Tag Archive for: equity

Harris County’s New Definition of Equity

8/26/24 – On Thursday night, 8/22/24, Doctor Arelia Johnson addressed the Harris County Community Flood Resilience Task Force about Harris County’s new definition of equity. Dr. Johnson is the County’s new Chief Equity Officer and has been in her job only three weeks. She has a PhD in sociology and criminology from Howard University. You can watch the video of her talk on YouTube. It begins at five minutes and ten seconds into the meeting. Below is a transcript of her talk up to the point where she started taking questions from the audience.

Arelia Johnson Intro slide
Introductory slide from Dr. Johnson’s talk.

Host: Whenever you’re ready Doctor Johnson, just let me know and I’ll help you advance through your slides.

Johnson: Thank you so much Amanda. This is Doctor Arelia Johnson. My pronouns are she, her, hers. And I am the chief equity officer for Harris County. And so, we’re going to talk about equity and where we are in this process of creating this foundational work and analysis. 

Racism, Sexism Declared Public Health Crisis

In June, 2020, Commissioners Court declared racism and sexism a public health crisis, and they then began to move towards creating a space for chief equity officer in 2021. The county then created its initial guidelines and definition for equity, and then more recently, we were able to update a definition that was more in alignment with the strategic planning that we’re doing. 

Current Definition of Equity

This particular definition feeds into our framework, which is three parts of the model. And we’ll talk about that shortly. But our definition as it stands right now is…

“Equity is the actionable pursuit of recognizing that there are groups who have disproportionately benefited from inequities, and others who have had the burden of solving the problems that have been created by inequities.” 

In other words…

“Equity is the actionable commitment to significantly reduce the disparity in the distribution of benefits and the actionable commitment in reducing the burdens of aligning and embedding goals, objectives, and outcomes related to inclusivity and accessibility to the historically marginalized.” 

Benefiting From or Being Hurt Disproportionally

Now, what does that mean? I’m glad you all asked. When we’re talking about equity, we have historically talked about equity in very vague, abstract ways. We have these huge aspirational goals, as if we can undo 250 years’ worth of work institutionalizing disparity.

However, we have to take a step back. And so, that’s what we’ve done as a county. We are taking a step back to figure out what can we do to recognize that there have been groups, multiple groups, who have benefited from disproportionality.

And then there have been multiple groups who have not benefited from disproportionality and who have been tasked with the burden, whether it’s the emotional labor, the physical labor, the social-political labor of solving the problems that inequity has caused and that has resulted in disparate treatment and what those consequences are. 

Equity is a conscious practice. It’s something that we are grounding in research, and it is informed by data that actively engages and addresses the historical, cultural and institutional dynamics and structures that privilege some and disadvantaged others.

Mitigating History

So, when you’re thinking about being a task force that wants to mitigate some of the flooding issues that we’re having, how do you then ground what you’re doing in research? How do you actively address the historical, cultural, institutional and structural dynamics?

And how do you know that you’re doing that? One of the tools that you can use is by actively engaging committees like this one, to where you can have a myriad of lenses and lived experiences at the table, to where you can hear from all of those different perspectives. 

There are three ways that we are looking at equity structurally, which is achieved when we take all of those dynamics that I just talked about into consideration. 

  • What is the historical context? How have certain groups been ignored or underserved or underprivileged? 
  • What are the cultural contexts? Are there biases or perspectives that are involved with dealing with the historically marginalized? 
  • What are the institutional dynamics that have traditionally privileged some and disadvantaged others?

Structural Equity

Now you’re talking about systems and systematic oppression, which does happen. It has structural consequences, especially when you’re talking about which areas are being served and which areas are going to be the hardest hit. 

Those are some of the things that we need to consider from a structural perspective. 

Structural equity also seeks to rectify underlying structures, frameworks and policies and practices. 

Procedural Equity

Procedural equity is more about the development and implementation of equitable distribution and sustainability. We want to look at standard operating procedures. 

What are those practices? How do we then create impact within those communities, not just in word but also in deed, and making sure that those populations are groups that are not otherwise considered:

  • One, have a seat at the table so they can have consideration, 
  • Two, they can also help with these efforts instead of those efforts being done for them. 

Socio-Emotionally-Intelligent Equity

And then you have socio-emotionally-intelligent equity. I think this is probably one of the things that we have to work hard because we have all been socialized and conditioned to some extent. 

This form of equity helps us to increase the capacity to recognize, understand and address and then mitigate the impacts of interpersonal, individual, structural, systemic and institutional racism and sexism on the well-being of others.

Aligning with Commissioner’s Court Priorities

We think this is really important as a county, because we want to be in alignment with all of the resolutions that are coming out of commissioner’s court. But then, we also want to be able to take a step back and be introspective and reflective when having interactions with others. 

Must Work on Unconscious Biases

Sometimes our implicit biases are our unconscious biases seep into interactions. It’s not because we intend on being harmful. Sometimes we are completely unaware that we are being harmful. 

And so, this is something that we really have to work on. And it has to be very intentional and conscious. 

Socio-emotionally intelligent equity is locational or context specific, which means that you have to recognize where you are, your generational context, your historical context, your social context, your political context, and recognize it and recognize that sometimes we assume things to the detriment of progress. 

What you may be experiencing with someone, if it looks like anger, may not actually be anger, it may be frustration or disappointment. 

And so doing all of those things, what it does for us, it helps promote a uniform starting place, which means that then we go into this place of what training looks like, what a shared language looks like, what commonality looks like. 

So, those are the three components of our equity framework and our definition. 

Posted by Bob Rehak on 8/26/24

2554 Days since Hurricane Harvey

2024 Flood-Bond Update Shows Changed, Changing Priorities

July 21, 2024 – Last week, Harris County Flood Control District (HCFCD) quietly shared this year’s flood-bond update with Commissioners Court. The update came during widespread power and internet outages from Hurricane Beryl that limited its visibility.

The flood-bond update details progress on the 2018 Flood Bond for the first time since the last update last October.

Combining the data in this flood-bond update with data from other sources reveals the impact of the County’s political divide and Equity Prioritization Indices. Both have affected projects in the Lake Houston area and Precinct 3 negatively.

But first some good news.

More Partner Funds Now Secured than Required by Original Bond

The total of secured funding now exceeds $5.2 billion. That includes the $2.5 billion approved by voters in 2018 plus $2.7 billion in other funding secured since then.

The additional funds include grants and matching funds from city, state and federal governments plus other local organizations, such as municipal utility districts. It also includes $87 million in Bond ID Z-07 – the Bond Program Reserve, formerly known as the Flood Resilience Trust.

Commissioners Court allocated this money to backstop bond funding before a massive infusion of funds from the General Land Office and the U.S. Department of Housing and Urban Development in 2022.

The total amount now available exceeds total project costs in both the original bond estimate and a slightly revised project list released in a 2021 flood-bond update.

HCFCD says it is working on revising costs to reflect inflation and the rising cost of property acquisition since then. However, it appears that HCFCD did not include inflation-adjusted project estimates in the current update.

Dollars Spent vs Dollars Secured

Regardless, we are now at a point in the bond where available cash covers the original estimates. So looking at dollars spent vs. dollars secured gives us a reasonable feel for how close we are to completing flood-bond projects in various watersheds. See the bar graph below.

Compiled by combining 2024 Bond Update Appendix B on Page 10 with spending data obtained separately via FOIA request. See data in table below.

Brays and Greens are more than 80% complete. Five others are more than 50%.

Meanwhile, 15 others are less than 50%. And of those, 10 are less than 25%. The county’s largest watershed, the San Jacinto, is only 19% complete (“spent”).

