According to Fourth Quarter 2022 data obtained via a Freedom of Information Act (FOIA) request from Harris County Flood Control District (HCFCD), the San Jacinto Watershed has fallen further behind other watersheds in flood-mitigation funding on a number of measures.
Since 2000, HCFCD has spent $3.437 billion. The San Jacinto Watershed is the county’s largest and had the deepest flooding during Harvey as measured by feet above flood stage.
The Minnow’s Share of Funding
Yet it has received only $65.5 million in flood mitigation funding since 2000, ranking it 14th among the county’s 23 watersheds. The 215-square mile San Jacinto Watershed received only $1.5 million out of $54.6 million spent by HFCD in the fourth quarter. Meanwhile, all of the following watersheds are surging ahead in the funding sweepstakes:
Addicks Reservoir received $1.9 million
Brays Bayou – $3.6 million
Buffalo Bayou – $4 million
Cypress Creek – $6.3 million
Greens Bayou – $5.3 million
Halls Bayou – $6.3 million
Hunting Bayou – $2.3 million
Little Cypress Creek – $3 million
Luce Bayou – $2.5 million
Sims Bayou – $4.6 million
White Oak Bayou – $2.1 million.
Most of these watersheds have received extensive funding in the past. For instance, Brays Bayou has received more than half a billion dollars since 2000 and $175 million since Harvey.
Low-to-Moderate Income Watersheds Leave the Pack Behind
And since 2000, four low-to-moderate income (LMI) watersheds have received virtually half of all funding. Brays, Greens, White Oak and Sims received half of $2.4 billion – as much as all 19 other watersheds combined.
If you compare ALL watersheds with a majority LMI population, 8 LMI watersheds received 60% compared to 40% for 15 others.
This next table shows watersheds ranked by LMI percentage and the amount spent on each. Halls is one fifth the size of the San Jacinto and has about half the population. But it has almost double the LMI population and received almost twice as much money.
The Slippery Slope
The chart below shows the rank order of all watersheds based on total funding – both before and after Harvey.
Since Harvey, the San Jacinto has fallen below both the average and median spending per watershed.
Here’s the breakdown in a table format of who got how much.
Percent of Planned Spending
Another way to look at spending is by comparing the percentages of planned to actual for each watershed.
The San Jacinto has received approximately $30 million from the flood bond as of Flood Control’s last update. That’s out of $360 million on the project list – only one twelfth of the planned total for the San Jacinto.
Compare that with $185 million in flood-mitigation funding so far from the flood bond for Brays Bayou. That’s out of a planned total of $286 million. Brays has already received two thirds of its flood-bond total. That’s the power of equity.
Posted by Bob Rehak on 2/7/2023
1988 Days since Hurricane Harvey
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In the last few weeks, Michael Bloom, a fellow member of the Harris County Community Flood Resilience Task Force, and I have debated the inherent bias and limitations of a Flood-Mitigation Benefit Index (FMBI) proposed by a majority of the Task Force to Harris County Commissioners Court.
According to Mr. Bloom, the index will:
Reveal and document patterns of historical discrimination.
Help plan where additional flood-risk reduction investments should be made.
Population-Based, Not Damage-Based Mitigation
The formula is:
Cost = total flood-mitigation construction spending (and only construction spending) that benefits a census tract.
Population = the number of people who live in census tracts.
Risk = the annual chance of flooding (applied to census tract(s)) expressed as a whole number. For instance, a 1% annual chance equals 1. And a 10% annual chance equals 10, etc.
The Task Force hopes to calculate and compare the results for each census tract in the county.
According to proponents, “a high benefit score means no more mitigation spending is needed. And a low score means more spending is needed.”
But consider these two examples:
4,000 people live with a 1% annual chance of flooding and have received $200 in prior investment. Their FMBI would be 0.05. That’s extremely low. And scores that low indicate such areas need help “regardless of prior investment.”
8000 people live in the 10-year flood plain and have received $10 million in prior investment. Their FMBI equals 125. That’s 2,500 times higher.
According to a spokesperson for the FMBI, “A high FMBI means we don’t need to make more investments in that location.” Yet twice as many people live with ten times the risk in the area with the higher index.
So, who deserves the most help? Residents with the lowest FMBI? The formulaSAYS they need help the most. But they actually have the lowest risk.
The Value of Market Testing
None of the hypothetical examples used to “sell” the formula hint at the possibility of such an upside-down result.
The example above proves several things:
The formula can produce inconsistent and misleading results.
Adjusting for population doesn’t prove historical discrimination. The most densely populated area has 50,000 times more investment.
The formula needs rigorous testing and ground-truthing before going any further. This is a best practice for any new scientific formula – especially one intended to guide future investment.
In addition to producing unintended results, the formula has several other problems that require discussion.
No Right-Of-Way Acquisition Costs Included
The FMBI formula includes only construction costs. It excludes right-of-way acquisition costs by assuming that they are “uniform throughout the county.” Therefore, “…costs included or excluded will not adversely impact results.”
In fact, Right-of-Way (ROW) Acquisition costs are huge and NOT UNIFORM throughout the county. I have documented that ROW costs typically comprise the second most expensive part of flood-control projects.
A quick glance at the Appraisal District website will tell you that land costs vary widely throughout Harris County and change over time.
In fact, acquiring land in densely populated areas for flood mitigation often costs more than construction, according to several engineers I consulted.
I worry that other methodological issues may compound each other, not cancel each other out.
