Tag Archive for: FEMA

Building-Code Pushback that Makes Disasters Worse

On 2/28/23, I attended an excellent online FEMA seminar about building codes. It was a two-part presentation. Part One discussed how higher building codes can reduce damages from flooding. Part Two discussed building-code pushback. For example, despite all the flood damage in Texas, the State hasn’t updated its building codes since 2012 – even though the International Building Code and International Resilience Code have been updated several times since then.

That raises the question, “Why not?”

Life-Saving Codes

Part One began by talking about how, after every major natural disaster, FEMA sends in building-code experts to examine how structures performed and make recommendations for code changes to reduce future damage. It’s part of a process of continuous improvement that could/should make us all safer. 

Part One ended with one of the most poignant stories I have ever heard. After a Cat 4 Hurricane struck Florida last year, a FEMA team was driving down a street littered with the debris of gutted homes and shattered lives. Mountains of waterlogged drywall, carpeting, furniture and cherished possessions lined both sides of the street waiting to be hauled away…just as it did in Houston after Harvey and Imelda.

Kingwood debris pile after Imelda.

But when the FEMA team got to the end of the street, they saw something that stunned them – a pristine home with nothing out front. It was actually the home on the street closest to the ocean. As they paused to marvel at the miracle, the homeowner drove up. They asked him the logical question, “Did you build above code requirements?” 

“Not really,” said the homeowner. “I just built to what the code required.”

He went on to elaborate how the building inspector was a real stickler. “I thought he just had it in for me because I was a hippie. I really hated the guy.”

“What do you think of him now?” asked the FEMA employees. The homeowner extended his arms and made a bowing motion as if to praise and thank the man who had been such a thorn in his side. 

Billions Saved

FEMA estimates that adoption of hazard-resistant building codes saved $32 billion during the last 20 years and could save another $132 billion by 2040. Not to mention saving a lot of heartbreak and misery.

So why are people so resistant to adopting higher building codes?

Resistance on Many Levels

Part Two of the presentation examined sources of resistance to adopting higher building codes. They used Louisiana’s attempt to increase freeboard factors as an example of the the types of resistance FEMA frequently encounters from various groups.

In engineering, freeboard is is the distance codes require you to build above the current estimated 100-year flood level.

The greater the freeboard, the safer you are.

But still, people found reasons not to increase the freeboard. The second presenter examined seven sources of resistance:

  1. Perceived conflict between statewide minimum codes and local governments that may wish to adopt higher standards.
  2. Uncertainty about where freeboard regulations had and hadn’t been adopted already.
  3. Debate about whether the state or local authorities should establish standards.
  4. Questions about why FEMA isn’t making the regulations at a national level.
  5. Perceived lack of discounts in Risk Rating 2.0 national flood insurance premiums for structures elevated to meet higher freeboard requirements.
  6. Concern about whether fill to elevate homes would make flooding worse.
  7. Confusion over how building code officials and floodplain managers can collaborate.

All are valid concerns. But all can be overcome. Pretty easily, it turns out.

Answers readily exist for each of these issues. For example, with #6 (probably the most valid concern), communities have adopted standards to limit fill in areas where floodwater storage is a major concern.

For the other answers, see the entire presentation. The point I really want to make is about the pushback against proven practices that save lives and property.

Why Resist Changes that Avert Human Suffering?

As I watched the presentation, the image floating through my head was of the NTSB investigating a plane crash that killed hundreds of people. Imagine if the investigation found a defective engine part caused the catastrophe. Do you think manufacturers would resist upgrading the part?

It’s unthinkable. Who would board such an airplane? What aircraft manufacturer would even lobby against the change? The negative publicity would put them out of business. 

But homebuilding and the development business are different. The industry has a million players, not a handful. A few bad actors can escape notice because:

  • The codes are so complex that few understand them.
  • Lobbyists frame discussion as “acceptable risk” vs. “unacceptable costs.”
  • Responsibility is shared among government regulators at many levels, their political masters, and private industry.
  • This creates an atmosphere of plausible deniability when disaster strikes. “We were just following regulations.” (Yeah, but who lobbied against them?) 

Building Codes Like Seat Belts

Some readers may remember the battles to pass and enforce seat belt laws. Even though the federal government required manufacturers to install seat belts in all new cars starting in 1968, only 14% of Americans regularly used them at first. Adoption of state laws mandating usage was spotty. And when a Michigan state rep introduced a bill in the early 1980s that levied a fine for not buckling up, he received hate mail comparing him to Hitler. American’s love their freedom so much, they can even react negatively to efforts to protect them.

It’s the same way with building codes. Even when they provide a greater than 10-to-1 payback and qualify you for a billion dollars in flood-mitigation funding!

If you want to see how appallingly out of date Texas building codes can be, explore these two websites.

Building Code Adoption Tracking Portal
Only six municipalities in all counties shown here have adopted up-to-date building codes.

So when the next disaster strikes, let the finger pointing begin.

No wait! Let’s just get a bailout from FEMA!

Posted by Bob Rehak on 3/1/2023

2010 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.

Lake Houston Gates Project Moves Closer to Reality

The Lake Houston Gates Project is moving closer to reality with breakthroughs on the benefit/cost ratio, funding and endorsements.

City of Houston Mayor Pro Tem Dave Martin and Chief Recovery Officer Stephen Costello provided updates on 2/27/23 at City Hall on the Lake Houston Gates Project. The wide-ranging, hour-long discussion covered several related topics. They included:

  • A critical path for construction
  • Dredging of the lake
  • Funding for gates and dredging
  • Several related engineering studies
  • A favorable ruling from FEMA on the Benefit-Cost Ratio
  • An endorsement to the area’s legislators by the Greater Houston Partnership.

Need For Gates

For those new to the area, the City of Houston has been pushing to add gates to the Lake Houston Dam ever since Harvey in 2017. Upstream, Lake Conroe’s gates can release 150,000 cubic feet per second (CFS). But Lake Houston’s can only release 10,000 CFS.

