Tag Archive for: CDBG-DR

GLO Reviewing HUD Applications for Harris County Projects Totaling Half Billion Dollars

The Texas General Land Office (GLO) is currently conducting a final review on more than $498 million in grant applications from Harris County Flood Control District (HCFCD) and Harris County Community Services Department (CSD). That’s out of a total allocation of $1,072,033,863 allocated to Harris County. And that means projects for almost half the Harvey money allocated to Harris County will soon go to Washington for a final review by HUD.

Additional applications for the rest of the money will soon follow the projects listed below. They will be submitted “on a rolling basis,” according to Brittany Eck, a GLO spokesperson.

The GLO administers all HUD funds in the state of Texas.

GLO Working Side by Side with Harris County

GLO has a “Strike Team” embedded at HCFCD headquarters, working side by side with both CSD and HCFCD to eliminate any delays on the HUD applications. The billion dollars allocated to the county falls into several different programs, each with different deadlines and complex rules.

“We are currently in the ‘Eligibility Phase,’ which is the most critical, but also the most time consuming. During this phase we must ensure that the projects proposed sync with HUD regulations in terms of LMI beneficiaries, environmental impacts and more,” said Eck. 

No Performance Benchmarks Missed So Far

“It is important to note that Harris County has not missed a performance benchmark yet on the HUD applications. The GLO is working with Harris County to ensure all administrative paperwork is completed in accordance with federal regulations. This protects both Harris County and the State of Texas from incurring costly ‘findings’ during the post-project audit process.”

A finding during a post-project audit could potentially cause HUD to claw back part of its grant money. So it’s vitally important to ensure all regulations are followed to the letter.

Three Main Batches of Money

The three main pots of money include:

  • Harris County CSD – $208,152,174 in CDBG-MIT funds
  • HCFCD – $322,033,863 in CDBG-DR funds
  • HCFCD – $541,847,826 in CDBG-MIT funds

That brings the total of original allocations to $1,072,033,863.

Since this involves the government, it also includes acronyms. So let me explain some of the terms.

CDBG stands for Community Development Block Grants. These grants provide communities with resources to address a wide range of development needs, providing projects meet one or more of HUD’s three defined national objectives. Namely, a CDBG project must:

  • Benefit to low- and moderate- income (LMI) persons
  • Aid in the prevention or elimination of slums or blight and/or
  • Meet an urgent need (UN), especially one impacting public health and safety.

But what about the rest of those acronyms?

  • DR stands for Disaster Relief
  • MIT stands for Mitigation.

What’s the difference? According to HUD, CDBG-DR grants provide housing, infrastructure, and economic revitalization assistance to impacted areas. The CDBG-Mitigation (CDBG-MIT) program provides additional funding to lessen the impact of future disasters.

To learn more about HUD applications for the specific Harris County projects, see below.


Harris County CDBG-MIT

Harris County Community Services Department was allocated $208,152,174 in CDBG-MIT funds for infrastructure, planning, and project delivery.

The contract was executed on 08/31/2022. All projects in this batch of funding must close out by 8/31/27.

The $208 million breaks down into three subcategories.

  • Infrastructure programs – $154 million
  • Planning programs – $37.5 million
  • Project delivery – $16.7 million
Infrastructure Programs

Of 11 projects initially proposed in this category, the three largest in terms of dollar amounts – totaling $75M of the $154M – have been submitted for preliminary review.

$37,500,000.00Pine Trails Subdivision Drainage Improvements
Involves upgrading approximately 63,650 LF of drainage systems and developing two (2) detention ponds in Harris County Precinct No. 2. 
66.97% LMI
$20,545,326.00Ralston Acres Subdivision Drainage Improvements
Involves upgrading approximately 15,250 LF of drainage systems and developing two (2) detention ponds in Harris County Precinct No. 1 and Ralston Acres Subdivision.  
Income Surveys TBD
$16,954,674.00 North Forest Subdivision Drainage Improvements
Involves upgrading approximately 19,700 LF of drainage systems and developing one (1) detention pond in Harris County Precinct No. 1 and the North Forest Subdivision.  
Income Surveys TBD
As of 3/19/24

Planning Programs 

Four projects – costing a total of $16.5M out of the $37.5 million – have been submitted for preliminary review out of the 23 proposed planning projects.