Census tract population typically varies by up to 4X (2,000 to 8,000), according to the Census Bureau. This will produce deceptive spatial comparisons.
Some Census tracts may comprise dozens of square miles while others comprise a few city blocks. Typically, flood mitigation projects are not considered at the Census-tract level. According to three engineers I consulted, that’s too small in most cases to be workable.
Larger Census tracts may contain multiple watersheds, each with independent levels of risk – or individual watersheds with varying levels of risk. In such cases, the formula would average risk. But averaging can mask a serious problem in one area with a non-problem in another. Thus, the formula has a bias in favor of spatially smaller Census tracts. Smaller tracts tend to be more uniform in risk, so problems will likely stand out rather than get lost in an average. But in larger watersheds, flood risk will feather out with increased elevation and distance from a river. That will make it extremely difficult to calculate the number of people exposed to varying degrees of risk. Averaging takes the simple way out. But averaging risk is like comparing saints and sinners, then declaring “No problem.”
The data collection effort for the index omitsmany sources of funding. So the formula will calculate investment dollars from some entities and areas, but not others. For instance, the formula will NOT measure drainage funding from Harris County Commissioner Precincts, dozens of cities, and 389 municipal utility districts in unincorporated areas. The difficulty of data collection in these areas will produce another spatial bias. Likewise, the FMBI formula will omit the considerable drainage-improvement contributions of reputable private developers.
No one has tested how these inconsistencies will affect each other. But there’s an even bigger data integrity issue.
Partially Updated Data
HCFCD and its partners invested more than $1.5 billion in flood mitigation between Harvey and the end of 2021. Since 2000, they’ve invested more than $3.5 billion. But as of this writing, new MAAPnext flood maps only reflect the POST-mitigation risk associated with projects in FIVE bayous: Brays, Greens, White Oak, Sims, and Hunting. The Army Corps partnered with HCFCD in those.
Unfortunately, according to a knowledgeable source, HCFCD has not yet updated the risk maps for its own Capital Improvement Projects in other watersheds. So if you ran the allocation formula now, it would compare PRE-mitigation risk in 18 watersheds with POST-mitigation risk in 5.
Mitigation in those five watersheds totals $439 million out of $1.5 billion since Harvey. So true, current risk is reflected in only 29% of spending since Harvey and 13% in this century. Those percentages will no doubt increase in the future. But if you ran the numbers today, you would compare numbers with PRE- and POST-mitigation risk.
And consider this. With HCFCD spending at the current rate of about $80 million per quarter, “current risk” is a constantly changing target. So we’ll never be able to compare apples to apples in all watersheds anytime soon.
And we want to use this formula to guide future mitigation spending? Using it could send more money back to fix areas we already fixed!
Difficulty of Assigning Investments to Census Tracts
Another challenge: How do you determine which census tract(s) to apportion project benefits among? Example: Addicks and Barker Reservoirs. The Army Corps developed those back in the 1930s to protect downtown Houston…15-20 miles away!
Do you credit the investment to:
All of downtown?
People living inside the reservoirs (who have their own census tract)?
The current population of the entire Addicks and Barker Watersheds?
All census tracts along Buffalo Bayou and parts of White Oak Bayou, our second and third most populous watersheds?
And virtually all residents of the Addicks and Barker watersheds live upstream from the Corps’ investment, so they will not benefit from the investment either.
Downtown has immense commercial and economic value but relatively few permanent residents.
So, who gets the benefit? Again, lots of room for interpretation and misplaced assumptions here that numbers can easily mask! Now, multiply this problem times thousands of Census tracts.
The population-based FMBI has a built-in bias against commercial areas that have little to no residential population. For example, consider the cases of Downtown, the Texas Medical Center, and the Port of Houston. Such areas support employment throughout the region, but the formula discriminates against them by giving huge weight to population and omitting actual damage.
No Thresholds Defined
To my knowledge, the task force has never discussed threshhold “benefit” levels that correlate to “needs help” or “doesn’t need help.” The extremes may sometimes be easy to determine. But what about outcomes in the middle?
Variables in the formula can offset each other as we saw above. In tight races for funding, who gets the next flood-mitigation investment? The area with the lowest investment, highest risk, or largest population? Such quandaries have not yet been addressed.
No Agreement on Weights of Other Factors
To help make future flood-mitigation decisions, proponents of the formula also suggest weighing (separately) other factors, such as the CDC’s Social Vulnerability Index. It includes the percentage of Low-to-Moderate residents in an area. However, no one has yet discussed the weight given the Benefit Index relative to other factors.
No Consideration of Actual Flood Damage
In deciding where to put flood mitigation projects, engineers traditionally look for damage clusters. It’s that simple. Dollars flow to damage.
Reducing flood damage is a tried and true, measurable way to evaluate projects. So why all the complexity?
What’s The Point?
What is this formula trying to prove? Is it attempting to develop a new approach to mitigation funding that eliminates a perceived bias in Benefit/Cost Ratios?
Commissioner Rodney Ellis often talks about how calculating the value of avoided damages in higher value homes disadvantages projects in poorer neighborhoods. That can be true in some instances. Expensive homes can ratchet up benefits (measured in dollars) faster than lower value homes can. And that can result in higher Benefit/Cost Ratios for projects in affluent neighborhoods – assuming density is held constant. But…
One high-value home on an acre would likely appraise less than an apartment building, also on an acre. In Kingwood, I compared the valuations of an expensive single-family home with a large apartment complex one block away. The appraised cost per acre (including structures) of the apartment complex is 4X higher.
