On December 13 – 1567 days after Hurricane Harvey – President Biden issued an executive order to improve disaster relief by the federal government. The order covers a range of other government services, too. It aims to improve service service to citizens with the ultimate goals of improving customer satisfaction and restoring trust in government.
The White House says 25 million individuals, families, and small businesses live through a Federally recognized natural disaster each year. This should be great news for all of them. In the last four years, I have posted about the disaster called disaster relief more than once.
FEMA Mandate: Streamline Applications and Rules Re: Documentation
Specifically, the order states that theDepartment of Homeland Security’s Federal Emergency Management Agency (FEMA) shall “design and deliver a streamlined, online disaster assistance application. It also requires FEMA to “work with States to proactively update existing rules and policies on supporting documentation needed for disaster assistance processes to reduce burden and increase accessibility.”
HUD Required to Inventory Ways to Improve Customer Service
Unfortunately, the Order only mentions Housing and Urban Development (HUD) once and doesn’t offer many specifics. It requires HUD to submit a report to the Office of Management and Budget that assesses improvements needed in the department’s customer experience management and service design capabilities to comply with the order. The report must also prioritize improvements within available and budgeted resources.
Types of improvements mentioned throughout the order include:
Streamlining and improving accessibility
Improving digital experiences
Eliminating unnecessary administrative burdens on customers
Ensuring accessibility for those with disabilities
Ensuring access for those with limited English proficiency
Coordinating between agencies to reduce the need for customers to interact separately with multiple agencies.
“After a disaster,” it says, “more survivors will be able to focus on helping their families, businesses, and communities because of streamlined assistance processes, rather than having to navigate a complex Government bureaucracy to get the help they need.”
“Disaster survivors will no longer need to navigate multiple assistance forms across multiple agencies to get the help they need, saving time and energy to allow them to focus on their recovery and well-being.”
“Survivors will have access to more flexible mechanisms to provide supporting documentation, such as virtual inspections and submitting photos of disaster damage from a mobile phone.”
The press release concludes: “The Government’s primary mission is to serve. By placing people at the center of everything we do, the Government will be able to deliver timely, modern, and secure services to you – the people. We will rebuild trust in our Government, ensure no one is left behind, and inspire others to join us in serving future generations of Americans.”
President Clinton had similar ambitions in the early days of the digital revolution. His plan helped transform government, but there’s still a long way to go. This sounds like a good deal if it works. But it will be a massive undertaking that takes place in stages over years, not overnight.
Posted by Bob Rehak on 12/16/2021
1570 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2018/10/SJR_305_019.jpg?fit=1800%2C1200&ssl=112001800adminadmin2021-12-16 19:39:412021-12-16 19:41:04Biden Orders Simplification of Disaster Relief
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).
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.
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 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.
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.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/10/Screen-Shot-2021-10-09-at-12.45.15-PM.png?fit=1918%2C1448&ssl=114481918adminadmin2021-10-09 18:49:242021-10-10 10:10:47Should City Be in Disaster Relief? For One Program, It Spent $3 Million to Get $3 Thousand
As June 1st rapidly approaches, Texas coastal communities are wondering what the 2021 Hurricane Season will hold. Will thousands of Texas families be spared, or will they endure hurricane-force winds and flooding with years of recovery ahead of them?
We cannot stop natural disasters from happening, but we can certainly speed recovery efforts. The Texas General Land Office (GLO) has administered recovery programs for seven of the 18 major declared disasters the State of Texas has experienced in the last 15 years. We know firsthand how exhausting and lengthy this process can be. After flood waters have abated and the debris has been cleared, communities face the next hurdle – navigating the arduous and overly burdensome bureaucracy shackling speedy recovery efforts.
