When Harris County Flood Control District (HCFCD) and the Army Corps began Project Hunting (the Hunting Bayou Federal Flood Risk Management Project) in 2014, they estimated it would cost $100 million and take until late this year.
A flyover of the construction along Hunting Bayou looks like it is nearing completion…right on schedule. It will soon be done, except for the backslapping. Compare the shots below to those I took last year.
Hunting Bayou runs just inside North Loop 610 most of the way from US59 to Wayside. However, starting at Wayside, it dips outside the Loop, then goes back inside again, and finally outside a second time. Eventually, the Bayou works its way to the Houston Ship Channel near the City of Galena Park.
Scope of Project
Project elements include:
Excavating a stormwater detention basin on a 75-acre site near the northeast corner of Homestead Road and Loop 610
Widening and deepening about 4 miles of Hunting Bayou
9 bridge replacements / 8 modifications and channel conveyance improvements under bridges
Project Benefits
HCFCD says that most neighborhoods near the bayou will see water surface elevation reductions of 3-4 feet for the 1 percent annual chance (100-year) flooding event. The number of homes and businesses subject to the 1 percent (100-year) flooding event would drop from 5,100 to 650. And all homes and businesses will benefit from the reduced frequency and depth of flooding.
Need for Project
The Hunting Bayou watershed has Harris County’s second highest percentage of Low-to-Moderate Income (LMI) residents – 69%. That means more than two out of every three people earn less than the average income for the region.
Hunting is a small watershed. It comprises only 31 square miles. Its size ranks 19th out of 23 watersheds in the county.
Population grew only by 2,323 residents between 2010 and 2020. It went from 75,908 to 78,231. That now ranks it 14th in population among all watersheds, and 8th highest in people per square mile.
In five major storms between 2000 and today (Allison, Tax Day, Memorial Day, Harvey and Imelda), floods damaged 15,763 structures in the watershed. But virtually all of that damage came from Allison (8,270) and Harvey (7,419). The other three storms combined damaged only 74 structures, according to statistics compiled from HCFCD Federal Reports.
Thus, Hunting ranked 7th in total damage out of 23 watersheds, but because of its small size and high density, it had 508.5 structures per square mile damaged by floods since 2000. That means…
Hunting ranked #2 out of 23 watersheds in damage per square mile.
Data Obtained from HCFCD Via foia request
The watershed is highly urbanized with a mixture of residential, commercial and industrial developments. It’s home to one of the largest rail yards in the Houston area.
Union Pacific Englewood Yard in NE Houston along Liberty Road (right). HCFCD had to replace three railroad bridges over Hunting Bayou as part of the project.
Aerial Survey Shows Mitigation Construction Almost Complete
On Tuesday this week, I flew over Hunting Bayou with Ken Williams and Bill Callegari. Both are fellow members of the Harris County Community Flood Resilience Task Force. The pictures below show highlights of the construction.
Looking west at Hunting Bayou while hovering over US59 North. The widening of Hunting stretches downstream for about 4 miles to where Loop 610 North (on the left) turns right and heads south.Same area. Looking SW toward 59 and downtown. Notice the rip rap (irregular chunks of broken concrete or rock) below storm sewer outlets. It disperses the force of rushing water and slows it down to reduce erosion.Work continues around two neighborhood bridges at Falls St. and Leffingwell St.Likewise, widening continues at Hirsch Road.Looking back upstream at all three bridges, plus a pedestrian bridge over a small tributary in the distance.Wider shot, looking upstream over Wayne Street.Previously finished section around Wipprecht bridge.Note how bayou narrows under Lockwood Bridge due to commercial development on either side.Looking back upstream (west) from over Kelly St. at linear park that parallels another large detention basin.Note the new pedestrian bridges.They have been widened to accommodate the wider bayou.Rotating 180 degrees from shot above, we can see downstream to rest of park and where the Bayou threads its way under Loop 610N. Also note large detention basin in distance.Looking back SW from over Kelley Street. Note concrete lining that now protects narrow section under 610 bridge.Looking SW toward Homestead Road (with the bridge) across the new 75 acre stormwater detention basin.
The Curtis M. Graves Detention Basin shown above provides approximately 1,000 acre-feet of stormwater storage capacity. That’s almost 10 inches of rain falling over a square mile. Construction of the basin began in 2020.
Looking west along 610 N at the section of Hunting that briefly dips outside of the Loop.Looking NW. Note again the new concrete lining where the channel narrows to go under the Loop 610 N bridge. Water flows toward the camera.
Compare Bayou Downstream From Project
Where the bayou narrows to go under a bridge, the increased water pressure during a flood can cause a “jetting” phenomenon that rapidly erodes banks and undermines bridge supports. Hence, the need for concrete reinforcement.
Looking S along East Loop 610 beyond the eastern end of the project. The Bayou loops around storage tanks (lower right) and heads south toward Wallisville Road, before heading east again. This shows what the bayou looked like before widening.Compare width to previous shots.
The tank farm is the approximate eastern limit of Project Hunting.
Project History
This project began on December 16, 2014, long before Harris County’s Flood Bond in 2018. It was a key project of County Commissioner El Franco Lee (who lived in the area) and Congressman Gene Green. Despite a low benefit/cost ratio, they called in favors and got the project started.
The agreement between the Army Corps and HCFCD lets HCFCD qualify for reimbursement from the Federal government for work completed.
Between the channel widening and detention basin, HCFCD has removed almost a million cubic yards of soil to create more room for floodwaters. Width of the Bayou now varies from about 30 to more than 500 feet between the project limits.
