Tag Archive for: Flood-mitigation funding

Latest Flood-Mitigation Funding Trends

New data obtained from Harris County Flood Control District via a FOIA Request breaks down flood-mitigation funding by watershed through the end of 2021. It shows where your flood-bond money is going. It also debunks some popular myths. Those include the oft repeated:

  • Rich watersheds get all the funding; poor watersheds get none.
  • Partner funding favors rich watersheds because home values are higher.
  • HCFCD has historically discriminated against low-to-moderate income (LMI) watersheds.

Eight out of 23 watersheds in Harris County have a majority of residents that fall into the LMI category. That means a majority make less than the average annual income for the region. As the data below shows, those eight LMI watersheds get the vast majority of county, partner, and total funding. In fact, four have received 54% of total flood-mitigation funding since 2000.

Funding now correlates more highly with LMI population than damage!

Data also calls into question why some feel compelled to tweak the equity prioritization framework endlessly.

Improved Basis for Reporting

Before I dive into the data, though, let me point out that between the 3Q21 and the end of last year, the county changed the way it compiles historical data. Instead of using the start/stop dates in project management software and reporting only completed projects, the county is now using invoice dates. This produces much higher accuracy. Dollars do not spill over from one period into another. The new data also reflects spending on projects that are ongoing, but still open.

In response to my FOIA Request, the county provided spending using both the old and new methods. They differ by roughly $615 million. Of that, approximately $215 million reflects actual fourth-quarter spending and $400 million reflects the change in when expenses are recognized.

Spending by Watershed

The rank order of spending by watershed has not changed much since last year. Several watersheds moved up or down by a place or two.

The top four are still the top four in the same order. But some of the amounts changed radically, mostly due to the change accounting. For instance, White Oak increased from $387 million to $521 million. But out of the $134 million difference, $102 million comes from when expenses are recognized.

Because this gets so confusing, and because the rank order did not change much, I will use only the new totals compiled by invoice date from now on. I will not compare old and new totals based on the different accounting methods.

Spending by watershed between 1/1/2000 and 12/31/2121 broken down by county and partner contributions, and LMI/Other watersheds.

Graphs of Spending

Here’s a graph of total funding by watershed since 2000, arranged from highest to lowest.

Watersheds rank ordered by amount of flood-mitigation funding received between 1/1/2000 and 12/31/2121.

Funding correlates with population. But you can see notable exceptions below. Some watersheds get far more funding than their proportion of the population, i.e., White Oak, Sims and Greens. Others get far less.

Spending is not allocated proportionately to population in all cases. Six out of eight LMI watersheds received more funding than their population alone would justify.

But population alone does not tell the whole story. Some watersheds are huge and some small. So I also looked at population density per square mile. The curves correlated even less.

Graphing population density vs. total spending shows more variance. Of the eight LMI watersheds, four (Brays, White Oak, Sims, and Greens) get far more than their population density alone would dictate.

As we saw last year, funding flows primarily to damage. The chart below plots funding versus the total number of structures in each watershed damaged in five major storms (Allison, Tax Day, Memorial Day, Harvey, and Imelda). The slope of the curves closely match. But several major exceptions exist.

Historical Discrimination?

Many community groups from LMI neighborhoods have alleged historical discrimination in the distribution of flood-mitigation funding. I just don’t see it. All of the pie charts below take into account all funding between 1/1/2000 and 12/31/2021 based on invoice dates.

The county itself sent almost 60% of its flood-mitigation funding to one third of the watersheds with majority LMI populations.
An even larger percentage came from partner funding.
Whether you look only at county funding, partner-funding, or the total, the picture is still roughly the same. One third of the watersheds get almost two thirds of the funding.
Top 4 include Brays, White Oak, Sims and Greens. All have an LMI percentage higher than 50%.

LMI Population Now Correlates Higher with Funding than Damage

A coefficient of correlation of 1.0 is considered perfect. A good example: between gallons of gas in your car and the distance they will take you.