The disparity in discharge capacity complicates joint-reservoir-management and pre-release strategies designed to avoid flooding by reducing the water level in Lake Houston.

Lake Houston releases cannot keep up with Lake Conroe’s. And pre-releasing water from Lake Houston takes so long that storms can veer away during the lowering process, often resulting in wasted water. That’s an important consideration for a water-supply lake.

According to Martin and Costello, the gate project will:

• Serve as the first phase of a long-term effort to extend the life of the Dam
• Enable the rapid lowering of lake levels in advance of a flood
• Eliminate the need for a seasonal lowering of both Lake Houston and Lake Conroe
• Provide potential water-rights savings
• Protect an estimated 5,000 residential properties in the surrounding area
• Yield an estimated half billion dollars in economic benefits during the life of the project

Gates, Funding, BCR, Studies

Preliminary engineering studies evaluated about a dozen different alternatives for adding discharge capacity to Lake Houston. The City initially favored adding crest gates to the spillway portion of the dam.

However, the City discarded that idea as “too risky” after further study. The engineering company cautioned the City that it would have a difficult time finding contractors willing to risk modifying a 70-year old concrete dam. The potential liability was just too great. So the City then revisited adding various numbers of tainter gates to the eastern, earthen portion of the dam.

Because tainter gates exceeded FEMA’s funding, the City had initially focused on crest gates. But after investigating the safety issues, the City decided to seek more funding for tainter gates instead.

The City now recommends adding 11 tainter gates.

Recommended location for new tainter gates is next to old ones, not farther east as I conjectured earlier.

The picture below is slightly wider and shows more of how both halves of the dam come together.

If funding comes through, new gates would go in the upper right along the earthen portion of the dam, next to the old gates.
Funding Needs

FEMA initially set aside $50 million for the gates. Plus Harris County committed $20 million in the 2018 Flood Bond to attract FEMA’s match. But the latest construction estimates show eleven tainter gates could cost between $200 and $250 million.

After engineering and environmental studies, only $68.3 million in funding remains. That includes an earmark secured by Congressman Dan Crenshaw. So the City is seeking another $150 million from the State of Texas. Martin and Costello have made weekly trips to Austin so far during this session to line up support from legislators, committee chairs, and the Texas Division of Emergency Management.

Social Benefits Improve Benefit/Cost Ratio

All this is suddenly possible because of a favorable ruling from FEMA on the benefit-cost ratio (BCR).

For years, Houston had struggled to get the BCR for the gate project above 1.0 (the point at which benefits exceed costs). Usually, FEMA strictly interprets benefits as “avoided damages to structures.”

But Houston Mayor Sylvester Turner and Costello met with FEMA to argue that the problem was much bigger than damaged structures.

As a result, FEMA allowed the City to add the value of “social benefits” to the BCR. Social benefits can include such things as avoiding lost wages when businesses are destroyed; transportation disruptions that reduce the region’s productivity; reducing negative impacts on student achievement when schools are disrupted; and more.

The social-benefit ruling covers a number of City projects, not just the gates. It should also benefit other areas, especially rural ones.

Said Costello, “The minute the social benefits came in, everything was great.” Instead of struggling to reach 1.0, the City is now far above it.

Greater Houston Partnership Endorsement

With that out of the way, the Greater Houston Partnership wrote a powerful letter to state legislators seeking their support for the gate project. See below.

Greater Houston Partnership letter endorsing Lake Houston Gates. For a printable PDF, click here.

The Partnership includes business leaders from 900 member companies in the 12-county Houston Region.

Dredging Update

While pressing ahead with the gates project, the City is also working on a long-term dredging plan for the lake and working with the SJRA on sedimentation and sand-trap pilot projects.

The Texas Water Department Board (TWDB) has estimated sediment inflow to Lake Houston at about 380 acre-feet of material annually.

The lake has already lost more than 20,000 acre feet of capacity due to sedimentation. That worsens flooding. While the Federal Government supports efforts to improve Lake Houston now, the chances of getting more money in the future will be reduced – unless we can show that we’re at least keeping pace with annual sediment deposits.

Since Harvey, FEMA, the Army Corps, TWDB, and City of Houston have removed almost 4 million cubic yards of material from the lake at a cost of $226 million.

We have to prevent more sediment from coming downstream or dredge it after it gets here.

Stephen Costello, City of Houston Chief Recovery Officer

The City is currently lobbying for another $50 million for maintenance dredging to add to the money secured in the last legislative session by now-retired State Representative Dan Huberty. New Representative Charles Cunningham will reportedly now carry that banner forward along with State Senator Brandon Creighton.

Legislative News to Follow

March 10th is the last day to file bills in the Texas Legislature this year. Please visit the legislation page on ReduceFlooding.com for updates once bills are filed and start moving forward in Austin.

Thanks to all of our elected and appointed representatives who have pushed so hard on so many fronts for the last 2008 days to tie all the pieces of this complicated flood-mitigation puzzle together.

Posted by Bob Rehak on 2/27/2023

2008 Days since Hurricane Harvey

FEMA Simplifying Procedures for Small Public Assistance Grants

On January 9, 2023, FEMA released a Simplified Procedures policy for Public Assistance grants to speed up recovery for applicants. Small projects are now defined as those up to $1 million.

The new policy should reduce administrative burdens and enable communities to recover more quickly after presidentially declared events by streamlining documentation requirements.

FEMA will accept estimates with summary information and the applicant’s certifications for damage and work, instead of requiring applicants to provide full or detailed documentation. 

FEMA Press Release

FEMA conducted a review in 2020. It showed that if a $1 million threshold were applied, 94 percent of projects would be considered small and help put additional recovery dollars in the hands of applicants faster and accelerate closure of projects.

FEMA intends to continue adjusting the threshold annually to reflect changes in the Consumer Price Index. It also intends to review the base threshold every three years.