The graph above does not include Carpenters Bayou. It was an anomaly at 1762%. The 2021 bond update included only half a million dollars for a study there. But HCFCD has spent almost $9 million so far. Including Carpenters in the bar graph distorted the scale and obscured the differences between the other watersheds. However, I did include it in the table below.

Compiled by combining Bond Update Appendix B on Page 10 with spending data obtained via FOIA request. County-wide projects not included.

Next month will mark the sixth anniversary of flood-bond approval. The bond was originally intended to be a 10-year program. So, totaling all these figures, we are about 40% done in 60% of the time. There’s certainly room for improvement on that front.

Projects in some watersheds are stalled while projects in others near completion. Take, for instance, the Kingwood Diversion Ditch and Taylor Gully Projects in the San Jacinto Watershed. The Kingwood Area Drainage Analysis identified them as the top two projects in Kingwood back in 2020.

But not a shovel full of dirt has been turned yet on the Diversion Ditch project. And a $1,000 excavation and removal contract on the Woodridge/Taylor Gully project was terminated last November when only one third complete.

Partisan Changes Negatively Impact Precinct 3

Another thing to look at: changes to projects (Dollar Increases or Decreases; Project Deletions or Additions). While a certain amount of changes are normal when dealing with rough, early estimates, in this case, the changes also reflect a partisan bias.

When calculating the differences, I compared projects by Bond ID in the 2024 flood-bond update to the original bond allocations in 2018.

Harris County has three Democratic commissioners and one Republican – Tom Ramsey in Precinct 3.

  • Thirty projects affecting the three Democratic Precincts increased by $162.6 million – $54.2 million per precinct on average. But projects in the lone Republican precinct increased only $27 million. Thus, the three Democrats each benefited twice as much from additions as the lone Republican.
  • Likewise, 12 projects in the three Democratic Precincts decreased by a total of $92.6 million or $30.6 million per precinct on average. But Ramsey’s precinct lost $40.5 million.
  • Ramsey lost $13.5 million more than he gained.
  • Ellis, Garcia and Briones each gained about $8 million more than they lost.

When watersheds crossed precinct boundaries, I split dollars evenly among them. For example, if a project increased in value by $10 million and benefited one Republican and one Democratic precinct, I allocated $5 million to each. While that may not be precisely accurate in all cases, more precise data is not readily available.

To see the evolution of the bond fund through various iterations during the last six years, see the Harris County Flood Control District tab on the ReduceFlooding Reports page.

Other Items of Note

I did not include Countywide Expenditures in the calculations above even though they took a large hit. Their decrease shows up in corresponding increases for watershed projects. And I was more interested in how those were skewed.

However, one item definitely deserves future exploration: the $50 million decrease in “Federal Grant Funded Volunteer Home Buyouts.” Typically, the Federal Government grants funds for specific purposes. Where did this money go? The 2024 flood-bond update does not say.

Also of note: HCFCD currently has 20 projects in construction or turnover. The District has spent more than $2 billion in bond and partnership funds out of the $5.2 billion now available.

The latest bond update points out that of 181 original projects, 42 have been completed and closed out.

Equity Being Redefined Again

Separate from the bond update, Commissioners approved an expansion of equity guidelines last week. Item 18 on the agenda discusses an expanded definition of “equity” that will be used to allocate future flood mitigation dollars. It includes three components:

  • Structural Equity – righting historical wrongs
  • Procedural Equity – implementing procedures, policies and programs for groups previously not considered.
  • Socio-emotionally Intelligent Equity – mitigates the impacts of interpersonal, individual, structural, systemic, and institutional racism and sexism.

More news to follow when I figure out how all that will affect flood-control-mitigation dollars which have historically correlated to flood damage more than sexism.

At the very least, the imposition of new metrics on projects will slow down project scoring and implementation. It’s additional overhead burden on already complex processes. But my real fear? More and more of the San Jacinto watershed budget will slip away to other watersheds.

Posted by Bob Rehak on 7/21/2024

2518 Days since Hurricane Harvey

HCFCD Grappling with Inflation’s Impact on Flood-Bond Purchasing Power

Inflation has reduced the 2018 Flood Bond’s purchasing power. The general rate of inflation during the last five years adds up to 20%. That could potentially eliminate one fifth of the projects in the flood bond.

It’s a serious concern for the people whose mitigation projects have been put at the end of the line by the County’s Equity Prioritization Framework. Some residents may never see any benefit from their tax dollars, which are going to other areas.

Here’s how Harris County Flood Control District (HCFCD) will look at projects that now have an uncertain future.

Local Costs Consistent with General Rate of Inflation

In a presentation to the Harris County Community Flood Resilience Task Force, Jesal Shah PE, the new Chief Project Delivery Officer for HCFCD, discussed the issue of inflation. Shah, a Houston native, has been in his job since May, 2023. He previously led flood-risk reduction planning, design, engineering, and construction efforts for the government of British Columbia.

Shah cited 15-20% increases in construction, material, and right-of-way acquisition costs for Harris County flood-mitigation projects.

This and other screen captures below are from Shah’s presentation to Flood Task Force on 12/14/23.

Summary of 2018 Flood-Bond Funding To Date

The 2018 flood bond contained $2.5 billion in funding for approximately $5 billion worth of projects. Partnership funding, i.e., grants, were supposed to make up the difference.

And at this point, all of the partnership funding has been secured thanks to an infusion of $825 million in Community Development Block Grant funding from the U.S. Department of Housing and Urban Development (HUD) and the Texas General Land Office (GLO).

“Anticipated” should now be removed from this slide.

That’s very good news.

63% of Bonds Sold Already

Shah says that the County has sold $1.575 billion worth of bonds to date, almost two thirds of the original $2.5 billion.

Of the two thirds, about half the money has been spent or “encumbered.” Encumbered means the money is committed to projects and difficult to move. For instance, a project may be in construction, but not yet completed.

The other half has been committed to projects, but not yet encumbered. For instance, bonds may have been sold, but the construction job may not have been awarded yet.

See below.

Securing the partner funding is huge good news. But the impact of inflation is worrisome. To help deal with that, the County is re-evaluating all projects associated with the flood bond.

How Projects are Being Re-evaluated

Shah cited three types of projects listed in the original bond. Those with:

  • Well defined scope and accurate estimates.
  • Clear scope but inaccurate estimates. For instance, the Lauder basin has almost tripled its original cost estimate.
  • Vague scope and unreliable estimates.

See examples below.

To complicate matters, some backstop funding from the Flood Resilience Trust is no longer available because of new “guidance” from Commissioners Court. That will eliminate $343 million in funding flexibility.

And keep this in mind. The bond program is far from complete. We could easily see another 15-20% of inflation before its over. So what to do?

Sharpening the Pencil

Shah’s team is dividing the remaining bond projects into two piles.

  • Those with clear scope and funding will be completed.
  • Those without clear scope or funding will be re-evaluated.

Shah hopes to present an updated project list to Commissioners Court sometime during the second quarter of 2024.

Shah has already taken a first pass at re-evaluating the bond’s project list. Of the 181 projects identified in the bond:

  • 30 have already been completed or eliminated.
  • 63 will continue moving forward.
  • 88 (almost half) will need more funding or more clarity (i.e., more engineering studies/tighter estimates) to move forward.

The slide below shows the guiding principles for evaluating the 88 projects that need more funding or clarity.

Lack of Balance Could Jeopardize Future Bond Offerings

One possible way to mitigate the toll of inflation involves phasing projects in areas that have already received large amounts of funding so that projects in areas that received little funding could move forward.

For instance, in a project that involves multiple stormwater detention basins, one or more of the basins could be delayed until the next bond. Meanwhile, delaying that basin could free up money for a basin in a different watershed.

However, during Q&A, Shah said he has no plans to phase projects.

A lack of equitable distribution could jeopardize future bond offerings.

