Equity Myth Buster: “Rich Neighborhoods Get All the Flood-Mitigation Funding”

A myth being promulgated in Harris County Commissioners Court and certain low-to-moderate income (LMI) watersheds these days goes something like this:

  • The FEMA Benefit/Cost Ratio (used to rank grant applications for flood-mitigation projects) favors high-dollar homes.
  • That disadvantages less affluent, inner-city neighborhoods compared to more affluent suburbs.
  • Therefore, less affluent neighborhoods get no help and the more affluent neighborhoods get it all.

This post busts that myth. But it won’t stop activists from demanding more “equity.”

If you look at all flood-mitigation spending in Harris County since 2000, on average, less affluent watersheds already receive 4.7X more partner funding per watershed than their more affluent counterparts.

Analysis of data obtained via FOIA request

Myth Ignores Other Factors, Frequently Leaps to Wrong Conclusions

Like much of political discourse these days, the myth focuses on a narrow sliver of truth, ignores other factors, and frequently leaps to the wrong conclusions.

An analysis of Harris County Flood Control District data going back to the start of this century shows how far off the myth can be.

There are dozens of different ways to slice and dice the data. I’ve looked at most of them and validated “dollars invested” with aerial photography.

Today, I focus on partner grants because they represent such a huge percentage of the flood-bond budget and because there is so much misinformation floating around about them.

And I will look at partner funding from the standpoint of outcomes, not just processes (as in the myth).

Methodology for Analysis

For this analysis I obtained Harris County Flood Control District spending data between 1/1/2000 and 9/31/2021 via a Freedom of Information Act (FOIA) request. I requested the data by watershed, decade, pre-/Post Harvey, source of funding (local vs. partner), and type of activity (i.e., engineering, right-of-way acquisition, construction and more). I cross-referenced this with other data such as flood-damaged structures, population, population density, and percentage of low-to-moderate income (LMI) residents.

When considering grants, the percentage of LMI residents in a watershed takes on special significance. Department of Housing and Urban Development (HUD) grants often require high percentages of LMI residents in the area under consideration.

In the charts below, you will see references to watersheds with LMI populations above and below 50%. Above 50% means more than half the residents in the watershed have an income LESS THAN the average for the region. Below 50% means more than half the residents earn more than the regional average.

Harris County has 23 watersheds. Eight have LMI percentages above 50% (less affluent). Fifteen have LMI percentages below 50% (more affluent).

When reviewing the charts below, pay particular attention to the italicized words: Total, Partner, and On Average. They represent three different ways to look at the same question: Do housing values disadvantage an area when applying for grants?

For this analysis, I focused only on the long term, since decisions on more than a billion dollars in flood-bond grants are still outstanding.

FOIA Analysis Contradicts the Popular Myth

One of the first things you notice when you look at watersheds above and below 50% LMI, is that the eight least affluent watersheds have gotten more than 60% of all dollars actually spent on flood mitigation since 2000.

Less affluent watersheds, despite being half as numerous, received 60% of all dollars since 2000.

Because the allegation was that partnership grants favored affluent areas, I then analyzed whether partner dollars went mostly to affluent or less-affluent watersheds. The answer is less affluent…overwhelmingly.

More than 70% of all partner dollars in the last 22 years went to the eight less-affluent watersheds.

The last observation by itself is telling. But because of the widely different number of watersheds in each group, I also wanted to calculate the average partner dollars per watershed in each group. This blows the “rich neighborhoods get all the grants” argument to pieces. Less affluent watersheds got, on average, 4.7X more.

Dividing the total partner dollars by the number of watersheds in each group shows that less affluent watersheds average 4.7X more than affluent ones.

This busts the myth. But digging even deeper into the data reveals two things: wide variation between sources of funding and within LMI groupings.

USACE Funding Skews Partner Totals

The U.S. Army Corps of Engineers (USACE) accounts for much of the partner funding. USACE has provided significant funding for projects in the Sims, Brays, White Oak, Hunting, and Greens Bayou watersheds. The Clear Creek watershed will also soon see work on a new USACE project. USACE has completed its planning process and proved positive benefits to national economic development. That made projects worthy of Federal investment. 

Halls Bayou: Digging Deeper

The Halls Bayou watershed also went through the USACE planning process, but the results did not show enough flood-damage-reduction benefits to outweigh the costs of the proposed projects. Thus, the Halls Bayou watershed currently has no USACE-funded projects.

Despite that, Halls has received more partner funding than 16 other watersheds since 2000. Only two watersheds in the affluent group of 15 received more partner funding. See the table below.