Now consider that apartments accommodate almost half of Harris County’s population.
Most Americans aspire to and encourage home ownership, in part, because of the stability it fosters in communities. But this formula – because of its emphasis on population density – favors apartment areas over areas with owner-occupied homes. There’s nothing inherently wrong with that. You just need to understand what the formula does.
Difference Between Vertical and Horizontal Density
The Benefit Index favors all areas with dense population. Proponents argue that helping more people is better. I don’t argue with that. However, the generalization masks the financial pain inflicted by a flood on owners vs. renters, and on the people who live at ground level compared to those who live above it.
Ground floor renters may lose contents in a flood, but they won’t be responsible for making structural repairs. The owner will.
And many living above the ground floor may find themselves more inconvenienced by flooding than financially devastated. So, is it fair to count all people on all floors when determining who suffers the most pain?
In the proposed formula, higher population will lower the benefit index, making it look as though all renters (almost half the county’s population) suffered more than owners of single-family homes.
The premise underlying such “equity” arguments is that poor people can least afford floods. But most people in apartments like those shown above won’t make structural repairs as a homeowner would.
No Perfect Formula
No perfect formula exists that’s equally fair to all in all circumstances. That’s why FEMA, HUD and the Army Corps allow consideration of multiple factors when determining which projects to fund.
The Flood Mitigation Benefit Index focuses totally on population, risk, and past investment. It ignores actual flood damage.
If we use ANY formula to HELP allocate future flood-mitigation funds, we should all strive to:
Understand its built-in biases
Maintain high standards for data integrity.
If we want to test a hypothesis of historical discrimination in flood-mitigation funding, there’s a much simpler way. It’s called direct measurement. Simply locate damage centers from past storms and compare funding in the following decade designed to mitigate those areas.
For More Information
For more background on issues with the formula, see my earlier posts:
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On 6/28/22, the Harris County Community Resilience Flood Task Force proposed yet another formula for allocating potentially billions of dollars in future flood-mitigation funding. It purports to objectively calculate the benefits received by different areas. But it doesn’t in any conventional sense. And therefore, the results can be deceptively counter-intuitive.
In each example below, I’ll hold two of the three variables constant. That makes it easy to see whether “benefit” varies in a predictable direction. And whether that matches what people expect when they hear the word “benefit.”
The value of “10” applied to Risk in each case represents a 10% annual chance of flooding.
If youhold risk and population constant, while increasing cost…
Population = 5000, Risk = 10 and Cost = $100,000, then Benefit = 2
Population = 5000, Risk = 10, and Cost = $1,000,000, then Benefit = 20
…benefit increases by spending morewithoutreducing risk! A taxpayer nightmare!
If you hold cost and risk constant, while increasing population…
Population = 2000, Risk = 10, and Cost = $1 million, then Benefit = 50
Population = 5000, Risk = 10, and Cost = $1 million, then Benefit = 20
…benefit decreases by helpingmore people with the same dollars! Again, counter-intuitive.
Both takeaways are confusing. What is this formula measuring?!
I would argue that, in a flood context, most people strongly associate the word “benefit” with “risk reduction.”
But this formula doesn’t measure risk reduction. And it doesn’t measure efficiency either. It measures per capita investment associated with a certain level of flood risk and calls that “Benefit.”
So, the more people you help with any given sum, the more the benefit goes down. Voila! That makes it look as though the highly populated watersheds (that have received the overwhelming majority of prior investments) have received little benefit. And that may be the point of this formula. It will send even more money to those same areas.
In logic, they call this the fallacy of incomplete evidence – more commonly known as cherry-picking. You cherry pick data that favors your argument and ignore the rest. For instance, consider the image below.
The total population in some areas includes many people in tall apartment buildings or high-rises. For many of them, flooding may be more inconvenient than financially devastating. Yet the formula assumes all people suffer equally.
The formula provides the appearance of objectivity and fairness. But it masks important information by lumping everything into a single number.
But the proponents of this formula don’t even want to discuss numbers. They want to render the results as heat maps, layered with Social Vulnerability Index, LMI and other data guaranteed to mask and perpetuate the lopsided distribution of flood-mitigation funds.
Omitting Benefits to Structures
By defining Benefit as the cost per person to achieve a certain level of flood risk, the formula omits any benefit to structures. That’s the traditional way to define the benefit of a flood-mitigation project. You measure “the value of damages avoided.” Whether one person lives in a house or two people live there, the cost to protect those people and that home remains the same.
For instance, widening a channel can reduce flood risk for a house. But with the proposed formula, that home and its value no longer count – only the number of people living within it. So, doubling the number of people in a representative home cuts the Benefit of a flood mitigation project in half.
The formula is a vast oversimplification. It omits valuable information such as avoided damages.
It’s also confusing and semantically deceptive in that results vary in counter-intuitive directions.
Yet the majority of the Community Resilience Flood Task Force proposes using it to help guide (potentially) billions in future flood-mitigation investments. That could hurt taxpayers, flood victims, future bonds and the credibility of local government.
The formula can deceive people into making bad flood-mitigation investments. But in this case, there’s no Securities & Exchange Commission to protect investors. Only the ballot box.
Posted by Bob Rehak on 7/6/22
1772 Days since Hurricane Harvey
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Fifth in a series of eight articles on flood-mitigation funding in Harris County
On June 11, Russ Poppe, executive director of the Harris County Flood Control District, resigned after two years of hounding by Commissioners Rodney Ellis and Adrian Garcia over the distribution of flood-bond money. Ellis and Garcia kept pushing Poppe to accelerate flood-mitigation projects in minority/low-income neighborhoods, using racial “equity” as the justification. But the discussion should be about damage, not race.
