This proposal attempts to establish new rules for the Equity Prioritization Framework adopted by commissioners in 2019 and changed several times since. These new rules were provided to Task Force members only within the last few days even though the document is dated December 14, 2021, more than a month ago.
The rule changes apply mostly to the distribution of Trust Fund money established to supplement the flood bond if partner funding did not materialize as expected. However, the proposed changes could affect the distribution of flood bond funds that voters approved by 86% in 2018.
Proposal #1:
Place more emphasis on number of people, using structures as a proxy for people. Benefit = efficiency.
Observation:
This may disadvantage LMI neighborhoods as those projects tend to cost more and the neighborhoods have more apartments. They also have large numbers of homes crowding channels and floodplains. So, buyout costs will be higher. And historically, buyouts cost almost as much as construction. Also, apartments cost far more than single family homes. We need time to look at data on this.
Proposal #2:
Potential partner funding should not be considered in prioritization for use of trust funds.
Observation:
What if you could make trust fund dollars go nine times further? Typically, HUD grants require only a 10% match.
Proposal #3:
Use trust funds for projects, like street flooding, not even mentioned in the bond.
Observations:
The County proposes using FEMA damage data back to 1977 to determine “Existing Level of Service.” This is a blatant attempt to tilt the playing field toward the inner city. In 1977, Beltway 8 and Intercontinental airport were still under construction. US59 was a 2-lane blacktop road. Outlying neighborhoods like Kingwood barely existed. This makes it impossible for any outlying neighborhoods to qualify for help with Trust Funds.
Choosing 1977 as the starting point ignores 45 years of flood mitigation spending totaling approximately $5 billion.
We don’t have enough money in the trust fund to complete all the bond projects. So, if we spend trust fund money on projects not in the bond – without partner help – it will mean cancelling bond projects somewhere else.
Implementing this proposal will make it very difficult to get voters to approve future flood bonds.
Street flooding is often caused by blocked drains. Rains can’t get to channels and streams. Fixing ditches has historically been the job of cities and precincts. HCFCD funds have focused on channels and streams. Street ditches were never mentioned in the bond.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/01/MultiBlockages.jpg?fit=1440%2C960&ssl=19601440adminadmin2022-01-19 10:46:072022-01-19 16:01:41Harris County Making Another Attempt to Shift Flood Mitigation Funds
Lakewood Cove residents reported yesterday and today that contractors at the Laurel Springs RV Resort are pumping stormwater from their detention pond into Precinct 4’s Edgewater Park. The reports are true. And it’s a permit violation.
I also found contractors bringing in fill from the outside that I thought was going to be “cut” from the detention pond. All photos below were taken on 1/18/22.
Pumping From Pond onto Neighboring Property
The approved permit plans clearly state that “Stormwater runoff shall not cross property lines.”
Stamp on many pages of approved Laurel Springs RV Resort plans.
I guess at some point the water in the pond ceased being runoff. Now it’s just a nuisance. The plans said pond water would be pumped into the City storm sewers. Hmmmm.
Photographed from Laurel Springs Lane looking west.
Here’s an aerial photo looking toward Laurel Springs Lane.
Check out all the muck being washed into the woods. Those woods belong to Harris County Pct. 4. That’s part of new Edgewater Park.
Note the lack of silt fences in the two photos above. Plans clearly state that silt fences will be installed to keep silt from escaping the property. Double Hmmmm!
Bringing in Fill instead of Moving It From Within the Site
As I photographed the pumping, I noticed a parade of dump trucks bringing in fill, dumping it, and leaving as a bulldozer spread it out and another machine quickly compacted it.
Looking NW toward Lowes in top center. Note dump truck depositing fill – one of many that I watched.The area where they deposited fill just north of the pond corresponds to the plans. See below.
From text on the image above, I assumed that the job was to be a routine “cut and fill” operation. Maybe I shouldn’t have assumed.
Cut and Fill is an industry standard in floodplains. It means you move dirt from one part of the site to another. So, there is no additional fill brought into the floodplain. The fill area above appears to be in the .2% annual chance floodplain, according to the old FEMA map below. However, the developer did not mark the .2% chance floodplain on plans.
FEMA floodplain map. Aqua = 1% annual chance. Brown = .2% annual chance.It appears the northern part of the detention pond (not shown on this old satellite image) cuts between the aqua and brown areas.