Total and partner spending by watershed since 2000 arranged in order of highest to lowest LMI percentages.

USACE also evaluated the more affluent Buffalo Bayou; results showed that costs outweighed the flood-damage-reduction benefits there.

Despite Halls having the highest percentage of LMI residents in Harris County, Halls has received more total funding and 2.5X more partner funding than Buffalo Bayou in the more affluent group.

FEMA Considers More than Home Values, Not All Grants Come From FEMA

While it’s true that FEMA considers housing values as a factor in benefit/cost ratios, benefit/cost ratios (BCRs) also consider factors such as:

  • The number of structures damaged
  • Threats to infrastructure
  • Proximity to employment centers
  • Need for economic revitalization
  • Percentage of low-to-moderate income residents in an area
  • Number of structures that can be removed from the floodplain by a project.

And not all grants come from FEMA. For instance:

So don’t settle for soundbites. They often mislead.

Posted by Bob Rehak on 12/30/2021

1584 Days since Hurricane Harvey

“Excluding” Partner Funds Could Lead to Shortfalls in Flood-Mitigation Funding

The new Harris County Administrator has proposed “excluding” potential partner funds from consideration in the allocation of flood-bond and flood-resilience trust dollars. There’s only one problem with that. Without partner funds, there won’t nearly be enough money to cover all the proposed flood-mitigation projects in the bond, the trust, or future bonds.

The conclusions above come from comparing projected project totals in the 2018 flood bond with the December 2021 flood-bond update that Harris County Flood Control District (HCFCD) provided to County Commissioners. The exercise also illustrates why people who are TRULY interested in making informed decisions about HCFCD’s Bond Program need to dig deep into the data.

Making conclusions based on hearsay or a glance at a chart could be self-defeating. There is more to the story. 

Partner Funds Make It All Possible

We anticipated 43% of the dollars in the flood bond would come from partners such as FEMA, HUD and the TWDB. We also anticipated it would take another 16% in local matching funds to attract the 43%. So 59% of the flood bond revolved around partner funds. Only 41% was local cash to pay for projects totally out of pocket.

From the project spreadsheet approved by voters in 2018.

Excluding Partner Funds Could Accelerate Construction in LMI Neighborhoods, Deny Others

David Berry, the County Administrator, proposed the partnership exclusion to accelerate construction of projects in Low-to-Moderate Income (LMI) watersheds, such as Halls. Halls, in particular, has waited on grant awards from the US Department of Housing and Urban Development (HUD) longer than most.

A HUD decision is expected sometime in January, according to the Texas General Land Office, which distributes HUD grants in Texas. So it’s not clear how much residents gain by Berry’s proposal. And they could lose big.

Most of the HUD grant applications for Halls are on a 90:10 basis, meaning the local share is only 10%. So excluding these grants means increasing the local contribution for that portion of the budget by 9X. That could cost local taxpayers hundreds of millions of dollars. For instance, HCFCD budgeted $500 million for Halls drainage alone. 90% of that is $450 million…to cover 2.4% of the county!

The effect would be to take money from affluent watersheds – which don’t qualify for HUD 90:10 grants – and shift it to LMI watersheds. No one then would get the grants and something would have to give somewhere down the road.

One Third of Way Through Flood Bond: Good Time to Take Stock

At the end of this month, exactly one third (3 years, 4 months) of the 10-year flood bond will have expired. So this is a good time to review spending versus projections.

Thirty-three percent of the way in, we’ve expended a little more than 16% of the flood-bond funds. While that may sound like a slow start, one must consider project lifecycles. Projects start with studies (feasibility, preliminary engineering, final engineering, design). These determine and validate cost projections. They also form the basis for grant applications, a plan and bids. But they are the least expensive part of a project. Together, they comprise only one eighth of project costs.

The expensive parts follow. They include right of way acquisition and construction. Those comprise more than three-quarters of all project costs. See the pie chart below which shows averages for the last two decades.

Average percent of costs in various project stages since 2000. ROW (Right of Way) Acquisition includes purchase of land upon which projects will be built.

For most flood-bond projects, we’re just now getting to the expensive phases. So I wouldn’t worry too much about that 16% overall average right now.

Spent/Unspent Funds by Watershed Gives Greater Insight

You can gain more insight by looking at spent and unspent dollars in each watershed.

Height of bars shows total amount budgeted per watershed in flood bond. Blue areas show dollars spent to date. Does not include any funds spent prior to flood bond.