And many areas have received little funding from this bond.

More than a 100 to 1 difference exists between projects on the left and right.

In the future, voters who saw no benefit from the 2018 flood bond might, once again, feel victimized by bait-and-switch tactics.

Selling future bonds will require restoring faith in the fairness of government. And that will require spreading bond funds around so that everyone – in all parts of the county – sees some benefit from them. That’s my humble opinion.

When HCFCD presents its updated project list to Commissioners Court in the second quarter of 2024, it will be interesting to see whether Commissioners and the County Judge agree with it.

John Whitmire’s landslide election in the Houston Mayor’s race may send a message to them. Whitmire is a Democrat who campaigned across the aisle and received heavy Republican support.

Posted by Bob Rehak on 12/16/2023

2300 Days since Hurricane Harvey

Differences in Ways County, State Propose Ranking Flood Projects

The Texas Water Development Board is seeking public comment on its plan to allocate $375 million in funding from the State’s flood infrastructure fund for the 2024-25 state fiscal year.

That prompted me to compare the TWDB and Harris County plans for ranking flood projects. The differences remind me of how the scoring systems favor certain projects in some areas and not others.

Harris County and the Texas Water Development Board (TWDB) use distinctly different priorities when considering which flood-mitigation projects to fund.

The biggest differences have to do with the weights given to severity of flooding, protection of infrastructure, social vulnerability and maintenance costs.

The state also uses “benefit/cost ratios” much like the federal government. The county, however, uses a measure called “project efficiency,” which is related but slightly different.

Differences in Ranking Projects

Here is the most recent prioritization framework that Harris County adopted in 2022 and again in 2023. And here is the draft “intended use plan” for the State of Texas 2024-25 Flood Infrastructure Fund.

Let’s look more closely at each plan and then examine their differences.

Harris County Prioritization Framework

Harris County examines:

  • Project Efficiency…
    • Using People Benefitted
    • Using Structures Benefitted
  • Existing Conditions
  • Social Vulnerability Index
  • Long Term Maintenance Costs
  • Environmental Impacts
  • Potential for Multiple Benefits

Each project is assigned a score for each criterion below ranging from 0 to 10. A score of “10” indicates the project fully met the criterion and a score of “0” indicates that it did not.

Summary of ranking matrix from page 4 of Harris County Framework. For explanations of scoring on each measure, see full document.

Proposed TWDB Matrix

The TWDB scoring matrix measures more factors and gives them different weights.

For larger, high res version and detailed explanation, see full plan.

The first thing you notice is that the table above is much wider and deeper than the County’s matrix. That’s because it lists evaluation criteria for different categories. And criteria sometimes change depending on the category.

Comparison of Differences

Social Vulnerability

Harris County gives 20% of all projects’ weights to social vulnerability. But the TWDB only gives it 5% weight. TWDB also uses social vulnerability as a tie breaker (see page 22).

Equity

Harris County has organized its flood-mitigation priorities since 2019 around equity. The proposed TWDB plan does not mention the word.

Efficiency

Harris County measures the efficiency of removing people and structures from the 100-year floodplain. The County defines efficiency as the cost of the project divided by the number of people or structures benefited. It gives them 45% weight within the final score.

TWDB also measures the number of people and structures removed from the 100-year floodplain. But unlike the county, it factors in critical facilities, the number of low water crossings, and miles of roads removed from the 100-year floodplain. Combined, they represent 55% of the weight. TWDB does not weigh cost against these measures at this point in its scoring matrix. However, it separately gives 2.5% weight to benefit/cost ratios.

Flood Risk

Harris County does not directly incorporate flood risk in its evaluations. It uses a proxy called “Existing Conditions” and gives it 20% weight. Existing Conditions measures the level of service provided by a detention basin or a channel. For instance, one with a 2-year level of service floods in a 2-year storm. One with a 25-year level of service floods in a 25-year storm, etc.

TWDB does not directly measure flood risk either. Rather it measures the number of structures, people, critical facilities, low-water crossings and road miles inside the 100-year floodplain. It’s a measure of what is “at risk.” These measures collectively add up to 100% of the score for a flood-management evaluation and 60% of the score for a flood-management strategy.

Severity

Harris County gives no weight to the severity of flooding. TWDB does. TWDB measures both the average depth of flooding in a 100-year storm and the percentage of a community’s population exposed to a 100-year flood. Together, they can account for 10% of a project’s total score.

Critical Facilities

Harris County does not differentiate among structures removed from a 100-year floodplain. But TWDB recognizes critical facilities. Such facilities could include sewage and water treatment plants; bridges; schools; hospitals; police and fire stations; and more. These affect entire communities, not just individuals.

Maintenance Costs

Harris County projects maintenance costs and gives them 5% of the weight. TWDB does NOT consider costs associated with current or future operations and maintenance activities.

No Right or Wrong Way

Neither the TWDB plan, nor the County’s plan is right or wrong. Their weights reflect the needs of different people and different organizations in different places. For instance, the state is not involved in maintenance, but maintenance historically has consumed as much as 50% of Harris County Flood Control District’s budget. So it makes sense for the county to prioritize low maintenance costs.

However, I would observe that Harris County could borrow some ideas from the state, such as incorporating measures for severity of flooding, protection of life, and protection of critical facilities. The areas that had the deepest flooding and the highest loss of life during Harvey have received little flood-mitigation assistance from Harris County compared to poor areas.

What happens when 240,000 cubic feet per second, 20-foot-high floodwaters tear through your home.
4000 Students at Kingwood High School
When sewage-contaminated floodwater invaded Kingwood High School to the third floor, 4,000 students had to study in shifts at another high school an hour away for a year.

What Do You Think?

TWDB seeks public comment on its proposed plan by January 1, 2024. What do you think? Based on your flood experience, do you think TWDB could do something better? Let them know.

Their plan includes more information than shown above. For instance, it also includes information on eligibility, minimum standards, program timeline, and financial assistance categories.

If you wish to comment email FIF@twdb.texas.gov and specify in the subject line “FIF IUP Comments.” Should you have any questions, please contact the TWDB by emailing the same address.

Posted by Bob Rehak on 12/11/23

2295 Days since Hurricane Harvey

Third-Quarter Flood-Mitigation Spending Trends, Surprises

Third quarter flood-mitigation spending data is now available for Harris County Flood Control District and its partners. In some ways, the data shows a continuation of previous trends. But the data also contained some surprises. The major findings:

  • Spending continued to dip. Slower project delivery means inflation will claim an increasingly large percentage of taxpayer dollars and may force cancellation of some bond projects.
  • If the last quarter of this year is anything like the first three, we could see less than half the activity in 2023 than we saw in 2020.
  • The trend toward investing more heavily in minority areas continued and even accelerated. But there was one notable exception – Cypress Creek and its tributaries.
  • An unusual $9.7 million real-estate transaction for a stormwater detention basin near the Mercer Arboretum skewed the Cypress Creek total. That was 16.5% of all HCFCD spending for the quarter.
  • Without it, many of the numbers below would also have been skewed. For instance, total spending and average spending per watershed would vary dramatically.
  • The focus on so-called “equity” spending and the Cypress Creek watershed meant 15 watersheds saw less than a million dollars in activity during the quarter. And five of those received less than $100,000.

Let’s look at each and the implications. Everything below INCLUDES the unusual real estate transaction near Mercer. In several places, I note how things would have changed without Mercer.

Overall, Slowdown Magnifies Inflation Concerns

Overall, flood-mitigation spending dipped about 5% in the third quarter compared to the previous quarter. It declined by a little more than $3 million to $58.8 million. That may not sound like much, but it continues a 3-year downward trend and creates delays that expose residents to more flood risk.

