Tag Archive for: equity

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)


  • 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

Questionable Validity of Flood-Mitigation Equity Formula

The results of an apparently invalid flood-mitigation equity formula could be used to steer billions of dollars in future flood-mitigation funding. Multiple data quality and collection issues may compound errors and the formula itself sometimes renders inconsistent, counter-intuitive results.

In the 6/28/22 Harris County Commissioners Court meeting, the Community Flood Resilience Task Force presented its first annual report. The report contains a lengthy discussion of a flood-mitigation equity formula developed by several Task Force members to “objectively” compare the “equity” of flood-mitigation investments (project costs). See the appendix starting on Page XVI and ending on Page XX.

The attempt to create objective comparisons between investments in different areas is well intentioned. However, I fear the proposed formula will create the appearance of objectivity while skewing data and producing misleading results. Here’s why.

The Formula

The formula is…

Flood Mitigation Benefits Index = Total Cost to Date/(Population Density X Risk)


  • Population Density is the number of people per square mile, calculated at the US Census Tract level.
  • Flood Risk is the current annual chance of inundation. For instance, a 1% chance = 1. Or a 10% chance = 10, etc.
  • Total Cost to Date shows cumulative dollars spent on flood-risk-reduction projects (construction only, adjusted for inflation) over the longest time period for which records are available, calculated at the US Census Tract level.

The report claims that a higher index means people have received more investment and therefore have less flood risk (i.e., more benefit). Conversely, a low index indicates less investment, more risk and less benefit.

The focus on census tracts is designed to make the data more granular than watersheds. Flood risk estimates will be averaged across the census tract and updated after MAAPnext data becomes available.

Here are several issues I have articulated to the Task Force.

Data Collection and Quality Issues

  1. Calculating only construction costs excludes other capital improvement costs such as engineering, design and right-of-way acquisition. Since 2000, construction costs have comprised only 40% of capital improvement costs. See below. And those costs don’t even reflect maintenance and repairs, which are crucial in reducing flooding.
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.

2. According to the report, costs factored into the formula will include those from City of Houston projects and Harris County Flood Control projects. But they don’t include other municipalities’. There are at least 33 other cities in the County. The formula will reflect street-flooding risk, but not all spending to reduce that risk.

3. Likewise, it’s not clear whether the risk reflects pre- or post-mitigation spending, or both. Every time I ask about that, I get silence not an answer. Flood Control has spent more than $1.5 billion on flood mitigation since Harvey, while simultaneously developing new flood maps. Will the numerator of the formula sometimes reflect that investment but not the denominator?

4. Readily available digital spending data goes back only to 2000. But the Task Force committee chairman insists on getting data going back to the start of the Flood Control District – in 1937. If those records still exist, they will radically skew historical comparisons between watersheds, many of which were farms or forests until much more recently.

5. Flood risk depends on more than just mitigation investments. It’s a shifting target that has changed multiple times since 1937 as our understanding of rainfall probabilities has improved, and as different jurisdictions recognize that risk at different times. Flood risk also depends on upstream growth. That has been exponential. In the 2020 Census, Harris County had 4.7 million people. But in the 1930 Census, Harris County had only 359,328 – one thirteenth of today’s population, and presumably one thirteenth of the census tracts. So, attributing all change in risk to investment is fallacious.

6. Many of the census tracts have changed since the 1930s. Census tract boundaries are only “relatively” permanent. They often change based on Census results. For instance, when a census tract’s internal population grows over 8,000 persons, it may split into two or more smaller census tracts. Also, census tract boundaries may cross watershed boundaries. Major thoroughfares usually define census tract boundaries, not the direction of flowing water.

7. HCFCD has said they do not collect spending data by census tract. They calculate how much it costs to remove structures from the floodplain. So census tract data will have to be estimated manually – something that makes data-quality experts nervous.

8. Many neighborhoods outside Beltway 8 didn’t exist back in the 1930s. Beltway 8 didn’t even exist then. Nor did Lake Houston; the City began impounding water only in 1954.

9. The formula – designed to reduce flood damage – doesn’t measure flood damage.

10. So much data in this study won’t be directly comparable that I worry the authors won’t be able to highlight areas worthy of future investment. Final results will include compounded error on multiple levels. It doesn’t compare apples to apples; it compares apples to oranges, bananas, blueberries, cherries, strawberries, coconuts, Monty Python’s elderberries and more.

Questionable Validity

In fairness, I’m sure the final report, when it becomes available, would disclose these problems in an appendix or footnotes. But how many people dig into those? And who will “peer review” this study?

