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.

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.”

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