As projects are delayed, their costs also escalate due to inflation, raising concerns about whether there will be enough money in the bond to finish all the projects promised to voters.

Spending this year will likely be a hundred million dollars less than the first full year of the 2018 flood bond – when projects were ramping up. See chart below.

Annualized estimate for 2023. 23Q4 data estimated based on average of first 3 quarters. Without Mercer, the 2023 estimate would be below $200 million.

Moreover, spending will be $200 million less than the peak year of 2020 – about half of what it was then.

Halfway through the 2018 10-year flood bond, HCFCD has spent only about a third of the funds approved by voters – $1.65 billion. However, if the present slowdown continues, this will be the third straight year of decline.

The slowdown in project delivery means inflation will increasingly raise costs and undermine the purchasing power of the dollars authorized by voters.

HCFCD acknowledges the serious impact of inflation in its latest bond update to Commissioners Court, and hopes toll-road money remaining in the Flood Resilience Trust will cover any shortfall.

Average Spending in LMI Areas Growing

Data also reveals that with one exception (Cypress Creek and its tributaries), the trend of preferentially allocating funds to Low-to-Moderate-Income (LMI) areas continued and even accelerated when measured by average spending per watershed.

On average during Q3, watersheds with a majority of LMI residents (hereinafter called “LMI watersheds”) received 2.5X more funding than more affluent watersheds – $3.1 million each vs. $1.2 million. That’s up from 1.7X over the longer period since Harvey. So, the gap is widening.

Without the Mercer real-estate transaction, the average for more affluent watersheds would have been cut in half to $600,000. That would have almost doubled the ratio. The recomputed average would created a 4.7X ratio between LMI and all other watersheds for the third quarter.

That trend will likely continue for some time as projects funded by HUD through the Texas General Land Office get approved and start construction. That pot of money will spread across the income spectrum, but projects in lower income areas will likely start first.

Cypress Creek Spending Explodes

In fifteen Harris County watersheds, more than 50% of residents make above the average income for the region.

As a group, those 15 received $18.6 million last quarter – $2 million more than the $16.6 million received by the eight LMI watersheds.

However, the first group is twice the size of the second. And looking deeper within the more affluent watersheds, we can see that Cypress Creek and its tributaries (Willow and Little Cypress) received 79% of that $18.6 million last quarter.

The three Cypress watersheds received almost 4X more funding than the 12 other watersheds in the more affluent category put together.

Cypress Creek and its tributaries consumed 79% of all HCFCD/Partner spending last quarter among watersheds without a majority of LMI residents.

Here’s how that same spending looks in a bar graph.

Only the first three watersheds on the left received more than a million dollars in Q3. The twelve on right received less than $1 million each.

The 12 other watersheds divvied up $3.8 million; they averaged just $348 thousand each.

FOIA request. Data supplied by HCFCD.

$348,000 is one ninth of the $3.1 million average for LMI watersheds. And we know that some of those, such as the San Jacinto, have huge, unmet needs.

Cypress Knocks Brays Out of First Place

Now, let’s look at ALL watersheds in both categories. When looking only at the third quarter, Cypress Creek surged into first place. It nudged out Greens, White Oak, Brays and Sims, all of which have LMI populations greater than 50%.

HCFCD and Partner spending by watershed
Includes all 23 watersheds during 23Q3.

HCFCD finished Project Brays 15 months ago, but still managed to spend $3.8 million there last quarter. That was almost 10X more than it spent during the third quarter in the San Jacinto watershed, the county’s largest, and where the flooding was deepest. HCFCD spent only $400 thousand in the entire San Jacinto watershed last quarter.

worst first
Comparison of 33 gages in Harris County during Harvey showed San Jacinto had worst flooding.

Brays Still Ranks #1 in Total Spending Since Harvey

Since Hurricane Harvey (not just last quarter), Brays still ranks #1. But Cypress now ranks second. If you added its Little Cypress and Willow Creek tributaries in the graph below to the Cypress Creek total, they would rank #1 by more than a $100 million.

Includes all 23 watersheds since Harvey

Brays even managed to increase in the last quarter by $1.5 million while the San Jacinto decreased by $55,000.

Granted, some watersheds have smaller needs than others, but the ratio between the highest and lowest spending exceeds 300X.

Impact of Equity Formula

The spending priorities shown in this post reflect the Equity formula adopted and periodically revised by Harris County Commissioners Court.

Ironically, the language approved by voters in the flood bond never mentions the word “equity.” Paragraph 14G does say that Commissioners Court shall provide for an “equitable expenditure of funds.”

However, most dictionaries define “equitable” as “nondiscriminatory.” Yet the current formula prioritizes projects largely on the racial composition of neighborhoods as described in the CDC’s social vulnerability index.

The theory is that poor people are financially less able to fix their homes after a flood. I accept that.

But some commissioners are using that to push the idea of fixing 500-year flooding in poor neighborhoods before fixing 2-year flooding in more affluent communities.

Therefore, I ask:

  • At what point do we do we say enough money has gone into an LMI watershed and start spending elsewhere to reduce greater flood risk?
  • Why isn’t HCFCD publishing updated flood risk maps as it completes mitigation projects so we can make objective comparisons and see what our tax dollars bought?
  • Why does Harris County’s formula for allocating flood-mitigation funds NOT consider:
    • Flood damage to homes, businesses and retirement communities?
    • Damage to infrastructure, such as bridges, schools, hospitals, grocery stores, traffic arteries, water and sewage treatment plants, etc.?
    • Height of floodwaters, i.e., the severity of flooding?
    • Deaths caused by floods?
  • Is a poor person’s carpet worth more than a rich person’s life?
  • Will there be enough money in the flood bond and flood resilience trust to finish all projects in the bond given inflation?

So many questions. So few answers. Perhaps this explains why trust in government has reached a 70-year low.

Only 20% of Americans now say they trust government “just about always or most of the time.” That’s something to think about as we near the next election.

Posted by Bob Rehak on 10/15/23 and updated 10/16/23 with additional info on Cypress Creek

2238 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.

Where Flood-Mitigation Dollars Have Really Gone

An analysis of Harris County Flood Control District (HCFCD) and partner spending since 2000 reveals striking contrasts between watersheds in terms of where flood-mitigation dollars have gone.

Watersheds vary as much as 130 to 1 since 2000 and almost as much since Harvey. Most watersheds remained relatively constant in the rankings during the different time periods. However, a few have shifted up or down a few positions as land was acquired for projects or construction kicked off.

Data below includes spending by HCFCD and its partners from 1/1/2000 to 6/30/2023.

Main Takeaways from the Data

The big stories:

  • Since 2000, the top four watersheds received more flood-mitigation dollars than all 19 others put together. The top four include: Brays, Greens, and White Oak Bayous, and Cypress Creek.
  • Since Harvey the top four received 48%.
  • The distribution of funds continues to show the impact of Harris County’s Equity Prioritization framework.

Harris County’s Equity Prioritization gives weight to race and low-income areas, but not flood damage, the severity of flooding, or protection of infrastructure.

San Jacinto Gets Above Average Damage, Below Average Funding

The San Jacinto ranks below the averages (before 2000 and since Harvey) for flood-mitigation dollars – despite ranking 8th in damaged structures among all 23 watersheds. Damage totals include five major storms (Allison, Memorial Day, Tax Day, Harvey and Imelda).

Compiled from HCFCD Federal Reports

Watersheds Ranked by Funding Since 2000

Here’s how the funding looks in graphs and tables. All data was obtained from HCFCD via FOIA requests.

Data obtained from HCFCD via FOIA requests. Includes Harris County and partner spending.

Here’s the actual data if you want to see exactly how much your watershed received.

From 1/1/2000 through 6/30/23

Watersheds Ranked by Funding Since Harvey

Now let’s look at the how spending shifted after Harvey. Not much, at least relatively speaking.

