A new flood-insurance rating system, designed to make rates reflect the true risk to an individual property will go into effect on October 1. FEMA calls it their Risk Rating 2.0 system. They describe it as Equity in Action. It’s FEMA’s attempt to put the National Flood Insurance Program (NFIP) on a sound actuarial footing and stop the system’s financial hemorrhaging.
“The new system moves away from basing price primarily on a handful of broadly drawn and often dated flood map zones,” according to the Pew Charitable Trusts. The new rates reflect “a more detailed set of factors, including proximity to and size of a water source, flood frequency and type (such as heavy rainfall or coastal erosion), ground and building elevation, foundation types, and drainage issues.”
Source: FEMA Presentation in MaapNext MeetingSource: FEMA Presentation in MaapNext Meeting
Sliding Scales not Price Brackets
“The more detailed analysis allows for prices that run along a sliding scale,” says Pew, rather grouping homes into brackets because they’re in the same mapped zone. Thus, low-risk homes will no longer be carrying the freight for high-risk homes.
Under Risk Rating 2.0, policyholders can save through mitigation activities such as elevating mechanical and electrical equipment above flood levels or installing flood openings.
Also, under the old system, all National Flood Insurance policy holders paid the same base rate. However, they could purchase additional insurance at substantially discounted rates. Thus, more expensive homes enjoyed an advantage over less expensive homes. But the new system will attempt to correct that imbalance.
Risk Rating 2.0 also gives policy holders savings for practical mitigation activities, such as elevating mechanical and electrical equipment above flood levels or installing flood openings.
So far, so good. Congress mandated the change to actuarily sustainable rates in 2012. At the time, people thought the rates would also help discourage development in flood prone areas.
A google search turned up many news stories about fears of massive rate increases. However, by law, most new rates may not increase by more than 18% per year, according to FEMA.
Gap Between Policies and Practice, At Least Initially
Still, several insurance companies have pointed out hidden inconsistencies between policy and practice in the new system.
A new artificial rate cap. Under Risk Rating 2.0, regardless of risk, policyholders will never pay more than $12,125 per year. This effectively creates a subsidy that encourages development in the most flood-prone areas.
Rates still do not align with risk. Current policy holders will not be penalized for any losses during the past two decades. That said, the artificially low rate will immediately increase to reflect actual risk after the first claim under Risk Rating 2.0. For a period at least, the NFIP provides no way for homebuyers to discover the flood-loss history of a structure.
Rate discounts unrelated to specific risk will continue. The NFIP’s Community Discount System will continue to provide community-wide premium reductions regardless of an individual property’s risk. These reductions impact more than 70% of NFIP policies and provide discounts of up to 45% to every structure in the community regardless of actual risk.
There are still no refunds for many policyholders who want to trade up. Once an NFIP policy has been in force for more than 30 days, the NFIP will not allow a refund to a policyholder who cancels an NFIP policy and replaces it with private coverage.
Pushback from Politicians
Several senators and congress people have complained about the new system and asked to delay the rollout to study impacts more closely.
The influential, Washington publication “The Hill” published a scathing op-ed of Risk Rating 2.0 in May. The author, Jainey Bavishi, director of the NYC Mayor’s Office of Climate Resiliency, felt that rising costs would force many to let flood-insurance policies lapse. She called the rollout “rushed.” She claimed, and I quote, the new policy “threatens to transform the National Flood Insurance Program from a financial lifeline into a crippling financial burden for thousands of low-income families in coastal cities.”
Phased-In Changes
Any change this massive was bound to cause political indigestion. FEMA has heard the criticisms and is trying to roll out the new system in a way that minimizes hardships. For instance, existing policies will be on an 18% “glide path” to their full risk rate. Said another way, FEMA will phase in the increases to make them more bearable. They will also give discounts for flood proofing, adding flood vents beneath homes, elevating homes and much more.
For policy holders in multi-floor apartment buildings, FEMA will now consider the actual floor you live on, not just quote a flat rate for everyone in a building. This should benefit renters who live on upper floors.