According to data obtained via a FOIA Request, HCFCD and its partners spent $96 million on Hunting Bayou between 2000 and the end of last year. Some of that money has been spent on other projects. To see a complete list of HCFCD projects in Hunting Bayou, visit the District’s Hunting page.
In the last few weeks, Michael Bloom, a fellow member of the Harris County Community Flood Resilience Task Force, and I have debated the inherent bias and limitations of a Flood-Mitigation Benefit Index (FMBI) proposed by a majority of the Task Force to Harris County Commissioners Court.
According to Mr. Bloom, the index will:
Reveal and document patterns of historical discrimination.
Help plan where additional flood-risk reduction investments should be made.
Population-Based, Not Damage-Based Mitigation
The formula is:
Benefit = Total Cost/(Population X Risk)
…where:
Cost = total flood-mitigation construction spending (and only construction spending) that benefits a census tract.
Population = the number of people who live in census tracts.
Risk = the annual chance of flooding (applied to census tract(s)) expressed as a whole number. For instance, a 1% annual chance equals 1. And a 10% annual chance equals 10, etc.
The Task Force hopes to calculate and compare the results for each census tract in the county.
The formula measures the historical per capita flood-mitigation costs supposedly associated with the “current” level of risk in a census tract – NOT historical flood damage.
According to proponents, “a high benefit score means no more mitigation spending is needed. And a low score means more spending is needed.”
But consider these two examples:
4,000 people live with a 1% annual chance of flooding and have received $200 in prior investment. Their FMBI would be 0.05. That’s extremely low. And scores that low indicate such areas need help “regardless of prior investment.”
8000 people live in the 10-year flood plain and have received $10 million in prior investment. Their FMBI equals 125. That’s 2,500 times higher.
According to a spokesperson for the FMBI, “A high FMBI means we don’t need to make more investments in that location.” Yet twice as many people live with ten times the risk in the area with the higher index.
So, who deserves the most help? Residents with the lowest FMBI? The formulaSAYS they need help the most. But they actually have the lowest risk.
The Value of Market Testing
None of the hypothetical examples used to “sell” the formula hint at the possibility of such an upside-down result.
The example above proves several things:
The formula can produce inconsistent and misleading results.
Adjusting for population doesn’t prove historical discrimination. The most densely populated area has 50,000 times more investment.
The formula needs rigorous testing and ground-truthing before going any further. This is a best practice for any new scientific formula – especially one intended to guide future investment.
In addition to producing unintended results, the formula has several other problems that require discussion.
No Right-Of-Way Acquisition Costs Included
The FMBI formula includes only construction costs. It excludes right-of-way acquisition costs by assuming that they are “uniform throughout the county.” Therefore, “…costs included or excluded will not adversely impact results.”
In fact, Right-of-Way (ROW) Acquisition costs are huge and NOT UNIFORM throughout the county. I have documented that ROW costs typically comprise the second most expensive part of flood-control projects.
All Flood Control and partner spending on all capital improvement projects from 1/1/2000 through the end of Q3 2021.Data obtained via FOIA Request from HCFCD.
A quick glance at the Appraisal District website will tell you that land costs vary widely throughout Harris County and change over time.
The cost of buying floodplain land or wetlands for preservation in rural parts of Harris County pales in comparison to land acquisition costs in densely populated parts of the county.
In fact, acquiring land in densely populated areas for flood mitigation often costs more than construction, according to several engineers I consulted.
Compounding Problems?
I worry that other methodological issues may compound each other, not cancel each other out.
Map of Census tracts in Harris County, Texas.
Consider that:
Census tract population typically varies by up to 4X (2,000 to 8,000), according to the Census Bureau. This will produce deceptive spatial comparisons.
Some Census tracts may comprise dozens of square miles while others comprise a few city blocks. Typically, flood mitigation projects are not considered at the Census-tract level. According to three engineers I consulted, that’s too small in most cases to be workable.
Larger Census tracts may contain multiple watersheds, each with independent levels of risk – or individual watersheds with varying levels of risk. In such cases, the formula would average risk. But averaging can mask a serious problem in one area with a non-problem in another. Thus, the formula has a bias in favor of spatially smaller Census tracts. Smaller tracts tend to be more uniform in risk, so problems will likely stand out rather than get lost in an average. But in larger watersheds, flood risk will feather out with increased elevation and distance from a river. That will make it extremely difficult to calculate the number of people exposed to varying degrees of risk. Averaging takes the simple way out. But averaging risk is like comparing saints and sinners, then declaring “No problem.”
The data collection effort for the index omitsmany sources of funding. So the formula will calculate investment dollars from some entities and areas, but not others. For instance, the formula will NOT measure drainage funding from Harris County Commissioner Precincts, dozens of cities, and 389 municipal utility districts in unincorporated areas. The difficulty of data collection in these areas will produce another spatial bias. Likewise, the FMBI formula will omit the considerable drainage-improvement contributions of reputable private developers.
No one has tested how these inconsistencies will affect each other. But there’s an even bigger data integrity issue.
Partially Updated Data
HCFCD and its partners invested more than $1.5 billion in flood mitigation between Harvey and the end of 2021. Since 2000, they’ve invested more than $3.5 billion. But as of this writing, new MAAPnext flood maps only reflect the POST-mitigation risk associated with projects in FIVE bayous: Brays, Greens, White Oak, Sims, and Hunting. The Army Corps partnered with HCFCD in those.
Unfortunately, according to a knowledgeable source, HCFCD has not yet updated the risk maps for its own Capital Improvement Projects in other watersheds. So if you ran the allocation formula now, it would compare PRE-mitigation risk in 18 watersheds with POST-mitigation risk in 5.
