On October 23, 2018, the President signed Senate Bill No. 3021, America’s Water Infrastructure Act of 2018, into law (Public Law 115-270).  The law, also known as the Water Resources Development Act (WRDA) of 2018, includes some interesting provisions that I will highlight in this post.

The Sense of Congress

The first provision reaffirms that Congress would like to pass a water resources development bill each time they meet. The first WRDA was passed in 1974 and in the 1980’s and 1990’s new legislation was passed almost every two years.  Between 2000 and 2014 the pace of reauthorizations slowed. The passage of the 2018 reauthorization sets Congress back on the every-two-years pace, with bills passed in 2014, 2016, and 2018.

Move Civil Works to Another Agency?

The law requires the U.S. Army Corps of Engineers (USACE) to hire the National Academy of Sciences to conduct a two-year study on:

The ability of the Corps of Engineers to carry out its statutory missions and responsibilities, and the potential effects of transferring the functions (including regulatory obligations), personnel, assets, and civilian staff responsibilities of the Secretary relating to civil works from the Department of Defense to a new or existing agency or subagency of the Federal Government, including how such a transfer might affect the Federal Government’s ability to meet the current statutory missions and responsibilities of the Corps of Engineers; and,

Improving the Corps of Engineers’ project delivery processes, including recommendations for such improvements, taking into account factors including: the effect of the annual appropriations process on the ability of the Corps of Engineers to efficiently secure and carry out contracts for water resources development projects and perform regulatory obligations; the effect that the current Corps of Engineers leadership and geographic structure at the division and district levels has on its ability to carry out its missions in a cost-effective manner; and the effect of the frequency of rotations of senior leaders of the Corps of Engineers and how such frequency affects the function of the district.

Economic Analysis Methods

The statute also requires the USACE to hire the National Academy of Sciences also to:

carry out a study on the economic principles and analytical methodologies currently used by or applied to the Corps of Engineers to formulate, evaluate, and budget for water resources development projects; and, make recommendations to Congress on potential changes to such principles and methodologies to improve transparency, return on Federal investment, cost savings, and prioritization, in the formulation, evaluation, and budgeting of such projects.

Transparency and Stakeholder Engagement

The law requires USACE to enhance transparency and information exchange. The USACE must issue project proposal guidance for non-Federal project sponsors, assist non-Federal interests with researching and identifying USACE project authorizations and decision-making documents. The law also strengthens stakeholder engagement.

Texas Projects

As for projects in Texas, the law:

• Authorizes a navigation feasibility study of the Trinity River and Tributaries near Liberty, Texas, as defined in the USACE 2017 and 2018 reports to Congress;
• Authorizes a flood risk management feasibility study associated with West Cell Levee, Irving, Texas, as defined in the USACE 2017 and 2018 reports to Congress;
• Directs the USACE to “expedite the completion of studies for flood damage reduction, hurricane and storm damage reduction, and ecosystem restoration in the coastal areas of Texas that are identified in the interim report due to be published in 2018 that describes the tentatively selected plan developed in accordance with section 4091 of the Water Resources Development Act of 2007;”
• Directs USACE to prepare a report on the status of the implementation of a water supply contract at Wright Patman Lake, Texas; and,
• Directs USACE to “expeditiously carry out any project for flood risk management or hurricane and storm damage risk reduction authorized as of the date of enactment of this Act to be carried out by the Secretary in Texas, Florida, Georgia, Louisiana, South Carolina, the Commonwealth of Puerto Rico, or the United States Virgin Islands.”

Please note that “authorizations” in federal law, just provide direction and permission to take action, but without any funding.  In federal water resources programs, Congress must then decide to “appropriate” funding to actually complete authorized projects.

Did you notice anything interesting in this year’s WRDA? Leave a comment if you did.

Oh, and Happy Halloween!

Someone recently asked me if I could estimate the financial impacts to the Houston area from the release of Atlas 14, Volume 11, Version 2.0. The short answer is no, but I can write a blog post with a rough qualitative and directional assessment of impacts!

