Should Already Lopsided Flood-Mitigation Spending Tilt Even More Toward LMI Neighborhoods?

Tomorrow, Harris County Commissioners Court will consider a proposal that could shift even more flood-mitigation dollars toward Low-to-Moderate Income (LMI) neighborhoods. Harris County has 23 watersheds. Eight have a majority of LMI residents; the other 15 have a minority.

For years now, certain Commissioners have argued that poorer watersheds should get more help because their residents are financially less able to recover from floods. But none has ever said what a fair split should be. They just incorrectly assert that rich neighborhoods like Kingwood get all the money to justify shifting even more money toward poorer neighborhoods.

Where Money Really Goes

So let’s look at where the money is really going. Via a Freedom of Information Act (FOIA) request, I obtained Harris County Flood Control District (HCFCD) spending data by watershed dating back to 2000. The numbers below go through the end of the third quarter this year.

LMI Watersheds Already Receive 61% of All Spending

Because of damage patterns during floods and “equity guidelines” established by Commissioner’s Court, eight LMI watersheds have received 61% of all flood-mitigation spending since 2000. Fifteen other watersheds cover twice as much area but receive only 39%.

LMI = residents earning less than half of average income for region. An LMI watershed is one where more than half the residents qualify as LMI.

But the lopsided spending is even more dramatic when you look at the distribution within the LMI category. Just four watersheds have received more than half of all spending since 2000.

Spending by watershed since 2000. Includes HCFCD plus partners.

The top four LMI watersheds alone (Brays, White Oak, Sims and Greens) have received 53% of all flood-mitigation spending since 2000 even though they comprise just one quarter of the square mileage in the county.

HCFCD spending data through end of q3 2021.

Proposed Changes in Allocation Formula Could Accelerate Spending in LMI Watersheds

In June, commissioners voted to eliminate flood risk reduction as a “weighting factor” in the allocation of flood-bond funds.

The changes being considered tomorrow would let projects in poorer neighborhoods move forward immediately before the status of $750 million in HUD funding becomes clear – reportedly in January. They would also let flood-bond money be used to cover street flooding, something never contemplated in the flood-bond project list and something that is not part of HCFCD’s charter.

These changes could ultimately leave projects in more affluent watersheds without enough money to complete them. For a fuller discussion of the impacts, see this post. What’s Fair?

As certain commissioners seek to increase spending in LMI neighborhoods even more, the question arises: “Are others getting their equitable share?” I’ve asked that question many times and can never get an answer. I’m always met with silence. Regardless, tomorrow, certain commissioners will try to tilt the scales even further. I’ll be watching to see how they try to justify it.

You can watch the meeting live at https://www.harriscountytx.gov/Government/Court-Agenda/Court-Videos.

To comment on the proposal (Item 17 on the agenda), you must sign up to speak before 10:00 a.m. on Tuesday, December 14, if you attend the meeting in person. If you attend virtually, you must sign up to speak no later than 8:00 a.m. at https://appearancerequest.harriscountytx.gov/. If you sign up to speak, you will be placed in a queue and called when it is your turn.

Posted by Bob Rehak on 12/13/2021

1567 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.

Mitigation Spending Correlates Even More Strongly with LMI Population than Damage

12/11/2021 – Data obtained via a Freedom of Information Act Request shows that four Harris County watersheds – those with the highest low-to-moderate income (LMI) populations – have received more flood mitigation spending than all other 19 watersheds combined since 2000.

Recent Harris County Flood Control District (HCFCD) figures show that the size of an LMI population in a watershed correlates more highly with mitigation spending than even damaged structures. Previously, I coined the phrase “funding flows to damage.” That’s still true, but the number of LMI residents in a watershed now correlates even more strongly.

The latest spending data through the third quarter of 2021 also debunks the myth that flood mitigation projects always go to neighborhoods with the highest home values.

How Correlation Works

Correlation is not causation. A coefficient of correlation indicates the strength of a relationship between two variables. In a perfect correlation (1.0), every unit of change in one variable produces a proportional amount of change in a second variable. Variables move together by the same percentage and direction 100% of the time. But in real life, one rarely finds perfect correlations. However, these come close. Statisticians consider them very strong.

Funding Correlates Strongly with Both LMI Population and Damage

Dollars spent on mitigation have the following coefficients of correlation:

  • .93 for LMI population by watershed
  • .84 for structures damaged in five major storms

The storms included Allison, Tax Day, Memorial Day, Harvey and Imelda. Spending included HCFCD and partner dollars from 1/1/2000 through 9/30/2021.

You would expect mitigation spending to correlate highly with damage. After all, no one spends money to fix areas that didn’t flood. And the most attention would be focused on areas that flooded the worst. So they vary closely in the same direction.