Timing
PHASE I
New policies beginning Oct. 1, 2021, will be subject to the new rating methodology. Also beginning Oct. 1, existing policyholders eligible for renewal will be able to take advantage of immediate decreases in their premiums.
PHASE II
All remaining policies renewing on or after April 1, 2022, will be subject to the new rating methodology.
Get a Quote From Your Insurance Agent
In its efforts to make pricing reflect true risk, FEMA will now consider many new data sources and variables. I reviewed an hour-long FEMA presentation on the subject. At the end, I was left with one overwhelming conclusion. Call your insurance agent. Your price may go down. It may go up. It costs nothing to get a quote. But the cost of NOT having insurance when you need it can break the bank as we saw during Harvey and Imelda.
1483 Days since Hurricane Harvey and 732 since Imelda
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/09/20210908-Screen-Shot-2021-09-08-at-4.24.22-PM.jpg?fit=1200%2C673&ssl=16731200adminadmin2021-09-20 15:51:182021-09-20 15:54:46New Flood-Insurance Rating System Starts October 1
For an engineering study, it’s exceptionally easy to understand and the recommendations were prophetic. It almost reads like a primer for flood control.
Recommendations of specific projects aside, the principal recommendations are as valid today as they were then. Had only someone acted on them.
Make sure you at least read Chapter 5: Conclusions and Chapter 6: Examination and Recommendation of Basic Design Criteria for Watershed. Together, they total just five pages.
Purpose of Upper San Jacinto Study
The Upper San Jacinto study had four main goals:
Develop a comprehensive stormwater drainage plan
Recommend specific improvements
Evaluate/compare alternatives
Provide drainage authorities with information necessary to control flooding.
Problems of Rapid Development in Flat Areas
The study begins with a discussion of the problems of rapid development in flat areas. The Upper San Jacinto Watershed covers 1200 square miles. It includes all of Montgomery County and parts of Walker, Grimes, Waller, San Jacinto, and Liberty Counties. For the purposes of this study, the Harris/Montgomery County line formed the southernmost boundary.
Seven major streams comprise the watershed: the West Fork, Lake Creek, Spring Creek, East Fork, Caney Creek, Peach Creek, Luce Bayou and Tarkington Bayou.
The topography changes from rolling hills in the north and west to flat coastal plains in the south and east. The lack of slope in the southern and eastern regions seriously affects the ability of streams to drain stormwater.
The authors warned that as development would move northward, hydraulic “improvements” would alter natural stream patterns by increasing flow velocities and reducing ponding.
Without sufficient retention, development can accelerate runoff, leading to faster, higher peaks that contribute to flooding.
Even before urban development, they said, channels in the Upper San Jacinto Watershed did not have adequate capacity to transport runoff from large storms.
In 1985, at the time of the report, less than 5% of the land area in the watershed was developed. The Woodlands was relatively new and still building out. The report warned that because of development, increases in impervious cover “will require a more efficient drainage system to collect and transport runoff.”
The report lauded the type of development in The Woodlands, where, “discharges are no higher today than they were years ago in the undeveloped stages.” However, the report also cautioned that “…with most of the current development in the southern and eastern extremities of Montgomery County, watershed flooding problems may be greatly enhanced by urbanization.”
The chapter which discussed planning said, “Right of way and reservoir land acquisition should occur while the land is open and available.” Sadly, with the exception of Lake Conroe, which had already been built, none of that happened.
Benefit/Cost Ratios of Regional Detention in Undeveloped Areas
The last advice sounds so simple, one wonders why no one acted on it. However, as I read through the economic analyses of alternatives (reservoirs, channel improvements, etc.), the reason became blindingly clear.
So few people lived in undeveloped areas in the Upper San Jacinto Watershed in 1985 that the annual flood damages are minuscule. For instance, there were only 39 structures in four Lake Creek floodplain areas that the authors examined. Annual damages totaled only $9,600. That made the Benefit/Cost Ratios (BCRs) for the various mitigation alternatives that they developed come out to less than .001 in some cases and .09 at most. Benefits equal costs at 1.0. So FEMA usually demands BCRs exceed 1.