Flood damage reduction infrastructure will need to be bigger to achieve the 1% annual chance risk level we have generally settled upon. This will mean that pipes or structures that carry the runoff that is generated from the 1% annual chance, 24-hour rainfall will be larger. Thankfully pipes, culverts, and earthen ditches don’t increase in cost linearly with their carrying capacity, but they do tend to get more pricey as they get bigger.

As you drive around the Houston/Harris County region you might sometimes notice concrete “notches” in the banks of some of the bayous or “flumes” that connect the bayou to a detention basin.  You might also see the same type of structure in smaller detention basins in and around neighborhoods.  Those structures allow the runoff from larger storm events to flow to or from the bayou and the channel with less chance of erosional damage.  Because they often are designed to carry the runoff from larger storms, they will be larger if they are designed to carry the flow arising from the updated rainfall stats. Here’s a screenshot of one of these structures from Google Maps:

Pipes that carry smaller storms may not increase in size that much or at all, because the Atlas 14 information did not change the smaller, more frequent rain event depths that much. For example, the 50% annual chance, 24-hour event reported for the center of Harris County near Houston in “Technical Paper No. 40: Rainfall Frequency Atlas of the United States, For Durations From 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years” (affectionately known as “TP-40”) (1961) is somewhere in the 5.1 to 5.2 range on the national scale map (screenshot below) and the same event in Atlas 14 is reported as 5.11 inches; so they are pretty close.  This means that the smaller neighborhood storm sewer pipes that are designed to carry runoff from these frequent, smaller events, might be able to stay the same size and, therefore, cost about the same.

One of my co-workers evaluated a hypothetical 160-acre green-field development site to see if detention ponds would need to be larger as a result of the initial draft release of Atlas 14, using a storm event depth of 17.7 inches in 24 hours. The evaluation showed that both the pre-development and the post-development flows increase, so the difference was not large enough to exceed the applicable regulatory minimum detention rates of 0.50 acre-feet or 0.65 acre-feet (Houston and Harris County). The results of this evaluation are shown below.

This suggests that most detention basins will still be sized to provide between 0.5 and 0.65 acre-feet per acre of development because most local governments won’t let folks install smaller ones.  This will have to be evaluated for more sites to be sure, but that’s what we saw for the one site we evaluated.

Regulatory floodplains will be remapped over the next three to four years using the more accurate rainfall depths. Harris County Flood Control District is already moving forward with this work.  This will enlarge them and more existing structures will then be located in the regulatory floodplain. This will increase the cost of insurance premiums to obtain coverage for many buildings and facilities. Approximately 37% of the county is inside one of the regulatory floodplains defined by the National Flood Insurance Program (NFIP). These include areas that have greater than a 1% annual chance riverine flooding, greater than 0.2% annual chance of riverine flooding, or greater than a 1% annual chance of coastal flooding.  The updated rainfall data will increase the area of the county that is in a regulatory floodplain by some amount.

Based on the elements above, it appears that the financial impact of the publication of the rainfall statistics update will be less significant than the financial impact of the floodplain map updates coming in a few years.

If you have other thoughts about cost or financial impacts, please leave a comment.

On September 27, 2018 Version 2.0 of the National Oceanic and Atmospheric Administration’s Atlas 14, Volume 11 was released and a press conference was held. As I’ve described in previous posts, Volume 11 provides us with a more accurate picture of the annual probability of rainfall of various depths and durations across the state of Texas.  These data were last updated across the entire state in 1961.  Volume 11 was created by evaluating rainfall records as early as the 1870’s up through 2017.

As I written previously, the depth of 1% annual chance, 24-hour rainfall is a key design storm we use for drainage and flood risk reduction infrastructure in the Harris County area.  Prior to Volume 11, this key design storm was about 12.4-inches in western Harris County and about 13.5-inches in southeastern Harris County, as shown below.

After Volume 11’s release the new 1% annual chance, 24-hour duration rainfall map for Harris County looks like this:

We used to believe that the 1% annual chance, 24-hour storm was 2.6-inches to 4.5-inches smaller than it actually is. This was because the rainfall records did not span as long a period as they do now. Our uncertainty bands have gotten a bit narrower and the overall magnitude of most storm frequencies and durations have increased.  The actual depth of the 100-year, 24-hour duration rainfall ranges from 21% to 33% higher than we thought.