Alleged “Back-of-the-Bus” Treatment
Ellis was particularly vocal. He described Halls and Greens Bayous as getting “back-of-the-bus” treatment. With Shakespearean flare, he would rub his bald head and perfectly frame himself in front of aggressive artwork that says “Pay,” “We are fed up,” and “No Way.” Then he would lean into his camera and pronounce, “They flood every time.” If we don’t fix that, “We’ll have blood on our hands.”
But there was also a Shakespearean irony to Ellis’ monthly melodrama. As the posts in this series have shown…
Narrow Questions Lead Viewers to Wrong Conclusion
This is a manufactured melodrama, born from a lie, and then exploited for political gain. Ellis even sweeps up community groups and flood survivors into his monthly melodrama. He would trot them out in meeting after meeting to anecdotally embellish his narrative, as he grilled Poppe like a prosecutor.
“Russ Poppe, is it not true? Did you not tell me that FEMA evaluates flood control projects with a benefit/cost ratio?”
Poppe would respond, “Yes, Commissioner.”
Ellis continued to ask pointed questions that demanded yes or no answers and could only lead to the conclusion he wanted. “Are the home values in Kingwood higher than around Halls Bayou?”
“Would that not raise Kingwood’s benefit/cost ratio?”
You get the idea. Ellis would focus on a narrow sliver of truth that bolstered his narrative of discrimination. Basically, it was a story of systemic racism – that the white man built the system to favor white men. He led listeners to conclude that areas like Kingwood got all the flood mitigation money, and that poor black and Hispanic neighborhoods got none.
However, Ellis had viewers looking through the wrong end of the telescope. He focused them on process, not outcomes. Had he bothered to check the facts, he would have found two problems:
Kingwood has NEVER received a Harris County Flood Control District Capital Improvement Project.
Benefit/Cost Ratios Factor in Far More than Home Value
The federal grant-funding process includes dozens of other factors besides home values. And when you combine them all, watersheds such as Greens, Brays, and Sims came away with benefit cost ratios as high as 6 or 7, while areas like Kingwood struggled to get above 1. The Flood Control District’s Federal Briefing document shows the benefit-cost ratios for all Federal Projects. See for yourself.
Percentage of low-to-moderate income residents in an area
Number of structures that can be removed from the floodplain by a project.
When you look at outcomes, instead of one small part of the process, you see that poorer, inner-city watersheds get the vast majority of funding in Harris County.
Dollars Flow to Damage
The two tables below compare actual flood-mitigation funding since 2000 in high and low quartiles when ranked by “damaged structures” in four major storms: Allison, Tax Day, Memorial Day, and Harvey. The last column ranks watersheds by LMI%. That’s the percentage of low-to-moderate-income residents with less-than-average income for the region. Halls has the highest LMI rank of any watershed – 71%, making it the lowest income watershed.
In comparing these two groups, several things become clear:
Dollars flow to damage.
Damage happens primarily in low-income watersheds.
Low-income watersheds received a billion more than the high-income (low LMI%) watersheds
Low-income watersheds averaged 3X more dollars
The median for low-income watersheds was 4X higher.
Stats Show No Racial Bias in Distribution of Flood-Mitigation Funding
Harris County does not discriminate against minority, low-income groups in the allocation of flood-mitigation funds. Dollars flow to damage. Of all the factors I examined, flood-mitigation funding most closely tracked damage. That’s a logical, valid basis for distribution of funding.
The most money went to the watersheds with the highest damage. They just also happened to be watersheds with high percentages of minority and low-income residents.
The real factors that contribute to flooding have become lost in the racially charged rhetoric. The sooner we lose the racial rhetoric, the easier it will be to address flooding.
The real factors that contribute to flooding become apparent when you look at the maps below. They correspond to the tables above.
Watersheds with the most damage lie mostly inside Beltway 8.
Watersheds with the least damage all lie outside Beltway 8.
Low Income Watersheds
Higher Income Watersheds
Neighborhoods inside the Beltway:
Were developed decades ago, with lower drainage standards
Have more structures built in floodplains and closer (lower) to street level
Have structures built right up to the edges of ditches and streams
Are downstream from newer areas, often in other counties that don’t mandate detention ponds
Are more densely populated, and thus have higher percentages of impervious cover
The sooner we can focus this discussion on issues such as these, the sooner we will solve our flooding problems. Polluting the discussion with antagonizing, racial rhetoric will only delay solutions and drive off more good people like Russ Poppe. Poppe’s only “sin” was that he was appointed in 2016, a year when Republicans controlled Commissioner’s Court. So, he became an easy target, like so many other department heads before him.
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.
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Fourth in a series of eight on flood-mitigation funding in Harris County
Since 2019, Commissioners Ellis and Garcia have harped on the need for more “equity” in flood-mitigation funding. They and some residents in their precincts allege that all the money is going to high-income watersheds while minority, low-income watersheds get “none.” Ellis repeatedly complains that Harris County Flood Control District gives those minority neighborhoods “back-of-the-bus” treatment. Garcia says he feels like he was “hit with a baseball bat.”
Unfounded Allegations of Racism in Construction Funding
In March, I became so alarmed at the allegations of racism, that I submitted a Freedom of Information Act Request to see if they were true. They aren’t. Funding data for new construction projects dating back to 2000 shows that:
Those first three articles in this series should suffice to disprove discrimination against minority, low-income watersheds. But more statistics just keep jumping out of the data.