From the charts above and below, you can see that spending rates vary widely among watersheds. Brays has consumed 57% of its budget already. On the opposite end of the spectrum, Sims has consumed just 1.6% of its. Why the wide variation?

To understand, we need to look at unique circumstances in each watershed. The chart below makes it easier to see actual spending as a percent of the budget that voters approved for each watershed in the flood bond.

Percentages represent the portion of budget spent to date. See discussion below for explanations of ranks.

The height of some of the bars above could be “predicted” by referring to the flood bond equity prioritization framework. Brays and Greens Bayous, for instance, are two watersheds with high percentages of LMI residents (58% and 57% respectively).

But others cannot. More than half the residents in Goose Creek/Spring Gully, Hunting, White Oak, Halls, Vince and Sims Watersheds also qualify as LMI. But dollars spent to date in those watersheds are far lower as a percent of the total budget. To see why, you need to put the numbers in a bigger context that includes:

Investment Prior to Flood Bond

Size of Total Budget for Each Watershed

Percentage of Partner Funds

Grant Application Status

Stage of Project Lifecycle

Bigger Context Shows Reasons for Variance

Brays and Greens had a large number of shovel-ready projects that had already been studied and approved when the flood bond passed. They were just waiting for dollars to become available. So they had head starts.

Other factors explain LMI watersheds further down the curve:

  • Sims received $380 million in federal funding for 23 Army Corps projects that finished construction by 2015. As a result, Sims was the only bayou in Harris County that stayed within its banks during Harvey. None of that spending shows up in the Bond Program charts. Because it’s already done! 
  • White Oak received full funding in the Bi-Partisan Budget Act of 2018. The Army Corps also started addressing many projects there before the flood bond.
  • Vince lies wholly within the City of Pasadena and is primarily the City’s responsibility.
  • Halls is the poorest watershed (71% LMI) and has only spent 6% of its projected budget to date. Lest you attribute this to racism, understand that the bond allocated more than HALF A BILLION DOLLARS to Halls. In percentage terms, the $29 million dollars spent to date looks small. But in absolute dollars, it outranks 15 other watersheds.
  • Far more affluent watersheds – such as Buffalo Bayou, Cedar Bayou, the San Jacinto River, Barker, Willow Creek, Armand Bayou, Galveston, Luce Bayou and Jackson Bayou – have each received fewer dollars from the flood bond than Halls.

HCFCD had just finished a watershed plan for Halls Bayou in 2018 when the flood bond passed. That explains the size of the watershed budget as well as the late start compared to Brays, White Oak, Greens, and Sims.

Other factors also explain affluent watersheds further up the spending curve, such as Little Cypress. HCFCD started working on that watershed long before the flood bond, too. Dollars spent to date on Little Cypress primarily reflect right-of-way acquisition costs, not construction. It’s also important to understand that the total budget for Little Cypress is only 37% of the total budget for Halls.

Creating a Win-Win For Everyone

In another three years and four months, these charts will look totally different than the ones you see today. Construction costs will surge for some and be long gone in the rear view mirror for others.

In my opinion, we need to stop creating chaos with endless tinkering in the bond program. The people have spoken. Leaders should listen. Let’s stop changing the allocation formula, focus on construction, and work like hell to win those grants. Then everybody wins.

Posted by Bob Rehak on 12/28/2021

1582 Days since Hurricane Harvey

Flood-Bond Update through End of November 2021

At the last meeting of Harris County Commissioners Court, Harris County Flood Control District (HCFCD) released a flood-bond update that shows spending through the end of November 2021. It provides a quick and easy way to see what your money is being spent on and where it is going. This differs from data reported recently from my FOIA Request. That data goes back to 2000 and looks at data pre- and post-Harvey, not just the start of the flood bond.

November Highlights

Below, some of the highlights from the November spending update:

  • Professional services invoices paid to date total $296 million. In November, payments totaled $338 thousand. Three quarters of that amount went to minority- or women-owned businesses.
  • HCFCD has awarded $354 million in construction contracts. Five more were awarded last month totaling $335 thousand.
  • Total spending since the approval of the flood bond through the end of November totaled $885 million. Of that, $447 million came directly from bond funds. Another $321 million came from grants. Other local funds totaled $117 million.
  • Three years into a ten year bond program, we’ve expended 17.9% of the anticipated total.
  • Home buyouts continue to drag out. HCFCD has completed 676, but 613 remain in the pipeline.