The updated information is presented by NOAA using a web-based map interface, located here: https://hdsc.nws.noaa.gov/hdsc/pfds/pfds_map_cont.html. It allows anyone to double click on the map at any point of interest and instantly get both a tabular and graphical display of the rainfall stats.

Here’s how it works for my neighborhood in west Houston.

This first image is from the map interface. I have zoomed into my part of town and have double-clicked on the map near my house. The red cross-hairs show the click point.

After double-clicking the following information appears below the map:

This shows that my house has a 1% annual chance of receiving 16.5 inches (or more) of rain in 24-hours.  If you read the fine print you will see that there is a 90% chance that the actual rainfall depth for this 1% annual chance, 24-hour storm ranges will be somewhere between 11.6 inches and 23.5 inches, because of the uncertainty of our statistical estimate.  The website also provides a graphic version of the same data:

The website also provides a graph that illustrates the confidence bands around the estimated rainfall depth. The figure below shows confidence range for all 24-hour storms.  The green line shows the upper limit of the 24-hour rainfall depth and the red line shows the lower limit. There is 90% chance that the “true” rainfall depth will fall in between those values (for any given recurrence interval).  Please recall that “recurrence interval” is the inverse of annual probability.  So the 1,000-year storm has a 1/1,000% chance of occurring in any given year.  If you convert the fraction to a decimal, that’s a 0.001% annual chance. Notice how that is not zero?

See how the confidence range grows for the larger, more rare events?  The 100-year recurrence interval corresponds to the 1% annual chance event. The math tells us that there is 90% chance that the 1% annual chance, 24-hour event is somewhere between 11.6 inches and 23.5 inches. The corollary is there is 10% chance that the real depth is outside that range.

The expanding confidence interval – the gap between the green line and red line – makes sense because we have statistically evaluated rainfall records that only go back to, at best the 1870s, and, at worst 1970’s.  This is a period of record of only between 47 and 148 years.  So our certainty about 500-year or 1,000-year recurrence interval events is low.

In my next post I will be providing some thoughts about the cost impacts of this refined view of our rainfall statistics.

On September 2, 2018, the Houston Chronicle published “Remember the Villains of Hurricane Harvey” as their lead editorial. The byline was listed simply as “The Editorial Board.”  The editorial board is currently composed of the following people (just in case you wondered):

• John McKeon, Publisher.
• Jack Sweeney, Chairman.
• Lisa Falkenberg, Opinion Editor.
• Evan Mintz, Deputy Opinion Editor.
• Jim Newkirk, Outlook Editor.
• Andrea Georgsson, Sunday Outlook Editor.
• Harold Jackson, Editorial Writer.
• Andrea White, Editorial Writer.

STAR WARS meme prepared by m. bloom paraphrasing the lead editorial only slightly.

The editorial called for Houstonians to remember villainous developers “who saw nothing wrong with building neighborhoods inside the flood pools behind Addicks and Barker reservoirs, and then kept the risks to themselves.”

First, some definitions of the word “villain,” to place the editorial in the proper context:

Dictionary.com: Villain: (1) a cruelly malicious person who is involved in or devoted to wickedness or crime; scoundrel; (2) a character in a play, novel, or the like, who constitutes an important evil agency in the plot.

Merriam-Webster: Villain: (1) a character in a story or play who opposes the hero; (2) a deliberate scoundrel or criminal; (3) one blamed for a particular evil or difficulty. 

Cambridge: Villain (1) a bad person who harms other people or breaks the law; (2) a cruel or evil character in a book, play, or film.

Let’s break this down one bit at a time.

The developers (and the professional engineers who designed their developments) invested private capital to provide affordable housing on privately-owned land, with an annual risk of flooding of much less than 1%, which is the consensus standard used by all communities in the United States to design and locate new homes and other structures.  Engineers designed streets, lights, traffic controls, water systems, wastewater systems, and drainage facilities that functioned perfectly from the day they were built until Harvey arrived.

