Tag Archive for: Method of Distribution

Last Chance to Comment on Distribution of $750 Million in HUD Flood-Mitigation Funds

Tuesday 2/21/23 at 5 P.M. will be your last chance to comment on Harris County’s proposed distribution of $750 million in HUD Flood-Mitigation funds.

Harris County Community Services Department (CSD) will request Commissioners Court approval of its plan for allocating $750 million in HUD Harvey mitigation funds Tuesday. (See item 489 on the Agenda.) The Texas General Land Office (GLO) has conditionally approved the preliminary plan and sent it back to Harris County for public comment.

However, the plan still consists only of a high-level outline. The county wants to split the money between itself and Harris County Flood Control District (HCFCD) after allocating 13% for planning and administration.

CSD doesn’t intend to say exactly what areas will get how much for which projects until AFTER public comments.

Preliminary Plan Still Contains Little Detail

CSD has posted a 15-minute YouTube video that explains the process. See the screen captures below from the video.

Basically, CSD wants your comments on a high-level outline for dividing up the money. Below is what they recommend.

Less than half will go to HCFCD. AFTER approval tomorrow, the County will develop a list of projects for submission to the GLO. See last line in slide below.

CSD’s video discusses the criteria the county intends to use when developing a project list.

Input obtained prior to developing list.

It appears that Harris County wants all of the money to benefit low-to-moderate income, socially vulnerable neighborhoods…the same neighborhoods that have gotten the lion’s share of funding to date.

Sound familiar? Even though 50% of the $750 million can go to higher income areas, up to 100% could go to low-to-moderate income areas. And it looks like the county wants to go in that direction. Again.

Public Comments Close at 5 P.M. Tuesday

The only way to get your fair share is if enough members of the public demand a more even split. We don’t have enough money to finish the flood bond without spending all of the $750 million on flood mitigation. But CSD’s plan would give less than half to HCFCD.

We need the entire $750 million to fully fund the 2018 flood bond. Given the prevailing politics in Harris County these days, if any projects get cancelled for lack of funding, they will likely be those in middle- to higher-income neighborhoods.

Get Your Promised Share of the 2018 Flood Bond

So please protest any diversion of these funds away from flood mitigation.

By law, CSD must forward all comments received by Tuesday at 5 P.M. to the GLO and HUD for review.

So hurry. Email your comments NOW. It will only take five minutes.

Deadline: February 21 at 5PM.  

Email to: DRplancomments@csd.hctx.net

Below is a sample letter with key points to make. Feel free to cut-and-paste or adapt.

Sample Letter

To whom it may concern:

I strongly protest the outline that Harris County Community Services presented to the GLO for the distribution of $750 million in HUD CDBG-MIT Harvey flood-mitigation funds.

Since adoption of Harris County’s Equity Prioritization Framework, the County has been funneling 2018 Flood Bond money and other local funds to projects in high LMI and SVI areas. 

Now, however, without all of the $750 million going to flood mitigation, there likely won’t be enough money to finish all of the defined flood-bond projects that voters approved by 88% in 2018.

Therefore, I suggest:

  1. The entire $750 million should go to Harris County Flood Control District to complete unfunded flood-mitigation projects in the bond. 
  2. Earmark half that money for projects in watersheds with more affluent residents (less than 50% LMI) who have been largely ignored until now.
  3. Prioritize projects by:
    • The number of damaged structures during Harvey
    • Depth of flooding during Harvey
    • Remaining, unmitigated flood risk
    • Ability to reduce threats to infrastructure, such as bridges, schools, hospitals, and sewage treatment plants.
    • Lack of previous flood-mitigation investment in watershed
  4. The County, GLO and HUD need to be fair to all people of Harris County as HUD’s rules allow. Half of the flood-mitigation funding in Harris County since 2000 has gone to just four watersheds (Brays, Greens, White Oak, and Sims). Other areas have needs, too.
  5. CSD should present a detailed plan and stick to it. Vague generalities invite suspicion and undermine trust in government. 
  6. Ensure transparency. Harris County CSD has a poor record of transparency and website updates. Create a dashboard that publicly displays:
    • Encumbrances
    • Spending to date on every project
    • Who gets how much money, when, for what
    • Each project’s progress 
    • Monthly updates
  7. The MOD should include guarantees that the county will meet performance deadlines. Because of the 20 months already squandered since the County became aware of the $750 million, I question the county’s ability to spend the money by HUD’s deadline.