The new policy is not directly aimed at individuals, but at state and local governments and certain types of private nonprofit organizations. Public Assistance grants cover such things as:

  • Disaster-related debris removal
  • Emergency protective measures
  • Repairs to damaged or destroyed infrastructure (i.e., roads).
FM 1010
FM1010 Washout during Harvey at Rocky Branch in Plum Grove near the East Fork. Still not repaired after 5.5 years.

Depending on repair cost and other factors, the road washout above is an example of the type of project that might benefit from the new policy. However, it’s not clear whether the simplified procedures apply retroactively to damage from past disasters or only future disasters. More details will follow.

How Public Assistance Usually Works

In general, applicants submit Requests for Public Assistance (RPAs) within 30 days of the disaster declaration. They must demonstrate that:

  • Damage is in a designated area
  • Applicant has legal responsibility to perform the work
  • Cost is reasonable.

Once FEMA and the state review and approve the government agencies’ or nonprofits’ RPAs, applicants work with their FEMA representative to develop a damage inventory. 

FEMA obligates funds to the state once a project meets Stafford Act eligibility requirements. The state is the official recipient of FEMA federal assistance. The state is then responsible for disbursing the money to applicants. 

FEMA will hold a series of webinars in coming weeks to explain more about the simplified policy. Additional details are not yet available.

Getting aid to people faster after a disaster is necessary. This is a very complex subject. I wish all forms of disaster relief, including hazard mitigation, could be simplified. We’re still waiting on the Harris County, the GLO and HUD to agree on a plan for spending $750 million in mitigation funds related to Hurricane Harvey – 5.5 years after the event!

Posted by Bob Rehak on 1/12/23 based on a FEMA Press Release

1962 Days after Hurricane Harvey

Flood Map Accuracy

On December 6, 2022, The Washington Post ran an article titled “America Underwater: Extreme floods expose the flaws in FEMA’s risk maps.” The lengthy story by Samuel Oakford, John Muyskens, Sarah Cahlan and Joyce Sohyun Lee cross-referenced photos and videos with FEMA flood maps from areas around the country that flooded last summer.

The basic premise: FEMA’s flood maps “are failing to warn Americans about flood risk.” The authors then claim, “The resulting picture leaves homeowners, prospective buyers, renters and cities in the dark about the potential dangers they face, which insurance they should buy and what kinds of development should be restricted.”

There’s certainly room for improvement in FEMA flood maps.

FEMA Map from National Flood Hazard Layer Viewer. Note how mapping stops at Montgomery County line, one of the issues cited in The Post article.

But is Climate Change the Reason for Inaccuracy?

However, the authors blame climate change for the inaccuracy far more than other contributing factors which are far more obvious.

FEMA is supposed to update flood maps every 5-10 years. It’s hard to imagine climate change invalidating them in that time period.

Climate is an average of weather occurring over much longer time periods. Depending on whether you talk to a meteorologist or a geologist, the time period could range from 30 to millions of years.

At least five major ice ages have occurred throughout Earth’s history: the earliest was over 2 billion years ago, and the most recent one began approximately 3 million years ago and continues today (yes, we live in an ice age!). Currently, we are in a warm interglacial that began about 11,000 years ago. The last period of glaciation, often called the “Ice Age,” peaked about 20,000 years ago. At that time, the world was on average probably about 10°F colder than today.

Interestingly, one day after The Post article, the New York Times ran a story about the DNA of animals found frozen in the permafrost of northern Greenland, just a few hundred miles from the North Pole. The 135 different species scientists found there paint a picture of an arctic once lush with life typical of warmer climates today.

But another thing puzzles me. I see climate change often mentioned as the reason for drought. The US Geological Survey states, “Climate change has further altered the natural pattern of droughts, making them more frequent, longer, and more severe.” But The Post uses almost identical language to blame climate change for frequent flooding in many of the same general areas at the same time. Which is it?

And to what degree can climate change explain flood map inaccuracy? Many more obvious reasons exist that are less of a stretch for any inaccuracies.

Reasons Listed in Post Article for Inaccuracy of Maps

Here’s a list of the references in The Washington Post story used to explain inaccuracies found within FEMA maps. I’ve broken them into two groups so you can see the weight they gave to climate change.

Climate-Change References:
  1. “As climate change accelerates, it is increasing types of flooding that the maps aren’t built to include.”
  2. “Extreme precipitation events are growing increasingly common.”
  3. “A warming climate allows storms to carry more moisture, producing greater rain or snow in a short period of time.”
  4. “Climate has changed so much that the maps aren’t going to keep up.”
  5. Maps are out of date, some decades-old “in a changing climate.”
  6. “The effects of a changing climate.”
  7. Climate change impacts are getting worse.
  8. Climate change is “pushing FEMA’s maps beyond their limits.”
  9.  A gap exists between the data that goes into FEMA maps and current climate conditions.
  10. Climate change baseline is changing.
  11. “Climate change velocities are high.”
  12. “Maps do not take climate change into account.”
  13. “Overestimating the rarity of some events even before climate change…”
Other Possible Explanations Mentioned by The Post:
  1. “Communities may resist expanding designated flood zones because it adds costs and can hamper development.”
  2. Not all areas that flooded are mapped yet.
  3.  “Local communities often resist the expansion of federal flood zones”
  4. “Maps do not forecast flooding. Maps only reflect past flooding…”
  5. “Local governments have been opposed to any maps that show an increasing risk.”
  6. Relatively high imperviousness of gentrifying areas.
  7. Maps don’t reflect intense bursts of rainfall in a short period and the resulting street flooding.
  8. Impervious surface is replacing porous surface.
  9. Maps cover mainly coastal and riverine flooding.
  10. “Rain combining with melted snowpack.”
  11. FEMA flood maps don’t even attempt to model urban flooding
  12. “City neglected drainage problems.”
  13. Local opposition to expanding the floodplain.
  14. No sense of urgency to update maps.
  15. “Multiple compounding factors contribute to the flooding”

However, the article makes no mention of the mathematical limitations of Extreme Value Analysis, the key to understanding the uncertainties associated with rainfall probabilities.

