Formula for Allocating Future Flood-Mitigation Funding Deceives

How do you fairly allocate flood-mitigation funds? Voters have argued about that since the day Harris County Commissioners Court redefined the conventional meaning of “equitable” with the first equity formula in 2019. Since then the formula has changed several times to ensure low-to-moderate income (LMI) areas continue to receive the lion’s share of mitigation funding, even as some commissioners claim LMI areas get none.

On 6/28/22, the Harris County Community Resilience Flood Task Force proposed yet another formula for allocating potentially billions of dollars in future flood-mitigation funding. It purports to objectively calculate the benefits received by different areas. But it doesn’t in any conventional sense. And therefore, the results can be deceptively counter-intuitive.

Problems With Formula

The formula shows increased benefit when:

  • Risk remains unchanged.
  • Costs increase.
  • Population decreases.

The formula is…

Benefit = Total Cost/(Population X Risk)

On July 2, 2022, I posted about a variety of issues that affect the validity of this formula. Admittedly, the post got complex. So let me give you two simple examples that dramatize these problems.

In each example below, I’ll hold two of the three variables constant. That makes it easy to see whether “benefit” varies in a predictable direction. And whether that matches what people expect when they hear the word “benefit.”

Cost Example

The value of “10” applied to Risk in each case represents a 10% annual chance of flooding.

If you hold risk and population constant, while increasing cost

  1. Population = 5000, Risk = 10 and Cost = $100,000, then Benefit = 2
  2. Population = 5000, Risk = 10, and Cost = $1,000,000, then Benefit = 20

…benefit increases by spending more without reducing risk! A taxpayer nightmare!

Population Example

If you hold cost and risk constant, while increasing population

  1. Population = 2000, Risk = 10, and Cost = $1 million, then Benefit = 50
  2. Population = 5000, Risk = 10, and Cost = $1 million, then Benefit = 20

…benefit decreases by helping more people with the same dollars! Again, counter-intuitive.

Both takeaways are confusing. What is this formula measuring?!

I would argue that, in a flood context, most people strongly associate the word “benefit” with “risk reduction.”

But this formula doesn’t measure risk reduction. And it doesn’t measure efficiency either. It measures per capita investment associated with a certain level of flood risk and calls that “Benefit.”

So, the more people you help with any given sum, the more the benefit goes down. Voila! That makes it look as though the highly populated watersheds (that have received the overwhelming majority of prior investments) have received little benefit. And that may be the point of this formula. It will send even more money to those same areas.

In logic, they call this the fallacy of incomplete evidence – more commonly known as cherry-picking. You cherry pick data that favors your argument and ignore the rest. For instance, consider the image below.

Brays Bayou at Calhoun, photographed May 2021. Note abundance of multi-story apartments.

The total population in some areas includes many people in tall apartment buildings or high-rises. For many of them, flooding may be more inconvenient than financially devastating. Yet the formula assumes all people suffer equally.

The formula provides the appearance of objectivity and fairness. But it masks important information by lumping everything into a single number.

But the proponents of this formula don’t even want to discuss numbers. They want to render the results as heat maps, layered with Social Vulnerability Index, LMI and other data guaranteed to mask and perpetuate the lopsided distribution of flood-mitigation funds.

Omitting Benefits to Structures

By defining Benefit as the cost per person to achieve a certain level of flood risk, the formula omits any benefit to structures. That’s the traditional way to define the benefit of a flood-mitigation project. You measure “the value of damages avoided.” Whether one person lives in a house or two people live there, the cost to protect those people and that home remains the same.

For instance, widening a channel can reduce flood risk for a house. But with the proposed formula, that home and its value no longer count – only the number of people living within it. So, doubling the number of people in a representative home cuts the Benefit of a flood mitigation project in half.

Conclusions

The formula is a vast oversimplification. It omits valuable information such as avoided damages.

It’s also confusing and semantically deceptive in that results vary in counter-intuitive directions.

Finally, as I previously posted, the formula is not valid. It masks several apples-to-oranges comparisons.

Yet the majority of the Community Resilience Flood Task Force proposes using it to help guide (potentially) billions in future flood-mitigation investments. That could hurt taxpayers, flood victims, future bonds and the credibility of local government.

The formula can deceive people into making bad flood-mitigation investments. But in this case, there’s no Securities & Exchange Commission to protect investors. Only the ballot box.

Posted by Bob Rehak on 7/6/22

1772 Days since Hurricane Harvey

Beginning of End for Last of Forest Cove Townhomes

Today, 7/5/22, marked the beginning of the end for the last of the three remaining townhome complexes on Marina Drive in Forest Cove. Demolition began at 4:45 this afternoon on the complex nearest the Forest Cove community center. The job foreman estimates that removal of the two complexes shown below could take a week or more. By then, the third complex nearest the Forest Cove swimming pool should also be ready for demolition. Back in mid-June, Harris County Flood Control scheduled it for demolition on 7/14/22. So by the end of this month, Forest Cove could look very different.