GANNT Charts Show Progress in All Watersheds

The San Jacinto River Basin has 10 active projects in various stages of development. Cypress Creek has 10. And Spring Creek has 4. To see what stage they are at, see the GANNT Charts on Pages 4 through 9.

Brays Leads Dollar Derby By Wide Margin

Brays Bayou still leads the dollar derby by a factor of two compared to the next three contenders. Brays has received $162 million flood-bond dollars to date. Cypress Creek, Addicks, and Greens Bayou have each received approximately half that. Then there are all others.

Where your flood-bond dollars have gone through the end of Nov 21..

This report PDF also contains maps that show:

  • Dollars spent in each watershed through the end of November.
  • Dollars funded in each watershed through the end of November.
  • Active maintenance projects and their values in December.
  • Active capital projects and their values in December.

The visual nature of this report makes it easy to see where your money is going at a glance.

Posted by Bob Rehak on 12/20/2021

1574 Days since Hurricane Harvey

Widening of Hunting Bayou Kicks into High Gear

Widening of Hunting Bayou, one of the poorest and most flood-damaged watersheds in the county, is kicking into high gear.

Annual Rate of Spending Almost Quadruples since Harvey

According to data obtained as part of a Freedom of Information Act (FOIA) request, Harris County Flood Control District and its partners (mainly the Army Corps and City of Houston), spent $44 million on flood mitigation in the Hunting Bayou watershed between 1/1/2000 and Hurricane Harvey.

That averaged $2.4 million per year for those 18 years. However, in the 4 years since Harvey, HCFCD has spent $37 million – more than $9 million per year.

That rate of spending averages 3.75X higher after Harvey than before.

HCFCD Spending Data Obtained via FOIA Request

Here’s a breakdown.

From FOIA Request. Hunting Bayou flood-mitigation expenditures by time period and category since 1/1/2000 through end of third quarter 2021.

Focus of Current Construction Activities

The upstream portion of Hunting Bayou parallels the south side of Loop 610 for most of its length. Where North Loop 610 turns south, Hunting cuts under it between McCarty and Wallisville Roads. From there it continues east. It then turns southeast at San Pedro Street and eventually joins Buffalo Bayou and the Ship Channel.

Note width of floodplains in red box. HCFCD is now widening Hunting between the left and right boundaries of the box. From Harris County Flood Education Mapping Tool. Blue = 100-year. Green = 500-year floodplain.
Current HCFCD Projects along Hunting Bayou. Compare to pictures below.

Poor, Industrial, Flat, Flood Prone

The Hunting Bayou watershed has the second highest percentage of low-to-moderate income (LMI) residents in the county (69%) after Halls Bayou (71%) immediately to the north.

Hunting also is heavily industrialized with rail yards, tank farms, manufacturing, and shipping companies. The highest points of land are the railroad tracks. Within the red box above, you can see how they affect the flood plain.

After driving around the neighborhoods along Hunting Bayou for an entire day, it appears that the worst storm damage is in the red box above. Many homes are boarded up and abandoned in this area. Others have been elevated. Some have been renovated and are waiting for the next flood.

Current Construction Photos of Bayou Widening Efforts

HCFCD bayou-widening efforts focus on this area right now. They extend from US59 on the west to approximately Wayside Drive on the east. Bayou widening may be an understatement. HCFCD appears to be creating a long series of connected detention basins, some more than 450 feet wide and several city blocks long that narrow at bridges.

This should help drain water from nearby neighborhoods during heavy storms. See pictures below all taken on Sunday, 12/19/2021. They generally trend from west to east, starting at US59 and heading downstream.

Looking east at first of numerous ponds along channel of Hunting Bayou. Photographed from over US59. Loop 610 is in upper left.
Looking east over Hunting Street. Loop 610 on left. Note new hike and bike trails in this and other pictures below.
Looking east from Kashmere Street at a previously excavated area now covered with grass and newly excavated areas beyond it.
Looking east from over Wipprecht Street at work in progress.
Looking east toward Lockwood from Pickfair Street and one of the constrictions mentioned above.
Closer shot of constriction at Lockwood.
Looking east from Hutcheson Park
Opposite angle. Looking west over expanse of Hutcheson Park. Loop 610 on right.
Looking NE from the eastern end of Hutcheson Park, where Hunting cuts under 610.
Looking NE from over Loop 610 toward Homestead Detention Pond in background. Kelly Street cuts left to right through top of frame.s
Looking east from over Homestead at limit of current downstream work.

Funding Flows to Damage

Altogether, the current excavation work stretches 3.33 miles.