$500,000.00 Harris County Multi-Jurisdictional Hazard Mitigation Plan
The Harris County Office of Homeland Security & Emergency Management is seeking to update the Harris County Hazard Mitigation Plan. The plan will develop strategies and action items to minimize vulnerabilities and damages and include 37 participating jurisdictions.
$12,500,000.00Drainage Master Plan for Unincorporated Harris County
The planning project will evaluate drainage infrastructure capacity status and deficiencies in Harris County’s unincorporated areas. It will also guide the identification and implementation of mitigation alternatives to reduce flood risk.
$500,000.00Halls Bayou Watershed Flood Risk Analysis Study
The scope of the Halls Bayou watershed study is to analyze the best available data incorporating the Halls Bayou watershed flood risk reduction-related project and to evaluate existing program benefits using the new Atlas 14 precipitation data to identify additional potential flood reduction needs within the watershed.
$3,000,000.00The Evacuation Routes Study
The Evacuation Routes Study aims to enhance transportation resilience in road-flooding-prone areas of Unincorporated Harris County.
As of 3/19/24

Project Delivery: 

$16,652,174 of the $208,152,174 County allocation will be used to administer the funds for projects.


HCFCD Disaster Relief

HCFCD was allocated $322,033,863 in CDBG-DR funds for infrastructure projects.

HCFCD submitted 13 projects costing a total of $317,494,724.78 for CDBG-DR grants and is putting up local funds in the amount of $45,899,821 for those same projects. All of the applications have been officially submitted and are being reviewed for HUD eligibility completeness by the GLO.

The HCFCD/CDBG-DR contract was executed on 11/27/2023 and must be closed out by 3/31/2026. The 13 projects include:

$20,361,143.56Arbor Oaks Stormwater Detention Basin
To construct one 431-acre-feet stormwater detention basin within the White Oak Bayou watershed. 
60.55% LMI
$20,247,760.00Isom Stormwater Detention Basin
To construct one 550-acre-feet regional stormwater detention basin within Halls Bayou. 
74.23% LMI
$8,692,644.00Lauder Stormwater Detention Basin
To construct one 341.47-acre-feet stormwater detention basin within Greens Bayou. 
78.10% LMI
$20,361,143.56Brookglen Stormwater Detention Basin
To construct one 33.45 acre-feet stormwater detention basin within Armand Bayou Watershed. 
52.54% LMI
$25,390,047.00Kluge Stormwater Detention Basin – Phase 3
To construct one 350 acre-feet stormwater detention basin within Little Cypress Creek watershed. 
14.25% LMI but qualifies under Urgent Need
$77,899,107.00Greens Bayou Mid-Reach Channel Conveyance Improvements
To rehabilitate 19,008 LF of channel conveyance along Greens Bayou. 
78.61% LMI
$18,878,499.00Cypress Creek Channel Rehabilitation, Main Stem, Batch 5
To rehabilitate 7,500 LF of channel conveyance along Cypress Creek. 
49.18% LMI, but qualifies under Urgent Need
$36,710,019.00Dinner Creek Stormwater Detention Basin ‐ Phase 1
To construct two (2) detention basins, northwest and southeast of Dinner Creek. 
52.36% LMI
$7,642,742.00Barker Reservoir Channel Rehabilitation, Repair Package 2
To rehabilitate 18,528 LF of channel conveyance at 19 different sites along Barker Reservoir. 
21.64% LMI but qualifies under Urgent Need
$9,742,750.00Stormwater Detention Basin along Jackson Bayou
To rehabilitate 2,025 LF of channel conveyance and construct one (1) 15 acre-feet stormwater detention basin within Jackson Bayou. 
60.78% LMI
$23,496,000.00Addicks Reservoir Channel Rehabilitation & Restoration, Repair Package 3
To rehabilitate 49,296 LF of channel conveyance at 49 sites along the Addicks Reservoir. 
37.04% LMI but qualifies under Urgent Need
$23,844,000.00East TC Jester Detention Basin – Compartment 1B
To construct one 725 acre-feet stormwater detention basin within the Cypress Creek watershed. 
36.14% but qualifies under Urgent Need
$12,293,732.00Keegans Bayou Stormwater Detention Basin Near Old Richmond Road – Phase 1
To construct one stormwater detention basin within the Brays Bayou watershed. 
56.71% LMI
As of 3/19/24

HCFCD CDBG-MIT

Harris County Flood Control District was allocated $541,847,826.00 in CDBG-MIT funds for infrastructure hazard mitigation projects.