Floods Can Also Be Explained Without Climate Change

The second group of references in The Post article seems far more immediate, compelling and easily provable when explaining any inaccuracy found in flood maps. They’re certainly typical of what I have found in the Houston area.

For the past five years I have been researching instances of flooding in and around Harris County. I published more than 250 articles on different aspects of the 2019 Elm Grove floods alone. And I don’t recall one person ever blaming those on climate change.

Elm Grove did not flood during Harvey, but did flood on two much smaller rains in 2019. The difference? Clearcutting and insufficiently mitigated upstream development. Contractors clearcut approximately 270 acres immediately north of Elm Grove without building sufficient detention capacity before the rains fell.

Similar stories – with variations – have played out over and over again throughout the Houston region. For instance, we see developers filling in wetlands. Exaggerating the infiltration rates of soils. Underestimating impermeable cover. Building in floodplains. Building to outdated codes and floodplain regulations. Being grandfathered under old regulations. Various jurisdictions refusing to update regulations. And more.

Regardless of your position on climate change, this discussion dramatizes the needs to:

  • Understand your local flood risk and the factors that affect it
  • Buy flood insurance.

Hopefully, Harris County Flood Control District’s MAAPnext project will address data deficiencies discussed in The Post article. But it will be years before those maps become official. And when they do, the landscape will have already changed.

Posted by Bob Rehak on 12/12/22

1931 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.

Forest Cove Townhome Complex Ready for Demolition

Harris County Flood Control District (HCFCD) has completed condemnation proceedings on the last unit in another townhome complex on Marina Drive in Forest Cove. They will schedule the units for demolition as early as next week.

Hurricane Harvey destroyed the units so completely that FEMA made them the centerpiece of a video after Harvey. Since then, they have become magnets for looters, arsonists, drug dealers and illegal dumping.

Forest Cove Townhomes Censored
Forest Cove Townhomes destroyed by Harvey on Marina Drive could soon be demolished. Red rectangle contains censored graffiti.

Amy Stone, a spokesperson for HCFCD said, “There were nearly 90 units in that community! All required appraisals, offers, negotiations, closings and demolitions.”

Reasons for Slow Pace of Buyouts

Demolition of the first units began on Timberline Court in March 2019. But HCFCD has had to navigate rough waters since then.

I previously reported that some owners abandoned their properties and that HCFCD could not locate them. Those units had to go through condemnation proceedings before demolition could begin.

Stone reports that two complexes remain. HCFCD closed on the last unit in one last month and completed the site inspection last Thursday. “We are waiting for the asbestos survey report to come back. We should have a demolition date by next week,” said Stone.

Asked about the other complex, Stone reported, “1020 Marina Dr. will be demolished once the last unit is purchased. This unit is currently in condemnation.”

HCFCD and FEMA like buyouts to be voluntary wherever possible. But in the case of missing owners, condemnation may be necessary. This is a big reason why buyouts take so long. HCFCD cannot demolish a building until they own all units within it.

Some Investors Never Learn

So here we are…1744 days since Harvey made the buildings structurally unsound.

Multi-family housing represents a poor choice for homes in such high risk neighborhoods. But before these units are even demolished, Chinese investors seek to build more, even closer to the river, about a mile downstream. Residents who bought condos in this area before Harvey tell me that they have spotted developers pitching this idyllic location to busloads of Chinese tourists in the area below.

I’m guessing Forest Cove is not on the tour.

Condos under construction in Kings Harbor last year. San Jacinto West Fork is just feet away.

Posted by Bob Rehak on June 8, 2022

1744 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.

Martin Updates Community on Additional Gates for Lake Houston

Perhaps no flood-mitigation project has generated more interest in the Lake Houston Area recently than the addition of more flood gates to the Lake Houston Dam. In recent months, as engineers worked on the project’s benefit/cost ratio, information about the project became hard to find. That fueled rumors.

But Tuesday night, at the Kingwood Community Center, Mayor Pro Tem Dave Martin put many of those rumors to rest. He denied the project was on hold, reaffirmed the City’s commitment to the project, and outlined the three main issues that engineers are currently grappling with.

Issues Still Being Evaluated

The main issues include:

  • Safety concerns about cutting into the concrete of a dam that’s almost 70 years old.
  • Getting the benefit/cost ratio up.
  • Finding a suitable alternative that significantly reduces flood risk within the budget.

Martin elaborated on each. Regarding:

Safety concerns – He described the risks of cutting into it to install crest gates. Among them, he said engineers worried about structural stability of the dam after construction. Accordingly, they are recommending significant reinforcement of the concrete. He also hinted that contractors might not bid on the project for fear of the potential liability.

Benefit/Cost Ratio – He said that the higher-than-expects costs on of some alternatives drove the BCR down, and that that was driving the exploration of additional alternatives. He did say, however, that FEMA allows including “social benefits” when the BCR is between .75 and 1.0. The inclusion of social benefits still must yield a BCR of 1.0 or greater. On a separate note, a federal employee told me that the Biden administration may change this policy. So significant uncertainty still exists re: calculation of the BCR.

Budget – He implied that some alternatives under consideration became non-starters because of high costs and inflation.

Alternatives Still Under Consideration

So, the search for a suitable alternative that meets all objectives continues. Among the options still in the running, Martin mentioned crest gates on the west side of the dam and adding a tainter gate to the earthen, eastern portion.

Martin shared a timetable that shows construction beginning in November. However, FEMA must approve the benefit/cost ratio before they release construction funds.

Schedule for adding gates to Lake Houston, first shown in July 2021. Also shown on 4/19/2022. Martin emphasized the schedule has not changed, but could.