Mitigation in those five watersheds totals $439 million out of $1.5 billion since Harvey. So true, current risk is reflected in only 29% of spending since Harvey and 13% in this century. Those percentages will no doubt increase in the future. But if you ran the numbers today, you would compare numbers with PRE- and POST-mitigation risk.
And consider this. With HCFCD spending at the current rate of about $80 million per quarter, “current risk” is a constantly changing target. So we’ll never be able to compare apples to apples in all watersheds anytime soon.
And we want to use this formula to guide future mitigation spending? Using it could send more money back to fix areas we already fixed!
Difficulty of Assigning Investments to Census Tracts
Another challenge: How do you determine which census tract(s) to apportion project benefits among? Example: Addicks and Barker Reservoirs. The Army Corps developed those back in the 1930s to protect downtown Houston…15-20 miles away!
Do you credit the investment to:
All of downtown?
People living inside the reservoirs (who have their own census tract)?
The current population of the entire Addicks and Barker Watersheds?
All census tracts along Buffalo Bayou and parts of White Oak Bayou, our second and third most populous watersheds?
And virtually all residents of the Addicks and Barker watersheds live upstream from the Corps’ investment, so they will not benefit from the investment either.
Downtown has immense commercial and economic value but relatively few permanent residents.
So, who gets the benefit? Again, lots of room for interpretation and misplaced assumptions here that numbers can easily mask! Now, multiply this problem times thousands of Census tracts.
Anti-Commercial Bias
The population-based FMBI has a built-in bias against commercial areas that have little to no residential population. For example, consider the cases of Downtown, the Texas Medical Center, and the Port of Houston. Such areas support employment throughout the region, but the formula discriminates against them by giving huge weight to population and omitting actual damage.
No Thresholds Defined
To my knowledge, the task force has never discussed threshhold “benefit” levels that correlate to “needs help” or “doesn’t need help.” The extremes may sometimes be easy to determine. But what about outcomes in the middle?
Offsetting Variables
Variables in the formula can offset each other as we saw above. In tight races for funding, who gets the next flood-mitigation investment? The area with the lowest investment, highest risk, or largest population? Such quandaries have not yet been addressed.
No Agreement on Weights of Other Factors
To help make future flood-mitigation decisions, proponents of the formula also suggest weighing (separately) other factors, such as the CDC’s Social Vulnerability Index. It includes the percentage of Low-to-Moderate residents in an area. However, no one has yet discussed the weight given the Benefit Index relative to other factors.
No Consideration of Actual Flood Damage
In deciding where to put flood mitigation projects, engineers traditionally look for damage clusters. It’s that simple. Dollars flow to damage.
Reducing flood damage is a tried and true, measurable way to evaluate projects. So why all the complexity?
What’s The Point?
What is this formula trying to prove? Is it attempting to develop a new approach to mitigation funding that eliminates a perceived bias in Benefit/Cost Ratios?
Commissioner Rodney Ellis often talks about how calculating the value of avoided damages in higher value homes disadvantages projects in poorer neighborhoods. That can be true in some instances. Expensive homes can ratchet up benefits (measured in dollars) faster than lower value homes can. And that can result in higher Benefit/Cost Ratios for projects in affluent neighborhoods – assuming density is held constant. But…
One high-value home on an acre would likely appraise less than an apartment building, also on an acre. In Kingwood, I compared the valuations of an expensive single-family home with a large apartment complex one block away. The appraised cost per acre (including structures) of the apartment complex is 4X higher.
Now consider that apartments accommodate almost half of Harris County’s population.
According to the latest census data, 54.9% of Harris County residents live in owner-occupied homes. The rest, 45.1 percent, live in apartments.
Most Americans aspire to and encourage home ownership, in part, because of the stability it fosters in communities. But this formula – because of its emphasis on population density – favors apartment areas over areas with owner-occupied homes. There’s nothing inherently wrong with that. You just need to understand what the formula does.
Difference Between Vertical and Horizontal Density
The Benefit Index favors all areas with dense population. Proponents argue that helping more people is better. I don’t argue with that. However, the generalization masks the financial pain inflicted by a flood on owners vs. renters, and on the people who live at ground level compared to those who live above it.
Ground floor renters may lose contents in a flood, but they won’t be responsible for making structural repairs. The owner will.
And many living above the ground floor may find themselves more inconvenienced by flooding than financially devastated. So, is it fair to count all people on all floors when determining who suffers the most pain?
Five-story apartment buildings crowding Brays Bayou with ground-level parking underneath. HCFCD has no way of knowing how many people live in apartments like this, yet HCFCD will be responsible for compiling the data.
In the proposed formula, higher population will lower the benefit index, making it look as though all renters (almost half the county’s population) suffered more than owners of single-family homes.
The premise underlying such “equity” arguments is that poor people can least afford floods. But most people in apartments like those shown above won’t make structural repairs as a homeowner would.
No Perfect Formula
No perfect formula exists that’s equally fair to all in all circumstances. That’s why FEMA, HUD and the Army Corps allow consideration of multiple factors when determining which projects to fund.
The Flood Mitigation Benefit Index focuses totally on population, risk, and past investment. It ignores actual flood damage.
If we use ANY formula to HELP allocate future flood-mitigation funds, we should all strive to:
Understand its built-in biases
Maintain high standards for data integrity.
If we want to test a hypothesis of historical discrimination in flood-mitigation funding, there’s a much simpler way. It’s called direct measurement. Simply locate damage centers from past storms and compare funding in the following decade designed to mitigate those areas.