Five projects – totaling $73 million – have been submitted for preliminary HUD eligibility completeness review out of the 19 mitigation projects originally proposed.

Overall Contract Status: Contract executed 11/07/2023

Projected Closeout: March 31, 2028

$3,235,715.00Halls Bayou Channel Conveyance Improvements Downstream of Hopper (HALLS HOPPER)
Includes widening approximately 4,525 LF of the existing channel along the left (east) bank from downstream of Hopper Road to just upstream of Pinewood Village Park. 
70.03% LMI
$10,427,946.00Hahl North Stormwater Detention Basin (Hahl North)
Includes construction of one 220 acres-feet of stormwater detention basin adjacent to Halls Bayou and the widening of approximately 2,100 LF of the existing channel along Halls Bayou. 
73.65% LMI
$17,300,036.00West TC Jester Stormwater Detention Basin
Will create one 414 acre-feet stormwater detention basin in the Cypress Creek watershed. 
36.13% LMI but qualifies under Urgent Need
$11,987,888.00Taylor Gully Channel Conveyance Improvements
Includes approximately 13,118 LF of stormwater drainage channel improvements in the affected stretch of channel.
20.92% LMI but qualifies under Urgent Need
$30,007,445.00Boudreaux Stormwater Detention Basin – Phase 1
Will build one 458 acre-feet stormwater detention basin west of Holderrieth Road along Willow Creek. 
33.59% LMI but qualifies under Urgent Need
Altogether, the HUD applications must benefit at least 50% LMI individuals according to HUD regulations governing these funds.
Taylor Gully Looking S from county line
Taylor Gully looking S from the Montgomery County Line. Up to 600 homes flooded twice here in 2019, after Perry Homes clearcut 270 acres without installing the required detention basin capacity. One of the HUD applications seeks to improve the channel.

Even though some projects drop below the 50% threshold, as a group they meet the requirement. Those that fall below the threshold also qualify under HUD’s Urgent Need mandate.

Extensions Requested, But Not Yet Confirmed

GLO has requested extensions for all these projects. While HUD reportedly seems favorable, written confirmation has not yet been received. That places a premium on HUD applications that can be executed quickly.

Posted by Bob Rehak on 3/19/24 based on information provided by the Texas GLO

2394 Days since Hurricane Harvey

Plum Grove, Splendora, Liberty, Others Receive HUD Grants Through GLO

GLO Commissioner Dawn Buckingham, M.D., announced yesterday more than $43 million in HUD grants for 44 infrastructure projects stemming from 2019 Disasters. The $43 million is the combined total of grants made to counties and cities stretching from the Rio Grande Valley to southeast Texas.

Counties where 2019 community development block grant disaster-relief (CDBG-DR) money will be distributed for infrastructure projects.

The infrastructure-project grants will help communities recover from the 2019 South Texas Floods as well as Tropical Storm Imelda, which devastated SE Texas.

List of Recipients

The funds will be used to improve streets as well as water and drainage facilities in:

  • Counties:
    • Cameron
    • Chambers
    • Harris
    • Hidalgo
    • Jefferson
    • Liberty
    • Montgomery
    • Orange
    • San Jacinto
    • Willacy
  • Cities
    • Beaumont
    • China
    • Combes
    • Daisetta
    • La Feria
    • La Villa
    • Laguna Vista
    • Liberty
    • Mercedes
    • Mission
    • Nome
    • Old River-Winfree
    • Orange
    • Palmview
    • Pasadena
    • Pine Forest
    • Pinehurst
    • Plum Grove
    • Port Arthur
    • Port Isabel
    • Primera
    • Rio Hondo
    • Santa Rosa
    • Splendora
    • Vidor
    • West Orange
    • Woodloch 

“Here to Help”

“Consecutive disasters have devastated communities in the Lower Rio Grande Valley and Southeast Texas, but the Texas General Land Office is here to help,” said Commissioner Buckingham. “These critical infrastructure awards will divert floodwaters away from homes, increase the resiliency of communities to respond to natural disasters, and restore peace of mind when the next storm hits.”