Background of Project

At the peak of Harvey, 425,000 cubic feet per second (CFS) went over the dam’s spillway. That’s five times the average flow of Niagra Falls. Floodwater backed up so far that it flooded thousands of homes and businesses. It also killed 13 people in the Lake Houston Area, 12 of them in one retirement center.

The release of 80,000 CFS from Lake Conroe contributed almost a fifth of the water going over the spillway. Lake Conroe gates can release 150,000 CFS while Lake Houston’s can release only 10,000 CFS. The disparity in release capacity caused many to ask whether more gates on Lake Houston could reduce flooding.

Martin pointed out that when water gets high enough in Lake Houston, it can escape over a 2,000-foot-wide spillway. However, more gates could play a role in a pre-release strategy.

Pre-releasing water from Lake Houston in advance of major storms, as the City does now, creates extra capacity in the lake so that it can absorb more water without flooding homes and businesses. This strategy (coupled with the seasonal lowering of Lake Conroe) has worked effectively since Harvey and prevented flooding on more than one occasion.

Time Vs. Release Capacity Vs. Water Preservation

However, right now, it takes so long to release water from Lake Houston that storms can sometimes veer away and miss us after the lowering starts. Thus, water could be wasted. But bigger gates would let dam operators release the same volume of water in less time, so operators would not have to start releasing water so far in advance. In other words they would have a higher degree of confidence that the the storm would not veer away and that release was worthwhile.

Martin reassured people that:

  • Smaller (i.e., less costly) floodgates can lower Lake Houston sufficiently if given enough time
  • The lake usually refills quickly
  • Even if it doesn’t, the City can always call for the release of water from Lake Conroe.

We should know within a few months whether Black & Veatch, the engineering company leading the project, has succeeded in designing additional gates within the budget that meet all other objectives.

Staying on the schedule above will be ambitious. FEMA must approve the BCR before releasing money for construction.

Posted by Bob Rehak on April 21, 2022

1696 Days since Hurricane Harvey

MAAPnext Offers Powerful Historical Flood Loss Visualization Tools

By accident, I stumbled across some powerful historical flood loss visualization tools on Harris County Flood Control’s MAAPnext site today. They can help you understand the capricious nature of storms as well as political claims about which neighborhoods flood the most.

About MAAPnext

In 2019, using two FEMA grants and Flood Bond money, Harris County Flood Control District launched its MAAPnext project. MAAP stands for Modeling, Assessment and Awareness. The goal: to use new methodologies and technologies to improve understanding of flood risks throughout Harris County. The project goes far beyond updating Flood Insurance Rate Maps in the wake of recent storms. It also includes:

  • Interactive historical flood loss visualization tools
  • Water surface elevation change grids (maps showing difference between effective and revised floodplains)
  • Flood depth grids (for various flood frequencies including 10%, 4%, 2%, 1% and 0.2% annual chance events)
  • Urban flood maps (street flooding caused by rainfall exceeding storm sewer capacity)
  • Percent annual chance grids (giving you your exact probability of being flooded within a mapped floodplain)
  • 30-Year chance grids (showing your home’s exact chance of flooding within the life of a 30-year mortgage)
  • Water surface elevation grids (showing the water surface elevation in various flood frequencies)

Not all of these maps have been released yet. For instance, MAAPnext/FEMA will release new preliminary flood insurance rate maps for public comment this fall. However, I did find three fascinating interactive maps showing the history of flood losses in Harris County.

Historical Flood Loss Tools

Cumulative Losses since 1978

The first map provides a visual representation of where all flooding claims have occurred throughout the county since 1978. A property’s flood risk can be a influenced by many factors but it’s important to remember that it can flood anywhere in Harris County. The darkest areas have the most cumulative flood losses. The lightest areas have the least.

Total flood losses in various census tracts within Harris County since 1978.

To understand exactly WHERE and WHEN these flood losses happened, you need to go to the next two series of maps.

Historical Inundation Map

The Historical Inundation Map shows the extent of flooding in five different major storms since 2015. These include only streams with gages, not all Harris County channels. Zoom and scroll into an area of interest and then select the storm of interest from the layer menu.

Extent of flooding along the West and East Forks in the Memorial Day 2016 flood.

You can toggle layers rapidly to see how floods compared to each other.

Flood-Loss History by Event

The map above shows the spread of flood waters in various events. However, to see the relative damage in census tracts, you need to go to the map called “Flood Loss History by Event.” Again, you’ll need to toggle layers to select the event of interest. The darker the colors, the more damage.

Tax Day 2016 Storm Damage
Selecting the Tax Day 2016 layer shows that most damage from that storm occurred in NW Harris County.
Hurricane Harvey 2017 Damage
Selecting the Harvey layer shows that that storm affected the entire county with some watersheds experiencing more losses than others.
Imelda 2019 Damage
Distribution of damage in Harris County from Tropical Storm Imelda

For More Interactive Exploration…

The four maps above only scratch the surface of what you can find on the MAAPnext site. To explore the distribution of damage in various storms, visit the page called Understanding Your Flood Risk.

Media accounts of major storms might lead you to believe that major storms affect all parts of the county equally. But they don’t. Who floods depends on upstream rainfall totals, dam releases, proximity to floodplains, development regulations, elevation above the flood plain and more.

The most interesting aspect of MAAPnext is that it will eventually incorporate all of these factors and give you an individual risk rating for your property or one that you are considering buying.

If knowledge is power, this is power cubed, because it let’s you look at flood risk in multiple dimensions.

Be Patient

I can’t wait until the project is fully finished. Check back often and click around this site as new features seem to be bolted on periodically. The bolted-on comment relates to my only complaint. All information (and there’s a lot of it) is grouped under five pages in ways that are rarely intuitive and often invisible from the highest levels. For instance, to get to the historical flood loss maps, you have to:

  • Click on the home page
  • Click on a link embedded in one of the visuals called “Flooding is Our #1 Disaster.”
  • It will take you to a page called (strangely enough) “Understand Your Flood Risk.”
  • Scroll down past 7 other topics to the bottom of page to find the interactive maps.