As a result of the constant tweaking of the equity funding formula, “Population” and “LMI Population” now correlate more highly with “Funding” than “Damage.” The correlation between “Funding since 2000” and:

  • Population Density = .54
  • Damage = .85
  • Population = .87
  • LMI Population = .89

Statisticians consider all of the last three very high.

With all the rhetoric flying around these days, it’s more important than ever to have facts to base your decisions on. To see all the original data from my FOIA Request, click here.

Posted by Bob Rehak on 2/26/2022

1642 Days since Hurricane Harvey

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

Six Low-Income Watersheds Receive One Billion Dollars More than Six High-Income Watersheds

Second in a Series of Eight Articles on Flood-Mitigation Funding in Harris County

If the charges of racial and income bias in flood-mitigation funding in Harris County were true, you would expect the poorest neighborhoods to get less funding than the most affluent. But the opposite is true. They get a billion dollars more

Contrary to the “equity” narrative repeated ad nauseum in Harris County political circles, an analysis of flood-mitigation spending shows that JUST SIX low-income watersheds already:

  • Received a billion dollars more than six high-income watersheds since 2000
  • Averaged three times more funding per watershed
Data obtained from HCFCD via FOIA Request compares six highest and lowest income watersheds. These numbers include only capital improvement projects, not maintenance.

Data obtained via a Freedom of Information Act (FOIA) request debunks the narrative that falsely claims high-income watersheds get more funding because they have higher home values. Higher home values theoretically create higher Benefit/Cost Ratios. And some political leaders claim that causes the Federal government to favor projects in affluent neighborhoods, compared to poor. 

However, that argument ignores dozens of other factors that enter into grant funding

So, look through the other end of the telescope. Examine actual funding instead of the funding process. You will see that, in Harris County at least, actual flood-mitigation funding favors low-to-moderate-income (LMI) watersheds by a wide margin. If the process favors high-income watersheds, why do the low-income get a billion dollars more?

Analysis Reveals Funding Favors Low-Income Neighborhoods

I requested from Harris County Flood Control District (HCFCD) the following data by watershed – broken up into various time periods:

  • Capital improvement funding (excluding maintenance)
  • Population totals
  • Low-to-moderate income (LMI) population
  • Watershed size in square Miles
  • Damaged structures in major storms

From that, I computed other factors such as $/square mile, population density, LMI %, LMI Rankings, etc. The data goes back to 2000, but also includes “Since Harvey.”

Comparing the quartiles for lowest- and highest-income watersheds since 2000 showed that HCFCD spent more than $1.5 billion dollars in six low-income watersheds, but only $472 million in six high-income watersheds.

The lowest income quartile received a billion dollars more than the highest. There’s just no truth to the “rich-neighborhoods-get-all-the-funding” story.

Terminology and Methodology

Before going further, let’s clarify some terms. LMI means Low-to-Moderate Income. 

  • High LMI means watersheds with a high percentage of low-to-moderate income residents.
  • Low LMI means watersheds with a low percentage of low-to-moderate income residents, which actually means High Income.

Instead of bogging readers down in confusing double negatives, I will simply use the terms “High Income” and “Low Income” for this discussion.

The numbers in the lists below represent the percentages of people with incomes below the average for the region. So, with 16% LMI, Little Cypress has 84% of residents making above the average. That’s why it ranks as “higher income” even though it has a lower LMI percentage.

To create each group of six, I started with seven. That’s because each included a statistical anomaly explained below.

Watersheds with the highest income (lowest LMI ranking) include:

  1. Little Cypress (16%)*
  2. Barker (22%)
  3. Cypress Creek (26%)
  4. Armand (26%)
  5. Willow Creek (27%)
  6. Jackson (30%)
  7. Spring Creek (31%)

The seven with the lowest income (highest LMI ranking) include:

  1. Halls (71%)
  2. Hunting (69%)
  3. Sims (65%)
  4. Vince (62%)*
  5. Brays (58%)
  6. Greens (57%)
  7. White Oak (51%)

*Note: For this analysis I substituted Spring Creek for Little Cypress because Little Cypress is a statistical anomaly. Harris County is buying vacant land there along creeks to prevent future flooding as part of their “frontier program.”  But the small number of people who currently live in the Little Cypress watershed skews most statistical comparisons. I also excluded Vince in the low-income category because it lies almost wholly within the City of Pasadena, which is responsible for it.