Cutting Red Tape
My GLO team and I recognize the importance of following procedures to safeguard federal funds, but also understand bureaucracy is an obstruction to recovery and mitigation. Community Development Block Grants for Disaster Recovery (CDBG-DR) appropriated by the U.S. Department of Housing and Urban Development (HUD) take years to reach disaster survivors. One of the most frequent concerns we hear—from survivors, county and local officials, and other stakeholders—is that CDBG-DR funds do not flow quickly enough to communities in need.
First, we must ensure effective and efficient disaster recovery by providing the framework for programs and activities that provide disaster relief; resiliency; long-term recovery; restoration of infrastructure and housing; economic revitalization; and mitigation in areas impacted by Presidentially declared disasters. This begins with codification of CDBG-DR program rules and regulations.
Reducing Upfront Delays
For every new allocation, a new series of rules are written and published in the Federal Register. In Texas we are currently implementing CDBG supplemental funding for 8 events governed by 22 separate Federal Registers (rule books for how funding allocations may be used). A good amount of those rules, such as the national objectives imposed and the range of eligible activities, remain largely the same each time, but others are entirely new. Based on our experience, it takes between nine to sixteen months for a Federal Register Notice to be published for allocations of recovery funding after the major disaster declaration takes place. These allocations must first be granted to a state or other grantee following a special appropriation from Congress.
Inspector General Recommends Codifying Rules
HUD going back to the drawing board for each appropriation consumes critical time that could be spent setting up programs at the state and local levels if the rules were codified. In July 2018, the HUD Office of Inspector General (HUD OIG) issued a report that identified 59 common rules HUD issues when drafting Federal Registers. The same report recommended HUD work to codify the CDBG-DR program.
Fund deployment speed can also be enhanced by:
Streamlining processes at the federal level and at HUD
Retaining and developing in-house knowledge
Empowering grantees to move with a purpose.
Five Specific Recommendations to Expedite Process
There are several steps the federal government can take to expedite this process. Here are the five I consider to be the most impactful:
Create Office of Disaster Relief and Recovery – HUD currently has several offices with jurisdiction over CDBG-DR funds. This creates a tangled web of bureaucracy when HUD drafts a Federal Register, approves an Action Plan, or a grantee must seek a waiver or other change to program, vastly delaying the distribution of funds. A distinct disaster recovery division headed by an Assistant Secretary with discretion over disaster recovery funds would limit stove-piped information, reduce redundancies, and expedite decision-making authority within HUD. This change alone would vastly reduce delays in program progress.
Facilitate capacity building – HUD should provide grantees an initial amount of administrative funds prior to approval of the action plan and grant agreement. This would enable grantees to hire staff to provide technical assistance for drafting the action plan and begin to build programs while the action plan is being developed so recovery efforts would not be delayed 6+ months while the process concludes. Many grantees lack the resources to essentially operate on credit until these funds are made available.
Standardize programs and only post changes – Congress should pass legislation standardizing rules so the Federal Register only includes what you cannot do versus everything you can. This would lessen the time waiting for the rules to be written and allow grantees to begin working on the general premise of what the program cannot do.
Codify data coordination between FEMA and HUD – The federal government must build a capable national data system to coordinate data sharing between federal, state, and local agencies. FEMA collects a tremendous amount of data following every disaster. This data is used to inform HUD allocations as well as to develop needs assessments by grantees. However, there is not a system in place that enables this data sharing to happen quickly, safely and effectively.
Codify allocation timeline – HUD is not currently restricted in how long it takes to allocate special appropriations of CDBG-DR and CDBG-Mitigation to grantees. Additionally, grantees cannot begin drafting hundreds of pages of state and local action plans until HUD issues the rules for use of funds in the Federal Register.
Example of Delays in Current System
For example, Congress appropriated nearly $28 billion to help disaster-affected states rebuild on February 9, 2018. Two months later, HUD allocated $4.383 billion to Texas. At the time, HUD also stated it “will issue administrative guidelines shortly for use of the funds to address grantees’ long-term recovery needs.” However, this did not happen for nearly a year and a half.