But compare the cost of a reservoir then and now. In 1985, the authors estimated the total cost of a Walnut Creek reservoir (a tributary to Spring Creek) to be only $41,000,000. Today, the cost would be $132 million – more than 3X. But it would take many more homes out of the floodplain. So the BCR today could be 1.04 making the project doable (see page 44)…although much more expensive and much to late to help those who flooded recently.
To get around this problem, the Harris County Flood Control District started its Frontier Program. The program buys up land for regional detention ponds (those that serve multiple developments), and then resells detention capacity back to developers for future use. Because regional detention is usually more efficient than developers building individual detention ponds on their own, it can actually lower developers’ costs while protecting the public and conserving money long term.
Most High-Level Recommendations Still Valid
Page 43 of the 1985 report makes six high-level recommendations (apart from specific projects) that are as valid today as they were then.
Create a central agency to control, monitor, remedy and finance flood control for the entire watershed.
Control development within the 100-year floodplain and prohibit it in the floodway with laws and regulations.
Establish minimum building slab elevations in flood-prone areas.
Limit fill in the floodplain.
Develop procedures to follow when allowing floodplain development, i.e., not obstructing 100-year floods.
Develop specific criteria, procedures and requirements for downstream impact analysis to compare Development A with Development B, and to analyze their combined effects.
Regular readers of this site have heard many of these recommendations before. The surprise, if there is one, is that we haven’t adopted them all already or that we haven’t adopted them consistently. Even where recommendations have been adopted, they are enforced inconsistently.
For future reference, the 1985 report can also be found on the reports page under the SJRA tab.
Posted by Bob Rehak on 9/19/2021
1482 Days since Hurricane Harvey and 731 since Imelda
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/09/Screen-Shot-2021-09-19-at-1.24.59-PM.png?fit=1084%2C1198&ssl=111981084adminadmin2021-09-19 15:07:542021-09-25 18:48:421985 Upper San Jacinto Flood Control Study Prophetic, But Largely Unheeded
The Texas General Land Office (GLO) has announced that the public comment period for the first amendment to the state’s action plan for Community Development Block Grants for Mitigation (CDBG-MIT) will close in twelve days – on September 29, 2021. The GLO first posted the amendment to its $4.3 billion action plan on August 23rd.
Harris County essentially got shut out of the first round of grants last summer. This amendment would allocate $750 million to Harris County in the second round. That’s good as far as it goes, but Harris County needs more and the proposed amendment needs tweaks. Read more below.
Townhome destroyed by 240,000 cubic feet per second during Harvey.
Background
Earlier this year, the GLO held a statewide competition for approximately $1.1 billion in Harvey flood mitigation funds. Harris County received none, despite being one of the most heavily populated and impacted counties in the state.
A public uproar ensued. GLO Commissioner George P. Bush then agreed to commit $750 million to Harris County for the second round of funding.
The amendment also obligates the county to define a method of distribution (MOD) for that money within US Department of Housing and Urban Development (HUD) rules.
The amendment is based on a Method of Distribution (MOD) program. It makes the GLO the direct recipient of HUD funds and Harris County a sub-recipient.
Harris County must define the MOD plan to allocate funds to eligible entities within rules defined by HUD.
Eligible entities include:
Local governments (cities/towns)
Special purpose districts (MUDs/improvement districts/drainage districts, etc.)
Ports
River authorities
GLO encourages prioritization of projects that meet regional mitigation needs.
Harris County’s MOD plan must benefit at least 50% LMI (low-to-moderate income) residents.
Eligible activities include:
Flood control and drainage improvements
Infrastructure improvements
Natural or green infrastructure
Communications infrastructure
Public facilities
Buyouts
Relocation assistance to outside of floodplains
Public service (housing, legal, job, mental health and general health counseling with a 15% cap)
Economic development
Elevation of critical structures
Planning (5% cap)
Ineligible activities include:
Emergency response services
Enlargement of a dam or levee
Assistance for privately owned utilities
Improvement of buildings used by government
Funding USACE projects in excess of $250,000
Projects involving use of eminent domain that benefit private parties
Buyouts
Have their own guidelines which are too complicated to summarize here.