Summary of High-Level Findings

The six low-income watersheds received $1.52 billion since 2000. But the six high-income watersheds received $472 million – more than billion dollars less.

Let’s also compare total spending since 2000 per square mile in each group.

  • Low-income watersheds got $2.8 million/sq. mi. 
  • High-income watersheds received $0.9 million/sq. mi.

Again, the 3X advantage for the low-income quartile held up.

Finally, let’s compare average dollars per watershed for all groups since 2000 (not adjusted by square mileage). The 3X advantage held up yet again for the low-income group, which also more than DOUBLED the countywide average. See below.

These comparisons make compelling evidence that the political narrative is misleading! However, these numbers don’t tell the whole truth either.

Low-income watersheds had 7X more damaged structures in four major floods (Allison, Tax Day, Memorial Day and Harvey) – 144,754 vs. 19,677.

If there’s one truth about flood-mitigation funding in Harris County, it’s that “dollars flow to damage.” The following tables show funding, damage and LMI% rankings for both income groups. 

Only one of the watersheds in the high-income group received more funding than Hunting, the lowest in the low-income group. (I will explore this further in article #7 in this series.) 

Reasons for Rankings

If you understand Houston neighborhoods, the reason for these rankings becomes apparent when you look at a watershed map. Here are the high-income watersheds…

High-income watersheds are generally newer and built to higher standards on the periphery of the City. They also generally have fewer developments beyond them to create flooding issues. Not one is predominantly inside the Beltway.

Now, let’s look at the low-income watersheds.

Each low-income watersheds IS predominantly inside the Beltway.
Homes and drainage in these older areas are not built to current standards.

Role of Density in Flooding and Flood-Mitigation Funding

Another huge disparity exists between these two groups of watersheds: population density. 

  • 1,517 per square mile for the high-income group 
  • 3,912 for the low-income – 2.6X more.

Higher density brings with it more impermeable surface; more and faster runoff; more crowding of floodplains; plus, less room for detention facilities, channel expansion and wetlands. Often, wetlands are destroyed to accommodate higher density.

Very high density can also escalate flood-mitigation costs and delay flood-mitigation construction projects. Sometimes, homes or even entire subdivisions must be “bought out” to widen ditches or install detention ponds. For an example, see this post about Halls Bayou.

Also understand that when homes must give way to flood-mitigation projects, the projects often generate significant pushback from people being displaced.

Moving Forward, Let’s Ask the Right Questions

The statistics in this post disprove racial bias in funding. However, inner-city, minority residents are more susceptible to flooding than their suburban counterparts. But it’s largely because of where they choose to live for whatever reason: affordability, proximity to work, transportation, etc. Sometimes people just have no options, despite flooding. (I’ll explore this subject more in #7 of this series.)

To help residents in these low-income areas, HCFCD is already spending 3X more than it does in high-income areas. This raises the question, “Are we underfunding some watersheds?” 

As development pushes past today’s high-income watersheds, they too will come under pressure from even newer developments beyond the Grand Parkway. It’s already starting to happen to the westnorth and northeast. Those along Cypress Creek may first to feel the full brunt on this (see rankings above).

To solve the problems that really plague us, we need to bury the racial rhetoric, realize the true nature of the problems, and work together on solutions. 

The current inflammatory “equity” discourse only seems to distract and divide people. The real question we should ask ourselves is, “How can we upgrade the drainage infrastructure (streets and storm sewers) in neighborhoods that are 60 – 70 years old?” I’ll discuss that more in the seventh article in this series.

If leaders truly want to reduce flood risk, then the discussion needs to focus on how best to support the professionals and organizations toiling to protect all residents from the next flood. 

If the conversation does not change, then that will prove flood prevention is not really a priority for Harris County leadership. 

For More Information on Flood-Mitigation Funding

For more information, see: 

Posted by Bob Rehak on 6/22/2021 based on data received from a FOIA request

1393 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.

