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
Precinct 1 Commissioner Rodney Ellis has placed an item on the Commissioners Court agenda for 1/10/23 with far reaching ramifications for flood control in Harris County. It would change the way every future project is prioritized using a formula that gives almost half the weight to population and building density. Meanwhile, it ignores the amount of damage, severity of flooding, danger to infrastructure, historical underinvestment, and the difficulty of accurately estimating population in flood zones. Ellis’ recommendation could be used to permanently deny projects to heavily flood-damaged areas like Lake Houston.
Text of Motion
In Agenda Item #250, Ellis seeks: “Request for approval to direct the Harris County Flood Control District (“District”) to assign prioritization scores using the adopted 2022 Prioritization Framework for the Allocation of Funds from the Harris County Flood Resilience Trust to all new flood risk reduction projects funded by the District when requesting Commissioners Court approval to initiate the project, and to transmit those scores as quartiles to Commissioners Court.”
So what is that framework and why do we need it?
History of Recent Efforts to Prioritize Projects
Before the 2018 flood bond, Harris County flood control looked primarily at clusters of repeat damage to define and prioritize projects. That damage also formed the basis for obtaining partner funding in many cases.
However, when the perpetually underfunded Flood Control District received the huge infusion of cash from the 2018 flood bond, a problem arose. Which of the many worthy projects would be launched first? There simply weren’t enough qualified contractors to handle all needs simultaneously.
The text of the 2018 flood bond approved by voters contained a sentence that said, “…Commissioners Court shall provide a process for the equitable distribution of funds…” (See Paragraph 14-G). That became the key to the answer…with some verbal legerdemain by Ellis that turned “distribution” into “prioritization” and “equitable” into “equity.”
20% Existing Conditions (Drainage Level of Service)
20% Social Vulnerability
10% Project Efficiency
10% Partnership Funding
5% Long Term Maintenance Costs
5% Minimizes Environmental Impacts
5% Potential for Multiple Benefits
Total 100%
Commissioners, including Ellis, repeatedly affirmed their intent to complete all projects originally identified as part of the bond. The framework simply prioritized their start dates.
Commissioners also talked a lot about prioritizing “the worst first.” It was a nice sound bite, but never defined. Were the worst areas those with the most damage, deepest flooding, poorest residents, highest risk, or some combination of the above? Notice that the formula above omits flood damage, the traditional way of prioritizing funds and “ground-truthing” flood-risk estimates.
At this point, all of the projects in the bond have started. Their natural lifecycles and complexity will determine their order of completion. So, the debate has shifted from the flood bond to other sources of funding and future projects.
2021 Changes Applied to Flood Resilience Trust
In 2021, Commissioners created a Flood Resilience Trust using Toll-Road funds to backstop potential shortfalls in flood-bond partner contributions. The weighting used to allocate funds from the Trust changed significantly.
25% Structures Benefitted
20% Flooding Frequency
20% Social Vulnerability
10% Cost Per Structure
10% Partnership Funding
5% Maintenance Cost
5% Environmental Impact
5% Secondary Benefits
Total 100%
Flood Control used this formula only to prioritize the use of backstop funds in the Trust. Note this version of the formula eliminated both damage and risk reduction from consideration.
2022 Changes
In April, 2022, Commissioners modified the 2021 weights within the Prioritization Framework – still only for Flood Resilience Trust Funds – as follows:
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 2022 formula omits consideration of damage, risk reduction and partnership funding. But it gives weight to population density (project cost divided by # residents benefitted). This 15-page PDF explains how projects are scored within each category above.
2023 Proposal
Commissioner Ellis now proposes applying the 2022 Resilience Trust formula to ALL FUTURE HCFCD PROJECTS.
Problems with Proposal
Flood Control would now use Ellis’ formula to decide which projects make the list, not just which go first.
Thus, the so-called “equity” formula once used to schedule projects could now be used to eliminate projects altogether.
Two thirds of the weight goes to density and social vulnerability. Only 20% relates to flooding.
The projects most likely to be eliminated would be outside the Beltway – in less dense areas that have traditionally received the least funding. In a post-bond, financially constrained environment, the weight given to density will put every project outside the Beltway at a disadvantage.
But the Ellis formula has many other problems, too. It:
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.
Forces Flood Control to judge projects before the District has engineering and cost data in hand that would help determine whether the projects are worth pursuing. That’s because “ALL FUTURE PROJECTS” include preliminary engineering projects.
Suggestions For Improvement
Below are several suggestions to improve the formula.
Define “worst first.” While the sentiment is noble, in practice, the term has no practical definition. (Ditto for equity.)
Incorporate measurements for severity of flooding and amount of damage. These really define worst.
Prioritize critical infrastructure such as bridges whose loss can jeopardize the economic vitality of the region.
Include partnership funds. They help stretch flood-mitigation tax dollars by almost a third. Even if people sometimes must wait longer to line up partner funding, partner funding helps more people in the long run.
