Last Chance to Comment on Distribution of $750 Million in HUD Flood-Mitigation Funds

Tuesday 2/21/23 at 5 P.M. will be your last chance to comment on Harris County’s proposed distribution of $750 million in HUD Flood-Mitigation funds.

Harris County Community Services Department (CSD) will request Commissioners Court approval of its plan for allocating $750 million in HUD Harvey mitigation funds Tuesday. (See item 489 on the Agenda.) The Texas General Land Office (GLO) has conditionally approved the preliminary plan and sent it back to Harris County for public comment.

However, the plan still consists only of a high-level outline. The county wants to split the money between itself and Harris County Flood Control District (HCFCD) after allocating 13% for planning and administration.

CSD doesn’t intend to say exactly what areas will get how much for which projects until AFTER public comments.

Preliminary Plan Still Contains Little Detail

CSD has posted a 15-minute YouTube video that explains the process. See the screen captures below from the video.

Basically, CSD wants your comments on a high-level outline for dividing up the money. Below is what they recommend.

Less than half will go to HCFCD. AFTER approval tomorrow, the County will develop a list of projects for submission to the GLO. See last line in slide below.

CSD’s video discusses the criteria the county intends to use when developing a project list.

Input obtained prior to developing list.

It appears that Harris County wants all of the money to benefit low-to-moderate income, socially vulnerable neighborhoods…the same neighborhoods that have gotten the lion’s share of funding to date.

Sound familiar? Even though 50% of the $750 million can go to higher income areas, up to 100% could go to low-to-moderate income areas. And it looks like the county wants to go in that direction. Again.

Public Comments Close at 5 P.M. Tuesday

The only way to get your fair share is if enough members of the public demand a more even split. We don’t have enough money to finish the flood bond without spending all of the $750 million on flood mitigation. But CSD’s plan would give less than half to HCFCD.

We need the entire $750 million to fully fund the 2018 flood bond. Given the prevailing politics in Harris County these days, if any projects get cancelled for lack of funding, they will likely be those in middle- to higher-income neighborhoods.

Get Your Promised Share of the 2018 Flood Bond

So please protest any diversion of these funds away from flood mitigation.

By law, CSD must forward all comments received by Tuesday at 5 P.M. to the GLO and HUD for review.

So hurry. Email your comments NOW. It will only take five minutes.

Deadline: February 21 at 5PM.  

Email to: DRplancomments@csd.hctx.net

Below is a sample letter with key points to make. Feel free to cut-and-paste or adapt.

Sample Letter


To whom it may concern:

I strongly protest the outline that Harris County Community Services presented to the GLO for the distribution of $750 million in HUD CDBG-MIT Harvey flood-mitigation funds.

Since adoption of Harris County’s Equity Prioritization Framework, the County has been funneling 2018 Flood Bond money and other local funds to projects in high LMI and SVI areas. 

Now, however, without all of the $750 million going to flood mitigation, there likely won’t be enough money to finish all of the defined flood-bond projects that voters approved by 88% in 2018.

Therefore, I suggest:

  1. The entire $750 million should go to Harris County Flood Control District to complete unfunded flood-mitigation projects in the bond. 
  2. Earmark half that money for projects in watersheds with more affluent residents (less than 50% LMI) who have been largely ignored until now.
  3. Prioritize projects by:
    • The number of damaged structures during Harvey
    • Depth of flooding during Harvey
    • Remaining, unmitigated flood risk
    • Ability to reduce threats to infrastructure, such as bridges, schools, hospitals, and sewage treatment plants.
    • Lack of previous flood-mitigation investment in watershed
  4. The County, GLO and HUD need to be fair to all people of Harris County as HUD’s rules allow. Half of the flood-mitigation funding in Harris County since 2000 has gone to just four watersheds (Brays, Greens, White Oak, and Sims). Other areas have needs, too.
  5. CSD should present a detailed plan and stick to it. Vague generalities invite suspicion and undermine trust in government. 
  6. Ensure transparency. Harris County CSD has a poor record of transparency and website updates. Create a dashboard that publicly displays:
    • Encumbrances
    • Spending to date on every project
    • Who gets how much money, when, for what
    • Each project’s progress 
    • Monthly updates
  7. The MOD should include guarantees that the county will meet performance deadlines. Because of the 20 months already squandered since the County became aware of the $750 million, I question the county’s ability to spend the money by HUD’s deadline.