So, today let’s compare watersheds with percentages of low-to-moderate-income (LMI) residents above and below 50%:
The low-income group has 7 watersheds, comprising 584 square miles.
The high-income group has 14 watersheds, comprising 1123 square miles.
The two groups vary radically in number and geographic size. So, to provide a valid comparison, we must evaluate them first on a per-square-mile basis. This pie chart shows how the smaller, low-income group gets triple the dollars per square mile.
Watersheds Above/Below 50% LMI
Here are the percentages of LMI residents in each group.
Lower Income Watersheds Get 3X More Construction Funding Per Square Mile
On a per-square mile basis, the low-income group averaged $2.5 million. The high-income group averaged only $0.8 million. See Table 2 below.
Smaller, Low-Income Group Also Receives About a Third More in Total Dollars
Comparing the total dollars (not $/square mile) received between the two groups is also illuminating.
In total dollars, the low-income group of 7 received $400 million dollars more than the high-income group of 14 since 2000. That skewed the averages back toward 3X again. See Table 3.
But More Damage in Low-Income Group
As we have seen elsewhere in this series, dollars flow to damage. Low-income watersheds had twice the total damage despite being half the size and number.
In four major storms since 2000 (Allison, Tax Day, Memorial Day and Harvey), the seven low-income neighborhoods had 146,832 structures damaged, compared to 70,719 for the higher income group of 14. However, on a per square mile basis, low-income group had four times as much (251 vs. 63).
*Vince Bayou omitted from the first group because it lies almost wholly within the City of Pasadena and is the City’s responsibility. Little Cypress Creek also omitted from second group because it is a newly developing area. Very few people live there and that skews statistical comparisons. HCFCD spending in Little Cypress relates to an experimental “frontier program.”
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Third of an eight-part series on flood-mitigation funding in Harris County
Some people and their representatives in low-to-moderate-income (LMI) watersheds have complained that they get “no” flood-mitigation funding and that the money is all going to richer watersheds. Allegedly, that’s because home values are higher there and thus favor higher benefit/cost ratios (a sort of systemic racial discrimination). But is that true? Do higher home values in a neighborhood really translate into “projects funded”? No. The allegation ignores many other factors that enter into funding, such as damage and population density. Density is two to three times higher in low-income neighborhoods and that influences damage totals. When you look at funding outcomes as opposed to a sliver of the mitigation process, low-income neighborhoods get far more money. Here’s how it breaks down.
Where Money is Really Going
Recently, I obtained flood-mitigation funding data for every watershed in Harris County via a Freedom of Information Act (FOIA) request. It sheds new light on this subject.
In addition to the quartile comparisons I did in earlier posts, I also compared the top quartile (six watersheds) to the rest with one exception in each group noted in previous posts and the footnote below.* The data showed that six watersheds with the highest percentages of LMI residents (meaning low income) have received 56.8% of HCFCD spending out of the 21 remaining watersheds since 2000.
In this post, I will examine both trends by looking at six watersheds with the highest percentages of LMI residents. They include Brays, Greens, Sims, Halls, Hunting and White Oak Bayous.
As a group, they:
Comprise 30.9% of the square miles in the county
Received 56.8% of total spending – $1.52 billion of the $2.6 billion spent by HCFCD since 2000.
That’s more than 15 higher income watersheds combined.
Dollars Flow to Damage
But if you stopped there, you could conclude that these six watersheds were getting more than 2-3X their fair share of funding. However, also consider that they had 144,754 out of the 222,739 structures damaged in Harris County during Allison, Tax Day, Memorial Day and Harvey floods.
One thing is certain: these six watersheds have not been at the “back of the bus.” They received more than $1.5 billion out of $2.6 billion invested by HCFCD since 2000.
The data DISPROVES discrimination on an income or racial basis. Money is not going disproportionately to rich neighborhoods. Far from it. It’s going disproportionately to poor and minority neighborhoods. However, that is also where the most flood damage occurred. Let’s take a closer look at each of the six low-income watersheds.
Received 19% of total spending since 2000, but represents just 6% of the county’s area.
Received more than half a billion dollars since 2000, the most of any watershed, and about one-fifth of all flood-mitigation spending in 23 watersheds in 21 years.
Received the second most funding since Harvey ($130,685,844.43).
Got 4 times the average and 7 times the median of flood-mitigation funding for all watersheds.
It certainly seems like an outsized injection of flood-mitigation funds. But the improvements also protect some major infrastructure and employment centers including the Texas Medical Center. See this photo essay taken from the air.
Also consider that Brays had the most damage in four major storms (Allison, Tax Day, Memorial Day, Harvey) – 32,194 structures flooded.
Brays has the fifth highest percentage of low-to-moderate income residents (58%).
HCFCD construction is on-going in this watershed.
Commissioners Ellis and Garcia often cite Greens Bayou as a “back-of-the-bus” watershed. They also say, that if the County doesn’t fix it, “we’ll have blood on our hands.”
Greens received the 3rd most dollars since 2000 and the 2ndmost since Harvey. That’s 11% and 14% of all HCFCD spending respectively during those two time periods. Only in Harris County politics can you call second place out of 23 “back of the bus.”
But Greens also had the second most damage in four major storms (28,815 structures).
Greens Bayou has the sixth highest percentage of LMI residents in the county (57%).
HCFCD construction is also on-going in this watershed.