But why does flood mitigation spending correlate so strongly with LMI population? That’s less expected.

Hypothesis to Explain High LMI Correlation

Observation suggests that LMI households tend to be in older neighborhoods often built to lower standards. For instance, homes tend to be closer to street level.

Moreover, in Houston, these neighborhoods tend to have roadside ditches rather than storm sewers. And those drainage ditches tend to fill in with silt over time, trapping water in neighborhoods.

Population density is also literally twice as high in LMI watersheds compared to affluent ones (3,947.11 people per square mile for watersheds above 50% LMI vs. 1,831.52 for watersheds below 50% LMI). So homes tend to be closer together, have a higher percentage of impervious cover, and crowd floodplains. Said another way, more people live in harm’s way.

Brays Bayou is a good example. It has the largest LMI population, the highest density and the most damage. It has received the most flood mitigation money since 2000 – $544 million or $158 million more than any other watershed.

At the opposite end of the spectrum, Luce Bayou has the smallest population and suffered the least damage. It received the least flood mitigation spending – only about 1% of Brays’ total.

LMI neighborhoods also tend to be in areas (inside the Beltway) surrounded by more upstream development. When developers built those older neighborhoods, they probably weren’t expecting the Houston Metro Area to explode from 700,000 people in 1950 to almost 7 million today.

We also didn’t know as much about flood mitigation in 1950. We didn’t force upstream developers to build detention ponds and didn’t reserve rights of way for future channel expansion. (Or at least not as much as we needed.)

Buying that additional right of way typically costs almost as much as construction – even more in densely populated areas. White Oak Bayou, for instance, has the third highest population and the fourth highest population density. Out of the $386 million it has received since 2000, a whopping 61% has gone toward right-of-way acquisition and 20% toward construction.

As a result of all these complex historical factors and dependencies, LMI population, damage and flood-mitigation spending tend to co-vary. That’s the best explanation I can offer.

In Harris County, Mitigation Spending Favors Low-, Not High-Income Areas

The narrative often heard in commissioners court is that higher home values increase the benefit cost ratio (BCR) for flood mitigation projects and that FEMA favors the highest BCRs. Those, in turn, theoretically favor mitigation projects in affluent communities. But that argument ignores:

For proof positive, see the charts below.

Brays, White Oak, Sims and Greens all have the highest LMI populations. And all have received the most flood-mitigation dollars since 2000. In fact, those four LMI watersheds alone received more money than all other 19 watersheds combined.

Watersheds with large low-income populations tend to cluster on the left; those with high-income on the right with a few exceptions.
Spending since 2000 for each Harris County Watershed shown with watershed’s LMI Population

To me, this debunks the myth that having less-expensive housing disadvantages some areas. In Harris County, density, public policy and other factors more than compensate for any influence home values exert on BCRs and the allocation of flood-mitigation dollars.

Posted by Bob Rehak on 12/11/2021

1565 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.

New County Administrator Moves to Modify Formula for Allocating Flood–Bond Spending – Again

The new county administrator, David Berry, put an item on the Commissioners Court Agenda for next Tuesday that would modify the formula for allocating flood-bond spending among watersheds – again. Item #21-6881 (17th on the agenda) reads: “Request for discussion and possible action to modify the previously adopted “Prioritization Framework for the Implementation of the Harris County Flood Control District 2018 Bond Program” (Prioritization Framework).”

First Change in Flood-Bond Spending Priorities

Commissioners adopted the “Equity Prioritization Framework” in 2019, a year after the flood bond passed. That was the first change.

At the time, Judge Lina Hidalgo and Commissioner Adrian Garcia swore that the guidelines would only affect the ORDER in which Harris County Flood Control District (HCFCD) initiated bond projects and that they would cancel no bond projects.

Second Change in Priorities

Then in June this year, Commissioner’s Court changed the “weight” given to elements in the flood-bond spending formula when they created the Flood Resilience Trust. They created the Trust with money from other departments, such as engineering and toll roads, so that low-income watersheds wouldn’t have to wait on HUD funding (which isn’t guaranteed).

Changes included eliminating flood-risk reduction from consideration (formerly 25% in original formula). They also eliminated “existing conditions” as a weighting factor (formerly 20%). So for instance, if a creek near you flooded every other year and someone else lived near a creek that only flooded every 25 years, that risk would be eliminated from comparison for funding purposes.

Third Change in Priorities Attempted

Later, in October, as part of the redistricting process, Adrian Garcia attempted to shift money from part of his old district to a new area that he would inherit. The switch would have deprived Cedar Bayou of $191 million in previously allocated flood-bond funds. Luckily Commissioner Cagle reminded Judge Hidalgo of her promise and she voted with Republicans on that issue to defeat it.