Publish level-of-service data, used in the “existing conditions” calculation, for all streams in the county. It seems to be secret. I’ve been trying to get it for a year. Keeping it secret undermines trust in government. How do we know money is really going to the areas with the greatest risk?
Publish a 5-year Capital Improvement Plan similar to the City of Houston. Let people see what is coming, when, and for how much. That way we can hold HCFCD and Commissioners accountable. Plus, we can see their “formula” in action.
Be fair to all. The proposed formula is like playing cards with a stacked deck.
Posted by Bob Rehak on 1/7/23
1957 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/2020/08/Ellis.jpg?fit=1200%2C809&ssl=18091200adminadmin2023-01-07 19:13:032023-01-08 10:27:15Ellis Trying to Change How All Flood-Control Projects Prioritized
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
Ellis Trying to Change How All Flood-Control Projects Prioritized
Precinct 1 Commissioner Rodney Ellis has placed an item on the Commissioners Court agenda for 1/10/23 with far reaching ramifications for flood control in Harris County. It would change the way every future project is prioritized using a formula that gives almost half the weight to population and building density. Meanwhile, it ignores the amount of damage, severity of flooding, danger to infrastructure, historical underinvestment, and the difficulty of accurately estimating population in flood zones. Ellis’ recommendation could be used to permanently deny projects to heavily flood-damaged areas like Lake Houston.
Text of Motion
In Agenda Item #250, Ellis seeks: “Request for approval to direct the Harris County Flood Control District (“District”) to assign prioritization scores using the adopted 2022 Prioritization Framework for the Allocation of Funds from the Harris County Flood Resilience Trust to all new flood risk reduction projects funded by the District when requesting Commissioners Court approval to initiate the project, and to transmit those scores as quartiles to Commissioners Court.”
So what is that framework and why do we need it?
History of Recent Efforts to Prioritize Projects
Before the 2018 flood bond, Harris County flood control looked primarily at clusters of repeat damage to define and prioritize projects. That damage also formed the basis for obtaining partner funding in many cases.
However, when the perpetually underfunded Flood Control District received the huge infusion of cash from the 2018 flood bond, a problem arose. Which of the many worthy projects would be launched first? There simply weren’t enough qualified contractors to handle all needs simultaneously.
The text of the 2018 flood bond approved by voters contained a sentence that said, “…Commissioners Court shall provide a process for the equitable distribution of funds…” (See Paragraph 14-G). That became the key to the answer…with some verbal legerdemain by Ellis that turned “distribution” into “prioritization” and “equitable” into “equity.”
2019 Equity Prioritization Framework
In 2019, Ellis proposed (and the Court adopted) the “Prioritization Framework for the Implementation of the Harris County Flood Control District 2018 Bond Projects.” This framework ranked projects with a multi-factor index using the following weights:
Commissioners, including Ellis, repeatedly affirmed their intent to complete all projects originally identified as part of the bond. The framework simply prioritized their start dates.
Commissioners also talked a lot about prioritizing “the worst first.” It was a nice sound bite, but never defined. Were the worst areas those with the most damage, deepest flooding, poorest residents, highest risk, or some combination of the above? Notice that the formula above omits flood damage, the traditional way of prioritizing funds and “ground-truthing” flood-risk estimates.
At this point, all of the projects in the bond have started. Their natural lifecycles and complexity will determine their order of completion. So, the debate has shifted from the flood bond to other sources of funding and future projects.
2021 Changes Applied to Flood Resilience Trust
In 2021, Commissioners created a Flood Resilience Trust using Toll-Road funds to backstop potential shortfalls in flood-bond partner contributions. The weighting used to allocate funds from the Trust changed significantly.
Flood Control used this formula only to prioritize the use of backstop funds in the Trust. Note this version of the formula eliminated both damage and risk reduction from consideration.
2022 Changes
In April, 2022, Commissioners modified the 2021 weights within the Prioritization Framework – still only for Flood Resilience Trust Funds – as follows:
This 2022 formula omits consideration of damage, risk reduction and partnership funding. But it gives weight to population density (project cost divided by # residents benefitted). This 15-page PDF explains how projects are scored within each category above.
2023 Proposal
Commissioner Ellis now proposes applying the 2022 Resilience Trust formula to ALL FUTURE HCFCD PROJECTS.
Problems with Proposal
Flood Control would now use Ellis’ formula to decide which projects make the list, not just which go first.
Two thirds of the weight goes to density and social vulnerability. Only 20% relates to flooding.
The projects most likely to be eliminated would be outside the Beltway – in less dense areas that have traditionally received the least funding. In a post-bond, financially constrained environment, the weight given to density will put every project outside the Beltway at a disadvantage.
But the Ellis formula has many other problems, too. It:
Suggestions For Improvement
Below are several suggestions to improve the formula.
Posted by Bob Rehak on 1/7/23
1957 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.