Mr. Ellis and Mr. Garcia also consider Halls Bayou funding to be “back of the bus.” It comprises only about 2.4% of the county but received almost 5% of total spending since 2000. It also received:
The fourth most funding per capita ($841.77)
The third most funding per square mile ($3,031,912)
The eighth most funding since 2000 ($128 million).
Halls has the highest percentage of LMI residents (71%) in Harris County.
HCFCD construction is on-going in this watershed.
Sims Bayou runs through the southern part of the county. It:
Ranks as the 8th largest watershed.
Received the 6th most funding since 2000 ($165,013,368)
Has the 7th largest population (310,537)
Has the 5th highest population density (3755 per sq. mi.)
Had the 6th most damage (18,122 structures)
Sounds proportional and it is.
However, these calculations do not include $254 million, which the U.S. Army Corps of Engineers spent on Sims between 1990 and 2015 (by itself) for a major flood-reduction project. The Corps’ contribution to Sims Bayou alone was almost 10% of all HCFCD spending since 2000 ($2.68 billion).
Sims has the third highest percentage of LMI residents (65%).
Hunting Bayou is one of the county’s smaller watersheds. It comprises 31 square miles or 1.7% of the county’s land mass. That ranks it as the 19th largest bayou out of 23. And it has the 14th largest population (78,213). Yet, since 2000, it has:
Had the seventh most damage (15,728 structures)
Received the third most dollars per capita since 2000 ($952.18)
Received the fourth most dollars per square mile ($2,402,908)
Hunting Bayou has the second highest percentage of LMI residents (69%).
HCFCD construction is on-going in this watershed.
White Oak Bayou is the sixth largest watershed in Harris County. Yet it received 13% of the flood-mitigation funding since 2000 – $349 million, the second highest total of any watershed. It also ranked second in dollars received per square mile – $3.14 million.
But also consider that it had the third highest number of damaged structures – 24,989 in Allison, Tax Day, Memorial Day and Harvey floods combined.
51% of the residents in White Oak qualify as low-to-moderate income.
HCFCD construction is on-going in this watershed.
“Damaged structures” and funding received had the highest correlation of any relationship I tested. For math majors, the coefficient was .86. That’s high. A perfect correlation would be 1.0. For the less technically inclined, see the table below.
Many projects in these lower income watersheds are still under construction or preparing for it. And major storms have not yet tested many recently constructed improvements. Regardless, their residents are safer than they otherwise would be. And they can take some comfort in knowing that the system is working for them, not against them.
Posted by Bob Rehak, based on information compiled from a FOIA request and Federal Briefings
1394 days since Harvey
*Omits Vince Bayou in low-income group because it is entirely within the City of Pasadena, which has responsibility for it. Includes White Oak Bayou instead. Also omits Little Cypress, which has a very small population and is an experiment by HCFCD in preventing future flooding.
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/06/Six-v.-15.jpg?fit=1200%2C679&ssl=16791200adminadmin2021-06-23 10:00:382021-06-23 10:01:21Six Low-Income Watersheds Receive More Funding than 15 Higher Income Watersheds Combined
The 2019 Federal Briefing (page 56) separates Brays improvements into two areas:
Upstream (west of Sam Houston Tollway)
3 detention basins: 595 surface acres; 9,623 acre-feet of storage – enough to hold a foot of water falling over 15 square miles (13% of entire watershed)
3.7 miles of channel conveyance improvements, including control structures, from Old Westheimer Rd. to SH 6
Downstream (east of Sam Houston Tollway)
17.5 miles of channel conveyance improvements from the mouth to Fondren Rd.
1 detention basin: 252 surface acres; 1,865 acre-feet of storage – enough to hold a foot of water falling over 3 square miles
30 bridge replacements/modifications, and/or channel conveyance improvements under bridges (16 due for completion this year)
Harris County Flood Control District (HCFCD) manages, designs, and builds the projects; buys land, easements, rights-of-way; relocates utilities; adjusts bridges (except for railroads); and operates and maintains the channel after construction.
Benefits and Costs
After completion, upstream improvements should give residents a 100-yr. level of flood protection (1% annual chance).
Likewise, downstream improvements should reduce the number of structures:
In the 4% or 25-year flood plain from 3,520 to 50.
In the 100-year flood plain from 16,800 to 1,800.
Total Cost Estimate: $480M though 2019 (Source: 2019 HCFCD Federal Briefing, Page 45)
Benefit-Cost Ratio: 7.0 (Source: 2019 HCFCD Federal Briefing, Page 56)
The size of the cost in conjunction with the benefit-cost ratio makes these numbers impressive. The primary requirement for the ratio is that it exceeds 1.0, i.e., that the benefits exceed the costs.
Brays’ watershed includes 114 square miles. That makes the cost per square mile a whopping $4.4 million throughout the watershed. However, one must also consider that the population of Brays is the largest of any watershed in Harris County – more than 700,000 of which (57.5%) qualifies as low-to-moderate income.
The map below, taken from a 2020 HCFCD grant application to the US Department of Housing and Urban Development (HUD), shows the distribution of income throughout the watershed. Areas such as West University and the Medical Center in the middle (blue) rank higher in income than areas east and west (tan/red).