Timeline
The clock starts ticking 4 months after HUD’s approval of Amendment #1.
50% of the grant must be expended by Jan. 12, 2027.
100% must be expended by January 12, 2032.
Experts say all this time may be needed given the complexity of navigating HUD processes, which are lengthier than other sources.
Discussion/Recommendations
Harris County and the Flood Control District support the amendment. It is certainly justified by the number of people in Harris County and the amount of damage inflicted by Harvey.
However, $750 million is not enough. A fairer amount would be closer to $1 billion. As the action plan points out, approximately one third of Harris County went under water during Harvey.
Alan Black, interim executive director of the Harris County Flood Control District, points out several other reasons for increasing the allocation:
The City of Houston has still been left out. Flooding in Harris County has a dual nature. “You can address the rivers and channels,” he says, “but if water can’t get to the bayous, people will still flood when water ponds in neighborhoods. Both riverine and street flooding must be addressed together.”
Black also points out that administrative fees are capped at 6%, but with HUD compliance costs, 8% is more realistic. Moreover, those administrative costs must come out of the $750 million – they are not on top of it. So the real amount of money available for flood mitigation would be reduced to about $690 million.
Finally, the Amendment also allocates approximately $450 million to Houston/Galveston Area Council, much of which would go back into the City of Houston. Black points out that flood mitigation is the Flood Control District’s core competency and that HCFCD can construct projects much faster and more efficiently than HGAC.
An estimated one third of Harris County went under water during Harvey. Photo courtesy of Sally Geis before her rescue.
But he worries about inflation of construction costs (which he is already seeing) and the admin costs.
Black intends to build projects as quickly as he can. If there’s a project in an LMI neighborhood that’s shovel ready, he will build it with bond money and not wait for HUD funding which could add years of delays.
That said, there are many projects that are not shovel ready that could benefit from this money. In fact, the need is greater than available funding, says Black.
Make Your Feelings Known
Please consider these points and take time to submit a public comment. Email is probably the easiest way. It doesn’t require you to wait through a meeting for your turn to speak, and doesn’t limit you to a certain amount of time.
Photo by Camille Pagel. Her children are helping to gut the kitchen instead of going to school after the Harvey flood.
How to Register Your Opinion
You can register your opinion in any one of five ways.
US Mail: Texas General Land Office Community Development and Revitalization, P.O. Box 12873 Austin, TX 78711-2873
Fax: 512-475-5150
All public comments submitted by 5 p.m. on Sept. 29, 2021, will be considered. The method of submittal does not matter. Per federal requirements, the GLO will respond to public comments before the amendment is sent to HUD for final approval.
Posted by Bob Rehak on 9/17/2021
1480 Days after Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/09/20170829-IMG_5756.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-09-17 20:15:172021-09-17 20:25:58Help Needed: Public Comment Period Swiftly Closing on $750 Million HUD Flood-Mitigation Grant for Harris County
New Flood-Insurance Rating System Starts October 1
A new flood-insurance rating system, designed to make rates reflect the true risk to an individual property will go into effect on October 1. FEMA calls it their Risk Rating 2.0 system. They describe it as Equity in Action. It’s FEMA’s attempt to put the National Flood Insurance Program (NFIP) on a sound actuarial footing and stop the system’s financial hemorrhaging.
Says FEMA, Risk Rating 2.0 is “not just a minor improvement, but a transformational leap forward. Risk Rating 2.0 enables FEMA to set rates that are fairer and ensures rate increases and decreases are both equitable.”
Based on More Data, More Variables
“The new system moves away from basing price primarily on a handful of broadly drawn and often dated flood map zones,” according to the Pew Charitable Trusts. The new rates reflect “a more detailed set of factors, including proximity to and size of a water source, flood frequency and type (such as heavy rainfall or coastal erosion), ground and building elevation, foundation types, and drainage issues.”
