On January 9, 2023, FEMA released a Simplified Procedures policy for Public Assistance grants to speed up recovery for applicants. Small projects are now defined as those up to $1 million.
The new policy should reduce administrative burdens and enable communities to recover more quickly after presidentially declared events by streamlining documentation requirements.
FEMA will accept estimates with summary information and the applicant’s certifications for damage and work, instead of requiring applicants to provide full or detailed documentation.
FEMA Press Release
FEMA conducted a review in 2020. It showed that if a $1 million threshold were applied, 94 percent of projects would be considered small and help put additional recovery dollars in the hands of applicants faster and accelerate closure of projects.
FEMA intends to continue adjusting the threshold annually to reflect changes in the Consumer Price Index. It also intends to review the base threshold every three years.
The new policy is not directly aimed at individuals, but at state and local governments and certain types of private nonprofit organizations. Public Assistance grants cover such things as:
Disaster-related debris removal
Emergency protective measures
Repairs to damaged or destroyed infrastructure (i.e., roads).
FM1010 Washout during Harvey at Rocky Branch in Plum Grove near the East Fork. Still not repaired after 5.5 years.
Depending on repair cost and other factors, the road washout above is an example of the type of project that might benefit from the new policy. However, it’s not clear whether the simplified procedures apply retroactively to damage from past disasters or only future disasters. More details will follow.
Applicant has legal responsibility to perform the work
Cost is reasonable.
Once FEMA and the state review and approve the government agencies’ or nonprofits’ RPAs, applicants work with their FEMA representative to develop a damage inventory.
FEMA obligates funds to the state once a project meets Stafford Act eligibility requirements. The state is the official recipient of FEMA federal assistance. The state is then responsible for disbursing the money to applicants.
FEMA will hold a series of webinars in coming weeks to explain more about the simplified policy. Additional details are not yet available.
Getting aid to people faster after a disaster is necessary. This is a very complex subject. I wish all forms of disaster relief, including hazard mitigation, could be simplified. We’re still waiting on the Harris County, the GLO and HUD to agree on a plan for spending $750 million in mitigation funds related to Hurricane Harvey – 5.5 years after the event!
Posted by Bob Rehak on 1/12/23 based on a FEMA Press Release
1962 Days after Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/10/20201025-DJI_0919.jpg?fit=1200%2C900&ssl=19001200adminadmin2023-01-12 13:04:432023-01-12 13:20:54FEMA Simplifying Procedures for Small Public Assistance Grants
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.
Chart showing feet above flood stage of 33 gages on misc. bayous in Harris County during Harvey.
During Hurricane Harvey, the highest flooding in the County occurred outside the Beltway along the San Jacinto River, Spring Creek and Cypress Creek.
North Shore evacuation route during Harvey. Photo by Jim Balcom.
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.
Since Harvey, 4.6 more flood-mitigation dollars have gone to the Brays watershed than the county’s largest, the San Jacinto.
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:
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.
Gives no weight to protecting critical infrastructure such as bridges, hospitals, grocery stores, wastewater treatment plants, etc.
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.
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.
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.
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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/10/Balcom-Evac.jpg?fit=1200%2C793&ssl=17931200adminadmin2023-01-11 15:13:312023-01-11 16:46:45Commissioners Approve New Formula for Scoring Future Flood Projects
Three areas in northwest Humble are in various stages of development. Parts or all of these areas flooded during Hurricane Harvey. The flooding was deep enough that reportedly one of the developers is not even going to try to raise the area. Instead, he said he will raise the homes 6-7 feet. Let’s hope that’s enough.
The numbers in the satellite image correspond to the groups of photos below. I took all shots on 1/3/23.
#1 will become light industrial. #2 will become single family residential. #3 will become single- and multi-family residential.
Area #1 – Light Industrial
According to a 2016 map by Skymark, the developer, the first area will become light industrial.
A four-lane divided road leads from the NW corner of Townsen Boulevard to Spring Creek on the north. By Skymark Development.The road abruptly stops before reaching Spring Creek and the Spring Creek Nature Trail.
The unpaved area between Spring Creek and where the road ends is owned by another developer (Pacific Indio) who also owns the land on the far side of the creek.
The Spring Creek Nature Trail cuts through the woods near the creek and follows it north toward I-45.Reverse angle shot looking SE toward Deerbook Mall shows large cleared area with stormwater detention basin.