On August 30, 2019, HUD finallypublished the Federal Register notice enabling the State of Texas to proceed in drafting an action plan for the CDBG-MIT funds. The Federal Register required a robust public outreach component. The GLO went above and beyond HUD’s mandates by extending the required 45-day public-comment period to 50 days and surpassed HUD requirements by hosting eight public hearings – three public hearings prior to the completion of the draft plan and five following publication of the draft plan. Prior to finalizing the draft of the action plan, the GLO responded to thousands of comments collected from 117 meetings and 936 individuals.
While the GLO waited 16 months for rules for the action plan, it only took the GLO approximately five months to draft the nearly 500 page document, conduct a historic public outreach effort, respond to comments, make revisions, and submit the plan to HUD for approval. It then took nearly two months before the GLO received approval from HUD.
The turnaround time for announcing rules should be substantially reduced to expedite the use of disaster recovery funding for those in urgent need of assistance.
Since 2011, the GLO has worked with hundreds of communities and several thousand families to repair homes; reimburse out-of-pocket home repairs; conduct buyouts and acquire flood-prone properties; strengthen infrastructure; and conduct major planning studies to support local government mitigation efforts. The success of our programs can be attributed in part to our staff of dedicated experts as well as our streamlined grant administration.
The GLO has proven that you can expedite recovery by eliminating unnecessary regulations, pre-positioning resources and putting contracts in place before a disaster. Disaster survivors shouldn’t have to wait years for assistance. It is plain and simple – we can and should lessen the burden on families and communities by reducing redundancies and implementing common-sense reforms.
Guest Editorial by Texas General Land Office Commissioner George P. Bush on May 8, 2021
1348 Days after Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2019/08/Harvey-Peak-Intensity.jpg?fit=1500%2C843&ssl=18431500adminadmin2021-05-08 06:23:432021-05-08 06:27:52“We Must Streamline Disaster Recovery Before the Next Disaster”
Sunday, May 9th will mark a special day in the history of flood mitigation. We will have spent more time responding to Hurricane Harvey – and accomplishing little – than it took us to win World War II. December 7, 1941 to VJ Day on August 15, 1945 was 1349 days. On May 9, 2021, it will have been 1349 days since Hurricane Harvey ravaged Texas and the Gulf Coast.
What Happened to American Determination and Unity?
After Harvey, we stood united in a sense of grief, loss and determination. We vowed to implement measures that would make us more resilient against such storms in the future.
In the Lake Houston Area, we had a three part mitigation strategy:
More upstream detention to help offset future releases from Lake Conroe.
Dredging to eliminate blockages in the rivers.
Additional flood gates on Lake Houston so we can shed water as fast as Lake Conroe sends it downstream.
The winners of a HUD Hazard Mitigation Grant competition for Hurricane Harvey have yet to be announced.
And the vast majority of money appropriated by Congress for Hurricane Harvey relief in February of 2018 has yet to work its way down to the local level.
We Need More Emphasis on Action
Imagine if we had still been studying an appropriate response to Pearl Harbor after 1349 Days. Somehow, we’ve confused studying problems with fixing them. Thought has become disconnected from action, or worse, substituted for it. This is not America’s finest hour.
We have compounded a natural disaster with:
“Paralysis through analysis”
Divided responses on the federal, state and local levels that have no central coordinator
Contradictory priorities between upstream and downstream interests
Complex, often contradictory, organizational requirements.
We CAN Be the Solution
We need to re-engineer business processes to focus on what matters:
Helping people rebuild their homes, businesses and infrastructure…
And reducing the risk of future disasters…
In the least amount of time possible.
That’s it. It’s that simple. The first two are clear statements of intent to unify purpose. And the third is a simple goal by which everyone involved can measure individual efforts.
In the coming days, I will publish a series of articles on how to streamline the business processes built up around flood mitigation and disaster relief. One will be authored by George P. Bush, the state’s highest disaster relief official. And another will be anonymous to allow several people to speak freely and frankly.
