Tag Archive for: MOD

$750 Million Flood Plan Ignores Flood Risk, Public

Twenty-two months after learning it would receive $750 million from the US Dept. of Housing and Urban Development (HUD) and the Texas General Land Office (GLO) for Harvey Flood Mitigation, Harris County Commissioners finally approved a Method of Distribution (MOD) for the money on 3/14/23.

The MOD must be approved by the GLO and HUD before the county can begin spending the money. However, the plan virtually ignores flood risk and public comments.

What Happened to Flood-Risk Reduction?

The basic purpose of the HUD money, administered by GLO, is to reduce flood risk. The word “risk” appears 490 times in the MOD submission. Only one problem!

The proposed project scoring matrices never mention “risk,” at least not directly.

The plan contains one scoring matrix for Harris County Flood Control District (HCFCD) Projects and another for Partnership Projects.

HCFCD Projects

For the portion of the money going to the Harris County Flood-Control District, the MOD bases funding on:

  • LMI (Low-to-Moderate Income) Population Percentage (35 points)
  • Social Vulnerability (30 points)
  • Population (15 points)
  • Repetitive Flood Loss (20 points)

Unfortunately, giving weight to damages as opposed to risk, gives the same weight to areas that have already been mitigated as it does to areas that have not received a penny.

The MOD also says distribution of flood-control funds will be governed by the Equity Prioritization Framework (even though it doesn’t explain how). The 2022 version of that Framework gives 20% weight in scoring projects to “Existing Conditions.” Existing Conditions refer to the capacity of a channel to manage flood events of different intensities. But that’s as close as the MOD comes to addressing flood risk in project scoring.

Watersheds with a majority LMI population have roughly a billion dollars worth of uncompleted 2018 flood bond projects. With roughly a half billion of the $750 million going to HCFCD, the LMI and SVI requirements put on that portion of the money virtually guarantee that none will be left for more affluent watersheds.

So even though HUD and GLO rules allow 50% of the money to be spent in more affluent watersheds, the criteria adopted by Commissioner’s Court will likely preclude any of the money going there.

Partnership Projects

The portion of the money going to Partnership Projects has slightly different criteria. But that matrix also includes NO references to flood risk. It scores projects based on:

  • Project Readiness (20 points)
  • Percent LMI Population (25 points)
  • Project Efficiency (cost per person and building benefitted) (20 points)
  • Ancillary Benefits (environmental, economic, quality of life) (10 points)
  • Partner Contribution (25 points)

Nowhere did the plan provide direct comparisons of flood risk so that areas with the highest risk could be addressed first. Neither did the plan address flood severity. Thus, areas already mitigated that got one inch of flooding will rank as high as unmitigated areas that got 20 feet.

worst first
Chart showing feet above flood stage of 33 gages of misc. bayous in Harris County during Harvey.

Virtually No One Happy

The Harris County Community Resilience Flood Task Force submitted a letter strongly prioritizing flood-risk reduction. That got ignored as were most of the 235 pages of other public comments submitted.

Virtually no one seemed happy with the plan or the fairness of the distribution of money.

The county did not bother to respond directly to those who took the time to study the plan and submit comments. However, it did provide responses within the plan itself.

To paraphrase one of the generic responses: “Thank you for your comment. Here’s what we’re going to do. The GLO encourages regional and countywide investments in flood mitigation. But we’re prioritizing population in low income and socially vulnerable areas.”

Typical comment and response to proposed MOD. Name of commenter redacted.

Harris County has already spent $1.7 billion on flood mitigation since Harvey – the vast majority of it in LMI areas. There’s no hint of spreading the $750 million around to other areas.

Transparency Issues Also a Problem

The Harris County Community Services Department (CSD) will manage this money. But CSD has a serious transparency problem.

  • The transparency portion of its website hasn’t been updated in six months.
  • The MOD portion of the website hasn’t been updated for six weeks, even though much has changed since then.
  • Potential partners have complained about being in the dark.
  • Two weeks ago, the interim director promised to put out a call for partner projects. But the website still hasn’t announced the opportunities yet.
  • CSD still has not posted the plan approved by commissioners.

CSD’s lack of transparency was a major theme in the hundreds of pages of public comments.

What Next for Flood-Bond Projects in Outlying Areas?

With virtually all of the HUD money going to LMI areas, and with not enough money left in the flood bond to finish all the projects, Judge Lina Hidalgo and Commissioners Rodney Ellis and Adrian Garcia owe us an explanation. How do they intend to fulfill the County’s promise to voters who approved the 2018 Flood Bond thinking they would get something out of it?

Posted by Bob Rehak on 3/29/2023

2038 Days since Hurricane Harvey

$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