I have worked with market research my entire career and know the painstaking extents to which researchers go to ensure validity of their studies.

Validity has to do with accuracy. Are you really measuring what you purport to measure? For instance, is flood risk influenced ONLY by mitigation investment? Or is it ALSO influenced by other factors, such as:

The answer is a resounding YES to all those questions and more.

Good research studies typically measure the impact of one variable on another variable. For instance, in Harris County, what was the death rate last year among adults over 50 who contracted Covid among vaccinated and unvaccinated groups? Researchers carefully match the two groups being studied for factors such as randomness of subject recruitment, age, living situation, and history of other diseases. There is only one variable: vaccination. That way, they can tell whether the death rate varies among vaccinated people.

But the Flood Mitigation Benefit Index wasn’t designed with that kind of rigor. For example:

While purporting to compare ‘benefits’ of flood-mitigation to different areas, it doesn’t even employ pre- or post-measurements.

Further reducing comparability of results during the period studied:

  • Census tracts changed.
  • Population density changed.
  • Building codes changed.
  • Channels filled up with sediment, but maintenance won’t be measured.
  • AND the data does not measure street-flooding mitigation investments in almost HALF the county.

Because the flood-equity formula doesn’t control for such factors, we won’t know what caused variation in the results.

Formula Produces Inconsistent Results

The flood-equity formula does not even yield results that vary intuitively. For instance, when you hold population density and flood risk constant, but increase investment, the benefit goes up.

  • Example A: If Density = 5000, Risk = 10 and Investment = $100,000, then Benefit Index = 2
  • Example B: If Density = 5000, Risk = 10, and Investment = $1 million, then Benefit Index = 20

So, spending more money to get the same results increases benefits? Shouldn’t it be the opposite?

That’s both depressing and confusing. You spend 10X the money; flood risk remains the same; and the “benefit” increases!!!???

You would think spending less money to achieve identical results would be more beneficial. It certainly is for taxpayers.

Although the Task Force won’t admit it, the formula is really trying to prove “historical disinvestment,” a claim tossed around frequently in Task-Force and Commissioners Court meetings without data to back it up.

But if the goal is to protect the most people from future flooding, why not just invest in projects where the highest risk remains for the greatest number of people? Both of those are simple, unambiguous direct measurements. But those might not produce the results that the authors of this formula hope to get.

I believe we should look forward, not back, with our flood-mitigation dollars. We can’t change the past…whatever it was. We can only affect the future by what we do today.

Posted by Bob Rehak on 7/3/2022

1769 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.

First Quarter 2022 Flood-Mitigation Spending Update, New Equity Formula

In the first quarter of 2022, Harris County Flood Control District spent a total of $84 million. That brought the total of flood mitigation spending since 2000 up to almost $3.8 billion.

For the first time since ReduceFlooding.com started tracking these numbers via Freedom of Information Act requests, spending in the Hunting Bayou watershed led all other watersheds. Brays Bayou, the previous front runner, dropped into second place. Cypress Creek, White Oak Bayou, Clear Creek, and Halls and Greens Bayous virtually tied for third place in spending. The San Jacinto Watershed came in 17th despite the fact that it is the largest in the county.

Watershed spending by Harris County Flood Control District last quarter and since 2000. Includes partner funds and all phases of all projects.

The Galveston Bay and Vince Bayou Watersheds had no invoices reported during the quarter. Totals for Jackson and Addicks were restated to account for a change in accounting, resulting in negative numbers. Previously HCFCD reported dollars spent by project management status. The District now reports totals by invoice date. The new method is more precise.

First Quarter 2022 Watershed Rankings

Negative numbers reflect adjustment for change in accounting described above.

Cumulative Spending Since 2000

Ratio between highest and lowest is almost 100 to 1.

Totals Since Harvey

Between Harvey and the end of 2021, HCFCD spent $1.45 billion on all watersheds. The $85 million spent in the first quarter of 2022 brings the total since Harvey up to $1.535 billion.

San Jacinto Watershed

Of the almost half million dollars spent in the San Jacinto Watershed during the first quarter of 2022, virtually all of it was spent on preliminary engineering and design. The Harris County Flood Control District shows only one active capital improvement construction project in the San Jacinto Watershed valued at $1,000. That’s the Excavation and Removal Contract on the Woodridge Village Property to develop additional floodwater detention capacity. Compare that to the $15.6 million spent on construction in Hunting Bayou.