My goal is to stimulate a public dialog that can help us get closer to the goals listed above.
Posted by Bob Rehak on 5/7/2021
1347 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/05/20210507-Arizona.jpg?fit=1200%2C801&ssl=18011200adminadmin2021-05-07 14:33:182021-05-12 15:17:20It’s Official: Harvey Flood Mitigation Is Taking Longer than World War II
Ironically, the GLO press release pointed out that 2016 grants were for repetitively damaged areas. And in the five years since the 2016 floods, we’ve also had Hurricane Harvey, Tropical Storm Imelda, and a record-setting 2020 hurricane season.
Reading the release felt like getting hit by three buses while waiting for the ambulance to arrive. That prompted a call to the GLO, which administers HUD grants in Texas. I asked a simple question.
Congress didn’t appropriate money for Disaster Declarations in 2015, 2016 and 2017 until February 9, 2018.
Texas received $4.3 billion from the U.S. Department of Housing and Urban Development for all those years.
Before the GLO could distribute those funds, it had to wait for HUD to develop and publish rules in the Federal Register governing the distribution of those funds. That took 1.5 years.
Then the GLO had to develop a state action plan. That required developing another set of rules, holding public meetings around the state, soliciting public comments, responding to the comments, and getting HUD approval of the plan. HUD finally approved the state action plan on March 31, 2020.
Then GLO had to translate the plan into Spanish, Chinese, Arabic, Vietnamese, and Korean before publishing it.
To be fair to everyone across the state, GLO then holds a “competition” to find the most worthy projects. The criteria for “worthiness” include multiple factors. But the biggest in HUD grants are: percentage of low-to-moderate income families being helped, how economically distressed an area is, and total expected benefits for dollars invested. For instance, when comparing applications for a $10 million grant that will help 1,000 families to a grant for the same amount that will help a 100,000 families, the latter would win.
But to determine that kind of information, applicants need to conduct preliminary engineering studies before they can even file applications.
The GLO must wait for all applications to be submitted, evaluate the applications, rank order them, and see how many will fit within available funding. In the case of the grants just announced, the GLO received requests for almost TWICE as much funding as they had available. The average over the years exceeds 3X. For Harvey, it was 5X.
HUD must then review and approve the grants.
GLO distributes the money.
Finally, mitigation projects can begin.
Are All These Steps Necessary?
When you look at the list above, each step sounds reasonable. But there may be ways to collapse steps and speed up the flood-mitigation funding process. Why, for instance, do you need 1.5 years to publish rules specific to these floods in the Federal Register? Why not have a generic set of rules for all floods and adapt the boilerplate as needed?
I also asked if a way existed to shorten the process by eliminating the competition. After all, its easier to approve one application than compare it to hundreds. Their reply: “Competitions are the only fair way to do it.”
Should We Go Back to Earmarks?
The current competition system replaced an earmark system whereby Congress directly allocated funds to certain projects in certain districts. Earmarks sped up construction, but had many problems of their own. For instance, unnecessary projects often went to the districts of congressional leaders. That sometimes deprived other areas with greater needs.
However, the competition system for flood-mitigation funding has obvious problems, too. It has spawned whole industries of grant writers, project managers and people who know how to navigate traps in the convoluted application process.
Hopefully, that doesn’t happen often. But when it does, we have proof that bureaucracy has become more important than the taxpayers it serves.
More about GLO/HUD Grants Announced This Week
For the record, out of the $135 million in grants announced yesterday, Harris County received $10 million for cloverleaf drainage improvements in Carpenters Bayou. City of Houston received $8.2 million for flood mitigation in the Alief Forest Area. Baytown, Freeport, Sweeny, and Jacinto City also received grants.
This table shows where the money went.