For More Information
For more background on issues with the formula, see my earlier posts:
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/07/20210520-RJR_6978.jpg?fit=1200%2C800&ssl=18001200adminadmin2022-07-14 17:54:142022-07-14 21:58:06Inherent Bias and Limitations of Flood-Mitigation Benefit Index
The Houston-Galveston Area Council of Governments (H-GAC) has allocated $60 million to Montgomery County. The money comes out of a $488 million of Harvey flood-mitigation funds previously allocated to HGAC by the U.S. Department of Housing and Urban Development (HUD) through the Texas General Land Office (GLO). The $60 million is the single largest allocation to any governmental entity in the region out of the $488 million pot.
50% Committed to LMI Areas
At least 50% of the money must go to low-to-moderate income (LMI) areas in Montgomery County. The GLO has determined that MoCo plans meet HUD rules and conditionally approved the allocation.
However, things could still change and Montgomery County has not yet received the money.
According to H-GAC, the conditionally approved preliminary method of distribution (a plan for whom gets how much) is still pending acceptance by eligible entities and is subject to change through a published re-allocation process. A complete list of eligible activities is available in the Texas General Land Office (GLO) guidelines for the Regional Mitigation Program – Council of Governments Method of Distribution (COG MODs). Depending on changes, another 30-day public comment period may necessary, according to the GLO.
Where, How MoCo Will Spend the Money
I reached out to the Montgomery County Judge’s office to see how MoCo hopes to spend the money. Jason Millsaps replied, “Montgomery County will attempt several projects with these funds as soon as final approval has been granted.”
Millsaps continued, “In East County, we will work to de-snag, de-silt and remove vegetation that hinders flow from the Peach Creek, Caney Creek, White Oak Creek, and East Fork of the San Jacinto River. We will do the same for Lake Creek and Stewart Creek in Central/North County, with additional bank armor going in for Stewart Creek near the River Plantation Subdivision.”
Peak flows in the San Jacinto Watershed during Hurricane Harvey
Posted by Bob Rehak on 7/12/22
1778 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/07/20220712-Screen-Shot-2022-07-12-at-1.17.19-PM.jpg?fit=1200%2C729&ssl=17291200adminadmin2022-07-12 13:31:032022-07-12 13:46:36Montgomery County Allocated $60 Million in Harvey Mitigation Funds
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.
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 youhold risk and population constant, while increasing cost…
Population = 5000, Risk = 10 and Cost = $100,000, then Benefit = 2
Population = 5000, Risk = 10, and Cost = $1,000,000, then Benefit = 20
…benefit increases by spending morewithoutreducing risk! A taxpayer nightmare!
Population Example
If you hold cost and risk constant, while increasing population…
Population = 2000, Risk = 10, and Cost = $1 million, then Benefit = 50
Population = 5000, Risk = 10, and Cost = $1 million, then Benefit = 20
…benefit decreases by helpingmore 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.
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
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On 6/29/22, Harris County Commissioners Court discussed a billion-dollar-plus bond package presented by County Administrator Dave Berry, Budget Director Daniel Ramos and Engineering Department Head Dr. Milton Rahman, P.E. The presentation talks about a $1 billion package. But during discussion, commissioners asked to look at several higher options – $1.1 billion, $1.2 billion and $1.5 billion. The discussion, which you can see posted on the Harris County Commissioners Court website, starts at 3:32 (timecode) and goes to 4:20. Since that’s almost 50 minutes, let me try to summarize it below using some of the slides presented by Rahman.
Proposed Uses for Money
In fairness, understand upfront that Rahman presented an introductory outline, not a detailed plan. With that in mind, he pitched a $1 billion plan broken down as follows.
The package includes $200 million to improve neighborhood drainage. That’s over and above the $600 million in the current budget.
Rahman focused on both the number of people (20,000) and structures (4,000) benefitted with the $600 million. That averages to $30,000 per person or $150,000 per structure. That also works out to 5 people per structure. But the Harris County average per household, according to the US Census Bureau, is 2.84 people for the five years ending in 2020.
That made me question where Rahman obtained his numbers. He never says. Does he base his estimate on a combination of apartments and single-family households? Who will benefit from another $200 million? If that $200 million works as efficiently as the $600 million, it should help another 1,333 homes (4000/3). Where are they? Which precinct? Which neighborhoods?
I get the need for rounding at this early stage. But they’re talking about going to voters in four months. 4.2% of the $5 billion flood bond is more than $200 million dollars of rounding error! That made me wonder about the accuracy of the numbers in the slides above.
The fact that the total “ask” varied by 50% during the discussion also made me wonder about how much research and planning went into these numbers.
Yet Commissioners Ellis and Garcia are eager to put it on the agenda for a vote during the next commissioners court meeting – without any public input. That raised more red flags, because the Community Flood Resilience Task Force has demanded public input on future bond programs. In multiple languages. A majority of the task force felt so strongly about public input, that they even asked HUD to fund it!
Other Highlights from Discussion
Commissioner Ellis wants to review a tighter proposal and put it to a vote at the next commissioners court meeting on July 19, 2022.
Garcia wants it on the ballot in 2022, not 2023.
Ramsey wants to slow it down. He wants to listen to voters, develop a tight plan, communicate the elements to the public, and advocate for it. He stated that it would take a long time to recover from a bond proposal that failed. Ramsey would prefer a vote in 2023.
Commissioners Court spent considerable time discussing whether the proposal should have a list of specific projects or just generic categories of spending. But the commissioners made no decision on that point.
Milton Rahman stated, “The wish list is bigger than we can afford.” That raised another red flag for me. It means someone will have to make hard decisions about where the money goes and who benefits. Who will make those decisions? On what basis? When? After the election?
Commissioner Cagle suggested voting on this proposal with additional requests to fund flood tunnels and the coastal spine project. That could delay this bond proposal until we knew how much federal funding we could get for those projects. And that could take two years. Congress will vote on the next Water Resources Development Act in 2024.