In the last five major storms (Allison, Tax Day, Memorial Day, Harvey, Imelda), 15,763 structures have flooded along Hunting Bayou. That ranks 7th among all Harris County Watersheds. But one must remember, that Hunting, comprises only 31 square miles. That ranks it 19th in size out of 23 watersheds. The damage per square mile ranked #2 (508.5 structures).

Another reason spending has accelerated here is political policy – namely the Equity Prioritization Framework implemented a year after the flood bond passed.

As with other watersheds, such as Halls, Greens, Brays and White Oak, it’s virtually impossible to grasp the scope of construction from the ground. That’s one reason why people in these watersheds complain they get no help from HCFCD when they are.

To learn more about this and other flood-mitigation projects in the Hunting Bayou watershed, visit this HCFCD page and click on the projects in the left hand column.

Posted by Bob Rehak on 12/19, 2021

1573 Days since Hurricane Harvey

White Oak Bayou Gets A Makeover…Again

Since 2000, White Oak Bayou has received $386.8 million in Harris County Flood Control (HCFCD), federal, and local partner funding. That ranks it #2 in dollars received among all 23 Harris County Watersheds, second only to Brays Bayou at $544.5 million. Data received via a Freedom of Information Act (FOIA) request, showed that these two watersheds alone have received close to a billion dollars out of $3 billion spent between 1/1/2000 and the end of the third quarter this year. Said another way…

Two watersheds out of 23 received about a third of all HCFCD flood-mitigation spending in the last 22 years.

Analysis of Data from FOIA Request

I flew over Brays Bayou earlier this year and documented all the construction there. Friday, I droned White Oak Bayou from FM1960 to south of West Little York, a distance of more than 11 miles.

White Oak is difficult to photograph. As with Brays, homes and apartments back up to White Oak almost the entire way. They largely conceal most of it from public view except near bridges. Those homes and apartments also conceal the magnitude of construction from public view.

A Low-to-Moderate Income Watershed

Within the watershed, White Oak has slightly more low-to-moderate income (LMI) residents (51%) than those who earn above the average for the region. Other interesting stats:

  • It comprises 111.1 square miles. That ranks #6 among all watersheds.
  • White Oak has 468,214 people. That ranks #3 among all watersheds.
  • White Oak ranks #3 in total damage and #5 in damage per square mile.

Continuous Improvement for Decades

Money has poured into the White Oak watershed – as it has for Brays – because of the large number of flooded structures and associated damage. White Oak has had almost 26,000 structures flooded in the last five major storms – Allison, Tax Day, Memorial Day, Harvey and Imelda. That ranks it #3 in total damage among all 23 Harris County Watersheds.

And as we have seen repeatedly, funding flows to damage.

The 2018 Bipartisan Budget Act helped fund the latest round of construction shown below on White Oak as well as Hunting and Brays Bayous. All three started more than 20 years ago and advance sporadically as more money becomes available.

Fighting Constrictions of Development to Make Room for More Floodwater

The photos below show HCFCD’s and the Army Corps’ commitment to completing a number of major projects along White Oak. Residential and commercial developments pressing against the bayou along its length make that difficult. They leave little room for widening to accommodate more floodwater. As a consequence, HCFCD is forced to buy out whole subdivisions to make room for detention basins.

Regardless, I photographed an impressive amount of construction along the length of White Oak between FM1960 and West Little York. Below are 10 out of more than 120 photographs. I took them all on 12/17/2021.

White Oak Bayou widening and deepening. Photographed from Kari Court.

Note how close houses are to the channel. Making more “room for the river,” as the Dutch say, would require buying out many of the homes you see below. 

White Oak Bayou photographed from over Lewis Street.
Looking upstream at White Oak from Gessner
Looking downstream from Gessner. Another example of not leaving “room for the river.” t
Looking SW across large detention basin. White Oak cuts through top of frame from left to right. Fairbanks North Houston cuts through top of frame on right.
Looking NE from over Fairbanks North Houston. White Oak cuts through center of frame. Note Greenspoint on horizon, right of center.
White Oak near Antoine, looking S toward downtown and Galleria on horizon.
White Oak from Tall Pines Drive looking SE.
White Oak from Deep Forest Drive looking downstream.
Looking upstream at White Oak from Antoine. The fairways of the golf course in the upper right will eventually become more detention basins.

Many Project Along Bayou Still Pending Buyouts

HCFCD currently has $45 million in ACTIVE construction projects underway in White Oak Bayou. But many more construction projects along the bayou are still pending buyouts to make way for more detention basins.