Includes Harris County and partner spending. San Jacinto climbed two spots, but it is still barely above the median and far below the average.

Here are the actual totals for each watershed shown in the graph above.

Spending from 17Q3 to 23Q2 inclusive.

Feet above Flood Stage

Now let’s look at the severity of flooding. The chart below measures feet above flood stage at different Harris County gages.

Flood Stage is the level at which a river, stream or channel comes out of its banks.

I compiled this chart from data in the Harris County Flood Warning System website.

That 20+ feet above flood stage at the San Jacinto West Fork and US59 was the highest I found in the county.

Damage to Infrastructure

That 20+ feet destroyed Kingwood College, Kingwood High School, all of the businesses in Kingwood Town Center and Kings Harbor, the southbound lanes of US59, the Union Pacific Railroad Bridge, Memorial Hermann’s new Convenient Care Center, sewage treatment plants, and a senior housing complex.

Lone Star College
Harvey flooded 6 of 9 buildings at Lone Star College/Kingwood. Repairs cost a total of $60 million.
I-69 damage and repairs
I-69 Bridge replacement after Harvey. Repairs took 11 months creating massive delays and detours.
UP Bridge
Union Pacific Railroad Bridge that parallels US59 was destroyed and required complete replacement.
Alspaugh’s Hardware during Harvey
New HEB shopping center 1.5 miles from the San Jacinto West Fork was under more than 7 feet of water during Harvey.

Six years after Harvey, many of the commercial areas in Kingwood still haven’t fully recovered. Anchor stores remain empty in three of five shopping centers on Kingwood Drive between Town Center and US59.

Achieving True Equity

While I’m sympathetic to the plight of poorer neighborhoods, I cringe at the self-serving definition of equity used by a Democratic-dominated Commissioners Court to deny funding to the hardest hit area in the county.

We need a system that’s fair to all, not just some. Anything less will perpetuate racial distrust. This is a public safety issue and public safety should not be politicized.

Posted by Bob Rehak on 9/30/23

2223 Days since Hurricane Harvey

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

HCFCD Spending Shows Slight Rebound

After a sharp decline in the first quarter of 2023, Harris County Flood Control District (HCFCD) spending rebounded slightly in the second quarter. Second quarter spending did not recover to recent peaks, but at least exceeded pre-2018 Flood Bond levels.

Data obtained via FOIA Request from HCFCD on 8/14/23

One Third of Bond Money Spent in Half the Projected Time

However, HCFCD is still behind schedule with mitigation related to the 2018 flood bond. HCFCD has not issued a flood-bond update since last December. But you can calculate progress yourself by looking at the charts in this post.

Six years after Harvey and five years after the flood bond, HCFCD and its partners have spent approximately $1.6 billion to improve Harris County drainage.

Taxpayers approved $2.5 billion in the 2018 flood bond. Approximately a third of that was designated for matching funds to attract another $2.5 billion from Federal, State and local sources.

That means five years after the bond (and six years after Harvey) we are are roughly one third of the way through the bond, which was intended to be a ten-year program. And that one third is likely overstated due to inflation.

Spending Inequities

The County has not spent the money to benefit all people equally, thanks to the so-called Equity Plan approved by Commissioners Ellis, Garcia, and Judge Hidalgo. They argue that people with low incomes should enjoy a higher level of flood protection because they are less able to fix their homes after disasters.

Harris County tracks spending by watershed. Eight watersheds have a populations where Low-to-Moderate Income (LMI) residents comprise a majority of the population. Those same watersheds also tend to have high social vulnerability indexes based on the CDC’s ranking criteria.

The eight LMI watersheds include:

  • Halls (72.5% LMI)
  • Hunting (67.8%)
  • Vince (64.9%)
  • Sims (60.8%)
  • Greens (59.8%)
  • Goose Creek (56.9%)
  • White Oak (51.9%)
  • Brays (51%).

HCFCD updated those LMI percentages at the end of 2022 to reflect the latest census data.

Actual Flood Damage No Longer Considered

Harris County no longer weighs damage in ranking flood-mitigation priorities.

Here’s how LMI-majority watersheds line up versus the county’s 15 other watersheds in terms of the money received since Hurricane Harvey.

Data obtained via FOIA Request from HCFCD on 8/14/23

Here’s how all watersheds ranked last quarter.

Data obtained via FOIA Request from HCFCD on 8/14/23

The San Jacinto declined a place in spending among the watersheds last quarter compared to “Since Harvey” (14th vs 13th). For the exact amounts each watershed received last quarter, see the table below.

Data obtained via FOIA Request from HCFCD on 8/14/23

Some readers might notice slight changes in the totals from past time periods. That has to do with ongoing transition of project and invoice coding in the county’s accounting systems. But they affect only about $2 million out of $1.6 billion. And most of those have to do with first quarter invoices received after my first quarter FOIA Request.

For those unfamiliar with the locations of various watersheds, see the map below.

watershed map of Harris County
From HCFCD 2019 Federal Briefing

Now compare spending to the actual flood damage during the last 44 years.

This map from MAAPnext, totals damage since 1979. Dark areas represent more damage. Compare the spending priorities above with actual damage in your watershed.

Flood control money used to flow to damage. But that’s no longer always the case.

Come back soon for more analysis of the latest data.

Posted by Bob Rehak on 8/15/23

2177 Days since Hurricane Harvey

Commissioners Approve New Formula for Scoring Future Flood Projects

Harris County Commissioners Court approved a motion on 1/10/23 that will change the formula for scoring future flood projects. It gives two thirds of a potential project’s score to population density, building density and social vulnerability, but only 20% to flood risk and nothing to actual flood damage.

Stacking the Deck

The new formula could be used both to compare and eliminate projects. With only 20% of a project’s score determined by flood risk, fixing minor flooding inside the Beltway could soon take precedence over fixing severe flooding outside the Beltway. The formula provides only the illusion of transparency and fails to ensure fairness.

worst first
Chart showing feet above flood stage of 33 gages on misc. bayous in Harris County during Harvey.

During Hurricane Harvey, the highest flooding in the County occurred outside the Beltway along the San Jacinto River, Spring Creek and Cypress Creek.

Evacuation Route during Harvey
North Shore evacuation route during Harvey. Photo by Jim Balcom.

Regardless, despite being the largest watershed in the county and one of the most heavily damaged, few flood-mitigation dollars have come to the San Jacinto Watershed.

Since Harvey, 4.6 more flood-mitigation dollars have gone to the Brays watershed than the county’s largest, the San Jacinto.

Brays is the county’s most populous watershed. It’s also where Commissioner Ellis lives. Could that have anything to do with the factors and weights in the new formula for scoring future flood projects? They include:

  • 45% Project Efficiency
    • 15% Resident Benefits 
    • 30% Structure Benefits 
  • 20% Existing Conditions 
  • 20% Social Vulnerability Index 
  • 5% Long Term Maintenance Costs 
  • 5% Minimizes Environmental Impacts 
  • 5% Potential for Multiple Benefits 

This new formula omits consideration of damage, risk reduction and partnership funding. Partnership funding has provided approximately one third of all Flood Control District funding since 2000. The new formula gives the most weight to building and population density incorporated in the Project Efficiency formula (project cost divided by # residents and structures benefitted). This 15-page PDF explains how projects are scored within each category above.