Withholding Judgment for Now
Until I see more detail, I will withhold judgement on this bond proposal. I can see how there may be a need. But I’m not going to vote for a billion dollars of vague generalities. I want to see where the money goes and I want to have time to study the bond language. I was fooled once by a non-standard definition of “equitable” applied to the 2018 flood bond. What other surprises lurk in the wings?
One reader who prefers to remain anonymous said, “We should trust this Court with a blank check for projects that are not defined??? NO DAMN WAY!!! What is the formula to determine which Precincts get how much money? What is the prioritization framework to select projects? How will equity considerations affect funding? How will the public know where this money goes? We have NO IDEA where previous bond funding went!!! This Court has not earned our trust. Some members just cannot be trusted. NO BOND!”
Frankly, that’s a fairly typical attitude outside the Beltway from comments i get.
Yet Rahman, Berry and Ramos, in their last slide, suggest this proposal – with a barely defined project list – is a foregone conclusion. See below. They want to identify only a few flagship projects to complement other unspecified projects in the bond. And they want to start drafting bond orders now.
Let’s see if Berry, Ramos and Rahman can advertise and conduct dozens of precinct meetings; solicit public input; and define a plan responsive to community needs before the next commissioners court meeting. If not, perhaps Ellis, Garcia, Hidalgo and the Community Flood Resilience Task Force should demand their resignations.
Posted by Bob Rehak on 6/29/2022
1765 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.
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The introduction to the request states, “Although the Harris County Flood Control District (HCFCD) continues to aggressively pursue partnership dollars … substantial amounts of anticipated partner funding remain unrealized.”
Of the roughly $5 billion in 2018 Flood-Bond Projects, officials hoped that Federal, State and local partners would supply roughly half the money. But it hasn’t all materialized yet. So last year, Commissioners created a flood-resilience trust fund to create backstop funding. Until now, the county has not needed it. But now the county does…for the sixteen projects listed below.
Projects recommended for first round of backstop funding. Some of these projects started before the flood bond, were later included in it, and ran over budget.
To date, Harris County has secured $1.275 billion in partnership funding for 2018 Bond Program projects from Federal, State, and local partners. Of the $2.5 billion in partner funds originally anticipated, “the county has not yet identified $754.2 million. This gap includes projects for which grant applications were submitted to various Federal and State programs such as CDBG-MIT, FEMA-BRIC, and others but not awarded,” says HCFCD.
Ironically, the backup documentation provided to commissioners by HCFCD makes no mention of the $750 million allocated by the U.S. Department of Housing and Urban Development (HUD) and the Texas General Land Office (GLO) to Harris County. More on that below.
Ranking Methodology
The document provided to commissioners by HCFCD contains information about the Trust, its history and intent, projects that need funding help now, and a methodology for ranking projects.
After ranking all flood-bond projects that are short of funding using the proposed matrix below (Appendix B), the county began whittling away from Trust funds. HCFCD started with the top-ranked project and proceeded to the lowest until the money ran out, i.e., the balance in the trust fund went negative. Only two projects from the entire San Jacinto Watershed made the “eligible” list: one near the ship channel and another below Highway 90. But neither of those is part of the group of 16 above.
Weighting Factors in Proposed Matrix
The scoring matrix used by the County includes evaluations of:
Cost per person (15%)
Cost per structure (30%)
Non-structural benefits (45%)
Existing conditions (20%)
Social Vulnerability Index (20%)
Long-term maintenance (5%)
Minimizing environmental impacts (5%)
Ability to deliver multiple benefits, i.e., flood mitigation, social and environmental (5%)
As additional partnership funding sources are identified, money remaining in the Trust may cover additional projects…assuming inflation doesn’t eat it all up.
For this exercise, HCFCD analyzed all projects with partnership funding gaps. However, that doesn’t mean that those projects will necessarily receive Flood Resilience Trust funds. When and if HCFCD identifies funding partners, some projects could drop off the list of those needing help. That could make funds available for lower ranking projects. See Appendix B, last page.
Future Plans
If approved, HCFCD will return to Commissioners Court twice each year with additional requests from the Flood Resilience Trust. Each of those requests will include an updated analysis of partnership and contingency funding needs, Trust funds remaining, and eligible projects.
HCFCD will request money from the Trust only when projects cannot move forward without it.
$750 Million HUD Allocation Not Discussed
The County’s Community Services Department is currently developing a Method of Distribution (MOD) for the $750 million designated earlier this year for Harris County by HUD. A MOD is a plan for distributing the $750 million. Where and how will the county use the money? Who will benefit?
HUD and the GLO require that at least 50% of the money benefits Low-to-Moderate Income neighborhoods.
At the time the GLO and HUD dedicated $750 million to Harris County, they also dedicated $488 million to the Houston Galveston Area Council (HGAC).
Verification that all recipients are still interested in participating.
According to a GLO spokesperson, HGAC began developing its MOD when the GLO submitted its action plan to HUD. However, Harris County reportedly delayed planning until AFTER HUD approved the GLO’s recommendations.
That delay could mean spending more local money. And that could penalize Harris County watersheds farther down on the Trust Fund priority list that don’t currently meet SVI and other requirements. Will there be money left for the Lake Houston Area by the time we work our way further down this list? Only time will tell.
Posted by Bob Rehak on 6/28/2022
1764 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/06/Screen-Shot-2022-06-27-at-10.09.28-AM.png?fit=546%2C578&ssl=1578546adminadmin2022-06-27 22:50:062022-06-28 13:35:45HCFCD Asking to Tap Flood Resilience Trust for Bond Projects
The Harris County Flood Control District (HCFCD) posted the June 2022 status of 2018 flood-bond expenditures for Commissioners Court last Friday. Among the report’s highlights: the spending drought continues in the Lake Houston Area where only two capital improvement construction projects are active. Their total reported value: $2 thousand. That’s out of more than $235 million in active construction projects during the month of June.