I believe that the engineers designing these neighborhoods did so in compliance with Sections 137.51 through 137.55 of the rules promulgated by the Texas Board of Professional Engineers under the legal authority of the Texas Engineering Practice Act.  These rules require engineers “to safeguard, life, health and property, to promote the public welfare” as well as “to protect the health, safety, property, and welfare of the public.” Please note that this rule does not require engineers to design neighborhoods with zero risk of flooding.

Why do I believe that the developers and engineers acted ethically and appropriately? Simply because the health, safety, property, and welfare of the residents were safeguarded.

Because the potable water provided to the residents was clean and healthy every day until Harvey arrived. Ever try to raise a family without potable water?

Because sanitary wastewater was collected from every home, treated, and properly discharged into nearby bayous every day until Harvey arrived.  Ever try to live in a home without a toilet or proper wastewater facilities?

Because none of the homes fell down on their owners every day until Harvey arrived and even during Harvey.

Because the roads carried traffic every day until Harvey arrived. What if there were no roads? Because the traffic lights and street lights worked every day until Harvey arrived. What if there were no lights?

Because rainwater from storm after storm was carried downstream from the developments without flooding anyone every day until Harvey arrived.  Because the systems worked.

All of these critical public health, safety, and welfare facilities were designed by ethical engineers with private funding from developers. All of the facilities and homes were made possible by the developers who invested private capital to create desirable places for people to live with a low and acceptable level of risk.

We’ve already decided to push our inundation risk exposure down for new construction in the City of Houston and Harris County to significantly less than 0.2% per year. Note that a finished floor elevation placed 2 feet higher than the 500-year flood elevation has an annual chance of inundation of much less than 0.2% per year in most places in this region.

But, if we collectively wish to retrofit existing homes and businesses in our region that are exposed to higher annual risk levels than 0.2% or 1% (think Hunting, White Oak, Brays – but certainly not neighborhoods in the Addicks or Barker flood pools) we need to have an open conversation about the desired risk level, the costs to achieve it, and the benefits realized.

We should avoid villainizing folks that built communities and facilities that worked and that beat the desired risk levels established at the time those facilities were built.

The villains pictured below are not developers.

A still from the silent comedy, Barney Oldfield’s Race for a Life MACK SENNETT/PUBLIC DOMAIN

On August 24, 2018, the Texas General Land Office released a new report entitled “Hurrican Harvey: Texas at Risk” the presents lessons learned, recommends policy changes, and administrative actions, mostly around housing.  This post will highlight the key recommendations included in the report.

The following recommendations are directly from the report’s Executive Summary (bold text added by me).