Texas GLO 2019 Disaster-Recovery Funds

The Texas General Land Office (GLO) is administering $227,510,000 in Community Development Block Grant Disaster Recovery (CDBG-DR) funds from the U.S. Department of Housing and Urban Development (HUD) related to 2019 flooding. This is separate from the $750 million in mitigation funding related to Harvey and Harris County.

Out of the $227.5 million, GLO allocated $61,430,000 in disaster recovery funds for infrastructure projects. They will assist disaster relief, long-term recovery, and restoration of infrastructure for local communities. The rest of $227 million was allocated to grants that help individuals recover.

GLO announced the opening of the application for eligible counties and cities on March 15, 2022. Applications closed on August 1, 2022. Each applicant was eligible to submit a total of two applications. All activities had to contribute to the long-term recovery and restoration of infrastructure.

The GLO recognizes that repair and enhancements of local infrastructure are crucial components of long-term recovery and viability of communities.

To learn more, visit https://recovery.texas.gov/2018-floods-2019-disasters/programs/2019-disasters-infrastructure-competition/index.html.

Plum Grove Drainage Improvements – $1,000,000

Tropical Storm Imelda released an unprecedented 3-day total rainfall amount of 28 inches on Plum Grove. That limited the city’s ability to provide an immediate response due to the inundation of flood water. As a result, this project will provide much-needed drainage improvements within Orange Branch Creek which is located in the middle of the city and runs from the northeast down to the southeast. The project will install culverts and restore roads.

Splendora Lift Station Drainage Improvements – $596,625

Imelda flooding submerged the Pinewood Lift Station site, as well as its emergency generator and electrical switchgear located at the northern intersection of Pinewood Drive and First Street. Loss of both primary and emergency back-up power led to a sanitary sewer overflow at Pinewood lift station. Vehicular access, including emergency vehicle access, was not possible because of the depth of flooding in the area. This project includes drainage and generator improvements at the Pinewood Lift Station.

Construction will include the following activities:

  • Regrade ditch and install double headwalls
  • Install reinforced concrete pipe culverts under First Street with road restoration and ditch regrading 
  • Install new natural gas generator and automatic transfer switch
  • Install an elevated metal platform, staircase and skid for generator

Liberty Water, Sewer Improvements – $1,000,000

The project will provide for water and sewer line improvements located within the eastern side of the city along Beaumont Road, Minglewood Road, Glenn Street and Tanner Street. These should reduce overflow concerns for residents and businesses along these streets. The project will make improvements to sewer lines and water lines and remove and replace existing lift stations with gravity sanitary sewer lines.

Descriptions of Other Grants

For a full description of other grants in this batch, see the GLO website.

Posted by Bob Rehak on 3/22/2023 based on information from the Texas General Land Office

2031 Days since Hurricane Harvey and 1280 Days since Imelda

Montgomery County Holding Three Meetings for Flood Victims Interested in Buyouts

Morgan Lumbley, Montgomery County’s Disaster Recovery Manager, will hold community outreach meetings in Spring, Conroe and Splendora in the next 10 days to explain buyout options for flood victims. “It is my hope that through positive engagement we can provide the ability for homeowners to relocate out of harm’s way,” said Lumbley. 

See specifics about times, dates and places in the poster below.

Anybody in Montgomery County may attend any meeting. Choose the most convenient.

The primary purpose of the meetings will be to explain FEMA’s 2021 Flood Mitigation Assistance (FMA) program, but Lumbley will also explain HUD’s Community Development Block Grant Disaster Recovery (CDBG-DR) buyout program.

If you’re a Montgomery County resident and you’ve ever wondered whether you qualified for a buyout, whether you could get fair compensation for your home, or how you could apply, these meetings are for you.

The meetings will cover:

  • Who qualifies (eligibility requirements)
  • For which type of assistance (FEMA vs. HUD)
  • How long it takes
  • The application process
  • How homes are valued
  • How to get help filling out the forms if you need it

Importance of Meetings and Timing

Lumbley described the meetings as community outreach. She needs to identify properties owners interested in buyouts and determine their eligibility. Once she does that, she will apply to FEMA for an FMA grant (Flood Mitigation Assistance) equal to the total value of all homes that quality.

The application process happens once a year. If interested, learn how to apply now.

“If we get awarded a grant,” said Lumbley, “those are the properties that we look to purchase first. Others may be considered only if someone drops out of the process.”