Said another way, the Lake Houston Area is getting less than one-thousandth of 1% of the construction budget (0.000851%). March and April updates show that no new capital improvement construction projects have started in the Lake Houston Area in months.
Finished detention Basins near Little York and Hopper in the Halls Bayou Watershed, with combined 200 acre-feet of storage.
Wrapped up Halls Bayou conveyance improvements
Began demolition of the old Raveneaux Country Club on Cypress Creek
Started drainage repairs in the Carpenters Bayou watershed
Issued a purchase order for the Atascocita Area Drainage Study, which had been approved on February 8.
Released the Phase II, 1800-page report on flood tunnel feasibility
Spending Breakdowns by Watershed
Harris County contains 23 major watersheds shown below.
The 23 watersheds in Harris County and the amount spent to date from all sources under the 2018 flood bond.
The table and bar graph below make the rank-order and relative magnitude of spending in various watersheds more apparent.
Spending by watershed ranked from high to low.San Jacinto is middle of pack despite being largest watershed in county,Bar graph of table above.
Factors Affecting Watershed Spending
Several factors affect the magnitude of spending in each watershed. They include:
Equity Prioritization Framework – This scoring matrix gives higher priority to projects in low-to-moderate income watersheds that have a high social vulnerability index. Projects with high scores started sooner.
Project Lifecycle Stage – Generally speaking, the earlier a project kicked off, the further along it is in its lifecycle. Studies have completed and construction has started or even completed. Some areas that flood repetitively had engineering studies completed and were already shovel-ready after Harvey.
Buyouts/Right of Way Acquisition – Sometimes entire subdivisions must be bought out to make room for flood mitigation projects. This can delay construction for years.
Lobbying – Squeaky wheels play a role on multiple levels.
Usually, no one factor accounts for a project’s or an area’s ranking. But multiple factors – working together – can push an area up or down the list.
Certainly, some areas have suffered spending-wise because of political priorities.
Other Highlights
HCFCD spent a total of $1.05 billion through the end of May. That compares to $1.025 billion through the end of April. So HCFCD spent $25 million in May.
Of the $1.05 billion spent to date, bond funds comprised $545 million. Grants comprised $367 million. And $140 came from other local funds.
HCFCD reported a schedule performance index of .97. That means projects are running slightly behind schedule. On-schedule performance would have earned a 1.0.
Overall, HCFCD has completed 21.8% of the bond projects when we’re 37.5% of the way through the 10-year program (45 months out of 120).
For the complete June update on bond spending, click here. Remember to review the last page. It shows capital improvement construction projects throughout the county and the spending drought in the Lake Houston Area.
Posted by Bob Rehak on June 26, 2022
1762 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2022/06/20220626-Screen-Shot-2022-06-26-at-10.12.36-AM.jpg?fit=1200%2C912&ssl=19121200adminadmin2022-06-26 12:42:522022-06-26 16:04:30May Flood-Bond Update Shows Spending Drought in Lake Houston Area Continues
Last week, one of the biggest issues in Harris County flood mitigation came into sharp focus for me: contrived ignorance regarding flood-bond spending. Three things brought it into focus:
The completion of the $480 million Project Brays, the largest in Harris County Flood Control District’s (HCFCD) history. The Brays watershed has 58% low-to-moderate income (LMI) residents.
HCFCD’s release of the May update on flood-bond spending. It showed that less than one one-thousandth of one percent of active flood-bond construction dollars are going to the entire northeastern part of the county (Kingwood, Huffman, Humble, Atascocita, and Crosby).
Ellis keeps rubbing me the wrong way. Why inflame racial distrust, Rodney, with statements so far from the truth?
Ignorantia Affectata
I’ve always had trouble understanding politicians who deny reality. But it turns out Thomas Aquinas, the great Catholic theologian and philosopher from the Middle Ages, described the phenomenon 800 years ago. He called it ignorantia affectata, a Latin phrase meaning “affected or cultivated ignorance.”
I found a great description of it on this blog. “The deniers first deceive themselves that they are sincere in their adherence to falsehoods. Thus they cannot be faulted for acting on genuinely held views. But in truth, they have cultivated an ignorance of the facts, an ignorance so useful that one protects it at all costs … in order to continue using it in one’s own self interest.”
David Luban, a professor at Georgetown Law, wrote a brilliant essay on the ethics of “Contrived Ignorance” (a related concept) and the law. It begins with a poignant description of how criminal defense attorneys discourage defendants from telling them everything they know. Admitting guilt could limit their defense of the client, because the law forbids lawyers from lying or knowingly putting on perjured testimony. Luban also touches on another related concept, plausible deniability, so common in politics and business.
Plausible Deniability No Longer Plausible
After Ellis spoke at the ribbon cutting ceremony – for the largest project in flood control history – he can no longer plausibly deny that poor neighborhoods can’t get flood-mitigation funding. They do!
But he tried. He trotted out his tired distortion about higher value homes in affluent neighborhoods skewing benefit/cost ratios. The problem: it ignores density. Higher density more than compensates for higher value homes. And in fact, from the ribbon cutting ceremony one could see apartments several stories high, stretching blocks in all directions.
While Ellis leads people to believe that projects in LMI areas struggle to achieve Benefit/Cost Ratios above 1.0, Project Brays had a 7.0 ratio. That’s extremely high. See this 2019 Federal Briefing. It will return $7 for every $1 invested!
