plans for ranking flood projects. The differences remind me of how the scoring systems favor certain projects in some areas and not others.
Harris County and the Texas Water Development Board (TWDB) use distinctly different priorities when considering which flood-mitigation projects to fund.
The biggest differences have to do with the weights given to severity of flooding, protection of infrastructure, social vulnerability and maintenance costs.
The state also uses “benefit/cost ratios” much like the federal government. The county, however, uses a measure called “project efficiency,” which is related but slightly different.
Differences in Ranking Projects
Here is the most recent prioritization framework that Harris County adopted in 2022 and again in 2023. And here is the draft “intended use plan” for the State of Texas 2024-25 Flood Infrastructure Fund.
Let’s look more closely at each plan and then examine their differences.
Harris County Prioritization Framework
Harris County examines:
Each project is assigned a score for each criterion below ranging from 0 to 10. A score of “10” indicates the project fully met the criterion and a score of “0” indicates that it did not.
Proposed TWDB Matrix
The TWDB scoring matrix measures more factors and gives them different weights.
The first thing you notice is that the table above is much wider and deeper than the County’s matrix. That’s because it lists evaluation criteria for different categories. And criteria sometimes change depending on the category.
Comparison of Differences
Social Vulnerability
Harris County gives 20% of all projects’ weights to social vulnerability. But the TWDB only gives it 5% weight. TWDB also uses social vulnerability as a tie breaker (see page 22).
Equity
Harris County has organized its flood-mitigation priorities since 2019 around equity. The proposed TWDB plan does not mention the word.
Efficiency
Harris County measures the efficiency of removing people and structures from the 100-year floodplain. The County defines efficiency as the cost of the project divided by the number of people or structures benefited. It gives them 45% weight within the final score.
TWDB also measures the number of people and structures removed from the 100-year floodplain. But unlike the county, it factors in critical facilities, the number of low water crossings, and miles of roads removed from the 100-year floodplain. Combined, they represent 55% of the weight. TWDB does not weigh cost against these measures at this point in its scoring matrix. However, it separately gives 2.5% weight to benefit/cost ratios.
Flood Risk
Harris County does not directly incorporate flood risk in its evaluations. It uses a proxy called “Existing Conditions” and gives it 20% weight. Existing Conditions measures the level of service provided by a detention basin or a channel. For instance, one with a 2-year level of service floods in a 2-year storm. One with a 25-year level of service floods in a 25-year storm, etc.
TWDB does not directly measure flood risk either. Rather it measures the number of structures, people, critical facilities, low-water crossings and road miles inside the 100-year floodplain. It’s a measure of what is “at risk.” These measures collectively add up to 100% of the score for a flood-management evaluation and 60% of the score for a flood-management strategy.
Severity
Harris County gives no weight to the severity of flooding. TWDB does. TWDB measures both the average depth of flooding in a 100-year storm and the percentage of a community’s population exposed to a 100-year flood. Together, they can account for 10% of a project’s total score.
Critical Facilities
Harris County does not differentiate among structures removed from a 100-year floodplain. But TWDB recognizes critical facilities. Such facilities could include sewage and water treatment plants; bridges; schools; hospitals; police and fire stations; and more. These affect entire communities, not just individuals.
Maintenance Costs
Harris County projects maintenance costs and gives them 5% of the weight. TWDB does NOT consider costs associated with current or future operations and maintenance activities.
No Right or Wrong Way
Neither the TWDB plan, nor the County’s plan is right or wrong. Their weights reflect the needs of different people and different organizations in different places. For instance, the state is not involved in maintenance, but maintenance historically has consumed as much as 50% of Harris County Flood Control District’s budget. So it makes sense for the county to prioritize low maintenance costs.
However, I would observe that Harris County could borrow some ideas from the state, such as incorporating measures for severity of flooding, protection of life, and protection of critical facilities. The areas that had the deepest flooding and the highest loss of life during Harvey have received little flood-mitigation assistance from Harris County compared to poor areas.
What Do You Think?
TWDB seeks public comment on its proposed plan by January 1, 2024. What do you think? Based on your flood experience, do you think TWDB could do something better? Let them know.
Their plan includes more information than shown above. For instance, it also includes information on eligibility, minimum standards, program timeline, and financial assistance categories.
If you wish to comment email FIF@twdb.texas.gov and specify in the subject line “FIF IUP Comments.” Should you have any questions, please contact the TWDB by emailing the same address.
Posted by Bob Rehak on 12/11/23
2295 Days since Hurricane Harvey
How Kingwood Voted in Whitmire Win
In the 2023 runoff election for Mayor of Houston, John Whitmire won by a landslide. Kingwood voted for Whitmire at much higher rates than the city as a whole. He won 91.4% of the votes in Kingwood – a 10.6 to 1 margin of victory over Sheila Jackson Lee, compared to 1.9 to 1 for the City as a whole.
Most of Undecideds Sided with Whitmire
Whitmire enjoyed a 7% lead over Lee in early polls, but picked up most of the undecideds. He finished with a convincing 65.26% to 34.74% victory, not quite a 2:1 margin.
Citywide, Whitmire won by a margin of 60,275 votes. In Kingwood, he beat Jackson Lee by 8,734 votes – 14.5% of his citywide margin.
That’s remarkable for two reasons.
Among the City’s 1.2 million registered voters, turnout was a meager 16.92%. But among Kingwood’s 44,000 registered voters, turnout was 23.86% – 7 percentage points higher.
Ten of Kingwood’s 12 precincts had turnout in the top quintile of all precincts.
So, Kingwood had higher turnout than most areas and those who voted preferred Whitmire overwhelmingly.
Meaning of Whitmire Win
Whitmire ran a positive campaign focused on crime, the economy, drainage/infrastructure, city services and bringing Houston together.
Kingwood is traditionally Republican. Kingwood’s overwhelming endorsement of the moderate Democrat may herald a sea change in local politics. Here, in this election, in this place, at this time, voters buried partisan politics and reached across the aisle to support centrist viewpoints that benefit the majority.
Precinct-By-Precinct Rundown
Kingwood has 12 voting precincts.
Here are the totals for each candidate in each precinct from HarrisVotes.com. See how your neighbors voted.
It appears to me that Sheila Jackson Lee’s winner-take-all politics of polarization backfired on her this time. I haven’t yet had time to check other Republican-leaning areas, but in Kingwood, it seems that Republican’s arms didn’t stretch to her extremes.
The Candidate Now Has a Mandate
While Whitmire could have won the City convincingly without Kingwood, he won it dramatically with Kingwood. He will start the job with a broad mandate.
Whitmire still has huge challenges to face. Now comes the hard part of governing a city saddled with debt.
The good news as far as the Lake Houston Gates Project is concerned: funding comes mainly from outside sources and can only be used for gates, according to current Mayor Pro Tem Dave Martin.
And after 50 years in Austin, Whitmire knows how to work across the aisle and only Whitmire made flooding an issue in his campaign.
I hope Whitmire’s win ushers in a new era for the City that gives everyone a seat at the table, not just those on the far left.
Posted by Bob Rehak on 12/10/23
2294 Days since Hurricane Harvey