Thank you for considering these thoughts.


Don’t forget to add your contact information so Community Services can tell the General Land Office and HUD where the comment came from.

More Information

The GLO has emphasized the need for Harris County to act quickly. Flood Control has projects already defined that need money. HUD will take the money back if local authorities can’t spend the money within deadlines. So hurry. These projects take a long time. HCFCD has already defined projects in the flood bond. We can’t afford the time to start from scratch to figure out the distribution of $750 million in HUD Flood-Mitigation funds.

For more supporting information, including charts and graphs that you can use to create a custom letter, click here.

Posted by Bob Rehak on 2/20/23

2001 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.

HCFCD Updates Show Continuing Bond Slowdown

A Harris County Flood Control District (HCFCD) year-end spending report shows a continuing bond slowdown. The most recent spending update to Commissioners Court reflects all activity through the end of 2022.

The big news to report is that there’s not much news to report.

The December update showed that the San Jacinto Watershed received only $76.6 thousand during the month, ranking it 15th among all Harris County watersheds. HCFCD has only spent 2.5% of all bond money spent to date in the entire county.

A separate Biannual Update shows that the paltry progress is NOT the result of available funds. The San Jacinto has about $167 million in committed funding, but has received less than $30 million from the bond so far.

But before we dig deeper into the San Jacinto, let’s look at the continuing bond slowdown in Harris County as a whole.

December Overview

Compared to November 2022’s update, the December 2022 update shows that HCFCD:

  • Has spent a total of $1.177 billion to date, up from $1.150 billion at the end of November, a $27 million increase.
  • Bought out 27 homes countywide.
  • Secured another $30 million in funding ($1.734 billion up from $1.704).
  • Saw no change budgeted active capital construction projects ($0.00, likely a reporting mistake).
  • Saw no change in budgeted active maintenance projects ($0.00, likely another reporting mistake).
  • Awarded just one construction project worth $7 million.
  • Saw its schedule performance index dip below 1.0 for 11 months in a row. (1.0 means on-schedule).
  • Completed another 0.3% of the bond, bringing the percent completed up to 24.1% with 43.3% of the time elapsed.
  • Still has NO active construction projects in the lone Republican-led precinct. All 18 are split among three precincts with Democratic commissioners.

Reporting Mistakes

Regarding those goose eggs under “active projects,” it appears that someone just picked up the active projects pages from November and changed the dates to December. However, the HCFCD website does show figures updated through January 2, 2023. Using those as the most current figures instead would mean:

  • The total budgeted for active maintenance projects FELL from $50.6 million to $37.2 million, a decrease of $13.4 million.
  • Likewise, the total budgeted for active capital improvement construction projects FELL from $239.8 million to $223.5 million, a decrease of $16.3 million.

I’m not sure which is worse. Zeros, decreases, or errors?

Continuing, Prolonged Slowdown

Another major concern is the continuing lag in the Schedule Performance Index (SPI). This is a measure of on-schedule performance. Temporary decreases can often happen between projects. However, HCFCD has fallen behind schedule and stayed behind for 11 months in a row. The last time it reported an SPI of 1.0 was in January of 2022.

At the current rate of spending, it will take HCFCD more than 20 years to finish the bond.

Slow performance means we all live with flood risk longer than necessary and pay higher flood-insurance premiums than necessary.

For all of last year, HCFCD averaged between $20 and $23 million per month in spending.

Compiled from HCFCD monthly updates.

Under previous leadership, HCFCD averaged $35 million per month and the rate was climbing, not falling.

Spending By Watershed During December

The table below shows spending in all 23 Harris County watersheds plus countywide spending for the month of December 2022 (in the “Difference” column). HCFCD reported a decrease in Countywide spending with no explanation. The District also shows NO spending at all in three watersheds.

Compiled from HCFCD Bond Updates from November and December of 2022.

The San Jacinto Watershed is the county’s largest. Floods have damaged more structures in the San Jacinto than in all but seven other watersheds. The damage total includes five major storms since 2000 – Allison, Tax Day, Memorial Day, Harvey, Imelda.

Yet the San Jacinto has received only 2.5% of total flood-bond spending through 2022, ranking it #15 on that scale.

To date the San Jacinto has received only 13% of the $223,256,195 allocated to it in the bond. Compare that to 79% for the Brays Watershed and 75% for the Greens.

