Tag Archive for: CDBG-MIT

Harris County Changes Proposed Project Lists for HUD Funding

In a transmittal to Harris County Commissioners Court today, Harris County Flood Control District (HCFCD) updated commissioners on how it hopes to spend $863 million in U.S. Department of Housing and Urban Development (HUD) funds.

Two projects in the Kingwood Area remain funding priorities: Taylor Gully Channel Improvements and Woodridge Village Stormwater Detention. However, the stormwater detention, currently listed as an alternate backup project, is being split up into two smaller projects to help improve funding chances for the most critical component. See more details below.

Ins and Outs of Funding

The HUD money comes in two “buckets” with different requirements – Disaster Relief ($322 million) and Mitigation ($541 million). Both buckets fall under HUD’s Community Development Block Grant Program (CDBG). CDBG’s flexibility lets people and communities design and implement strategies tailored to their own needs and priorities.

When I last reported on the CDBG lists, the Lake Houston Area had one project in each bucket.

  • In Disaster Relief, the Woodridge Village Stormwater Detention Basin was “below the line.” That means it was an alternate on the backup list; a primary project would have had to have been canceled for it to receive funding.
  • In Mitigation, Taylor Gully Improvements were above the line, i.e., primary recommendations.
Extent of Woodridge excavation when paused before applying to HUD

Changes Outlined in Transmittal

The latest updated project lists feature five main changes. They affect both Lake Houston Area projects. But first, let me explain the others that are changing, because their financial impact affects everything else.


  • Deleted the Riggs Road Stormwater Detention Basin (Part 2) from the recommended DR list, saving $6.5 million.
  • Transferred the Boudreaux Basin (Phase 1) from the DR list to Mitigation, so that it could benefit from the longer timeline for Mitigation projects. This project is between Willow Creek and SH99 at Huffsmith Kohrville Road. The transfer will free up another $38.6 million on the DR list.
  • Moved an East TC Jester Stormwater Detention Basin from the mitigation list to the DR list. This put $23.8 million back on the DR list.
  • Removed the Mercer Stormwater Detention Basin from the mitigation list without transferring it to DR.

Thus, you would think approximately $21.3 million was freed up on the DR list. That would theoretically let the Woodridge Stormwater Detention Basin move up from “below the funding line.” However, it remains below…at least for now.

Moreover the Woodridge Stormwater Detention Basin has morphed into two projects. One provides the detention required to help mitigate Taylor Gully now. The other provides an extra safety margin as a hedge against future developments.

Splitting the detention up into two smaller pieces gives HCFCD more flexibility and greater confidence that the most important part will get funded.

The Woodridge/Taylor Gully discussion in the document is a bit confusing unless you speak HUD.

Amy Crouser, an HCFCD spokesperson provided this translation. Regarding the two DR detention projects, she said that the detention basin which HCFCD already began excavating (and which they paused in November 2023) remains the top priority.

“The second basin will provide additional regional stormwater detention. Splitting the project helps us ensure the compartment of the Woodridge basin that mitigates Taylor Gully can move forward,” said Crouser.

She concluded, “The ultimate goal is to eventually construct both compartments. This follows our traditional rationale for phasing projects when possible and practicable. Both compartments will be advanced to bid-ready state using local dollars. That will give us the maximum flexibility to advance the projects.” 

For More Information

This HCFCD document titled CDBG Program Financial Planning & Performance Management, lays out all the costs, restrictions, deadlines and accountabilities related to all the projects on each list.

Posted by Bob Rehak on 4/23/24

2429 Days since Hurricane Harvey

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


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

Construction Beginning Soon on Mercer Stormwater Detention Basin

Harris County Flood Control District (HCFCD) will soon start building the new Mercer Stormwater Detention Basin, a large flood-risk reduction project along Cypress Creek adjacent to Mercer Botanical Gardens. HCFCD issued a notice to proceed to the contractor in December 2023 and the contractor is now mobilizing. 

The basin is north of FM-1960, east of the Hardy Toll Road, south of Cypress Creek and west of the Memorial Hills.

Combined 512 Acre Feet in Two Basins

The Mercer Stormwater Detention Basin project will include the excavation of 512 acre-feet of soil and other materials from the site. Once complete, the $14.8 million dry-bottom stormwater detention basin will provide approximately 166.8 million gallons of stormwater storage during heavy rainfall events.

The U.S. Department of Housing and Urban Development’s Community Development Block Grant Disaster Recovery program provided a $15.4 million grant for the project. Another $9.7 million comes from the 2018 Bond Program.

Arrowstone Contracting, LLC received a $14,846,391 contract for construction. Land acquisition, engineering and administration will consume the rest of the budget.

The stormwater detention basin will include two separate compartments, north and south, with an equalizer pipe connecting them. An 54″ outfall pipe will also be constructed along the north compartment so stormwater can slowly flow back into Cypress Creek after storms pass.

Construction Caution

Contractors will access the work area via FM-1960 or Lazy Ravine Lane in the Memorial Hills Subdivision. The contractor may use heavy construction equipment such as dump trucks, excavators and bulldozers. Motorists should be aware of truck traffic when passing near construction access points and along truck routes.

The HUD Grant stipulates that construction needs to finish by Fall 2024. And construction is scheduled to take 348 days.

Reducing Backwater in Tributaries

This is among multiple stormwater detention basin projects the Flood Control District is developing in the Cypress Creek watershed.

A regional drainage study for the watershed found that flooding along tributaries of Cypress Creek is predominately caused by rising stormwater in Cypress Creek backing up into tributaries. Flooding is not caused by a lack of sufficient stormwater conveyance or drainage capacity on the tributaries themselves. Therefore, stormwater detention basins could be a beneficial project to reduce that backwater issue.

Project Benefits

The Mercer Basins will remove the 100-year area of inundation from 30 structures and the 500-year area of inundation from an additional 17 structures.

The project also includes a 30’ wide berm to accommodate maintenance and future recreational amenities.

The project avoids wetlands and will lower the water surface elevation by .35 feet during a 100-year storm event, according to HCFCD.

Upstream detention was one of three major prongs of the strategy to reduce flooding in the Lake Houston Area. This and every other little bit will help downstream.

The regional drainage study found here recommends nearly 25,000 acre-feet of additional stormwater detention in the Cypress Creek watershed. That would be enough to hold back the peak flow during Harvey for almost 5 hours. In lesser storms, the benefit would last even longer.

Posted by Bob Rehak on 1/2/24 based on information from HCFCD

2317 Days since Hurricane Harvey

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”