Of the $386 million spent on White Oak in the last 23 years, $235 million has gone to buyouts and right-of-way acquisition compared to $90 million so far for construction. White Oak buyouts have cost 2.6X more than construction. Normally, buyout and construction costs differ by only a few percentage points.

That tells you how how many homes and businesses are overcrowding the flood plain!

And that brings to mind my grandmother’s favorite saying, “An ounce of prevention is worth a pound of cure.”

The 2018 Flood Bond allocated more than $490 million for 16 projects in the White Oak Watershed. However, only $88 million has been spent since Harvey. So, White Oak will receive another $402 million before bond projects are completed. Eventually, White Oak conveyance improvements between 2000 and the end of the bond fund will total $788 million!

But at this point, we’re less than halfway there.

To learn more about HCFCD’s active projects in the White Oak Watershed, visit this page.

Posted by Bob Rehak on 12/18/2021

1672 Days since Hurricane Harvey

Move by Dems Could Mean Flood-Bond Projects in Outlying Neighborhoods Never Get Built

Harris County Commissioners Court considered a motion today by the County Administrator to change the prioritization of flood-bond projects for the fourth time. By a 3-2 party-line vote, they approved a proposal that could soon lead to depriving outlying neighborhoods of flood bond funding. The vote today was preliminary. Before they take a final vote, they will submit the proposal to the Community Flood Resilience Task Force (CFRTF) for input, then take a final vote in 60 days. Based on past experience, the CFRTF will likely rubber stamp the three recommendations in the proposal:

  • Exclusion of partner funding
  • Inclusion of street flooding in 500 year floodplain
  • Counting people not structures when measuring benefits

Exclusion of Partner Funding

The exclusion of partner funding will mean that 90% match grants from the US Department of Housing and Urban Development (HUD) will no longer be available to anyone. Inner city neighborhoods will use flood-bond money to complete their projects instead of HUD money. And more affluent, outlying neighborhoods do not qualify for HUD grants.

County Judge Lina Hidalgo, Precinct 1 Commissioner Rodney Ellis, and Precinct 2 Commissioner Adrian Garcia all admitted during debate that there wasn’t enough money to complete all the bond projects. But they voted to consider the allocation changes regardless.

Precinct 4 Commissioner Jack Cagle and Precinct 3 Commissioner Tom Ramsey also agreed there wasn’t enough money to complete all bond projects. However, they voted against the proposal.

The 3-2 vote will send the proposal to the CFRTF for input. To date, the CFRTF has rubber stamped everything proposed by Democrats that benefits low-to-moderate income (LMI), inner-city neighborhoods at the expensive of outlying neighborhoods.

That means construction funds may not be available for outlying projects by the time inner city neighborhoods complete theirs.

Those who compiled the list of bond projects were counting on approximately $2.5 billion in partner funding. The Flood Control District has already secured more than a billion just three years into a ten year bond. But this move could now jeopardize a large portion of the remaining partner funding.

Inclusion of Street Flooding

Not one project in the flood bond addressed street flooding. That is not within HCFCD’s scope of responsibility.

Regardless, Commissioner Garcia said, “People don’t care where they flood from. They just want it fixed.” He never addressed the budget issue or who was responsible for cleaning out those roadside ditches – Garcia, Ellis, Turner and other City mayors!

Expanding the scope of the bond and eliminating partner funding will mean even fewer dollars left over to address flooding in outlying neighborhoods.

I have photographed hundreds of clogged roadside ditches like these in watersheds inside Beltway 8. Dems now want to use what’s left of your flood bond money to clean them out even though the flood bond never mentioned them.

Counting People Not Structures

Typically, the objective of flood-mitigation projects is to remove structures, not people, from a flood plain. By counting people, not structures, in an evaluation matrix, you push funding toward more densely populated neighborhoods. Normally, helping more people is good. But what if the density is vertical, not horizontal?

Let me give you an example. Consider an apartment building with a hundred residents. But none lives on the ground floor.

Now consider 25 single family homes each with three people. All live on the ground floor.

Project A could take a 100 people out of the flood plain whose apartments would not flood. Project B would take 75 people out of the floodplain and prevent damage to 25 structures that would flood. Should A or B get the flood-mitigation project?

This provision would also drive funding away from outlying neighborhoods which generally have fewer apartments.

The People Spoke and Are Being Ignored

The People – with a Capital P – voted on the flood-bond and approved it overwhelmingly. Now its being repeatedly changed by a few individuals to push ever more funding to inner-city neighborhoods which already get the lion’s share. These latest moves could deprive outlying neighborhoods of construction dollars needed to complete projects.