Presumably, helping people understand their flood risk is the most important objective of this site, but the page by that name appears nowhere in navigation. That said, have fun exploring. You’ll find many other hidden gems on this site.

And remember that all flood insurance policies renewing on or after April 1, 2022, will be subject to FEMA’s new Risk Rating 2.0 methodology.

Posted by Bob Rehak on 3/12/2022

1656 Days since Hurricane Harvey

How Soon We Forget!

How soon we forget. Hurricane Harvey was just 4.5 years ago. Since then I have documented dozens, if not hundreds of questionable practices that erode margins of flood safety.

It Didn’t Have to Be That Bad

Harvey was the largest rainfall event in the history of North America. However, with better regulations and construction practices, it didn’t have to be as destructive as it was.

  • Lax regulations;
  • Willful blindness;
  • Development and construction practices that pushed the safety envelope;
  • Relentless destruction of forests and wetlands near rivers and streams;
  • And homebuyers who didn’t realize their true flood risk…

…made Harvey’s destruction worse than it otherwise would have been.

No one factor by itself would explain Harvey’s destruction. But put them all together, and it’s like “death of a thousand cuts.”

The sheer volume of material – more than 1,000,000 words on this site – makes it difficult for people to see the big picture sometimes. To put 1,000,000 words into perspective, the average novel contains only about 100,000. So I’m condensing the website into a book that includes the themes below.

No One Wins Arguments with Mother Nature

During an interview with Milan Saunders and his daughter Lori, Milan said, “No one wins arguments with Mother Nature.” How profound! It doesn’t matter how many surveys, studies and engineer stamps you have on your home’s title. If you don’t:

  • Respect the rivers.
  • Give them room to roam.
  • Protect wetlands.
  • Allow plenty of margin for safety…

…you will flood.

Thought courtesy of Milan Saunders, Chairman/CEO of Plains State Bank. That’s his daughter Lori’s house during Harvey.

Understanding the Causes of Flooding

Excess sedimentation is one of them. Sediment pollution is the single most common source of pollution in U.S. waters. Approximately 30% is caused by natural erosion, and the remaining 70% is caused by human activity.

Large islands built up during Harvey blocked both drainage ditches and rivers. Below, you can see a large sand island (top) built up at the confluence of the Kingwood Diversion Ditch where it reaches the San Jacinto West Fork at River Grove Park. This sand bar reached 10-12 feet in height above the waterline and helped back water up into Trailwood, the Barrington and Kingwood Lakes and Kings Forest. Before the Army Corps dredged this island, River Grove flooded five times in six months. It hasn’t flooded since.

The Kingwood Diversion Ditch and West Fork San Jacinto were almost totally blocked by sediment dams deposited during Harvey.

The second photo above was taken a few hundred yards downstream on the West Fork from the first. It shows “Sand Island” – so nicknamed by the Army Corps. It took the Corps months to dredge this island which they say had blocked the West Fork by 90%.

A certain amount of this sedimentation can be explained by natural erosion. But mankind also contributed to the sheer volume by other practices which I will discuss below.

Respect the Rivers

The red polygons in the satellite image below surround 20-square miles of sand mines on the West Fork of the San Jacinto in a 20 mile reach of river between I-45 and I-69. That exposes a mile-wide swath of sediment to erosion during floods and increases the potential for erosion by 33x compared the river’s normal width.

Even without floods, mines sometimes flush their waste into the rivers. The shot below on the top right shows the day the West Fork turned white. The TCEQ found the source of the pollution upstream: a sand mine that had flushed 56 million gallons of sludge into the West Fork (bottom right).

Influence of sand mines of West Fork San Jacinto water quality.

End the War on Wetlands

Wetlands are nature’s detention ponds. During storms, they hold water back so it won’t flood people downstream. But we seem to want to eradicate wetlands. The images below show the Colony Ridge development in Liberty County. Wetlands (right) are being cleared (left) to make way for the world’s largest trailer park. The acceleration of runoff wiped out FM1010 during Harvey. The road still has not been repaired.

Colony Ridge in Liberty County.

Conservation Costs Much Less than Mitigation

Halls Bayou at I-69 near Fiesta. Image on left shows whole subdivisions that that to be bought out before detention ponds on right could be built.

All across Harris County, especially in older areas inside Beltway 8, apartment complexes, homes and businesses are built right next to bayous and channels. This makes it difficult to enlarge streams or build detention ponds when necessary. One study showed that preservation of floodplains is 5X more cost effective than mitigation after homes flood. Yet private developers keep crowding bayous and residents keep demanding public solutions.

Respecting Individuals’ Property Rights While Protecting Others’

In Texas, it sometimes feels that an individual’s right to do what he/she wants with property trumps others’ rights NOT to flood. You may think you’re protected by all those public servants reviewing and approving plans. But what happens when developers and contractors decide to ignore the approved plans? Here’s a prime example: the Laurel Springs RV Resort near Lakewood Cove.

The approved plans said that “Stormwater runoff shall not cross property lines.” So what did the contractors do? They pumped their stormwater over the development’s detention pond wall. When that took too long, they dug a trench through the wall. Then they laid pipes through the wall to permanently empty the sludge into the wetlands of Harris County’s new Edgewater Park.

This apparently violated the developer’s City of Houston permit, the Texas Water Code, TCEQ’s construction permit and the developer’s stormwater pollution prevention plan. Four investigations are currently swirling around this development. The contractor also cut down approximately 50 feet of trees in Edgewater Park along the entire boundary line and received a cease-and-desist letter from the Harris County Attorney. But the damage is done.

Balance Upstream and Downstream Interests

About 10% of all the water coming down the West Fork at the peak of Harvey came from Crystal Creek in Montgomery County. But the wetlands near the headwaters of Crystal Creek are currently under development. And the developer is avoiding building detention ponds with a “beat-the-peak” survey. This loophole allowed by Montgomery County says that if you get your stormwater to the river faster than the peak of a flood arrives, then you’re not adding to the peak of a flood and you don’t have to build detention ponds. So developers conduct timing surveys to reduce costs and maximize salable land.