FEMA Requirements Explained at Meeting

The FEMA Flood Mitigation Assistance Grant basically has two requirements.

  • It has to be a severe repetitive loss or a just a repetitive loss property, as indicated by the National Flood Insurance Program (NFIP).
  • You must currently have a NFIP policy backed by FEMA. Private insurance is not eligible.

Lumbley cautions that getting a buyout can take years. “It’s not a tomorrow-type thing,” she said. “We may not have anything final for another year and a half to two years. So we’ll talk about that first. Then realizing that some may not qualify for FEMA’s program, we will also talk about HUD buyouts.”

FEMA Applications Due Back November 15th

Once Lumbley determines the number of homes that meet requirements, she will build a budget around those eligible homes. “We are basically saying to FEMA, ‘If you give us this money, these are the homes that we’re going to buy out. That’s how we establish the budget.”

“It all comes down to how many eligible individuals want to participate,” said Lumbley. “We will submit the county’s application to FEMA with five or a 100 homes.”

Definitions of Repetitive Loss and Severe Repetitive Loss

“Very specific definitions exist for repetitive loss and severe repetitive loss properties,” she said. “A repetitive loss property has had flood related damage on two occasions in which the cost of repairs averaged together equal or exceed 25 percent of the market value of the structure – at the time of the floods. Severe repetitive loss properties have had four or more separate floods, with each claim being $5000 or more. And at least two of those claims have to be within a 10 year period.”

“Another way to qualify as a severe repetitive loss is to have at least two separate NFIP claims that that total more than the market value of the structure,” she added.

Valuation

“We will write the county’s 2021 FEMA grant application to reflect current market value of homes. If FEMA approves that, applicants would get whatever the competitive open market value is on the day that the appraiser goes out to appraise it.”

HUD grants are based on pre-disaster valuation. “So it goes back to the disaster on which funding is based,” said Lumbley. “We’re currently working off the 2015/2016 floods and Hurricane Harvey. So what value did the home have before the storm hit, minus any funding that the owner might have received that did not go back into the home as it was intended?”

Eligible Years Vary by Type of Grant

Community Development Block Grants from HUD are disaster specific. So to be eligible for a HUD grant, you must have been damaged during one of those ‘funded storms,’ such as 2015, 2016 or Harvey.

But FEMA FMA grants are not disaster based. So as long as you have a current NFIP backed flood insurance policy and you meet the definitions of repetitive loss or a severe repetitive loss, you could to be eligible. For instance, maybe you flooded four times in 1978, 1982, 1994 and 2001.”

it gets complicated. If you’re interested in a buyout, the time to explore it is now – at one of these meetings – and the person to ask is Lumbley.

For more information, visit the Recovery MXTX page on Facebook.

If you know someone interested in a buyout, make sure he/she attends one of these meetings. Please share this post with others in Montgomery County.

Posted by Bob Rehak on 11/3/2021 based on information from Morgan Lumbley

1527 Days since Hurricane Harvey

Should City Be in Disaster Relief? For One Program, It Spent $3 Million to Get $3 Thousand

One of the more alarming facts that came out of Thursday’s City Council meeting is that Houston’s Housing and Community Development is spending far more on disaster relief than it gets back in reimbursements. In the case of one program, Economic Development, the ratio between costs and reimbursements to date was actually 1100 to 1, even higher than the headline indicates ($3,596,821 spent vs. $3,260 reimbursed).

The program’s purpose: to help small businesses damaged by Harvey. But the City launched the program just this year. And four years after the storm, those who needed assistance the most have already gone out of business. Most small businesses can’t survive that long after losing essential equipment. Is this program chasing business applicants that no longer exist? It’s hard to tell without more information. (The City’s most recent pipeline report, published just yesterday, doesn’t even mention the Economic Development Program.)

Regardless, the Economic Development Program isn’t the only area where expenses seem out of whack. This raises the questions, “Should the City even be in the disaster-relief business?” And “Can others do it better?”

Disaster Relief Costs Exceed Reimbursements and Budgets in Multiple Areas

Temika Jones, the Department’s new Chief Financial Officer and Assistant Director showed the chart below as part of her presentation. She has one year on the job. Before that, she served as an auditor for a major accounting firm. Her presentation spotlighted two giant problems: Costs exceed reimbursements. And costs exceed budgets – so some may never be reimbursed.