Surprise! Surprise! Halls, Greens Watersheds Get $422 Million of Flood-Mitigation Funding, Not “ZERO.”

First in an Eight-Part series on Flood-Mitigation Funding in Harris County

Recently, many local leaders, citizens and media have claimed that two largely minority and low-to-moderate-income (LMI) Harris County watersheds – Halls and Greens Bayous – have gotten no flood-mitigation funding. The actual data shows the exact opposite of what many people have been told, i.e., that racial bias affects the distribution of flood mitigation funds. 

Halls and Greens have received $422 million since 2000. And they received $200 million of that since Harvey. Meanwhile, Kingwood has never had one Harris County Flood Control District (HCFCD) capital improvement project.

FOIA Request Shows Where Money Has Actually Gone

Information, newly available through a Freedom of Information Act (FOIA) Request, reveals that Greens and Halls Bayous, have received 16% of all Harris County Flood Control District (HCFCD) funding since 2000 and 18% since Hurricane Harvey. That’s almost one fifth of all flood-mitigation funding for 23 watersheds in the whole county!

Data based on information provided by Harris County Flood Control in response to FOIA request

But the popular perception is that flood mitigation money is all going to affluent neighborhoods like those in Kingwood at the expense of low-to-moderate income areas, such as Greens and Halls.  Local media have helped spread this misinformation:

From the twitter feed of a Houston Chronicle writer who covers flooding.

FOIA Request Reveals Flaws in Narrative

One Harris County commissioner frequently claims Greens and Halls are being discriminated against in the allocation of flood-mitigation funding. He says residents in those watersheds are at the “back of the bus” and if commissioners don’t fix that, “We’ll have blood on our hands.” 

That sounded extreme. So, to see how bad the problem was, I submitted a Freedom of Information Act (FOIA) request in early March. Out of 23 watersheds: 

  • Since 2000, Halls and Greens rank #8 and #3 respectively in flood mitigation “dollars received.” 
  • Since Harvey, Halls and Greens rank #11 and #2 respectively

While #11 and #8 may sound “middle of the pack” for Halls, keep in mind that Halls ranks #16 in size. The entire watershed is only 42 out of 1,776 square miles that make up Harris County. 

Halls actually ranks #3 among all watersheds in “dollars/square mile” 
since 2000 (eclipsed only by Brays and White Oak).

Since 2000, Halls has received more than $3 million per square mile. Compare that to $0.5 million for the San Jacinto watershed, a frequent target of Precinct 1 Commissioner Rodney Ellis and his followers. 

Here’s what all watersheds have received and where they rank, along with other measures, such as:

  • Watershed area
  • Population
  • Density
  • LMI population 
  • Spending per capita
  • Spending per square mile
  • Structures damaged in floods
Current as of end of March 2021. Note: data excludes maintenance spending. Spending shows only capital-improvement flood-mitigation projects. To see the original HCFCD data, click here. For a high resolution, printable PDF of my summary sheet above, click here.

You can look at this data in dozens of ways. And I will. However, any way you cut it, it does not support discrimination against the poor or a racial bias in funding. If you didn’t look any further, you could use this data to support the opposite point of view, i.e., that funding discriminates against more affluent neighborhoods. However…

Spending Actually Closely Tracks Damage

Halls and Greens Bayou watersheds contain large percentages of low-to-moderate income (LMI) households. Versus other watersheds, Halls ranks #1 in LMI households (71%) and Greens ranks #6 (57%).

Of all the rankings on all the measures, the measure that seems to track most closely with funding is “properties damaged.” One would hope for that! It’s a perfectly rational, non-biased basis for allocating funds. 

Data shows that the Flood Control District is spending the most money where flooding has damaged the most structures. 

Dollars Flow to Damage

See below.

Flood-mitigation funding by watershed arranged from highest to lowest with spending and damage rankings.

To underscore that point, consider that:

  • Greens ranks #3 in funding since 2000 and #2 since Harvey. It also had the 2nd most damage in four major floods (Allison, Tax Day, Memorial Day, and Harvey).
  • Halls ranks 3rd in spending per square mile since 2000 and 4th since Harvey. It also had the 4th most damage in all four storms. 