Seems to me that the three Dems and their proxies are depriving half the county of their votes and taxes.

The two Republicans on Commissioners Court, Precinct 4 Commissioner Jack Cagle and Precinct 3 Commission Tom Ramsey, argued against the changes.

Commissioner Cagle argued that “We must do what we say. We must work on projects in the bond.” He went on, “Changing the projects included in the 2018 flood bond is a bad idea. The promises we made to voters in 2018 are sacred. While I support the concept of asking to finance more flood mitigation projects in the future, the public has to know that we can be trusted to keep our word.”

Top 4 LMI Watersheds Receive 53% of All Funding since 2000

However, when you look at spending to date and the ever-changing “equity” guidelines, we’re far from approaching anything that resembles equity. And we’re getting farther from it with each round of changes to the so-called “equity” guidelines.

Four LMI watersheds out of 23 (Greens, Sims, Brays and White Oak) have received 53% of ALL funding since 2000, yet their representatives complain about historical prejudice and demand more.

Analysis of HCFCD Spending Data from 1/1/2000 through Q3 2021 obtained via FOIA request

For the record, that’s $1.6 billion out of $3.1 billion during the period of comparison.

Top LMI Watersheds Get More than Twice as Much as Top NON-LMI Watersheds

Comparing those 4 LMI watersheds with the most dollars to the four NON-LMI watersheds with the most, we can see that LMI watersheds have received more than two dollars for every dollar received by a non-LMI watershed.

Pie represents total dollars spent among top four LMI and NON-LMI watersheds. An LMI watershed is one where more than half the residents earn below the average annual income for the region.

The four LMI watersheds receiving the most money included Brays, Greens, Sims, and White Oak Bayous.

The four NON-LMI watersheds receiving the most included Cypress Creek, Addicks, San Jacinto and Buffalo.

All dollars include HCFCD and partner spending from 1/1/2000 through Sept. 30, 2021.

Bottom 4 LMI Watersheds Get 3X More than Bottom 4 NON-LMI

At the opposite end of the spectrum, the four LMI watersheds receiving the least money have received 3X more dollars than the four lowest NON-LMI watersheds since 2000.

Comparison of total dollars spent in the four lowest LMI and NON-LMI watersheds since 2000 through the end of Q3 2021.

There are only 8 LMI watersheds hence the comparison of groups of four.

  • The four LMI receiving the least dollars since 2000 include Halls, Hunting, Goose Creek/Spring Gully, and Vince.
  • The four NON-LMI watersheds receiving the least include Luce, Galveston, Jackson and Carpenters.

But what about those other NON-LMI watersheds in the middle of the spending pack? Simple. Altogether, the scale is already so tilted, they can’t tilt the balance back much. See comparison below of ALL LMI and NON-LMI watersheds.

LMI vs. Non-LMI flood-mitigation funding
LMI vs. Non-LMI flood-mitigation funding through Q3 2021 for ALL watersheds. Note Non-LMI watersheds outnumber LMI watersheds almost 2:1, yet have gotten only a little more than a third of total funding.

Partner Funding Also Favors LMI Watersheds, Not Affluent Ones

Anyone who doubts the percentages above can check my calculations. Here’s the raw spending data for each watershed with percentages of low-to-moderate income residents – including pre- and post-Harvey spending.

I’ve also included partnership funding since 2000 for each watershed. Because the dollars involved vary widely and because Non-LMI watersheds outnumber LMI watersheds 2:1, the fairest way to compare partner funding is by looking at it as a percentage of total funding for each watershed since 2000.

Watersheds with a high percentage of LMI residents are not disadvantaged in total spending or partner funding. LMI watersheds are those with a percent of LMI residents above 50%.

During that period, 26% of all flood mitigation funding in Harris County has come from partners, such as FEMA, HUD, the Army Corps, TWDB or cities. However, LMI watersheds have attracted a higher percentage of partner spending: 30%.

While that’s not a huge advantage, it shows conclusively that LMI watersheds, as a rule, are not disadvantaged when it comes to partnership funding.

The correlation between total dollars and partnership dollars spent in all watersheds is not a perfect (1.0), but very high at .79.

In fact, the two highest partner percentages both belong to LMI watersheds (Sims at 55% of the watershed total and White Oak at 33%). The two lowest partner percentages belong to two of the most affluent watersheds (Willow Creek at 6% and and Barker at 3%).