From a Presentation by HHCD to A Joint Committee Meeting of Budget & Fiscal Affairs, and Housing and Community Affairs

In the chart above, focus on the last two columns in the Total row. They show that the City is incurring disaster relief costs that average 2.3X higher than reimbursements – across the board.

Also focus on the big red numbers at the bottom of the slide. They show budgets that have already been exceeded.

Now compare Columns 3 and 6 in Line 1. The City has already overspent its four-year budget for administration in the first year of its contract with the GLO by $1+ million. Oops. The budget was $15 million. But the City already spent $16 million and has only had draws approved for $1.2 million.

Finally, compare Columns 3 and 5 on Line 4: The Homeowner Assistance Program. The department budgeted only $8.2 million for project delivery, but has already spent $30.6 million – almost quadruple. That means they have no budget remaining to finish the program. Worse, reimbursement for $22.3 million could be in jeopardy.

City Operating Outside of Its Core Competencies

There are several reasons for the problems discussed above:

  • HUD and the GLO operate on a reimbursement basis. The City can give money to flood victims and expect reimbursement, but then have the victim’s application refused for some reason – often missing forms or incomplete data.
  • The City’s track record with successfully completing applications has not been good. Many have been kicked back because they are incomplete.
  • That’s apparently because of staffing, training, and management issues.
  • The City’s accounting systems don’t handle disaster relief programs well, so the problems lack visibility.

Disaster relief just doesn’t seem to be one of the City’s core competencies.

The City is operating waaaaay outside of its areas of expertise. Police. Fire. Water. Streets. Trash. Those are the things people expect from the City and what the City should focus on. In business, any time you tread outside of your core competencies, your costs and risks escalate exponentially. That takes money away from flood victims.

It appears that the City was so eager to get its hands on hundreds of millions of dollars in disaster relief money that no one asked whether the City even should be in that business. Or whether the City should just have let the GLO handle disaster relief – as it did so well in 48 other counties.

As of the end of last year, the GLO had reimbursed 2961 homeowners; Houston reimbursed 119.

And while the GLO reconstructed 2500 homes, the City reconstructed only 117.

Increasing the Pace, But Falling Father Behind

The City has accelerated its pace this year, but Jones’ presentation also shows that the City is still sitting on top of applications worth $114 million that have yet to be filed. That’s almost triple the previous year’s number. Meanwhile, expenses have more than tripled.

From Page 16 of Jones’ Presentation to City Council

That brings us full circle. The City’s Economic Development Program has spent more than $3 million to get $3 thousand approved. It makes one wonder whether the purpose of pursuing HUD money was to create employment in Housing and Community Development or to help flood victims.

Turfing this to the GLO could have helped many more flood victims much faster at a lower cost.

The City put a third bureaucracy between money in Washington and the flood victims who need it. Two could have done the job faster, easier, and better.

Posted by Bob Rehak on 10/9/2021

1502 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.

Harris County Changing How It Will Choose Which Flood Projects to Support; Welcome to the “Equity Bias”

Imagine you pull up to a stoplight and two needy people approach you for a handout. You want to help, but have only $1 in your pocket.

Do you give the dollar to the person who has not eaten for the longest time? Or to the person from the zip code with the highest percentage of minorities and lowest average household income?

As you may have guessed, the people at the stoplight are a metaphor for flood victims.

More Needs than Dollars

Harris County doesn’t have enough dollars to build every flood mitigation project that everyone needs. Flood mitigation requires tough choices.

So the County is setting up a supposedly unbiased task force to decide whom to help. But its composition will be biased toward people who believe flood bond money should favor low income, minority neighborhoods, i.e., the constituents of the three politicians pushing the task force (Judge Lina Hidalgo, Precinct 1 Commissioner Rodney Ellis, and Precinct 2 Commissioner Adrian Garcia).

Stacking the Jury

Look at the proposed overview and bylaws for the Community Resilience Task Force. You will see that they embed the concepts of equity, social justice, and social vulnerability into every recommendation the task force will make. For flood mitigation. Housing. Health. Construction. Urban planning. And more. For the next 30 years!

Proposed bylaws for the task force explicitly state that the members MUST demonstrate:

  • An interest in “equitable” flood mitigation.
  • Interest in socioeconomic and demographic factors that affect resilience.