Sliding Scales not Price Brackets
“The more detailed analysis allows for prices that run along a sliding scale,” says Pew, rather grouping homes into brackets because they’re in the same mapped zone. Thus, low-risk homes will no longer be carrying the freight for high-risk homes.
Under Risk Rating 2.0, policyholders can save through mitigation activities such as elevating mechanical and electrical equipment above flood levels or installing flood openings.
Also, under the old system, all National Flood Insurance policy holders paid the same base rate. However, they could purchase additional insurance at substantially discounted rates. Thus, more expensive homes enjoyed an advantage over less expensive homes. But the new system will attempt to correct that imbalance.
Risk Rating 2.0 also gives policy holders savings for practical mitigation activities, such as elevating mechanical and electrical equipment above flood levels or installing flood openings.
So far, so good. Congress mandated the change to actuarily sustainable rates in 2012. At the time, people thought the rates would also help discourage development in flood prone areas.
Not Everyone Happy with New System
Not everyone is happy with the system, however. The Sugar Land City Council unanimously approved a resolution during an Aug. 3 meeting stating its opposition to Risk Rating 2.0. They expect it to result in increased flood insurance rates for the vast majority of policyholders in Fort Bend County.
A google search turned up many news stories about fears of massive rate increases. However, by law, most new rates may not increase by more than 18% per year, according to FEMA.
Gap Between Policies and Practice, At Least Initially
Still, several insurance companies have pointed out hidden inconsistencies between policy and practice in the new system.
NU Property Casualty 360, for instance, pointed out several hidden inconsistencies that undermine the equity goal. They include:
Pushback from Politicians
Several senators and congress people have complained about the new system and asked to delay the rollout to study impacts more closely.
The influential, Washington publication “The Hill” published a scathing op-ed of Risk Rating 2.0 in May. The author, Jainey Bavishi, director of the NYC Mayor’s Office of Climate Resiliency, felt that rising costs would force many to let flood-insurance policies lapse. She called the rollout “rushed.” She claimed, and I quote, the new policy “threatens to transform the National Flood Insurance Program from a financial lifeline into a crippling financial burden for thousands of low-income families in coastal cities.”
Phased-In Changes
Any change this massive was bound to cause political indigestion. FEMA has heard the criticisms and is trying to roll out the new system in a way that minimizes hardships. For instance, existing policies will be on an 18% “glide path” to their full risk rate. Said another way, FEMA will phase in the increases to make them more bearable. They will also give discounts for flood proofing, adding flood vents beneath homes, elevating homes and much more.
For policy holders in multi-floor apartment buildings, FEMA will now consider the actual floor you live on, not just quote a flat rate for everyone in a building. This should benefit renters who live on upper floors.
Timing
PHASE I
New policies beginning Oct. 1, 2021, will be subject to the new rating methodology. Also beginning Oct. 1, existing policyholders eligible for renewal will be able to take advantage of immediate decreases in their premiums.
PHASE II
All remaining policies renewing on or after April 1, 2022, will be subject to the new rating methodology.
Get a Quote From Your Insurance Agent
In its efforts to make pricing reflect true risk, FEMA will now consider many new data sources and variables. I reviewed an hour-long FEMA presentation on the subject. At the end, I was left with one overwhelming conclusion. Call your insurance agent. Your price may go down. It may go up. It costs nothing to get a quote. But the cost of NOT having insurance when you need it can break the bank as we saw during Harvey and Imelda.
Of the 154,170 homes flooded in Harvey, 64% did not have a flood insurance policy in effect.
And in Tropical Storm Imelda, almost two-thirds of the homes flooded were outside the 100-year floodplain.
Posted by Bob Rehak on 9/20/2021
1483 Days since Hurricane Harvey and 732 since Imelda
1985 Upper San Jacinto Flood Control Study Prophetic, But Largely Unheeded
This morning, I came across a 1985 study by Wayne Smith and Associates for the Texas Water Development Board and the San Jacinto River Authority. It’s called the San Jacinto Upper Watershed Drainage Improvement and Flood Control Planning Study.
Recommendations of specific projects aside, the principal recommendations are as valid today as they were then. Had only someone acted on them.