What happens when upstream areas develop without consideration for the impact on downstream property owners.

Of course, speeding up the flow of water in a flood is the opposite of what you want to do. To reduce flooding, you should hold back as much water as possible.

The slide above shows part of a new development called Madera at SH242 and FM1314 being built on wetlands near Crystal Creek.

The graph on the right shows what happened on Brays Bayou without suitable detention upstream. Floodwaters peak higher, sooner. Harris County has spent more than $700 million in the last 20 years to remediate flooding problems along Brays.

How much will we need to spend when more areas like Madera get built upstream on the West Fork?

How Quickly We Forget!

FEMA’s Base-Flood-Elevation Viewer shows that in that same area, developers have already built homes that could go under 1-5 feet of water in a 100-year flood. These homes are actually in a ten-year flood zone. And yet more homes are being built nearby. On even more marginal land!

In recent years, the price of land as a percent of a new home’s cost has risen from a historical average of 25% to approximately 40% today. This puts pressure on developers to seek out cheaper land in floodplains, reduce costs by avoiding detention pond requirements, pave over wetlands, and reduce lot sizes resulting in more impervious cover. All contribute to flooding.

Of course, smart homebuyers would not make such risky investments. But few lack the expertise to gauge flood risk. Educating such homebuyers will be one of the major objectives of the book I hope to write.

Posted by Bob Rehak on 2/23/2022

1639 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.

New MoCo Development Being Built on Wetlands in 10-Year Flood Zone

At least part of Madera, a new 1,700-acre development in Montgomery County that straddles FM1314 immediately north of SH242, is being built on wetlands and is in a 10-year flood zone.

US Fish & Wildlife Map Shows Wetlands Dot Development

Magera Wetlands
From US Fish & Wildlife Service National Wetlands Inventory. Madera will stretch past the left/right edges of this picture north of SH242 (the east/west highway near bottom.) FM1314 bisects picture from N to S in middle.

FEMA’s Base Flood Elevation Viewer Shows Flood Risk

From FEMA’s Base Flood Elevation Viewer. Extent of 100-year flood zone shown on left. 10-year flood zone shown on right.

Note that this survey shows only about a quarter of Madera (see below). The survey stops abruptly on the western margin. So, it is hard to say with certainty how bad flooding is throughout the rest of the site.

Yellow outline shows approximate outline of FEMA BFE survey shown above within Madera tract (black/white outline).

Option to See Depth of 100-Year Flood Waters

Also note that the purple area shows only the extent of 100- and 10-year floods. However, within the FEMA BFE viewer, you also have the option to select a layer that illustrates the depth of 100-year floodwaters. See below. (FEMA does not offer the option to show the depth of 10-year floods.)

FEMA BFE viewer
FEMA’s estimated Base Flood Elevation Viewer showing extent of 100-year flood on left and depth on right.

Limitations of BFE Viewer

Of course, FEMA shows “estimated conditions” before developers bring in fill and alter drainage. But notice how a pre-existing development near Madera would fare in the same 100-year flood. You can see the close up below just above SH242 near the right edge of the image above.

FEMA shows that most homes in this development are still in the flood zone and would still flood to a depth of 1-2 feet in a hundred-year flood.

The street leading out of the development to SH242 could be under more than FIVE FEET of water in places!

FEMA Base flood Elevation Viewer

FEMA’s “Estimated Base Flood Elevation” is “The estimated elevation of flood water during the 1% annual chance storm event.” Structures below the estimated water surface elevation may experience flooding.” A 1%-annual-chance flood is also known as a 100-year flood. FEMA defines properties with a 1% annual chance of flooding as having “high flood risk” and says they have a 26% chance of flooding during the life of a 30-year mortgage.

Purposes of BFE Viewer

The agency developed its Base Flood Elevation viewer with several purposes in mind. To:

  • Inform personal risk decisions related to the purchase of flood insurance and coverage levels.
  • Inform local and individual building and construction approaches.
  • Prepare local risk assessments, Hazard Mitigation Plans, Land Use Plans, etc.
  • Provide information for “Letter of Map Amendment” (LOMA) submittals.

A LOMA lets the developer of a subdivision change the depiction of how flooding affects his/her subdivision. It’s the key to offering up-to-date risk assessments.

Full BFE Reports Available

FEMA also lets you download or print full BFE reports that give more specific estimates of flood depth at exact points, not just within a wide area.

FEMA’s BFE Viewer also gives you the option to print out a detailed flood-risk report by clicking on a point.

At the point shown above, you could expect 4.2 feet of water above the land surface in a 1%-chance flood. For the full report, click here.

Here’s what that point looked like last Saturday (1/22/22) from the air.

Madera will eliminate wetlands but claims it will have no adverse impact.
Madera development today at FM1314 and SH242, the point shown in BFE report above.

Cross-check this area on the maps above for wetlands and swamps! Then you can see why it’s so soupy.

BFE, Fill Not Mentioned in Drainage Analysis or Construction Plans

Text searches of Madera’s construction and drainage plans showed no references to “BFE” or “base flood.”

It seems unlikely that a “cut and fill” operation could excavate enough dirt from Madera’s drainage channel (dotted blue line with red parallel lines) and detention ponds to raise the whole site out the hundred-year flood zone. Five feet is a lot of fill for a 1700 acre site.

To raise a site this large, contractors would likely have to bring in fill from outside the property. But a text search from the word “fill” did not turn up any exact matches either.

So maybe they’re just planning to create the world’s biggest drain and hope to carry water off before it can reach homes.

However, a summary of the Madera master drainage plan notes…

“Coordination with MCED [Montgomery County Engineering Department] and adjacent property owners is recommended … on the potential need for inundation easements.”