Possible Reasons for Large Investment
You could justify this extraordinary level of investment any number of ways. By the:
High population density
High benefit/cost ratio
Protection of critical infrastructure, such as the Texas Medical Center
Number of homes and businesses flooded historically – also the largest in Harris County: 32,194 structures since Allison (Source: 2019 Federal Briefing: Pages 16-21)
Length of time projects have been in the pipeline (most before Harvey and some even before Allison)
Proximity to older, central part of county
Do not underestimate the last two points. Funding for many flood-mitigation projects can take decades.
Regardless of the reasons why Brays has received so much investment, one can also look at what this example does not show. It does not support the “equity” narrative propounded by some. That narrative asserts low-to-moderate-income neighborhoods receive less flood-mitigation funding because of lower home values compared to more affluent neighborhoods. Those affluent neighborhoods theoretically get more flood-mitigation funding because they allegedly support higher benefit-cost ratios (BCRs).
Home Value Alone Does Not Determine Benefit/Cost Ratio
The 7.0 BCR in Brays proves that low-to-moderate income neighborhoods are not automatically disadvantaged. Population density can offset lower property values. A whole apartment complex can sit on the same amount of land as one suburban home, yet the apartments would have higher value.
Direct Physical Damages to Buildings, Contents and Inventory
Essential Facility and Critical Infrastructure Serivce Loss
Brays Watershed Investment Not Suffering From Discrimination
The Brays watershed cuts across racial, ethnic and socio-economic boundaries. Flooding has been recognized as a problem here for decades and HCFCD has successfully obtained many grants during that time. HCFCD has also invested more in Brays than any other watershed. Like Halls Bayou and Greens Bayou, the narrative re: Brays is far more complex than some acknowledge.
Photos of Improvements in Bray’s Bayou Watershed
On May 26, I flew from Beltway 8 West to the Ship Canal east of downtown along Brays Bayou. Out of more than 1100 images, here are 16 that represent what you see along the way. Lots of detention ponds, channel improvements, and new bridges. The bridges are higher and often wider, with wider supports to avoid constrictions and blockages. New bridges never have more than two supports in the water flow; some old ones had seven.
As these pictures show, flood mitigation funding isn’t all about home value. Brays traverses some of Houston’s most critical infrastructure, job centers, rail lines, diverse neighborhoods and employment centers.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/06/20210520-RJR_6999.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-06-03 10:53:512021-08-24 15:07:33Brays Bayou Received Approximately Half Billion in Flood Mitigation Funding In Last 23 Years
Today marks the 1349th day since Hurricane Harvey. That’s also how long it took the United States to win World War II. To date, we’ve studied problems, made bold plans and, in a few cases, actually started constructing flood mitigation projects. But none of the $2.1 billion allocated for Texas flood mitigation by the US Department of Housing and Urban Development (HUD) has yet to work its way down to the local level.
Imagine What That HUD Money Could Have Done By Now
The Texas General Land Office (GLO) administers HUD flood mitigation funds for Texas. However, it has yet to announce the results of a statewide grant application competition for the first half of that $2.1 billion. Hopefully, those announcements will come this month. The GLO intends to hold a second competition for the second half of the money at a later date.
Below are thoughts contributed by others. To encourage their candor, I promised them anonymity.
I. Consolidation Under One Agency
One federal official suggested that all flood mitigation funds should flow from the Federal Emergency Management Agency (FEMA), not HUD.
Rationale: Disaster relief is FEMA’s core competency. FEMA’s good at it. FEMA responds quickly. They are on location after disasters. They collect immense amounts of data, manage the National Flood Insurance Program, and have resources to get the job done quickly.
Right now, HUD, the slowest agency with the most rules and regulations, is responsible for helping the poorest neighborhoods, i.e., those that often need it most. Many think that’s unfair.
Dividing responsibilities among agencies creates needless bureaucracy, complexity, overlap and “stove piping.”
Stove-piping is where people in one bureaucracy are blind to activities in another. Eliminating the stove-piping requires cross checking data between agencies and programs, for instance to eliminate duplication of benefits. But that can also slow projects down.
Rationale: Not all earmarks are meritless. In cases of exceptional need, they can send money directly to cities or counties trying to build important flood mitigation projects. With proper safeguards against bogus earmarks, this idea could shave years off construction projects designed to protect people.
III. Partner with Army Corps More
Another expert suggested directing more money to the Army Corps for “project partnership agreements.” The Corps work directly with a local entity such as a city or county to help construct projects faster.
Previously, the Corps built the Antoine Stormwater Detention Basin in the Greens Bayou Watershed. HCFCD bought out the properties that comprised that basin and currently maintains the property.
IV. Establish a “Quick Reaction Fund”
A financial expert suggested establishing a “Quick Reaction Fund.” It would be activated by a Presidential Disaster Declaration and provide loans to get projects started quickly. The money could be used to jumpstart upfront activities, such as buyouts, environmental surveys and preliminary engineering reports. It could also be used to build entire projects that are needed quickly.
Rationale: Local entities often don’t have the money or staff to conduct these upfront activities. Buyouts can be especially problematic. They must often be completed before other flood mitigation activities, such as ditch improvements or detention ponds, can start.
“But we often have to wait 18 months or more for approval of buyouts,” said one engineer. “The vast majority of people can’t wait that long.”
So they fix up their homes and become more committed to them. Or they may just leave the area. Either way, this slows flood mitigation down even more.
Loans could be paid back later by grant awards from the Feds.
V. Pass a Hazard Tax
To bypass the delays and uncertainties of competitive grant funding through state and federal levels, one local entity suggested passing a “hazard tax.”