1. The State of Texas should create a Business Advisory Council on Disaster Recovery and Mitigation to access private business expertise and as a conduit for problems they have in disaster recovery. The Council would not have the authority to spend money or write regulations but would provide much-needed private sector advice and expertise.
2. The Texas Water Development Board’s statutory authority should be substantially expanded to cover flood control and have directive control over the state River Authorities in carrying out these duties. The same Board should have directive control over drainage districts to ensure they are keeping drainage ditches and waterways in a continuous state of repair.
3. The State of Texas should establish a permanent disaster recovery training center for local government officials focused on recovery, disaster fortification, and resilience.
4. The state legislature should establish by state statute a Regional Building Code District (RBCD) with standard-setting authority in the high-risk hurricane region of Southeast Texas which would replace the existing weak and uneven building code system. The Commission would have oversight over building codes in the RBCD which will be composed of the following ten Councils of Government or regional planning areas: Lower Rio Grande Valley, Coastal Bend, Golden Crescent Regional Planning Commission, Houston-Galveston Area, Central Texas, Alamo Area, Brazos Valley, Capital Area, Deep East Texas, and South East Texas. These are the areas historically most at risk of hurricane flooding and wind damage.
5. The state should fund at least 75% of the salary costs of building code enforcement (local inspectors and third-party contractors working for cities and counties) with 25% funded by building permit fees in this new Regional Building Code District. The same capacity strengthening salary program should be extended by the State of Texas for city and county recovery managers.
6. This report recommends that a large reserve account be established using federal funding initially before the next hurricane season later funded by state, city, and county resources to accelerate the existing housing buyback programs for homes which repeatedly flood. Counties and cities participating in these programs would then take the homes out of use and the property used for green space. This fund would be used in the weeks following a hurricane or flooding event before private companies purchase the properties that have a repeated history of flooding. The state legislature should also require rental units or houses for purchase which have repeatedly flooded to disclose this in rental or purchase documents and title registrations.
7. This report endorses the efforts of city and regional planning groups in Texas buying land at market prices without the use of eminent domain to reduce the risk of flooding and preserve reservoir water recharge. This report recommends the state legislature create a commission to study this land purchase program and report on what might be done by the state to support these efforts in the future.
8. Texas should continue to support private philanthropic programs after major disaster and develop a system to integrate public and private sector efforts to help survivors of natural disasters without endangering the independence of the private social service groups.
9. The GLO should implement a saturation Public Information Campaign before and during every hurricane season to ensure the local officials and the public understands what FEMA’s temporary housing programs will provide and what it will not provide under existing federal law in the event of a major hurricane or flooding event.
10. The federal government should consolidate funding for all temporary FEMA housing programs into one block grant to states with a high risk of natural disasters.
11. The GLO should bid out indefinite quantity contracts (IQCs) for information management, construction, and other engineering construction services under the Federal Acquisition Regulation (FAR) procedures before the annual hurricane season each year, so contracts are in place to be used within a week of a major disaster.
12. Congress should grant “notwithstanding authority” to those high disaster risk states which have demonstrated competency in disaster response and recovery for one year following a major disaster. This would allow the waiver of most federal procedural regulations and speed contracting and program management.
13. Congress should expand the definition of what is eligible for reconstruction using FEMA temporary housing funds under the Stafford Act so that damaged housing can be rebuilt to be more resilient and fortified to withstand disasters in the future. In the absence of the phase-out of recreational vehicles and mobile housing units by FEMA, the state legislature should give the Governor the authority to waive city and county prohibitions of their use for one year after a Presidential disaster declaration.
14. Should the federal government expand the definition of what is permissible for reconstruction funding within FEMA programs, the GLO should investigate and consider using new technologies for housing construction which are less expensive, more resilient, and can be implemented faster than traditional housing construction techniques.
15. Congress should enact legislation to consolidate disaster housing programs of FEMA, HUD, and the SBA into one agency or department to eliminate competing missions and business systems which slow down the temporary housing response.
16. Congress should amend the privacy act to give state and local officials managing disaster response and recovery efforts full access to survivor information generated by FEMA if they have applied for and are qualified for assistance. An integrated database should be built from the beginning with full access by state and local recovery and housing response administrators. In the absence of such a change in law, we urge FEMA to amend their benefits application form to allow
    people to voluntarily make their data available to state and local government agencies in order to provide them services.
17. HUD should rewrite the formula for the allocation of funding to municipal and county governments directing aid to low and moderate-income people so that all people in these categories are assisted.
18. This report endorses acceleration of the studies needed to advance the Texas Coastal Barrier System and Upper Texas Coastal Levee system, and the funding of these projects by the U.S. government.

I’ll post a little narrative summary of the findings at some point, but here is the slide deck I presented on August 13, 2018, in Nashville at the International Low Impact Development Conference, hosted by the Environmental & Water Resources Institute of the American Society of Civil Engineers.

Birnamwood Drive Results Presentation (2018)

I was saddened to see the videos and read the news stories about the flooding and landslides which occurred in Japan over the past several days.

Photo: Baltimore Sun

As of this writing, more than 179 people have been confirmed killed and 8 million people have been ordered to evacuate their homes.

Photo: Toronto Star

The flooding in Japan illustrates that Houston is not alone in dealing with flood risk. The news prompted me to do some research into the situation in Japan. This post provides some additional information about flood risk management and hydrology in Japan.

The first important difference between Japan and Houston is topography.  The rivers in Japan are very steep and convey water with high velocities.  The graphic below, which I adapted from a figure in an un-dated publication of the Network of Asian River Basin Organizations (NARBO) called “Flood Management in Japan,” illustrates the river profiles (horizontal distance and vertical fall) for selected rivers in Japan (blue) and some selected rivers in other countries (green).