Together, Halls and Greens have received $422 million since 2000. That’s hardly “nothing.” Hardly “back of the bus.” And their high rankings hardly make an argument for racial or income bias.

Crucial Role of Tropical Storm Allison

Flood-mitigation studies, funding, and construction can take years and even decades. Tropical Storm Allison, 20 years ago this month, played a role in the rankings above. Compare the watershed and rainfall maps below. The heaviest rainfall in Allison fell directly over Halls and Greens Bayous. Thus, both of these watersheds experienced major damage two decades ago.

Map of Harris County Watersheds. Note the location of Halls and Greens in the upper left quadrant of Beltway 8. 
Allison rainfall map. Source: HCFCD via NOAA. Rain was heaviest within the northeast quadrant of Beltway 8. It contains Halls and Greens Bayous. The 15” band also tracked WNW across the upstream portions of Halls and Greens.

Projects Identified Earlier Are Farther Along 

That actually helps explain why they rank so high in funding today. During Allison, Greens ranked #1 in damage (15,590 structures) and Halls ranked #2 (12,820). 

Many projects identified decades ago, such as those in Halls and Greens, received sporadic funding before the 2018 flood bond. Surveys and engineering reports may have been completed or “rights of way” acquired. But many costly construction projects had to be postponed until money became available.

Before 2018, the Flood Control District only had $60M per year to spend across all of Harris County. Then, when voters approved the flood bond in 2018, Halls and Greens projects were “shovel ready” and could start immediately.  In essence, they had a head start and it shows in funding!  

Also, in 2019, commissioners adopted an “equity” prioritization plan that accelerated spending in LMI watersheds. So, Halls and Greens got an extra boost. 

That’s not to say these watersheds have gotten everything residents wanted or needed. But then, who has? 

Numbers Contradict Narrative

Those who watch Commissioners Court are treated month after month to tales about how flood-mitigation spending has discriminated against people in low-income watersheds with high percentages of LMI households. Halls and Greens are repeatedly held up as examples. 

The FOIA data does not support that theory. It shows that low-income watersheds are not being ignored. And higher income watersheds are not getting all the money. Anyone who says they are is not looking at the numbers.  

In fact, data from the FOIA request revealed that the Kingwood area has had exactly ZERO Flood Control District capital improvement projects in the last 20 years. The often-cited Buffalo Bayou watershed has had exactly TWO capital Flood Control District capital improvement projects in the last 20 years.  

Those who make allegations of racial bias ignore projects on the ground. 

To learn more about recently completed projects or projects currently under construction in Halls and Greens Bayou watersheds, see these previous posts:

Tomorrow, I will examine flood-mitigation funding in six watersheds with the lowest income rankings versus six with the highest. 

Posted by Bob Rehak on 6/21/2021 based on HCFCD data supplied in response to a FOIA request.

1392 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.

Why Does Flood-Mitigation Funding Take So Long?

On Tuesday this week, Harris County Commissioners Court erupted into heated discussion over flood-mitigation funding for Halls and Greens Bayous. Construction delays had to do with the length of time for awarding grants from the U.S. Department of Housing and Urban Development (HUD). Then, in a cosmic coincidence, yesterday, the Texas General Land Office (GLO) sent out a press release announcing $135 million in HUD flood mitigation grants – for 2016 floods that happened under President Obama.

Ironically, the GLO press release pointed out that 2016 grants were for repetitively damaged areas. And in the five years since the 2016 floods, we’ve also had Hurricane Harvey, Tropical Storm Imelda, and a record-setting 2020 hurricane season.

Reading the release felt like getting hit by three buses while waiting for the ambulance to arrive. That prompted a call to the GLO, which administers HUD grants in Texas. I asked a simple question.

“What Takes So Long?”