Other Problems with Formula

The formula for scoring future flood projects, proposed by Precinct 1 Commissioner Rodney Ellis has many other problems. It also:

  1. Does not differentiate between types of structures while giving them almost a third of the weight. Thus, a mobile home counts for as much as a hospital or college. 
  2. Gives no weight to protecting critical infrastructure such as bridges, hospitals, grocery stores, wastewater treatment plants, etc. 
  3. Omits actual damage from consideration, which “ground-truths” risk assumptions (see Existing Conditions, Page 6).
  4. Eliminates consideration of partnership funds, which have provided almost one third of HCFCD funding since 2000. 
  5. Gives 20% weight to social vulnerability, but ignores the severity of flooding. Thus a low-income home with one inch of flooding counts as much as an entire condo complex swept away by 22-foot deep floodwaters. 
  6. Makes awards more subjective because HCFCD has no way of estimating how many people live in apartment buildings or homes. HCFCD can count buildings in satellite photos, but the number of residents benefitted will always be a guess. Census tracts do not follow floodplain boundaries. 
  7. Undermines efforts to prevent flooding, as opposed to correcting it after people are damaged. Prevention, such as HCFCD’s Frontier Program, is always more cost effective in the long run. 
  8. Places 45% of the weight on cost data that has not yet been determined when deciding whether to explore projects further.

Ellis’ proposal passed 3-1 yesterday. Commissioners Rodney Ellis, Adrian Garcia, and Lesley Briones voted for it. Commissioner Tom Ramsey voted against. County Judge Lina Hidalgo was absent. Commissioner Ellis ran the meeting.

To see the discussion on Ellis’ proposal, click on “Departments 2 of 2” in the meeting video and scroll forward to 3:03:53. The discussion lasts 16 minutes. Below is a summary of key points and their time codes.

Summary of Debate with Video Timecodes

Ellis positions his proposal as a “transparency measure.” 3:04:10

Dr. Tina Petersen, head of the Flood Control District describes it as a “clear, consistent and equitable basis” for comparing projects that the flood control district is undertaking. 3:04:53

Precinct 3 Commissioner Tom Ramsey says “criteria and frameworks are not necessarily a bad thing,” but then expresses a list of concerns about the proposal, none of which are addressed later in discussion. 3:06:19

Petersen responds that it’s “not perfect.” She says, “there’s no reason we can’t continue to refine this tool.” It’s very “general.” It let’s us “use what we have as a basis for comparison and continue to look forward to opportunities to refine” the tool.

Precinct 2 Commissioner Adrian Garcia asks whether the proposal will add costs or time to projects. 3:11:00

Petersen says no. “The framework should not require additional costs as long as we don’t look back.”

New Precinct 4 Commissioner Asks Probing Questions

New Precinct 4 Commissioner Briones then asks “how often will it be updated?” 3:13:20

Petersen replies, “We’re not considering making any changes to the framework.” She describes the primary uses as: comparing projects and determining which are eligible for funding from the Flood Resilience Trust.

Briones asks whether the framework incorporates “severity of flooding.”

Petersen points to the “efficiency” metric as the closest thing because it incorporate the number of people and structures benefitted. But Petersen sidesteps the point of the question about “depth of flooding” raised by Ramsey earlier. 3:14:25

Briones questions why partnerships are excluded.

Petersen responds that the framework was designed for use with the flood resilience trust, on projects where partnership dollars were no longer considered a possibility. “It was intended to be a backstop for projects that do not have partnership funding.” Petersen does not mention $750 million in HUD/GLO dollars pending final approval.

Briones next asks whether the framework will provide a threshold for making go/no-go decisions on projects. 3:15:40

Petersen replies, “I want to be clear. It will be used for determining whether a project is eligible for flood resilience trust funds.”

At 3:19:30, Ellis quickly closes debate before someone asks for clarification. The measure passes.

Debate Filled with Unresolved Contradictions

Petersen sidestepped Brione’s tough questions about severity of flooding and the eliminating projects. At one point, Petersen said it was “only a point of comparison.” Later, she said it would determine project “eligibility.”

She also equivocated in her response to Ramsey’s concerns. At first she implied the framework was a first step. Later she said that she didn’t plan to change it. Even though the framework is intended for future projects, most of Petersen’s answers related to the past.

Bellwether Vote

Only one thing is certain.

We’re in for four more years of fog described as transparency!

Posted by Bob Rehak on 1/11/2023

1961 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.

Ellis Trying to Change How All Flood-Control Projects Prioritized

Precinct 1 Commissioner Rodney Ellis has placed an item on the Commissioners Court agenda for 1/10/23 with far reaching ramifications for flood control in Harris County. It would change the way every future project is prioritized using a formula that gives almost half the weight to population and building density. Meanwhile, it ignores the amount of damage, severity of flooding, danger to infrastructure, historical underinvestment, and the difficulty of accurately estimating population in flood zones. Ellis’ recommendation could be used to permanently deny projects to heavily flood-damaged areas like Lake Houston.

Text of Motion

In Agenda Item #250, Ellis seeks: “Request for approval to direct the Harris County Flood Control District (“District”) to assign prioritization scores using the adopted 2022 Prioritization Framework for the Allocation of Funds from the Harris County Flood Resilience Trust to all new flood risk reduction projects funded by the District when requesting Commissioners Court approval to initiate the project, and to transmit those scores as quartiles to Commissioners Court.”

So what is that framework and why do we need it?

History of Recent Efforts to Prioritize Projects

Before the 2018 flood bond, Harris County flood control looked primarily at clusters of repeat damage to define and prioritize projects. That damage also formed the basis for obtaining partner funding in many cases.

However, when the perpetually underfunded Flood Control District received the huge infusion of cash from the 2018 flood bond, a problem arose. Which of the many worthy projects would be launched first? There simply weren’t enough qualified contractors to handle all needs simultaneously.

The text of the 2018 flood bond approved by voters contained a sentence that said, “…Commissioners Court shall provide a process for the equitable distribution of funds…” (See Paragraph 14-G). That became the key to the answer…with some verbal legerdemain by Ellis that turned “distribution” into “prioritization” and “equitable” into “equity.”

2019 Equity Prioritization Framework

In 2019, Ellis proposed (and the Court adopted) the “Prioritization Framework for the Implementation of the Harris County Flood Control District 2018 Bond Projects.” This framework ranked projects with a multi-factor index using the following weights:

  • 25% Flood Risk Reduction
  • 20% Existing Conditions (Drainage Level of Service)
  • 20% Social Vulnerability
  • 10% Project Efficiency
  • 10% Partnership Funding
  • 5% Long Term Maintenance Costs
  • 5% Minimizes Environmental Impacts
  • 5% Potential for Multiple Benefits
  • Total 100%

Commissioners, including Ellis, repeatedly affirmed their intent to complete all projects originally identified as part of the bond. The framework simply prioritized their start dates.

Commissioners also talked a lot about prioritizing “the worst first.” It was a nice sound bite, but never defined. Were the worst areas those with the most damage, deepest flooding, poorest residents, highest risk, or some combination of the above? Notice that the formula above omits flood damage, the traditional way of prioritizing funds and “ground-truthing” flood-risk estimates.

At this point, all of the projects in the bond have started. Their natural lifecycles and complexity will determine their order of completion. So, the debate has shifted from the flood bond to other sources of funding and future projects.

2021 Changes Applied to Flood Resilience Trust

In 2021, Commissioners created a Flood Resilience Trust using Toll-Road funds to backstop potential shortfalls in flood-bond partner contributions. The weighting used to allocate funds from the Trust changed significantly.

  • 25% Structures Benefitted
  • 20% Flooding Frequency
  • 20% Social Vulnerability
  • 10% Cost Per Structure
  • 10% Partnership Funding
  • 5% Maintenance Cost
  • 5% Environmental Impact
  • 5% Secondary Benefits
  • Total 100%

Flood Control used this formula only to prioritize the use of backstop funds in the Trust. Note this version of the formula eliminated both damage and risk reduction from consideration.