For the record, Chapter 19 of Houston’s Code of Ordinances currently does not prohibit bringing fill into the .2% annual chance floodplain. See Section 19.34.
Posted by Bob Rehak on 1/18/2022
1603 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/2022/01/20220118-DJI_0490.jpg?fit=1200%2C799&ssl=17991200adminadmin2022-01-18 20:33:432022-01-18 20:40:31RV Resort Pumping Stormwater Into Edgewater Park, Bringing in Fill
Here’s a regulatory update on the synchronization of flood regs in cities and counties throughout the region.
Harris County can spend billions on flood mitigation, but if upstream communities keep sending more water downstream, we may never see improvement. That’s why Harris County Flood Control and Harris County Engineering launched an initiative to harmonize regulations in 2020. The program is still active but has had mixed results to date.
The departments identified five key measures that they asked surrounding cities and counties to implement:
Use Atlas 14 rainfall rates for sizing storm water conveyance and detention systems.
Require a minimum detention rate of 0.55-acre feet per acre of detention for any new development one acre or larger. However, a single-family residential structure and accessory buildings proposed on an existing lot is exempt from providing detention.
Prohibit the use of hydrograph timing as a substitution for detention on any project unless it directly outfalls into Galveston Bay.
Require no net fill in the current mapped 500-year floodplain, except in areas identified as coastal zones only
Require the minimum Finished Floor Elevation (FFE) of new habitable structures be established at or waterproofed to the 500-year flood elevation as shown on the effective Flood Insurance Study.
The county used partnership agreements as a lever. Communities/counties that didn’t update their regulations were not eligible for partner funds from the flood bond. The pitch worked well in some cases, partially in others, and not at all in a few.
Where Adoption Stands
The table below shows where things stand in different communities. The three columns represent those who:
Already finished upgrading regulations to minimum standards.
Identified updates but have not yet made them
Have not taken any action to update their ordinances or regulations.
Cooperation status as of December 2021
EHRA is an engineering company working with Harris County to analyze current regulations and identify which areas need updates. In the last column, municipalities/counties either didn’t respond, chose not to participate, or refused. Waller, Brazoria County and Galveston County did not respond. Montgomery County said it would not participate. The other four didn’t request the free EHRA analysis when offered.
According to the Harris County Engineering Department, an analysis only takes a month. And some cities have updated their regulations within a month of completing the analysis.
In fairness, it’s important to note that some jurisdictions, such as Montgomery County, have adopted Atlas 14 standards, even if they haven’t adopted the other recommendations.
Ways to Help
Please help address the holdouts. Do you know influencers in communities that have not yet updated their regs? Can you leverage industry connections willing to show support? Spread the word within your community? Generate some buzz online? Write an email to your county commissioner or judge? Enlist the help of friends or relatives in neighboring communities?
The further we get from the pain of Harvey and Imelda, the less motivated people seem to be to adopt regulatory reforms. So please act soon.
Posted by Bob Rehak on 1/17/2022
1602 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/2019/09/Elm-Grove-9.19_13.jpg?fit=1500%2C1000&ssl=110001500adminadmin2022-01-17 17:00:342022-01-23 18:04:00Post-Harvey Regulatory Update: Mixed Results to Date
Harris County Making Another Attempt to Shift Flood Mitigation Funds
Harris County is making another attempt to shift flood mitigation funds from outlying neighborhoods toward the city center. Here’s the latest proposal that will be considered by the Community Resilience Flood Task Force at a noon meeting today.
Key Concerns About Proposal
This proposal attempts to establish new rules for the Equity Prioritization Framework adopted by commissioners in 2019 and changed several times since. These new rules were provided to Task Force members only within the last few days even though the document is dated December 14, 2021, more than a month ago.
The rule changes apply mostly to the distribution of Trust Fund money established to supplement the flood bond if partner funding did not materialize as expected. However, the proposed changes could affect the distribution of flood bond funds that voters approved by 86% in 2018.
Proposal #1:
Place more emphasis on number of people, using structures as a proxy for people. Benefit = efficiency.
Observation:
This may disadvantage LMI neighborhoods as those projects tend to cost more and the neighborhoods have more apartments. They also have large numbers of homes crowding channels and floodplains. So, buyout costs will be higher. And historically, buyouts cost almost as much as construction. Also, apartments cost far more than single family homes. We need time to look at data on this.