When I asked the GLO “Why does flood-mitigation funding take so long”, they referred me to this page. Key takeaways include:

  • Congress didn’t appropriate money for Disaster Declarations in 2015, 2016 and 2017 until February 9, 2018.
  • Texas received $4.3 billion from the U.S. Department of Housing and Urban Development for all those years.
  • Before the GLO could distribute those funds, it had to wait for HUD to develop and publish rules in the Federal Register governing the distribution of those funds. That took 1.5 years.
  • Then the GLO had to develop a state action plan. That required developing another set of rules, holding public meetings around the state, soliciting public comments, responding to the comments, and getting HUD approval of the plan. HUD finally approved the state action plan on March 31, 2020.
  • Then GLO had to translate the plan into Spanish, Chinese, Arabic, Vietnamese, and Korean before publishing it.
  • To be fair to everyone across the state, GLO then holds a “competition” to find the most worthy projects. The criteria for “worthiness” include multiple factors. But the biggest in HUD grants are: percentage of low-to-moderate income families being helped, how economically distressed an area is, and total expected benefits for dollars invested. For instance, when comparing applications for a $10 million grant that will help 1,000 families to a grant for the same amount that will help a 100,000 families, the latter would win.
  • But to determine that kind of information, applicants need to conduct preliminary engineering studies before they can even file applications.
  • The GLO must wait for all applications to be submitted, evaluate the applications, rank order them, and see how many will fit within available funding. In the case of the grants just announced, the GLO received requests for almost TWICE as much funding as they had available. The average over the years exceeds 3X. For Harvey, it was 5X.
  • HUD must then review and approve the grants.
  • GLO distributes the money.
  • Finally, mitigation projects can begin.

Are All These Steps Necessary?

When you look at the list above, each step sounds reasonable. But there may be ways to collapse steps and speed up the flood-mitigation funding process. Why, for instance, do you need 1.5 years to publish rules specific to these floods in the Federal Register? Why not have a generic set of rules for all floods and adapt the boilerplate as needed?

I also asked if a way existed to shorten the process by eliminating the competition. After all, its easier to approve one application than compare it to hundreds. Their reply: “Competitions are the only fair way to do it.”

Should We Go Back to Earmarks?

The current competition system replaced an earmark system whereby Congress directly allocated funds to certain projects in certain districts. Earmarks sped up construction, but had many problems of their own. For instance, unnecessary projects often went to the districts of congressional leaders. That sometimes deprived other areas with greater needs.

However, the competition system for flood-mitigation funding has obvious problems, too. It has spawned whole industries of grant writers, project managers and people who know how to navigate traps in the convoluted application process.

I talked to one project manager today who told me about a grant that cost more to apply for than the grant was worth.

Hopefully, that doesn’t happen often. But when it does, we have proof that bureaucracy has become more important than the taxpayers it serves.

More about GLO/HUD Grants Announced This Week

For the record, out of the $135 million in grants announced yesterday, Harris County received $10 million for cloverleaf drainage improvements in Carpenters Bayou. City of Houston received $8.2 million for flood mitigation in the Alief Forest Area. Baytown, Freeport, Sweeny, and Jacinto City also received grants.

This table shows where the money went.

For descriptions of individual projects, please click here.
Texas Counties Affected by 2016 Floods. MID stands for Most Impacted and Distressed Areas.

Hurricane Harvey Competition Results Not Yet Announced

Winners of the first round of the Hurricane Harvey Mitigation Competition are expected to be announced in late spring or early summer. The GLO received 220 extensive applications totaling more than $5 billion in requests for the $1 billion in available funding (Round 1).

The Hurricane Harvey State Mitigation Competition for flood-mitigation funding is open to cities, counties, COGs, state entities, and special purpose districts. Examples of projects include flood control and drainage improvements, infrastructure improvements, green infrastructure, public facilities, and buyouts. Each proposed project must have a total proposed cost between $3 million to $100 million.

What We Need

Getting disaster relief 5-10 years after the fact is the largest disaster of all. We need Congress to reform the process to speed up the delivery of flood mitigation funding. How many homes and businesses that flooded in 2015, flooded again in 2016, 2017, 2019 and 2020? And what were the associated costs? Did repeat-flooding damages for these years due to funding delays cost more than the amount of mitigation funds appropriated by Congress? Somebody, somewhere has that information.

Posted by Bob Rehak on 3/12/2021

1291 Days since Hurricane Harvey