Rodney Ellis at ribbon cutting ceremony for the $480 million Project Brays. The project helps reduce flood risk in neighborhoods where Ellis grew up and also where he now lives.Brays Bayou, looking west toward medical center from Almeda Drive.
Contrived Ignorance Vs. Informed Debate
The problem with contrived ignorance is that it prevents informed debate. Why would you look for evidence that undermined your world view? That prevented you from reducing flood risk in your neighborhood even further?
Why use the commonly accepted dictionary definition of “equitable” when you can redefine the word to serve your self interest?
I find it incredible that in 18 months, a majority of the Community Flood Resilience Task Force:
Refuses to discuss what percentage of flood-mitigation funding affluent neighborhoods should get.
Won’t admit that flood-mitigation projects have already been built in their neighborhoods.
Is arguing about how to float another flood bond for $60 billion when we’re only 20% complete with the first $5 billion.
Won’t discuss whether 2-year flooding in affluent neighborhoods should be fixed before 500-year flooding in LMI neighborhoods.
Attributes past flooding to racially motivated neglect without examining the role of development practices
Recommended that HUD paypeopleonly from poor neighborhoods to protest the unfair distribution of flood-mitigation funds.
When you try to discuss actual facts in Task Force meetings, shocked silence often greets you. Members keep talking about how they want facts. But a full year after requesting flood-risk data, no one seems concerned about the fact that they haven’t gotten it yet. Could this be what Thomas Aquinas meant?
Posted by Bob Rehak on 5/30/22
1735 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/2022/05/20220526-RJR_9480.jpg?fit=1200%2C800&ssl=18001200adminadmin2022-05-30 18:23:132022-05-31 13:58:44Editorial: Contrived Ignorance in Flood Mitigation
Harris County Flood Control District (HCFCD) delivered its March 2022 Flood Bond Spending Update yesterday to Commissioners Court. It shows $226,476,745 dollars worth of active capital construction projects underway throughout the county. But only two of those valued at a grand total of $2,000 are in the Lake Houston Area.
That’s less than one-tenth of one percent, despite the fact that the Lake Houston Area was one of the most heavily damaged in the county during Harvey.
The update also includes active maintenance projects. However, those are grouped in ways that make it difficult to determine the exact cost of each. The Lake Houston Area had 3 out of 36 of those. At least one of the three is now complete. It consisted of cleaning a block-long stretch of the drainage ditch that parallels Stonehollow Drive in Kingwood. Judging by the group costs, none of the three qualifies as major.
The update does not disclose the value of past projects. Nor does it break out the value of studies, right-of-way acquisition, or future improvements.
19.7% of the bond work has been completed as of the end of March. That’s up from 19.4% at the end of February. That percentage should increase faster as HCFCD completes more preliminary studies and moves into the expensive phases of projects, such as right-of-way acquisition and construction.
Of 1175 buyouts identified, 457 have completed – 39%.
Biggest winners to date in the flood-bond, mitigation-funding sweepstakes have been:
Brays Bayou – $173.1 million
Cypress Creek – $87.4 million
Greens Bayou – $82.7 million
Addicks Reservoir – $75.4 million
Little Cypress Creek – $53.7 million
White Oak Bayou – $53.2 million
Clear Creek – $38 million
Halls Bayou – $35.4 million
Hunting Bayou – $34.1 million
Willow Creek – $33.5 million
The San Jacinto River watershed has received $20.7 million despite being the largest in the county.
HCFCD completed two projects during the month and began construction on one other.
Eight other projects changed stages, i.e., from feasibility study to preliminary engineering.
“Partner Funds” To Date Virtually Equal “Bond Funds”
Virtually half of flood bond spending through the end of March 2022 came from partner funds. Local funds plus grants totaled $483 million. Money spent out of the bond itself has totaled $492 million. So, 49.5% of spending to date came from partner funds. It has gone largely to watersheds supposedly disadvantaged by partnership requirements. A popular political narrative claims low-to-moderate income watersheds get no partner funding and more affluent watersheds get it all. But that simply isn’t true.
49.5% of mitigation dollars to date have come from partners. 50.5% came from the bond itself.
Glaring $750 Million Omission
Although the March update contained a discussion of several partnership grants, it failed to mention $750 million allocated to Harris County by HUD and the GLO for flood mitigation on March 18. The March update did, however, discuss several smaller grants, earmarks and partner funds. Those took up two and a half pages.
The $750 million, together with the flood resilience trust approved last year, would fully fund the flood bond. That means that no watershed should have to wait on partner funding for construction projects to begin once engineering is completed.
Only one step remains before Harris County can start using the money – approval of a “method of distribution.” That’s a final plan for how and where the money will be used.
Posted by Bob Rehak on May 11, 2022
1716 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/2022/05/20220511-Screen-Shot-2022-05-11-at-4.51.43-PM.jpg?fit=1200%2C912&ssl=19121200adminadmin2022-05-11 17:06:202022-05-12 10:50:43Of Active HCFCD Bond Construction Spending Totaling $226 Million, Lake Houston Area Has $2 Thousand
Since then, dozens of people have contacted me describing the impact of turnover on programs and service.
One manager used the word “chaos” to describe the environment since Lina Hidalgo took office. All of the sources for this post have requested anonymity because they fear reprisals – a chilling comment in itself.
No doubt, many good, talented, hard-working people remain in Harris County government, but the problems described below make it harder for them to do their jobs.
Unexplained Changes in Direction
One person told me about a new Harris County juvenile center that was being planned, due to overcrowding and substandard living conditions at the old center. Then one day, “…like out of nowhere, we got a sense that the whole project was canceled. We tried to explain how far along the project was and why it was necessary. And they didn’t care. It was just like, ‘Well, we [the judge’s office] are not going in that direction.’” The source added, “We had a lot of things in motion that just came to a halt.”