This debunks another myth frequently heard in commissioners court, i.e., that partner dollars always go to the watersheds with the highest home values.

Conclusion: Organize, Protest

Outlying communities must organize and protest en masse before commissioners take a final vote on shifting even more dollars to LMI communities based on bad information. If they change the deal on this flood bond, they’ll do it again on the next.

Fool me once, shame on you. Fool me twice, shame on me.

Posted by Bob Rehak on 12/14/2020

1568 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.

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

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

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

Where Money Really Goes

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

LMI Watersheds Already Receive 61% of All Spending

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

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

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

Spending by watershed since 2000. Includes HCFCD plus partners.

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

HCFCD spending data through end of q3 2021.

Proposed Changes in Allocation Formula Could Accelerate Spending in LMI Watersheds

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

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

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

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

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

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

Posted by Bob Rehak on 12/13/2021

1567 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

Mitigation Spending Correlates Even More Strongly with LMI Population than Damage

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

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

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

How Correlation Works

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

Funding Correlates Strongly with Both LMI Population and Damage

Dollars spent on mitigation have the following coefficients of correlation:

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

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

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

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

Hypothesis to Explain High LMI Correlation

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

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

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

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

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

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

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

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

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

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

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

For proof positive, see the charts below.

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

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

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

Posted by Bob Rehak on 12/11/2021

1565 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

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

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

First Change in Flood-Bond Spending Priorities

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

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

Second Change in Priorities

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

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

Third Change in Priorities Attempted

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

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

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

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

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

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

Fourth Potential Change in Priorities

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

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

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

Key changes include:

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

Here’s my take on these.

Number of People

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

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

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

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

Excluding Partnership Funding

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

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

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

Inside AND Outside 100-year Floodplain

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

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

Where Will Extra Money Come From?

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

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

Belly Laugh of Day

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

He provides three pieces of backup to explain it:

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

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

Legislation Details – a blank page. See below.

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

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

So much for transparency!

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

1164 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

HCFCD Accelerating Spending on Mitigation Projects

Harris County Flood Control District (HCFCD) is accelerating its spending on flood mitigation projects. I compiled the chart below with data from a FOIA Request. This request parallels an earlier request at the end of the first quarter and includes spending through the end of the third quarter. In the 3.5 years since the flood bond, HCFCD has completed many preliminary studies and engineering designs. Now many projects are moving into the capital-intensive phases: Right-of-Way Acquisition and Construction.

Current Spending Rate is 8X over pre-Harvey Rate

Comparing the periods before and after Harvey, spending per month tripled. And comparing the last six months to the post-Harvey period, you can see that the pace accelerated another 2.75X. The average for the last six months is up a whopping 8X compared to the pre-Harvey period.

HCFCD Flood Mitigation spending is rapidly accelerating.

That’s good news.

Where/When Spending Occurred

The chart below shows where HCFCD has spent that money. It ranks watersheds by total spending. But within that, you can see tremendous variability between the pre- and post-Harvey eras. In some watersheds, such as Sims, HCFCD largely completed projects with its partners, before Harvey. In other watersheds, such as Little Cypress, you see the opposite. HCFCD accelerated spending on land acquisition as part of its Frontier Program to help prevent, rather than remediate flooding.

Looking at spending before and after Harvey shows the most watersheds ramping up spending as a few taper off.

Four Watersheds Have Received 53% of All Spending since 2000

The flood bond prioritization framework helps shape the curve above. It gives priority to low-income, socially vulnerable neighborhoods. Those projects started first while others wait.

Thus, most of projects in low-income watersheds cluster toward the left. Likewise, with a few exceptions, more affluent watersheds tend to cluster toward the right.

In the years ahead, as HCFCD completes more projects on the left and begins more projects on the right, the slope of the curve may change.

Spending continues to be concentrated in a handful of watersheds. Four have received more than half of all dollars since 2000.

In the meantime, however, looking at subsets of this data, reveals much about priorities. Only five watersheds out of 23 have been allocated significant dollars above the average.

If you took Cypress Creek out of that mix, four other watersheds would be at the average. And fourteen would be below it.

But the top four watersheds alone comprise 53% of all spending since 2000.

Additional Analysis to Follow

In the next few days, I will examine other aspects of spending and what drives it. Those other aspects will include, but are not limited to:

  • Where the most damage has occurred
  • Population density
  • Watershed size
  • Percent of low-to-moderate income residents
  • Partnership funding

More news to follow.

Posted by Bob Rehak on 12/9/2021

1563 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.