Thank you for considering these thoughts.

Don’t forget to add your contact information so Community Services can tell the General Land Office and HUD where the comment came from.

More Information

The GLO has emphasized the need for Harris County to act quickly. Flood Control has projects already defined that need money. HUD will take the money back if local authorities can’t spend the money within deadlines. So hurry. These projects take a long time. HCFCD has already defined projects in the flood bond. We can’t afford the time to start from scratch to figure out the distribution of $750 million in HUD Flood-Mitigation funds.

For more supporting information, including charts and graphs that you can use to create a custom letter, click here.

Posted by Bob Rehak on 2/20/23

2001 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.

$750 Million MOD Going to GLO

Correction: since posting this, I have learned that Community Services has not even started compiling a list of projects that will comprise the Method of Distribution. The department has only defined a “process” for compiling the list and is waiting for “direction from leadership.”

On September 8th, the Harris County Community Services Department (CSD) distributed a schedule showing that it would complete the first draft of its Method of Distribution (MOD) for spending $750 million in mitigation funding by the end of the month.

The Texas General Land Office (GLO) and U.S. Department of Housing and Urban Development (HUD) allocated the money to Harris County earlier last year. The draft MOD will now hopefully go to the GLO for review and approval by the end of October.

What MOD Entails

Early last year, the GLO allocated the money to Harris County along with another $450 million to the Houston-Galveston Area Council.

A MOD lists projects and amounts. It shows how Harris County wants to distribute the money, i.e., who will get how much for what from the $750 million.

will this get any of the $750 million in CDBG-MIT funds from the GLO?
US 59 at Townsen Boulevard during Hurricane Harvey

The GLO must verify that all planned expenditures meet requirements of the funding allocated by HUD and Congress.

MOD Developed With Public Input

Harris County CSD held online and in-person meetings to share information with the public. English-language meetings were held on August 17th,  25th, and 31st. CSD also held a Spanish meeting on September 1st. They then gathered written and oral comments from the public. (The deadline to submit comments has passed.)

Next Steps

After a public planning meeting on September 8th, CSD spent the rest of September developing a draft Method of Distribution (MOD) for the $750 million. The department will now submit it to the GLO for review and preliminary approval. Steps after that include:

  • Publish Draft MOD by October 30
  • Nov 15-Dec 2 – 15-day public comment Period and hearing
  • Contract entities included in the MOD with funding level and gain confirmation of participation via Funding Acknowledgement Letter from entity
  • Dec 5-7 – Document Responses to Public Comment, add to Draft MOD document
  • December or January- Draft MOD document approved at Commissioners Court
  • January 2023 – Final MOD document submitted to GLO
  • GLO approval of final MOD and MOD allocated entities complete project information package process
  • March/April 2023 – MOD Entity project information packets submitted to GLO for review and approval
  • Kick-off contract development for projects.

So, the GLO has until the end of the month to review and approve the draft MOD. Once approved, CSD can publish it. Then CSD will hold more public meetings and submit any revisions to Commissioners Court and the GLO for final approval.

Pressure On to Develop Projects Quickly

Expect projects to begin sometime in the second quarter of 2023. But keep in mind that all dates are subject to change.

Starting to develop projects almost six years after Harvey will put some pressure on Harris County Flood Control and any other entities designated as recipients.

  • 50% of the grant must be expended by Jan. 12, 2027.
  • 100% must be expended by January 12, 2032 – 15 years after Harvey

Half of the $750 million must be spent within four years. To put that in perspective, Flood Control estimates it’s only 23.5% done with a 10-year flood-bond package four years after it was approved by voters.

Posted by Bob Rehak on 10/1/2022

1859 Days since Hurricane Harvey