So they are baking “equitable” into the job descriptions.

Difference Between Equitable and Equal

“Equitable” treatment sounds like “equal” treatment. But it’s not.

Treating people equally means treating them identically. Treating people equitably means treating them differently, but fairly.

For instance, handicapped people get to park closer to the door. That’s fair…based on need.

But what happens when you start making flood mitigation decisions on the basis of race, income, and social vulnerability? Is that fair to more affluent communities destroyed by flooding?

Flood Spending Based on Race and Income?

Ms. Hidalgo, Mr. Ellis, and Mr. Garcia define “equitable” so preference goes to the “socially vulnerable.” Their argument goes like so.

Because poor people have a harder time recovering from floods, they should get more protection from flooding. They can’t afford to flood (…as if anyone can).

Hidalgo, Ellis and Garcia all advocate the use of a CDC social-vulnerability index and LMI (low-to-moderate-income) data to prioritize flood projects.

They argue in meeting after meeting that FEMA bases grant decisions on a benefit/cost ratio (BCR) that favors neighborhoods with more expensive homes. That’s true, but…

Socially Vulnerable Neighborhoods Already Receive Preferential Treatment

They never mention that Department of Housing and Urban Development (HUD) Community Development Block Grants for mitigation (CDBG-MIT) and disaster recovery (CDBG-DR) already favor poorer (LMI) neighborhoods.

Nor do they mention that the County has already received a BILLION dollars in CDBG-DR funds. Or that the Texas General Land Office is sitting on top of approximately $4.2 billion in CDBG-MIT funds that it’s trying to distribute. The vast majority of those funds must go toward LMI/socially vulnerable neighborhoods. (The exact percentages vary by storm and type of grant. But they often range up to 70%.)

Problems With Basing Flood-Mitigation Decisions on LMI Data

There are two more problems with basing flood-mitigation decisions on racial and LMI data.

  • First, it ignores need. Shouldn’t projects that help the largest numbers of people or the worst flooding be mitigated first?
  • Second, LMI data only comes by zip code. Zip codes can mask huge disparities in wealth. So even if you feel poor people deserve more flood protection than the middle class, it’s hard to ensure that result with zip code data. Elm Grove, for instance, is an LMI neighborhood embedded within an affluent zip code.

Mr. Ellis argued that his Precinct One constituents, who are 76% African-American and Hispanic, would not get their projects because money they deserved more was being spent in affluent Kingwood.

He did not mention Army Corps of Engineers grants to HCFCD for work on four bayous in his precinct. Nor did he mention that in the entire history of Harris County Flood Control (which dates back to 1937), not one federal dollar has ever been funneled through HCFCD by the Corps for work in the Lake Houston Area.

4 Out of 5 Flood Bond Projects in SVI Neighborhoods

How much have Ellis, Hidalgo and Garcia skewed flood bond spending to date?

During the Commissioners Court meeting on June 30, 2020, Harris County Flood Control was asked to prepare a report to document the status of flood bond risk reduction projects in socially vulnerable neighborhoods. See Item 2E on Tuesday’s Commissioners Court Agenda. It shows a startling fact.

Out of the 145 active bond projects, 79% are located in high or moderately high SVI areas.

Letter from HCFCD to Commissioners Court

The distribution looks like this.

79% of Flood Bond Projects are located in the most socially vulnerable neighborhoods; only 21% in the least socially vulnerable neighborhoods. Source: Memo to Commissioners Court from HCFCD.

If you live in a “socially vulnerable” neighborhood, you’re 4X more likely to have a flood bond project near you.

And those are just the projects based on Flood Bond money. The Flood Control District is also pursuing additional CDBG grants and Army Corps funding to help fund even more projects in socially vulnerable areas. Those projects are not reflected in these percentages.

Rushing Through Public Comment Period

One measure of how much Ellis, Hidalgo and Garcia want to institutionalize their own definitions of equity is that they’re giving only six more days for public comment with little public warning.

You can bet that the commissioners court meeting on the 28th will be packed with surrogate speakers for Ellis, Hidalgo and Garcia who favor the “equity bias.” They’ve shown up in Commissioners Court for months.

Why wouldn’t they? It’s worked. They now have 4 out of every 5 flood bond projects going into their neighborhoods and they could get even more if this task force goes through in its current form.