2022 Changes

In April, 2022, Commissioners modified the 2021 weights within the Prioritization Framework – still only for Flood Resilience Trust Funds – as follows:

  • 45% Project Efficiency
    • 15% Resident Benefits
    • 30% Structure Benefits
  • 20% Existing Conditions
  • 20% Social Vulnerability Index
  • 5% Long Term Maintenance Costs
  • 5% Minimizes Environmental Impacts
  • 5% Potential for Multiple Benefits

This 2022 formula omits consideration of damage, risk reduction and partnership funding. But it gives weight to population density (project cost divided by # residents benefitted). This 15-page PDF explains how projects are scored within each category above.

2023 Proposal

Commissioner Ellis now proposes applying the 2022 Resilience Trust formula to ALL FUTURE HCFCD PROJECTS.

Problems with Proposal

Flood Control would now use Ellis’ formula to decide which projects make the list, not just which go first.

Thus, the so-called “equity” formula once used to schedule projects could now be used to eliminate projects altogether.

Two thirds of the weight goes to density and social vulnerability. Only 20% relates to flooding.

The projects most likely to be eliminated would be outside the Beltway – in less dense areas that have traditionally received the least funding. In a post-bond, financially constrained environment, the weight given to density will put every project outside the Beltway at a disadvantage.

But the Ellis formula has many other problems, too. It:

  1. Does not differentiate between types of structures while giving them almost a third of the weight. Thus, a mobile home counts for as much as a hospital or college.
  2. Gives no weight to protecting critical infrastructure such as bridges, hospitals, grocery stores, wastewater treatment plants, etc. 
  3. Omits actual damage from consideration, which “ground-truths” risk assumptions (see Existing Conditions, Page 6).
  4. Eliminates consideration of partnership funds, which have provided almost one third of HCFCD funding since 2000.
  5. Gives 20% weight to social vulnerability, but ignores the severity of flooding. Thus a low-income home with one inch of flooding counts as much as an entire condo complex swept away by 22-foot deep floodwaters. 
  6. Makes awards more subjective because HCFCD has no way of estimating how many people live in apartment buildings or homes. HCFCD can count buildings in satellite photos, but the number of residents benefitted will always be a guess. Census tracts do not follow floodplain boundaries.
  7. Undermines efforts to prevent flooding, as opposed to correcting it after people are damaged. Prevention, such as HCFCD’s Frontier Program, is always more cost effective in the long run.
  8. Forces Flood Control to judge projects before the District has engineering and cost data in hand that would help determine whether the projects are worth pursuing. That’s because “ALL FUTURE PROJECTS” include preliminary engineering projects.

Suggestions For Improvement

Below are several suggestions to improve the formula.

  1. Define “worst first.” While the sentiment is noble, in practice, the term has no practical definition. (Ditto for equity.)
  2. Incorporate measurements for severity of flooding and amount of damage. These really define worst.
  3. Prioritize critical infrastructure such as bridges whose loss can jeopardize the economic vitality of the region.
  4. Include partnership funds. They help stretch flood-mitigation tax dollars by almost a third. Even if people sometimes must wait longer to line up partner funding, partner funding helps more people in the long run.
  5. Acknowledge that HUD dollars go disproportionately and preferentially to Low-to-Moderate Income neighborhoods.
  6. Publish level-of-service data, used in the “existing conditions” calculation, for all streams in the county. It seems to be secret. I’ve been trying to get it for a year. Keeping it secret undermines trust in government. How do we know money is really going to the areas with the greatest risk?
  7. Publish results of the new prioritization index periodically, so we can see which projects are being eliminated and why. And so we can understand why 18 of the 20 currently active capital improvement projects are in Precincts 1 and 2.
  8. Publish a 5-year Capital Improvement Plan similar to the City of Houston. Let people see what is coming, when, and for how much. That way we can hold HCFCD and Commissioners accountable. Plus, we can see their “formula” in action.
  9. Acknowledge where money has really gone historically.
  10. Be fair to all. The proposed formula is like playing cards with a stacked deck.

Posted by Bob Rehak on 1/7/23

1957 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.

Inherent Bias and Limitations of Flood-Mitigation Benefit Index

In the last few weeks, Michael Bloom, a fellow member of the Harris County Community Flood Resilience Task Force, and I have debated the inherent bias and limitations of a Flood-Mitigation Benefit Index (FMBI) proposed by a majority of the Task Force to Harris County Commissioners Court.

According to Mr. Bloom, the index will:

  • Reveal and document patterns of historical discrimination.
  • Help plan where additional flood-risk reduction investments should be made.

Population-Based, Not Damage-Based Mitigation

The formula is: 

Benefit = Total Cost/(Population X Risk)

…where:

  • Cost = total flood-mitigation construction spending (and only construction spending) that benefits a census tract.
  • Population = the number of people who live in census tracts.
  • Risk = the annual chance of flooding (applied to census tract(s)) expressed as a whole number. For instance, a 1% annual chance equals 1. And a 10% annual chance equals 10, etc.

The Task Force hopes to calculate and compare the results for each census tract in the county.

The formula measures the historical per capita flood-mitigation costs 
supposedly associated with the “current” level of risk in a census tract – NOT historical flood damage.

According to proponents, “a high benefit score means no more mitigation spending is needed. And a low score means more spending is needed.”

But consider these two examples: 

  1. 4,000 people live with a 1% annual chance of flooding and have received $200 in prior investment. Their FMBI would be 0.05. That’s extremely low. And scores that low indicate such areas need help “regardless of prior investment.”
  2. 8000 people live in the 10-year flood plain and have received $10 million in prior investment. Their FMBI equals 125. That’s 2,500 times higher. 

According to a spokesperson for the FMBI, “A high FMBI means we don’t need to make more investments in that location.” Yet twice as many people live with ten times the risk in the area with the higher index.

So, who deserves the most help? Residents with the lowest FMBI? The formula SAYS they need help the most. But they actually have the lowest risk.

The Value of Market Testing

None of the hypothetical examples used to “sell” the formula hint at the possibility of such an upside-down result. 

The example above proves several things: 

  • The formula can produce inconsistent and misleading results.
  • It doesn’t always measure what it purports to measure. It has validity problems, as previously discussed.
  • Adjusting for population doesn’t prove historical discrimination. The most densely populated area has 50,000 times more investment.

The formula needs rigorous testing and ground-truthing before going any further. This is a best practice for any new scientific formula – especially one intended to guide future investment. 

In addition to producing unintended results, the formula has several other problems that require discussion. 

No Right-Of-Way Acquisition Costs Included

The FMBI formula includes only construction costs. It excludes right-of-way acquisition costs by assuming that they are “uniform throughout the county.” Therefore, “…costs included or excluded will not adversely impact results.”

In fact, Right-of-Way (ROW) Acquisition costs are huge and NOT UNIFORM throughout the county. I have documented that ROW costs typically comprise the second most expensive part of flood-control projects.

All Flood Control and partner spending on all capital improvement projects from 1/1/2000 through the end of Q3 2021. Data obtained via FOIA Request from HCFCD.

A quick glance at the Appraisal District website will tell you that land costs vary widely throughout Harris County and change over time.

The cost of buying floodplain land or wetlands for preservation in rural parts of Harris County pales in comparison to land acquisition costs in densely populated parts of the county.

In fact, acquiring land in densely populated areas for flood mitigation often costs more than construction, according to several engineers I consulted.

Compounding Problems?

I worry that other methodological issues may compound each other, not cancel each other out.

Map of Census tracts in Harris County, Texas.