Make sure you at least read Chapter 5: Conclusions and Chapter 6: Examination and Recommendation of Basic Design Criteria for Watershed. Together, they total just five pages.
Purpose of Upper San Jacinto Study
The Upper San Jacinto study had four main goals:
Problems of Rapid Development in Flat Areas
The study begins with a discussion of the problems of rapid development in flat areas. The Upper San Jacinto Watershed covers 1200 square miles. It includes all of Montgomery County and parts of Walker, Grimes, Waller, San Jacinto, and Liberty Counties. For the purposes of this study, the Harris/Montgomery County line formed the southernmost boundary.
Seven major streams comprise the watershed: the West Fork, Lake Creek, Spring Creek, East Fork, Caney Creek, Peach Creek, Luce Bayou and Tarkington Bayou.
The topography changes from rolling hills in the north and west to flat coastal plains in the south and east. The lack of slope in the southern and eastern regions seriously affects the ability of streams to drain stormwater.
The authors warned that as development would move northward, hydraulic “improvements” would alter natural stream patterns by increasing flow velocities and reducing ponding.
Even before urban development, they said, channels in the Upper San Jacinto Watershed did not have adequate capacity to transport runoff from large storms.
In 1985, at the time of the report, less than 5% of the land area in the watershed was developed. The Woodlands was relatively new and still building out. The report warned that because of development, increases in impervious cover “will require a more efficient drainage system to collect and transport runoff.”
The report lauded the type of development in The Woodlands, where, “discharges are no higher today than they were years ago in the undeveloped stages.” However, the report also cautioned that “…with most of the current development in the southern and eastern extremities of Montgomery County, watershed flooding problems may be greatly enhanced by urbanization.”
The report even prophesied ever greater amounts of subsidence moving north with urbanization.
The chapter which discussed planning said, “Right of way and reservoir land acquisition should occur while the land is open and available.” Sadly, with the exception of Lake Conroe, which had already been built, none of that happened.
Benefit/Cost Ratios of Regional Detention in Undeveloped Areas
The last advice sounds so simple, one wonders why no one acted on it. However, as I read through the economic analyses of alternatives (reservoirs, channel improvements, etc.), the reason became blindingly clear.
So few people lived in undeveloped areas in the Upper San Jacinto Watershed in 1985 that the annual flood damages are minuscule. For instance, there were only 39 structures in four Lake Creek floodplain areas that the authors examined. Annual damages totaled only $9,600. That made the Benefit/Cost Ratios (BCRs) for the various mitigation alternatives that they developed come out to less than .001 in some cases and .09 at most. Benefits equal costs at 1.0. So FEMA usually demands BCRs exceed 1.
But compare the cost of a reservoir then and now. In 1985, the authors estimated the total cost of a Walnut Creek reservoir (a tributary to Spring Creek) to be only $41,000,000. Today, the cost would be $132 million – more than 3X. But it would take many more homes out of the floodplain. So the BCR today could be 1.04 making the project doable (see page 44)…although much more expensive and much to late to help those who flooded recently.
It’s instructive to compare the project costs in the 1985 plan to those in the San Jacinto River Basin Master Drainage Study released last December. Reliance on the BCR in this case seems to dis-incentivize future planning and cost reduction. There’s a major opportunity for improvement.
To get around this problem, the Harris County Flood Control District started its Frontier Program. The program buys up land for regional detention ponds (those that serve multiple developments), and then resells detention capacity back to developers for future use. Because regional detention is usually more efficient than developers building individual detention ponds on their own, it can actually lower developers’ costs while protecting the public and conserving money long term.
Most High-Level Recommendations Still Valid
Page 43 of the 1985 report makes six high-level recommendations (apart from specific projects) that are as valid today as they were then.
Regular readers of this site have heard many of these recommendations before. The surprise, if there is one, is that we haven’t adopted them all already or that we haven’t adopted them consistently. Even where recommendations have been adopted, they are enforced inconsistently.
For future reference, the 1985 report can also be found on the reports page under the SJRA tab.