Proposal #2:
Potential partner funding should not be considered in prioritization for use of trust funds.
Observation:
What if you could make trust fund dollars go nine times further? Typically, HUD grants require only a 10% match.
Proposal #3:
Use trust funds for projects, like street flooding, not even mentioned in the bond.
Observations:
How To Be Heard
Here is a presentation that the Community Resilience Flood Task Force will review at noon today. It provides a little more detail than the County Administrator’s description.
If this proposal concerns you, please send your comments to: CFRTFpubliccomment@gmail.com.
To view the meeting online, register at Cfrtf.harriscountytx.gov. It goes from 12-2 today.
Posted by Bob Rehak on 1/19/2022
1604 Days since Hurricane Harvey
RV Resort Pumping Stormwater Into Edgewater Park, Bringing in Fill
Lakewood Cove residents reported yesterday and today that contractors at the Laurel Springs RV Resort are pumping stormwater from their detention pond into Precinct 4’s Edgewater Park. The reports are true. And it’s a permit violation.
I also found contractors bringing in fill from the outside that I thought was going to be “cut” from the detention pond. All photos below were taken on 1/18/22.
Pumping From Pond onto Neighboring Property
The approved permit plans clearly state that “Stormwater runoff shall not cross property lines.”
I guess at some point the water in the pond ceased being runoff. Now it’s just a nuisance. The plans said pond water would be pumped into the City storm sewers. Hmmmm.
Note the lack of silt fences in the two photos above. Plans clearly state that silt fences will be installed to keep silt from escaping the property. Double Hmmmm!
Bringing in Fill instead of Moving It From Within the Site
As I photographed the pumping, I noticed a parade of dump trucks bringing in fill, dumping it, and leaving as a bulldozer spread it out and another machine quickly compacted it.
From text on the image above, I assumed that the job was to be a routine “cut and fill” operation. Maybe I shouldn’t have assumed.
Cut and Fill is an industry standard in floodplains. It means you move dirt from one part of the site to another. So, there is no additional fill brought into the floodplain. The fill area above appears to be in the .2% annual chance floodplain, according to the old FEMA map below. However, the developer did not mark the .2% chance floodplain on plans.
For the record, Chapter 19 of Houston’s Code of Ordinances currently does not prohibit bringing fill into the .2% annual chance floodplain. See Section 19.34.
Posted by Bob Rehak on 1/18/2022
1603 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.
Post-Harvey Regulatory Update: Mixed Results to Date
Here’s a regulatory update on the synchronization of flood regs in cities and counties throughout the region.
Harris County can spend billions on flood mitigation, but if upstream communities keep sending more water downstream, we may never see improvement. That’s why Harris County Flood Control and Harris County Engineering launched an initiative to harmonize regulations in 2020. The program is still active but has had mixed results to date.
Five Upgrades Recommended
The departments identified five key measures that they asked surrounding cities and counties to implement:
The county used partnership agreements as a lever. Communities/counties that didn’t update their regulations were not eligible for partner funds from the flood bond. The pitch worked well in some cases, partially in others, and not at all in a few.
Where Adoption Stands
The table below shows where things stand in different communities. The three columns represent those who:
EHRA is an engineering company working with Harris County to analyze current regulations and identify which areas need updates. In the last column, municipalities/counties either didn’t respond, chose not to participate, or refused. Waller, Brazoria County and Galveston County did not respond. Montgomery County said it would not participate. The other four didn’t request the free EHRA analysis when offered.
According to the Harris County Engineering Department, an analysis only takes a month. And some cities have updated their regulations within a month of completing the analysis.
In fairness, it’s important to note that some jurisdictions, such as Montgomery County, have adopted Atlas 14 standards, even if they haven’t adopted the other recommendations.
Ways to Help
Please help address the holdouts. Do you know influencers in communities that have not yet updated their regs? Can you leverage industry connections willing to show support? Spread the word within your community? Generate some buzz online? Write an email to your county commissioner or judge? Enlist the help of friends or relatives in neighboring communities?
The further we get from the pain of Harvey and Imelda, the less motivated people seem to be to adopt regulatory reforms. So please act soon.
Posted by Bob Rehak on 1/17/2022
1602 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.