Consider that:

  • Census tract population typically varies by up to 4X (2,000 to 8,000), according to the Census Bureau. This will produce deceptive spatial comparisons.
  • Some Census tracts may comprise dozens of square miles while others comprise a few city blocks. Typically, flood mitigation projects are not considered at the Census-tract level. According to three engineers I consulted, that’s too small in most cases to be workable.
  • Larger Census tracts may contain multiple watersheds, each with independent levels of risk – or individual watersheds with varying levels of risk. In such cases, the formula would average risk. But averaging can mask a serious problem in one area with a non-problem in another. Thus, the formula has a bias in favor of spatially smaller Census tracts.
    Smaller tracts tend to be more uniform in risk, so problems will likely stand out rather than get lost in an average. But in larger watersheds, flood risk will feather out with increased elevation and distance from a river. That will make it extremely difficult to calculate the number of people exposed to varying degrees of risk.
    Averaging takes the simple way out. But averaging risk is like comparing saints and sinners, then declaring “No problem.”
  • The data collection effort for the index omits many sources of funding. So the formula will calculate investment dollars from some entities and areas, but not others. For instance, the formula will NOT measure drainage funding from Harris County Commissioner Precincts, dozens of cities, and 389 municipal utility districts in unincorporated areas. The difficulty of data collection in these areas will produce another spatial bias. Likewise, the FMBI formula will omit the considerable drainage-improvement contributions of reputable private developers. 

No one has tested how these inconsistencies will affect each other. But there’s an even bigger data integrity issue.

Partially Updated Data

HCFCD and its partners invested more than $1.5 billion in flood mitigation between Harvey and the end of 2021. Since 2000, they’ve invested more than $3.5 billion. But as of this writing, new MAAPnext flood maps only reflect the POST-mitigation risk associated with projects in FIVE bayous: Brays, Greens, White Oak, Sims, and Hunting. The Army Corps partnered with HCFCD in those.

Unfortunately, according to a knowledgeable source, HCFCD has not yet updated the risk maps for its own Capital Improvement Projects in other watersheds. So if you ran the allocation formula now, it would compare PRE-mitigation risk in 18 watersheds with POST-mitigation risk in 5. 

Mitigation in those five watersheds totals $439 million out of $1.5 billion since Harvey. So true, current risk is reflected in only 29% of spending since Harvey and 13% in this century. Those percentages will no doubt increase in the future. But if you ran the numbers today, you would compare numbers with PRE- and POST-mitigation risk.

And consider this. With HCFCD spending at the current rate of about $80 million per quarter, “current risk” is a constantly changing target. So we’ll never be able to compare apples to apples in all watersheds anytime soon.

And we want to use this formula to guide future mitigation spending? Using it could send more money back to fix areas we already fixed!

Difficulty of Assigning Investments to Census Tracts

Another challenge: How do you determine which census tract(s) to apportion project benefits among? Example: Addicks and Barker Reservoirs. The Army Corps developed those back in the 1930s to protect downtown Houston…15-20 miles away! 

Do you credit the investment to:

  • All of downtown?
  • People living inside the reservoirs (who have their own census tract)?
  • The current population of the entire Addicks and Barker Watersheds?
  • All census tracts along Buffalo Bayou and parts of White Oak Bayou, our second and third most populous watersheds?

The Corps certainly didn’t build the reservoirs to protect the people living inside them. That’s what all the lawsuits are about!

And virtually all residents of the Addicks and Barker watersheds live upstream from the Corps’ investment, so they will not benefit from the investment either.

Downtown has immense commercial and economic value but relatively few permanent residents. 

So, who gets the benefit? Again, lots of room for interpretation and misplaced assumptions here that numbers can easily mask! Now, multiply this problem times thousands of Census tracts.

Anti-Commercial Bias

The population-based FMBI has a built-in bias against commercial areas that have little to no residential population. For example, consider the cases of Downtown, the Texas Medical Center, and the Port of Houston. Such areas support employment throughout the region, but the formula discriminates against them by giving huge weight to population and omitting actual damage.

No Thresholds Defined

To my knowledge, the task force has never discussed threshhold “benefit” levels that correlate to “needs help” or “doesn’t need help.” The extremes may sometimes be easy to determine. But what about outcomes in the middle? 

Offsetting Variables

Variables in the formula can offset each other as we saw above. In tight races for funding, who gets the next flood-mitigation investment? The area with the lowest investment, highest risk, or largest population? Such quandaries have not yet been addressed. 

No Agreement on Weights of Other Factors

To help make future flood-mitigation decisions, proponents of the formula also suggest weighing (separately) other factors, such as the CDC’s Social Vulnerability Index. It includes the percentage of Low-to-Moderate residents in an area. However, no one has yet discussed the weight given the Benefit Index relative to other factors.

No Consideration of Actual Flood Damage

In deciding where to put flood mitigation projects, engineers traditionally look for damage clusters. It’s that simple. Dollars flow to damage.

Reducing flood damage is a tried and true, measurable way to evaluate projects. So why all the complexity? 

What’s The Point?

What is this formula trying to prove? Is it attempting to develop a new approach to mitigation funding that eliminates a perceived bias in Benefit/Cost Ratios? 

Commissioner Rodney Ellis often talks about how calculating the value of avoided damages in higher value homes disadvantages projects in poorer neighborhoods. That can be true in some instances. Expensive homes can ratchet up benefits (measured in dollars) faster than lower value homes can. And that can result in higher Benefit/Cost Ratios for projects in affluent neighborhoods – assuming density is held constant. But…

One high-value home on an acre would likely appraise less than an apartment building, also on an acre. In Kingwood, I compared the valuations of an expensive single-family home with a large apartment complex one block away. The appraised cost per acre (including structures) of the apartment complex is 4X higher.

Now consider that apartments accommodate almost half of Harris County’s population.

According to the latest census data, 54.9% of Harris County residents live in owner-occupied homes. The rest, 45.1 percent, live in apartments.

Most Americans aspire to and encourage home ownership, in part, because of the stability it fosters in communities. But this formula – because of its emphasis on population density – favors apartment areas over areas with owner-occupied homes. There’s nothing inherently wrong with that. You just need to understand what the formula does.

Difference Between Vertical and Horizontal Density

The Benefit Index favors all areas with dense population. Proponents argue that helping more people is better. I don’t argue with that. However, the generalization masks the financial pain inflicted by a flood on owners vs. renters, and on the people who live at ground level compared to those who live above it. 

Ground floor renters may lose contents in a flood, but they won’t be responsible for making structural repairs. The owner will. 

And many living above the ground floor may find themselves more inconvenienced by flooding than financially devastated. So, is it fair to count all people on all floors when determining who suffers the most pain? 

Five-story apartment buildings crowding Brays Bayou with ground-level parking underneath. HCFCD has no way of knowing how many people live in apartments like this, yet HCFCD will be responsible for compiling the data.

In the proposed formula, higher population will lower the benefit index, making it look as though all renters (almost half the county’s population) suffered more than owners of single-family homes. 

The premise underlying such “equity” arguments is that poor people can least afford floods. But most people in apartments like those shown above won’t make structural repairs as a homeowner would.

No Perfect Formula

No perfect formula exists that’s equally fair to all in all circumstances. That’s why FEMA, HUD and the Army Corps allow consideration of multiple factors when determining which projects to fund. 

The Flood Mitigation Benefit Index focuses totally on population, risk, and past investment. It ignores actual flood damage. 

If we use ANY formula to HELP allocate future flood-mitigation funds, we should all strive to:

  • Understand its built-in biases
  • Maintain high standards for data integrity.

If we want to test a hypothesis of historical discrimination in flood-mitigation funding, there’s a much simpler way. It’s called direct measurement. Simply locate damage centers from past storms and compare funding in the following decade designed to mitigate those areas.

For More Information

For more background on issues with the formula, see my earlier posts:

Or consult Mr. Bloom’s rebuttals.

Posted by Bob Rehak on 7/14/22

1780 Days since Hurricane Harvey