Posted by Bob Rehak on 9/19/2021
1482 Days since Hurricane Harvey and 731 since Imelda
Help Needed: Public Comment Period Swiftly Closing on $750 Million HUD Flood-Mitigation Grant for Harris County
The Texas General Land Office (GLO) has announced that the public comment period for the first amendment to the state’s action plan for Community Development Block Grants for Mitigation (CDBG-MIT) will close in twelve days – on September 29, 2021. The GLO first posted the amendment to its $4.3 billion action plan on August 23rd.
Harris County essentially got shut out of the first round of grants last summer. This amendment would allocate $750 million to Harris County in the second round. That’s good as far as it goes, but Harris County needs more and the proposed amendment needs tweaks. Read more below.
Background
Earlier this year, the GLO held a statewide competition for approximately $1.1 billion in Harvey flood mitigation funds. Harris County received none, despite being one of the most heavily populated and impacted counties in the state.
A public uproar ensued. GLO Commissioner George P. Bush then agreed to commit $750 million to Harris County for the second round of funding.
The amendment also obligates the county to define a method of distribution (MOD) for that money within US Department of Housing and Urban Development (HUD) rules.
The “amendment” has been folded into the state’s action plan. The combined document totals a whopping 1134 pages – more than 100 megabytes. You can download the entire doc from the GLO site here. You can read the relevant seven pages (Section 5.4.5) here. Or read the discussion below.
Outline of MOD Rules
The amendment is based on a Method of Distribution (MOD) program. It makes the GLO the direct recipient of HUD funds and Harris County a sub-recipient.
Harris County must define the MOD plan to allocate funds to eligible entities within rules defined by HUD.
Eligible entities include:
GLO encourages prioritization of projects that meet regional mitigation needs.
Harris County’s MOD plan must benefit at least 50% LMI (low-to-moderate income) residents.
Eligible activities include:
Ineligible activities include:
Buyouts
Have their own guidelines which are too complicated to summarize here.
Timeline
Experts say all this time may be needed given the complexity of navigating HUD processes, which are lengthier than other sources.
Discussion/Recommendations
Harris County and the Flood Control District support the amendment. It is certainly justified by the number of people in Harris County and the amount of damage inflicted by Harvey.
However, $750 million is not enough. A fairer amount would be closer to $1 billion. As the action plan points out, approximately one third of Harris County went under water during Harvey.
Alan Black, interim executive director of the Harris County Flood Control District, points out several other reasons for increasing the allocation:
The City of Houston has still been left out. Flooding in Harris County has a dual nature. “You can address the rivers and channels,” he says, “but if water can’t get to the bayous, people will still flood when water ponds in neighborhoods. Both riverine and street flooding must be addressed together.”
Black also points out that administrative fees are capped at 6%, but with HUD compliance costs, 8% is more realistic. Moreover, those administrative costs must come out of the $750 million – they are not on top of it. So the real amount of money available for flood mitigation would be reduced to about $690 million.
Finally, the Amendment also allocates approximately $450 million to Houston/Galveston Area Council, much of which would go back into the City of Houston. Black points out that flood mitigation is the Flood Control District’s core competency and that HCFCD can construct projects much faster and more efficiently than HGAC.
But he worries about inflation of construction costs (which he is already seeing) and the admin costs.
Black intends to build projects as quickly as he can. If there’s a project in an LMI neighborhood that’s shovel ready, he will build it with bond money and not wait for HUD funding which could add years of delays.
That said, there are many projects that are not shovel ready that could benefit from this money. In fact, the need is greater than available funding, says Black.
Make Your Feelings Known
Please consider these points and take time to submit a public comment. Email is probably the easiest way. It doesn’t require you to wait through a meeting for your turn to speak, and doesn’t limit you to a certain amount of time.
How to Register Your Opinion
You can register your opinion in any one of five ways.
All public comments submitted by 5 p.m. on Sept. 29, 2021, will be considered. The method of submittal does not matter. Per federal requirements, the GLO will respond to public comments before the amendment is sent to HUD for final approval.
Posted by Bob Rehak on 9/17/2021
1480 Days after Hurricane Harvey