Meanwhile, the San Jacinto watershed, says the Greater Houston Flood Mitigation Consortium, received 0% of the mitigation budget prior to Harvey, yet had 14% of the region’s damages during Harvey. 

How Do We Decide What’s Fair?

So, should projects go to neighborhoods that:

  • Had the fewest flood mitigation projects?
  • Flooded the worst?
  • Help the greatest number of people for the dollars invested?
  • Are the poorest?

Or should the money be split equally or on some other basis?

Personally, I think decisions like these should be left in the hands of engineers, not partisan politicians.

Register Your Opinion

The County Judge’s office is inviting the public to share their thoughts and ideas on the proposed draft bylaws of the Task Force. You can register your opinion from now until July 30th, 2020, via one of the following methods:

  • Email CRTF@cjo.hctx.net and submit comments digitally, beginning July 21
  • Join a virtual focus group via Zoom. After registering, participants will receive a confirmation email containing information about joining the meeting.
  • Offer input during the July 28th Commissioner’s Court

Posted by Bob Rehak on July 24, 2020

1060 Days since Hurricane Harvey


For more information on the “equity bias,” see this series on “Where Flood Mitigation Dollars Have Really Gone”

Or this series on “The Equity Flap”

Texas Delegation Urges HUD to Release Funds Voted by Congress a Year Ago

In February of last year, Congress appropriated $4.383 billion to Texas through Community Development Block Grant–Disaster Recovery (CDBG-DR) funds explicitly to rebuild and mitigate against future storms.  Almost one year later, Texas cannot begin to utilize this important funding because HUD has not published the rules governing use of the money (i.e., the projects they are funding) in the Federal Register.

CDBG-DR funds can help provide local matches for things like additional gates for Lake Houston. I posted about how drawn out this process was on June 1 last year. The City was hoping for an answer in November for its grant reequest. Now, it’s February. HUD describes CDBG-DR funds as “crucial seed money to start the recovery process.”

Small gates on Lake Houston limit City’s ability to release water before storms.

What Big Lebowski would say about this?

LEBOWSKI: Where’s my goddamn money, you bum?!

DUDE: Well we–I don’t–

LEBOWSKI: They did not receive the money, you nitwit! They did not receive the goddamn money. HER LIFE WAS IN YOUR HANDS!

BRANDT: This is our concern, Dude.

Taking a Cue from the Movie

As WALTER says: If the plan gets too complex something always goes wrong.

So today, Congresswoman Lizzie Fletcher (TX-07) and Congressman Pete Olson (TX-22), Governor Greg Abbott, Senators John Cornyn and Ted Cruz, and the Houston Congressional delegation sent a letter to HUD. The language is considerably more diplomatic. The letter urges acting Office of Management and Budget (OMB) Director Russell Vought to approve the rules for spending the money in Texas. Representatives Kevin Brady (TX-08), Al Green (TX-09), Randy Weber (TX-14), Sheila Jackson Lee (TX-18), Michael McCaul (TX-10), Sylvia Garcia (TX-29), Brian Babin (TX-36), Michael Cloud (TX-27), and Dan Crenshaw (TX-02) also signed the letter.

Real People, Real Needs

It has been a year since these funds were allocated by the 115th Congress. “Now, we need the money to show up,” Rep. Lizzie Fletcher said.  “There is much work still to do, and we need these funds to do it.”

“When Hurricane Harvey hit Texas over a year ago, families were uprooted, homes were destroyed and innocent lives were lost,” Rep. Pete Olson said. “I urge HUD and OMB to act quickly so we can finish the Harvey recovery process.”

The Texas Two Step

Just when I thought it was simply a matter of printing the rules, the letter tells us that there is yet another step before the money can start doing some good. It continues. Because the rules have not yet been published, “GLO has been significantly delayed in drafting a State Action Plan for the funds, the critical next step at the state level before the grants can begin to flow.”

The Plan to Make the Plan

The letter concludes, “Texans cannot afford to wait any longer. We urge you to expedite publication of these rules.  Thank you for your attention to this important matter.” The government shutdown affected HUD. But now the shutdown has ended and still no rules, no money, no plan. Hopefully, it won’t take very long.

Posted by Bob Rehak on February 4, 2019

524 Days since Hurricane Harvey