The new center never did get built. It had reportedly gone all the way through the design phase, so the unexplained cancellation was costly.
Not So Resilient Resiliency Plan
Another person mentioned a county-wide resiliency plan. The heads of multiple Harris County departments had worked on it for months. At the eleventh hour, people in Hidalgo’s office with no experience rewrote everything that people withexperience had developed. “It just changed completely,” said one person involved.
Transportation Plan Stalled
Yet another person told me, “In Hidalgo’s mind, if you’re building a road, you’re doing taxpayers a disservice. Philosophically, she’s into multi-modal transportation. But a lot of times, she misses the point that the county is only allowed to do what the state of Texas allows it to do. That’s where they’ve had more problems. Their thought process a lot of times was, ‘Well, if they want to sue us for that, then they can.’ We’ve seen that play out several times.”
Other sources told me about progress on various components of Harris County’s Transportation Plan.
Nothing notable has happened lately on Low Impact Development, Green Infrastructure, or other environmentally-friendly projects.
Lack of Clarity, Direction
Another major problem contributing to the chaotic work environment: lack of clarity and direction. One mid-level manager told me, “We would often be moving in a direction when everything kind of went on pause because we were waiting to see which direction to go. But we couldn’t ever narrow down a direction. It felt as if, in every single Commissioners Court meeting, we spent all day watching mommy and daddy fight. Even among the Democrats.”
Lack of Attention to Operational Details
Former managers of various Harris County departments also complained about lack of attention to operational details.
“Ellis’ office and the Judge’s office would work together to develop these big picture concepts of where we were going. But it was never clear how we would get there,” said one person.
“We’d sit there and go, ‘Well, that’s great. But you didn’t set up any funding for it. For example, we talked about big sweeping programs like MWBE – the Minority/Women-owned Business Enterprise program. That was four years ago and it’s still not off the ground.”
Hiring People Without Relevant Experience
They hired Pamela Chan to set up the new Harris County Department of Economic Equity and Opportunity. According to one person I talked to, Chan was a “a great academic,” but had no real-world, operational MWBE experience. Another said, “the guidance and support that Chan got was like almost nil and then she’d get beat up at court.” She soon left. That department has had two executive directors in a little more than a year.
According to many of his employees, Noriega’s lack of IT understanding contributed to high turnover beneath him at multiple levels. And that rapidly compromised the integrity of systems.
Noriega also pushed out people with excellent professional credentials and replaced them with political appointees in many cases.
Not long after Noriega took over the department, he lost his Chief Administrative Officer, Chief Operating Officer, Chief Technology Officer, and Chief of Cybersecurity (twice).
The department also lost 100% of its group directors beneath them and approximately one third of its employees in 17 months.
So many employees have left that the department doesn’t even put names on org charts anymore.
Incomprehensible Org Chart Without Names Revised More than 30 Times
In fact, the department doesn’t even call organization charts ‘org charts’ anymore. It refers to them as its “ecosystem.” See below.
At this point, the chart above has reportedly gone through more than 30 revisions under Noriega. Yet multiple sources told me, “No one understands it.”
Toxic Work Environment Accelerates Already High Turnover
The work environment in Universal Services has become so toxic according to sources that approximately one third of the department has left in 17 months and the rate of attrition is reportedly accelerating.
Universal Services org charts updated the day before Commissioners Court appointed Noriega the permanent department head show everyone who left since his arrival. The source told me that some positions have turned over more than once. So this 12-page chart understates the numbers involved. It shows that at least 134 people have left since Noriega assumed command. That’s out of approximately 400 to 450 total employees. The highlighted names represent people who left the organization in the last 17 months.
One third of a workforce turning over would not be surprising in fast food. But these are professional jobs with highly skilled people doing complex work that few understand.
Noriega reportedly tried to dismiss the turnover. But significantly, 100% of his group directors left, leaving much of the department rudderless, especially since Noriega did not have an IT background himself.
If that percentage holds true in IT, losing one third of your workforce would cost one third of your payroll.
Self-Inflicted Damage
Some damage has been self-inflicted. While most IT companies let employees work remotely, Noriega forces managers to come into the office. This policy goes against the industry norm and has reportedly contributed to several of the departures at the managerial level.
“It’s Scary.”
One former IT employee told me Universal Services has refilled so many positions with inexperienced people that “They can’t even support the simple stuff. It’s scary.” This person called the replacements “Garcia’s puppets.”
Commissioner Adrian Garcia recommended Noriega for the job. Another Garcia loyalist, James Henderson, is Universal Services new Deputy Executive Director and Chief Operating Officer. They have reportedly replaced many departing employees with people loyal to Garcia.
Can It Be Saved?
When the department’s crucial JWEB program went down recently, IT staff reportedly worked 8 hours on and 4 hours off around the clock trying to restore the system. But they couldn’t get it back up. So, hundreds of criminal suspects didn’t receive probable cause hearings in time and had to be released.
A former manager in the department told me, “I don’t think enough meat is left on the bone to fix what’s going on there.”
Harris County’s annual budget next year will exceed $3.5 billion. We’re one third of the way through a $5 billion flood bond. And these are the custodians of our tax dollars.
Posted by Bob Rehak on 5/1/2022
1706 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/2022/05/Universal-Services-Ecosystem-V.25-their-version-of-org-chart-e1651429500897.png?fit=1200%2C600&ssl=16001200adminadmin2022-05-01 14:43:572022-05-19 11:32:14Editorial: “Chaos” in Harris County Government