Area #2 – Single Family Residential
Contractors are in the process of building roads into an area west of Target and Kohls. Saratoga Homes reportedly plans to build 357 homes and townhomes on this location.
Looking S from over Townsen Blvd. we can see two large stormwater detention basins (lower and upper left) Same area, but looking east toward Kohls and Target.
The closer shot below shows that not all the roads have been built yet.
Saratoga plans to build elevated homes here.
Area #3 – Single- and Multi-Family Residential
Looking south toward Sam’s with Townsen Blvd West on right, we can see a large stormwater detention pond that already has grass growing. This area will become single- and multi-family residential, some of which will be dedicated to seniors.
Note last of trees in center foreground being cleared and shredded for mulch. Spillway from detention basin seems to have a detour built into it. The purpose? Likely to slow the water and avoid erosion at the base of the utility poles.The long ditch on the left will drain Areas 2 and 3.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2023/01/20230103-DJI_0559.jpg?fit=1200%2C799&ssl=17991200adminadmin2023-01-09 13:31:172023-01-09 13:39:27Development Update on 3 Areas in NW Humble
FEMA Simplifying Procedures for Small Public Assistance Grants
On January 9, 2023, FEMA released a Simplified Procedures policy for Public Assistance grants to speed up recovery for applicants. Small projects are now defined as those up to $1 million.
The new policy should reduce administrative burdens and enable communities to recover more quickly after presidentially declared events by streamlining documentation requirements.
FEMA conducted a review in 2020. It showed that if a $1 million threshold were applied, 94 percent of projects would be considered small and help put additional recovery dollars in the hands of applicants faster and accelerate closure of projects.
FEMA intends to continue adjusting the threshold annually to reflect changes in the Consumer Price Index. It also intends to review the base threshold every three years.
The new policy is not directly aimed at individuals, but at state and local governments and certain types of private nonprofit organizations. Public Assistance grants cover such things as:
Depending on repair cost and other factors, the road washout above is an example of the type of project that might benefit from the new policy. However, it’s not clear whether the simplified procedures apply retroactively to damage from past disasters or only future disasters. More details will follow.
How Public Assistance Usually Works
In general, applicants submit Requests for Public Assistance (RPAs) within 30 days of the disaster declaration. They must demonstrate that:
Once FEMA and the state review and approve the government agencies’ or nonprofits’ RPAs, applicants work with their FEMA representative to develop a damage inventory.
FEMA obligates funds to the state once a project meets Stafford Act eligibility requirements. The state is the official recipient of FEMA federal assistance. The state is then responsible for disbursing the money to applicants.
FEMA will hold a series of webinars in coming weeks to explain more about the simplified policy. Additional details are not yet available.
Getting aid to people faster after a disaster is necessary. This is a very complex subject. I wish all forms of disaster relief, including hazard mitigation, could be simplified. We’re still waiting on the Harris County, the GLO and HUD to agree on a plan for spending $750 million in mitigation funds related to Hurricane Harvey – 5.5 years after the event!
Posted by Bob Rehak on 1/12/23 based on a FEMA Press Release
1962 Days after Hurricane Harvey
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:
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:
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.
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.
Development Update on 3 Areas in NW Humble
Three areas in northwest Humble are in various stages of development. Parts or all of these areas flooded during Hurricane Harvey. The flooding was deep enough that reportedly one of the developers is not even going to try to raise the area. Instead, he said he will raise the homes 6-7 feet. Let’s hope that’s enough.
The numbers in the satellite image correspond to the groups of photos below. I took all shots on 1/3/23.
Area #1 – Light Industrial
According to a 2016 map by Skymark, the developer, the first area will become light industrial.
The unpaved area between Spring Creek and where the road ends is owned by another developer (Pacific Indio) who also owns the land on the far side of the creek.
Area #2 – Single Family Residential
Contractors are in the process of building roads into an area west of Target and Kohls. Saratoga Homes reportedly plans to build 357 homes and townhomes on this location.
The closer shot below shows that not all the roads have been built yet.
Area #3 – Single- and Multi-Family Residential
Looking south toward Sam’s with Townsen Blvd West on right, we can see a large stormwater detention pond that already has grass growing. This area will become single- and multi-family residential, some of which will be dedicated to seniors.
Together, all three areas comprise approximately 260 acres according to this map on the Skymark Development website.
To learn more about the history of these sites, see the posts below. They contain floodplain and wetland maps.
Onward. Into the danger zone!
Posted by Bob Rehak on 1/9/23
1959 Days since Hurricane Harvey