Hurricane Harvey Competition Results Not Yet Announced
Winners of the first round of the Hurricane Harvey Mitigation Competition are expected to be announced in late spring or early summer. The GLO received 220 extensive applications totaling more than $5 billion in requests for the $1 billion in available funding (Round 1).
The Hurricane Harvey State Mitigation Competition for flood-mitigation funding is open to cities, counties, COGs, state entities, and special purpose districts. Examples of projects include flood control and drainage improvements, infrastructure improvements, green infrastructure, public facilities, and buyouts. Each proposed project must have a total proposed cost between $3 million to $100 million.
What We Need
Getting disaster relief 5-10 years after the fact is the largest disaster of all. We need Congress to reform the process to speed up the delivery of flood mitigation funding. How many homes and businesses that flooded in 2015, flooded again in 2016, 2017, 2019 and 2020? And what were the associated costs? Did repeat-flooding damages for these years due to funding delays cost more than the amount of mitigation funds appropriated by Congress? Somebody, somewhere has that information.
Posted by Bob Rehak on 3/12/2021
1291 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/03/image.jpeg?fit=1200%2C752&ssl=17521200adminadmin2021-03-12 18:09:502021-03-12 21:22:56Why Does Flood-Mitigation Funding Take So Long?
With Hurricane Delta behind us, now we face a political storm. KPRC Channel 2 News reported earlier this week that the US Department of Housing and Urban Development (HUD) is putting the State of Texas back in charge of the City of Houston’s $1.3 billion Harvey relief dollars. That wouldn’t happen unless something was seriously wrong with City’s program.
HUD Eliminates Direct Funding to City
According to KPRC, Acting HUD Assistant Secretary John Gibbs said this “… eliminates direct allocation funding to the City of Houston. The City’s sub-recipient agreement will be terminated, and the funding used for State-run programs to support recovery efforts within the City. The General Land Office (GLO) will administer homeowner assistance, rental, and economic revitalization programs to serve eligible City of Houston residents.”
One Home per Week
The state said the City has only been able to address 163 homes to date that Harvey damaged. That’s exactly one per week since the storm. Even considering that the City didn’t get the money immediately, the rate still averages less than two per week.
3+ Years in a Black Hole then a Start Over
I know one family – neighbors – who applied for a grant to help rebuild their home after Harvey. They waited more than 18 months for a call back. When one didn’t come, they called the State’s General Land office, the agency taking over the funds. With a nudge from the GLO, the City finally returned the family’s calls. The City requested more information which the family supplied. Then came another long wait. The case fell into another black hole. The neighbor called two or three times a day, then learned that the lady managing the case was no longer in her job. They had to start over with another case worker. Now it appears they will have to “start over” again – three years after Harvey.
The lengthy wait for help has been doubly disappointing for my neighbors.
Not only were their lives destroyed; now their hopes are dashed.
The family cashed in their kids’ college funds and 401Ks to rebuild their home when help never materialized. Those kids will soon be in high school. And how the family will pay for their college is another source of worry.
The family is still waiting with a shoebox full of receipts and photographs of the damage – for a call that may take years to come.
In trying to figure out why this happened, I talked to several sources familiar with City government. The answers I usually got involved “complex process,” “under-qualified staff,” “set up in a hurry,” and “inadequate supervision,” “contractor issues,” and “lack of accountability.”
One went so far as to predict, “Most of this money will never get to recipients. It will get ground up in overhead.” Meanwhile…
“Many poor families don’t have college funds to tap. Many still live in mold-infested homes without wallboard. Or they’ve just abandoned their homes.”
As I said in 2018 – 276 Days after Harvey – there’s definitely an opportunity for business-process re-engineering here. Simplifying the process will help more people.
Posted by Bob Rehak on 10/10/2020
1138 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2020/05/Cart-in-Living-Room.jpg?fit=1200%2C900&ssl=19001200adminadmin2020-10-10 14:21:272020-10-10 16:11:34HUD Orders State to Take Over CoH’s Harvey Relief Funds