Equity Formula Being Changed Again

The disparity in totals between watersheds largely has to do with Federal partner funding and the equity funding formula passed by three Democrats at Harris County Commissioners Court. The original formula has been revised again and again to send more and more funding to watersheds with high percentages of low-to-moderate income residents. Commissioners started debating another set of changes to the formula today that would apply to money in the Flood Resilience Trust, but did not vote on it.

The changes recommended include:

  • Prioritizing people over structures
  • Eliminating partnership funding from consideration
  • Recommending proxies for FEMA data since 1977
People Over Structures

This change would favor spending in densely populated neighborhoods inside Beltway 8 as opposed to neighborhoods with more single-family homes outside Beltway 8. For example, 100 people could live in an apartment building on a single acre. So could 3 people in a single family home. The only problem: Flood control has no way of determining how many people live in an apartment building. So the District will have to use an average for the watershed, according to Dr. Tina Petersen, the new head of flood control.

Partner Funding

Democrats don’t want to wait for partner funding. They want to start projects right away, using bond money and other funds diverted from the toll road. Using out of pocket money could speed up flood-mitigation projects in low-to-moderate income neighborhoods, but it could also reduce the size of the total pot, jeopardizing badly needed projects somewhere.

Dated Data

Using 1977 data would disadvantage areas outside the Beltway, which was under construction at that time. Places like Kingwood were just beginning to be built. So using the older data from the Seventies would stack the deck in favor of inner-city neighborhoods. However, there was no universal agreement on a suitable substitute for the FEMA damage claims.

“Who Goes First?” No Longer the Issue

These constant changes to an equity formula which was originally conceived as a “Who goes first?” tool, seem to make less and less sense now that all flood bond projects have started. So commissioners are considering these changes in regard to the Flood Resilience Trust. That money will theoretically allow development of more projects when the flood bond expires. But no one has yet determined the list of projects for that money. So Commissioners still have many details to work out.

One huge related detail is developing a plan for how to spend $750 million in HUD partner funds. The county administrator seems to have turfed the assignment to the Community Services Department. Said another way, they took it out of Flood Control and put it in a department that has had four leadership changes in four years.

Out of 154,000 homes in the county damaged by Harvey, Community Services managed to distribute only $21.4 million in repair funds.

No offense. I’m sure this is a difficult job. And I’m sure the county has talented people. But justifying flood-mitigation grants seems to be more of a job for engineers than people who handle claims. The adventure continues. More details in coming weeks.

Posted by Bob Rehak on 4/26/2022

1701 Days since Hurricane Harvey

How Do You Define “Worst First”?

In the rush to mitigate flooding after Hurricane Harvey, most people agreed that we should attack the areas with the worst flooding first. While almost everyone agreed with the “worst first” mantra, no one defined it – until after the flood bond passed.

Alternative Ways to Define “Worst First”

How would you define the “worst” flooding? The area with the:

  • Most flooded homes?
  • Most frequent flooding?
  • Most damage in dollar terms?
  • Largest population living in a 100-year floodplain?
  • Most low-to-moderate income residents who can least afford to fix their homes?
  • Largest minority populations?
  • Highest Social Vulnerability Index (SVI)?
  • Most damage to infrastructure (bridges, hospitals, grocery stores, schools, sewage treatment plants, etc.)?
  • Highest water above the tops of banks in a widespread storm like Harvey?

You could make valid arguments for each. And people have – almost from the day the flood bond passed – as they fought for more funding for their watersheds.

Least Considered Alternative

But the one I have heard talked about the least is the last one: highest water above tops of banks. Surely, the depth of a flood must count for something. It affects the ability to evacuate and rescue people. It puts lives at risk. Can destroy infrastructure. Spread sewage. Increase erosion. Even cause rivers to migrate. And sweep whole apartment buildings into rivers.

Yesterday, as I reviewed a doctoral thesis from a student at the Colorado School of Mines, I saw a graph that compared the height of the Harvey flood at the San Jacinto West Fork and US59 to other rivers/streams in the region. The West Fork flood towered above the others. So it made me wonder. How did the flood at that location compare to other streams and bayous in Harris County?

How to Determine “Feet Above Flood Stage”

There’s an easy way to find out. The Harris County Flood Warning System contains all the pertinent information.

  1. Go to the home page.
  2. Click on a gage.
  3. Click on the “For more information” link in the pop-up box.
  4. On the new page (dedicated to historical information about that gage), click on the stream elevation tab.
  5. Note the “flooding likely” elevation. This roughly coincides with the top of bank, though banks can vary slightly.
  6. Scroll down to the bottom of the page and note the elevation of the flood at that location during Hurricane Harvey.
  7. Subtract the “flooding likely” level from the Harvey level, to determine the feet above flood stage in Harvey.
  8. Click on the drop-down box with the gage information to compare the same stats for additional gages.