Rationale: This would put local entities in charge of their own destinies rather than making them dependent on Washington and Austin for handouts. It would let cities and counties build up a war chest from their own tax revenues. Think of it as a savings account with a dedicated purpose – disaster mitigation. The money could be used to fund projects directly and quickly, or as the basis for matching funds when projects are less time critical.
In my opinion, we desperately need a way to resolve such issues faster. I hope this series of articles will start a public dialogue among political leaders at all levels.
Posted by Bob Rehak on 5/9/2021
1349 Days after Hurricane Harvey, the number of days in WWII
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/05/TS-Harvey-8-30-17-209.jpg?fit=1024%2C768&ssl=17681024adminadmin2021-05-09 14:24:502021-05-09 19:15:39How to Speed Up Flood Mitigation Funding: Part II
The last three posts on the equity flap have focused on how minority neighborhoods in Precinct 1 already receive more flood mitigation funding than affluent areas like Kingwood. Tonight, I focus on why that is likely to continue for the foreseeable future. But first, a recap for context.
Biggest Beneficiary of Funding Claims Discrimination
Last Tuesday, the equity flap erupted again in Harris County Commissioners Court. Precinct 1 Commissioner Rodney Ellis complained that because of historical discrimination (i.e., slavery, which was abolished more than 150 years ago), he needs to fight for “equity” in the distribution and implementation flood bond projects. Precinct 1 already receives the lion’s share of many types of funding.
What Mr. Ellis does not point out to the Commissioners Court is that Precinct One:
When talking about “historic discrimination,” Commissioner Ellis needs to shift his focus forward in time and look at other areas of the county that receive NO such joint projects and far fewer flood mitigation dollars. Take the San Jacinto Watershed, for instance. It contains Kingwood. Because of Kingwood’s affluence, it’s one of the favorite whipping boys for Commissioner Ellis and his surrogates who argue for equity. They keep bringing equity up every time a Kingwood-related item is on the Flood Control agenda at commissioners court. But the Kingwood/Lake Houston Area has NO such joint projects. Why?
Causes of Inequity
There are two reasons for this inequitable distribution: one obvious, one not so.
First, the obvious: The Houston region has grown from the downtown area outward. Precinct 1, which includes downtown, is older. Flood problems became apparent sooner. Precinct 1 documented problems, identified solutions, and rallied Federal support decades ago.
Commissioner Ellis’ predecessors also started this process decades ago and Precinct 1 enjoys the rewards today. As a consequence…
Buffalo Bayou and all of its tributaries are eligible for Corps support on non-emergency projects; the San Jacinto is not.
Even though the problems in the Lake Houston Area have been building for decades, the danger didn’t become apparent until Harvey.
At this point, rallying the kind of Federal support that Precinct 1 has historically enjoyed will involve an act of Congress and Presidential approval. Literally. That’s an uphill battle compared to the battle that Mr. Ellis’ projects face.
Political Challenges for San Jacinto Watershed
A local sponsor, such as the City, would have to file an application for a project. Congressional representatives would have to get the President to build it into the annual budget, then include it in the Water Resources Development Act. Both houses of Congress would have to pass the act. The President would have to sign it. And then the government would have to distribute the money. The distribution usually happens in phases, after approval of each phase of a project, such as:
Engineering and design
Construction, operation and maintenance
Changes after construction authorization
Changes after construction
It could easily take three to five years just to get the engineering and design phase on a project, such as additional flood gates for Lake Houston.
A second challenge: Mr. Ellis and his surrogates using unfounded “equity” arguments to further handicap and delay flood mitigation in the Lake Houston Area.
Then along came the Tax Day, Memorial Day and Hurricane Harvey floods. They deposited an estimated 5 to 10 million cubic yards of sediment in the East and West Forks. Much of that came from sand mines upstream of Lake Houston, which Lake Conroe inundated when it released 80,000 cubic feet per second at the peak of the storm. This further exacerbated flooding by backing water up in the river and drainage ditches.
Citing historical discrimination that goes back to pre-Civil-War days, Mr. Ellis argues for equity to increase his precinct’s share of flood mitigation dollars and to accelerate projects in his precinct.
As the data shows, his precinct already has far more than its fair share of mitigation dollars. Now, he threatens other areas, property and lives by delaying and usurping their aid.
If any area is underfunded and fighting discrimination now, it’s the Lake Houston Area. Ironically, the discrimination is coming from the Rodney Ellis’ of the world.
I don’t begrudge Precinct 1 a penny of the flood mitigation funds it has received to date. And I admire Mr. Ellis for fighting so hard for his constituents. However, I despise the way he does it.
Mr. Ellis represents one fourth of the people in the county. Yet he cries “equity” and ignores facts to usurp more than half of flood mitigation funding and put his Bond projects at the front of the construction line. I wish he would acknowledge:
The inequality that exists in current funding and that is likely to continue for years.
That a Kingwood, Humble, Atascocita or Huffman life is as valuable as a life in Precinct 1.
Ironically, the Lake Houston Area argued for equity in the bond language to prevent the very kind of reverse discrimination that we are now seeing. We need to work together to mitigate flooding everywhere as quickly as we can. This equity flap is fanning racial flames that divide us, perpetuate distrust, delay mitigation, and threaten lives. It’s time to get on with the hard work at hand. Two wrongs don’t make a right.
Posted by Bob Rehak on 6/28/2019
668 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2019/06/BBT.jpg?fit=1500%2C971&ssl=19711500adminadmin2019-06-27 23:07:522021-07-29 16:17:10Where the Flood Mitigation Dollars Have Really Gone: Part 4