Commissioners Court Agenda Also Shows Slowdown

HCFCD has only 11 items on the Commissioners Court agenda for Tuesday, February 21. Contrast that with engineering which has 108.

And few of HCFCD’s requests involved new flood-mitigation work.

  • Four items transitioned projects to HCFCD’s maintenance program.
  • Four items involved contract changes.
  • One involved a permit for a MUD doing environmental enhancement work.
  • One would let Pasadena build recreational facilities on HCFCD property.
  • One would reimburse Union Pacific for a preliminary engineering study that UP was doing to relieve repetitive flooding along Halls Bayou adjacent to its railroad tracks.

Bi-Annual Bond Update

For additional information on the progress of the bond, see this Bi-Annual Update issued by HCFCD in January. It contains dozens of spending breakdowns. Especially interesting are the funding-gap calculations on page 11. See table below.

From HCFCD’s Jan. 2023 2018 Biannual Report.

Note that the table above shows different “actual spending to date” figures than the monthly updates farther above.

Regardless, these figures show that lack of funding is NOT responsible for the slow progress in the San Jacinto Watershed. The San Jacinto has $167 million dollars in committed funding. We’re just not spending the money.

Political priorities, not funding availbility, are the reason for the continuing bond slowdown – at least in the San Jacinto watershed. Spring Creek residents are way behind, too.

Posted by Bob Rehak on 2/19/23

2000 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.

How to Find the Best Option to Mitigate Floodprone Structures

How do you find the best option to mitigate floodprone structures? What will work best in your particular situation? FEMA discusses many different options in an interesting brochure titled “Selecting Appropriate Mitigation Measures for Floodprone Structures.”

The intended audience is for state and local officials. But don’t let that scare you. This brochure can also help home- and business owners think about their options, the pros/cons of each, their relative costs, and suitability for a particular location.

The first part of the 198-page document deals with how to use something called FEMA’s National Tool. It collects information from a variety of different sources. Planners use the data to create a “scorecard” that helps rank the alternatives.

Flood-Mitigation Alternatives Discussed

The major types of alternatives discussed in the brochure include:

  1. Drainage Improvements
  2. Barriers
  3. Wet Floodproofing
  4. Dry Floodproofing
  5. Elevation
  6. Relocation
  7. Acquisition (Buyouts)

Helpful Screening Questions

Chapter 3 contains a variety of screening questions designed to help determine the “fit” of each option for a particular location. For instance, to name a few, “What is the…”

  • Structure type
  • Condition of the structure
  • Foundation type
  • Number of stories
  • Building footprint

Example of Material in Typical Chapter

The meat of the discussion starts after that. The document contains a chapter on each of the seven major options and sub-options within them.

At a minimum, these chapters explain how flood professionals are trained to evaluate options and make recommendations in your situation.

While FEMA’s text is aimed at professionals, it’s well written, clear, and easy to understand. I won’t elaborate on each chapter, but will give you an example – Chapter 5: Barriers.

Levees and walls, two of many barriers against flooding discussed in Chapter 5.

Other sub-options include berms and temporary barriers (inflatable, floatable, and water filled).

Advantages:

  • They keep floodwaters out of the house and prevent flood damage
  • They require no significant changes to structures.

Disadvantages:

  • Barriers may not bring a substantially damaged structure into compliance with local floodplain management ordinances
  • Cost may be prohibitive
  • Large area needed for construction
  • Need for maintenance
  • Can affect local drainage, making flooding worse for others.

Whether they’re suitable in your situation will depend on:

  • The depth of flooding
  • Height of the barrier needed
  • Local building codes
  • Type of foundation (i.e., these don’t work well with basements)
  • Soil conditions (load-bearing capacity and permeability)
  • Duration of floods
  • Costs
  • Requirements for human intervention
  • Annual maintenance
  • Access to structure during normal times
  • Escape from structure if barrier is overtopped during an extreme event
  • Interior drainage (what happens if water starts filling in behind the barrier)

The brochure contains lucid and thought provoking discussions on each of these issues. If you start exploring such barriers, this brochure will help you plan discussions with contractors.

Highly Recommended

And so it goes for each of the other major types of mitigation found in other chapters. This is a valuable resource for anyone considering a major investment. It won’t help you make a final decision. But it will help you make a more intelligent decision.

So if you’re trying to find the best option to mitigate floodprone structures, click here.

Posted by Bob Rehak on 2/18/2023

1999 Days since Hurricane Harvey