North Harris County Had Highest Floods

This morning, I compiled the data for 33 gages. The chart below shows what I found. Of the gages I sampled, the four highest floods all occurred in the upper San Jacinto River Basin: West Fork at 59, Spring Creek at 45, Cypress Creek at Cypresswood, and West Fork at 99. Also note the preponderance of high water along Greens Bayou at numerous locations.

Data compiled from Harris County Flood Warning System using the technique described above.

Limitations of Measure

“Feet above Flood Stage” by itself won’t tell you which area had the worst flooding during Harvey. It’s just one measure. You must consider other factors, too, such as those listed above.

But this chart sure makes it hard to ignore the fact that something is happening in north Harris County to exacerbate flooding. I’ve chronicled many of those things in the pages of this website: sand mining, development, rapid growth, impervious cover, loss of wetlands, lack of detention ponds, lax regulation/enforcement and more.

One must also acknowledge the role that topography plays in a chart, such as this. A narrow floodplain with steep banks can force water higher. A wider floodplain through a flat area allows water to spread out, lowering the height of floodwaters.

Variations in rainfall across an area can also skew results.

And finally, I didn’t click on every gage in the region. There are hundreds. You wouldn’t have been able to read the chart because the type would have been so small. So investigate on your own and let me know what you find.

Need for Active Discussion/Debate in Upcoming Elections

The Harris County Community Flood Resilience Task Force just voted to change the way “worst first” is calculated – again! The highest correlation between funding and all of the other factors I have evaluated is now with low-to-moderate-income population. It’s not with damaged structures, dollar damage, watershed size, or population density.

If you want to ensure that outlying areas get their fair share of flood mitigation dollars in the future, you need to demand them when you go to the polls this fall.

Posted by Bob Rehak on 3/29/2022

1673 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.

City Seeks Your Feedback on Equity Indicators Survey

The City of Houston is launching its “Equity Indicators” project by asking for your comments to one important question: What makes a community equitable?

Reflecting Houston’s Diversity

Houston is the most diverse city in the nation, but despite the strength of our diversity and multiculturalism, Houstonians experience vast racial and ethnic disparities. The Equity Indicators Project will facilitate broader conversations on equity and inclusion, take active steps to measure disparities, and have leaders across multiple sectors be held accountable for taking action to increase equitable outcomes for all Houstonians.

The city is seeking feedback from community members to ensure that this project is reflective of Houston’s diversity and multiculturalism.  Visit houstontx.gov/equity to share your thoughts on what makes a community equitable between March 6 until April 2.

“In a city where 146 languages are spoken, we must use every tool possible to ensure that every Houstonian’s voice is being heard,” said Mayor Sylvester Turner. “This survey is a direct, impactful way to participate in making the city, its services, and its opportunities more accessible to people regardless of their background.”

Houston Mayor Sylvester Turner
File Photo: Houston Mayor Sylvester Turner speaking at the Kingwood Community Center

Project Sponsored By…

The Equity Indicators project is led by the Planning and Development Department, Mayor’s Office of Resilience and Sustainability, and Complete Communities, and ties to the vision and framework for a resilient community outlined in the Resilient Houston strategy. The city has partnered with Rice Kinder Institute for Urban Research using the methodology developed by CUNY- Institute for State & Local Governance to focus on key indicators for equity in Houston. The Shell Foundation has funded this initiative that focuses on six themes:

  • Economic opportunity
  • Health
  • Public Safety
  • Environmental and Climate Risks
  • Built Environment
  • Access and Inclusion

How Data Will Be Used

The data analysis will result in an overall Equity Indicators Score for the City of Houston.  The public, city departments, city programs, and community service organizations can track the score to document progress and change over time.  The numerical value is based on a 100-point scale.  A high score signifies Houston’s level of success toward building an equitable city, whereas a low score represents a high level of inequity and more opportunity for improvement.

For More Information or Printed Survey…

A printed survey card will also be available at city locations. Houstonians with questions or needing assistance filling out the survey may call 832-393-6637.  For more information, visit Equity Indicators online atwww.houstontx.gov/equity.

Thought Starters: Aspects of Equity Measured by Various Indices

It seems everybody has a way to measure equity these days. Without trying to influence your opinion, I would simply reprint this list of indexes compiled by the Brookings Metropolitan Policy Program.

Posted by Bob Rehak on 3/9/2022 based on a press release by COH and info compiled by Brookings

1653 Days since Hurricane Harvey