Although Garcia lost that particular motion, before the debate ended, he made a demand – that HCFCD address flooding in the 500-year flood plain, not just the 100-year. This is a complex issue. Usually, homes flooding OUTSIDE the 100-year floodplain – on less than 100-year rains – indicates local (street) drainage systems are deficient.

Such flooding is a common complaint in large parts of Northeast Houston. See the reason why below.

I photographed hundreds of ditches like these while driving around NE Houston for an entire day in June this year.

HCFCD doesn’t build or maintain street drainage systems. That is the job of cities and precinct commissioners. Flood-bond spending was never intended to cover such repairs. So now, if flood bond money is forced to stretch to cover them, something else must give.

Garcia’s demand was really a veiled attempt to have flood-bond spending cover part of his budget. And in fact, that demand showed up in the…

Fourth Potential Change in Priorities

In my opinion, this latest proposal has the potential to cancel projects and shift money between watersheds. However, Berry’s office does not address either of those possibilities in backup materials provided to Commissioners and the public.

Here is the entire text of the proposal sent to commissioners by Berry. And here is some backup documentation.

Berry says of the changes to the equity framework, “We are proposing a number of modifications to improve the Framework to more effectively and more equitably allocate money from the Flood Resilience Trust, as well as to help prioritize new projects not included in the 2018 Bond Program.”

Key changes include:

  • Placing greater emphasis on the number of people that a project benefits.
  • Excluding partnership funding
  • Addressing flooding both inside and outside of the mapped 100-year floodplain

Here’s my take on these.

Number of People

While it’s always good to help the greatest number of people possible, in Harris County, most people live inside Beltway 8. That places areas outside Beltway 8 at a disadvantage – especially those in rapidly growing areas, for instance near the Grand Parkway.

It also places emphasis on flood mitigation at the expense of flood prevention. In that sense, it emphasizes short-term as opposed to long-term gains.

As the Grand Parkway builds around to the east, we have only to look at flooding on the west side to see the future on the east. This measure, if adopted, would be like a doctor who only treats disease and ignores disease prevention. Both are important.

Harris County’s Frontier program is currently buying up land on the periphery of the county in the Little Cypress Creek watershed in an attempt to prevent rapidly developing areas from inundating current residents downstream. We could use more of that! It’s much less expensive and more humane in the long run than waiting until after people flood to do something.

Excluding Partnership Funding

Approximately half of total flood-bond spending relied on Partnership Funding from sources such as FEMA, HUD and the Texas Water Development Board.

Voters actually only approved $2.5 billion in flood bonds. Officials at the time counted on another $2,389,261,250 in partner funds (grants) to complete the list of flood-bond projects. However, if this motion passes, we will no longer consider potential HUD funding. We’ll just pay cash out of the flood bond or flood resilience trust for projects in low-income neighborhoods, some of which have a 90% match for a 10% local share. Then, when the $2.5 billion runs out, the people with uncompleted projects (those that started last) won’t even be eligible for HUD funding, because they don’t live in low-to-moderate income neighborhoods with a high social-vulnerability index.

Basically, Berry’s proposal could increase out-of-pocket costs up to 9X for a large portion of the flood bond.

Inside AND Outside 100-year Floodplain

As previously mentioned, there’s not enough money in the flood bond to shift responsibility for street flooding to HCFCD, Even with the flood-resilience trust. Something has to give.

That something will likely be projects that are still in the study phase where right-of-way acquisition and construction have not yet started. Hmmm. Guess who that is!

Where Will Extra Money Come From?

Berry maintains at the end of his proposal that all of the projects in the bond have already started. True dat! But he also says that the new guidelines will determine how the flood resilience trust is used, without mentioning the potential shortfall in that.

A spokeswoman for the GLO said she expects HUD to rule on $750 million in grants to Harris County in January. That could make all of this juggling a tempest in a teapot. So why the rush?

Belly Laugh of Day

Mr Berry also proposed a new “Open Data Policy” for the County under the guise of providing more transparency (Agenda Item #20).

He provides three pieces of backup to explain it:

Legislation Text – which doesn’t contain the text of the proposed motion.

Legislation Details WITH Text – a duplicate of the file above.

Legislation Details – a blank page. See below.

Text of new County Administrator’s proposed legislation on “open data,” AKA transparency.

As if to underscore Mr. Berry’s commitment to transparency, he has placed yet another item on the Agenda – #119. It would take $20 million out of the flood resilience trust for engineering studies for projects that he considers high priorities. But he never describes what the projects are. Nor does he disclose who would get the $20 million.

So much for transparency!

Posted by Bob Rehak on 12/10/2021 based on the agenda for the next Harris County Commissioners Court meeting.

1164 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.