Revised Channel Alignment Memo, 2/19/21, Page 11

Still, engineers for the development claim it will have “No adverse impact.”

To review Montgomery County regulations regarding flood zones and drainage, see the documents under the “Construction Regs in Flood Hazard Areas” tab on my reports page. You’ll see plenty of opportunities for improvement.

Posted by Bob Rehak on 1/27/22

1612 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.

Equity Myth Buster: “Rich Neighborhoods Get All the Flood-Mitigation Funding”

A myth being promulgated in Harris County Commissioners Court and certain low-to-moderate income (LMI) watersheds these days goes something like this:

  • The FEMA Benefit/Cost Ratio (used to rank grant applications for flood-mitigation projects) favors high-dollar homes.
  • That disadvantages less affluent, inner-city neighborhoods compared to more affluent suburbs.
  • Therefore, less affluent neighborhoods get no help and the more affluent neighborhoods get it all.

This post busts that myth. But it won’t stop activists from demanding more “equity.”

If you look at all flood-mitigation spending in Harris County since 2000, on average, less affluent watersheds already receive 4.7X more partner funding per watershed than their more affluent counterparts.

Analysis of data obtained via FOIA request

Myth Ignores Other Factors, Frequently Leaps to Wrong Conclusions

Like much of political discourse these days, the myth focuses on a narrow sliver of truth, ignores other factors, and frequently leaps to the wrong conclusions.

An analysis of Harris County Flood Control District data going back to the start of this century shows how far off the myth can be.

There are dozens of different ways to slice and dice the data. I’ve looked at most of them and validated “dollars invested” with aerial photography.

Today, I focus on partner grants because they represent such a huge percentage of the flood-bond budget and because there is so much misinformation floating around about them.

And I will look at partner funding from the standpoint of outcomes, not just processes (as in the myth).

Methodology for Analysis

For this analysis I obtained Harris County Flood Control District spending data between 1/1/2000 and 9/31/2021 via a Freedom of Information Act (FOIA) request. I requested the data by watershed, decade, pre-/Post Harvey, source of funding (local vs. partner), and type of activity (i.e., engineering, right-of-way acquisition, construction and more). I cross-referenced this with other data such as flood-damaged structures, population, population density, and percentage of low-to-moderate income (LMI) residents.

When considering grants, the percentage of LMI residents in a watershed takes on special significance. Department of Housing and Urban Development (HUD) grants often require high percentages of LMI residents in the area under consideration.

In the charts below, you will see references to watersheds with LMI populations above and below 50%. Above 50% means more than half the residents in the watershed have an income LESS THAN the average for the region. Below 50% means more than half the residents earn more than the regional average.

Harris County has 23 watersheds. Eight have LMI percentages above 50% (less affluent). Fifteen have LMI percentages below 50% (more affluent).

When reviewing the charts below, pay particular attention to the italicized words: Total, Partner, and On Average. They represent three different ways to look at the same question: Do housing values disadvantage an area when applying for grants?

For this analysis, I focused only on the long term, since decisions on more than a billion dollars in flood-bond grants are still outstanding.

FOIA Analysis Contradicts the Popular Myth

One of the first things you notice when you look at watersheds above and below 50% LMI, is that the eight least affluent watersheds have gotten more than 60% of all dollars actually spent on flood mitigation since 2000.

Less affluent watersheds, despite being half as numerous, received 60% of all dollars since 2000.

Because the allegation was that partnership grants favored affluent areas, I then analyzed whether partner dollars went mostly to affluent or less-affluent watersheds. The answer is less affluent…overwhelmingly.

More than 70% of all partner dollars in the last 22 years went to the eight less-affluent watersheds.

The last observation by itself is telling. But because of the widely different number of watersheds in each group, I also wanted to calculate the average partner dollars per watershed in each group. This blows the “rich neighborhoods get all the grants” argument to pieces. Less affluent watersheds got, on average, 4.7X more.

Dividing the total partner dollars by the number of watersheds in each group shows that less affluent watersheds average 4.7X more than affluent ones.

This busts the myth. But digging even deeper into the data reveals two things: wide variation between sources of funding and within LMI groupings.

USACE Funding Skews Partner Totals

The U.S. Army Corps of Engineers (USACE) accounts for much of the partner funding. USACE has provided significant funding for projects in the Sims, Brays, White Oak, Hunting, and Greens Bayou watersheds. The Clear Creek watershed will also soon see work on a new USACE project. USACE has completed its planning process and proved positive benefits to national economic development. That made projects worthy of Federal investment. 

Halls Bayou: Digging Deeper

The Halls Bayou watershed also went through the USACE planning process, but the results did not show enough flood-damage-reduction benefits to outweigh the costs of the proposed projects. Thus, the Halls Bayou watershed currently has no USACE-funded projects.

Despite that, Halls has received more partner funding than 16 other watersheds since 2000. Only two watersheds in the affluent group of 15 received more partner funding. See the table below.

Total and partner spending by watershed since 2000 arranged in order of highest to lowest LMI percentages.

USACE also evaluated the more affluent Buffalo Bayou; results showed that costs outweighed the flood-damage-reduction benefits there.

Despite Halls having the highest percentage of LMI residents in Harris County, Halls has received more total funding and 2.5X more partner funding than Buffalo Bayou in the more affluent group.

FEMA Considers More than Home Values, Not All Grants Come From FEMA

While it’s true that FEMA considers housing values as a factor in benefit/cost ratios, benefit/cost ratios (BCRs) also consider factors such as:

  • The number of structures damaged
  • Threats to infrastructure
  • Proximity to employment centers
  • Need for economic revitalization
  • Percentage of low-to-moderate income residents in an area
  • Number of structures that can be removed from the floodplain by a project.

And not all grants come from FEMA. For instance:

So don’t settle for soundbites. They often mislead.

Posted by Bob Rehak on 12/30/2021

1584 Days since Hurricane Harvey