Pictures Taken 7/5/22

The two complexes that started undergoing demolition today. These back up to the new Houston Parks Board Trail that will connect Kingwood with Precinct 3’s Edgewater Park at the NE corner of 59 and the West Fork.

Hurricane Harvey destroyed the townhomes almost five years ago, when approximately 240,000 cubic feet per second of stormwater inundated the homes to the third floors.

The homes became structurally unsound as you can see below.

Destruction wrought by Harvey.

HCFCD began buyouts of the 14 townhome complexes in this area back in 2019. The District completed 80% of the buyouts by February 2020. They expected to complete the remainder by the end of that year. But completing the buyouts took much longer than expected. This story explains why. Basically, HCFCD cannot tear town a complex until it has bought out all units within the complex. And some owners had left the area without forwarding addresses.

First bite into the first of three remaining complexes late this afternoon.
The second bite took out the corner of the structure.
Demolition will resume in the morning.

Harvey destroyed these townhomes so thoroughly that FEMA chose to film a video about the power of Harvey here.

Once prized for their river views, seclusion, and laid-back lifestyle, the remaining townhomes will come down this month and then HCFCD will let the area return to nature. It’s not clear at this time whether the county has plans to extend Edgewater Park this far.

More pictures and news to follow as the project progresses.

Posted by Bob Rehak on 7/5/22

1771 Days since Hurricane Harvey

CWA Exploring Alternate Plan for Adding Lake Houston Dam Gates

Coastal Water Authority (CWA) recently posted minutes from its May 11th board meeting that reveal a possible new direction for adding more flood gates to the Lake Houston Dam. After months of discussing various crest gate alternatives to increase the release capacity of the dam, engineers will now focus on examining two tainter gate alternatives. One would add six tainter gates, the other twelve.

Neither alternative would modify the concrete portion of the spillway, as crest gates would. Black & Veatch, the engineering firm in charge of the project, will explore adding the tainter gates in the earthen embankment to the east of the existing spillway. See below, upper right.

Looking ENE at Lake Houston Dam. Black and Veatch is now exploring adding tainter gates to the earthen portion of the dam in the upper right.

The eastern embankment is a solid earthen area 2800 feet long east of the spillway and existing gates (see upper right of photo above). Water cannot get over it in a storm because it is so much higher than the spillway. By adding various structures in this area, engineers could widen the current spillway capacity, allowing release of more stormwater.

Tainter gates rotate up from a central pivot point. Crest gates rotate down from a bottom hinge, like a piano lid.

Minutes from May CWA Board Meeting

Item IV(B) on Page 3 of the May 11, 2022, minutes states, “…CWA, City of Houston (COH), and Black and Veatch (B&V) met on April 14, 2022. During that meeting the COH requested that an alternate gate location to the east of the existing gate structure be further [emphasis added] evaluated.”

Following the meeting, B&V developed a scope of work to update the gate concepts and construction costs for this area. The COH provided comments and B&V modified its proposal. B&V reportedly began work on the new direction by June 1.

Additional Funding Needed

Each of the new alternatives would require additional funding; neither fit within the existing budget, according to the CWA staff. COH Public Works will pay for the new evaluation.

Wayne Klotz, P.E. and President of the CWA Board, reminded everyone present that COH owns the dam and is the FEMA grantee for this project, while CWA works for and takes direction from COH.

Minutes from the June CWA meeting have not yet been posted. The last post about gates on the COH District E website was almost a year ago on July 8, 2021.

7/4/22 Screen Capture from District E Website.

However, City Council member and Mayor Pro Tem Dave Martin did take questions on the project at an April 2022 community meeting. At the time, Martin expected to have a final answer on gates in a “September-ish” time frame.

Based on costs of the Addicks and Barker dam modifications by the Army Corps, some remain skeptical of any alternative for adding gates to the dam. The reason: budget and the Benefit/Cost Ratio.

Currently, the release capacity of tainter gates on the Lake Conroe Dam is 15X greater than those on the Lake Houston Dam (150,000 cubic feet per second (CFS) vs. 10,000 CFS.)

Concept Studied and Rejected Once Already

Adding gates to the eastern embankment was one of the original concepts evaluated. (See Column 5, Offsite Alternative #2, Column 5, Page 4.) But engineers focused on adding crest gates instead, largely because the total estimated costs for adding tainter gates at that time exceeded $90 million for a $50 million budget. However, the Army Corps also had environmental concerns about adding gates to the eastern embankment.

FEMA initially gave the City three years to complete the project (18 months for engineering and 18 for construction). Engineering began in April 2020.

No other details about May’s change in direction have been released to my knowledge.

Posted by Bob Rehak on 7/4/2022 based on minutes from the May CWA Board meeting

1770 Days since Hurricane Harvey