When Dutch engineer Johannis de Rijke saw the Jōganji River in Toyama Prefecture (the steepest one shown above – to the far left) he famously said: “this is not a river [its] a waterfall.”

The topography in Houston is very, very flat. I added the approximate profile of Buffalo Bayou from the Barker Dam to Upper Galveston Bay in pink.

Flood risk literature generally reports that about 5% to 14% of the population of the United States lives in a mapped flood risk zone (1% annual chance).  In Japan, due to the steep, mountainous terrain, the populated areas are located in the flatter, alluvial plains between mountains and towards the mouths of most rivers.  The publication referenced above indicates that 50% of the Japanese population are located in these alluvial plains. I was not able to locate flood risk mapping products indicating what annual chance risk exposure they have.

I was able to locate information about rainfall statistics. A paper from 2017 by Sugi, et. al. used a statistical method called “extended regional frequency analysis” (ERFA) to evaluate three sets of rainfall data to estimate the depth of the 1% annual chance, 24-hour storm. This method is similar to the Atlas 14 project approach I’ve posted about on September 27, 2017, November 20, 2017, November 24, 2017, December 7, 2017, and February 21, 2018.  The three sets of rainfall data they evaluated were:

• Actual rainfall observations from 1979 to 2006, across a wide (regional) geographical area;
• Modeled rainfall observations using ocean temperatures, atmospheric carbon dioxide concentrations, and atmospheric aerosol concentrations from 1979 to 2003, across the same wide geographical area; and,
• Modeled rainfall observations using ocean temperatures, atmospheric carbon dioxide concentrations, and atmospheric aerosol concentrations predicted from the IPCC RCP8.5 scenario for 2075 to 2099, across the same wide geographical area. The RCP8.5 is a “worst case” simulation of unrestricted carbon emissions.

The results of these evaluations are presented below in a graphic that I adapted from the paper.

The key takeaways:

• Some of the inland, higher elevation areas of Japan have a less than 1% annual chance of getting 10 or more inches of rain in 24-hours.
• Some coastal areas in the south have a 1% annual chance of seeing 24 inches or more of rain in 24-hours. Compare that to Houston’s current 1% annual chance, 24-hour rain depth of about 13.5 inches.
• Climate change is projected to expand the areas with a 1% annual chance of seeing 24 inches of rain, or more in 24-hours.

Now let’s compare these data to what happened in Japan on July 6, 2018. Much like our own Harris County Flood Control District “Flood Warning System” gauge network (with 163 gauges), the Japan Meteorological Agency (JMA) operates a network of 160 rain gauges and 20 Doppler radar stations across Japan. On July 6, 2018, the JMA recorded rainfall depths up to 15 inches in 24-hours in specific locations and over 7 or 8 inches of rain over widespread areas of southern Japan. The graphic below was adapted from JMA historical data maps obtained from their data web page.

The gauge locations with the black diagonal line and box indicate new 24-hour rainfall depth total records for that gauge location.

So the high rainfall totals coupled with the steep terrain and people and infrastructure located in the alluvial plains all combined to lead to the loss of life and infrastructure damage.

There quite a buzz these days about significant private investment flowing into cities to build green stormwater infrastructure. It is a noteworthy trend, and after Harvey, more than one group has asked me about how they might help make that happen in Houston.

The question is why is this happening in other places and not so much in Houston?  What makes a private equity firm or an institutional investor jump at the chance to finance some green public infrastructure projects?

To be clear, this is different than private philanthropists making grants to Houston area projects, like the Bayou Greenway, the Museum of Fine Arts, Discovery Green, or Memorial Park. Those are pure gifts where the grantor does not expect to be paid back.

This post is about private investors lending money for green stormwater projects, getting paid back, and earning a reasonable amount of interest on their money.

PHOTO CREDIT: Organisation for Economic Co-operation and Development

Some recent examples are illustrative:

1. District of Columbia Water and Sewer Authority (DC Water) Environmental Impact Bond: In 2016, Goldman Sachs and the Calvert Foundation announced that they would purchase the first environmental impact bond (EIB) issued in America to fund the construction of $25 million of green stormwater infrastructure (GSI) in the Rock Creek sewershed. DC Water agreed to build GSI in public rights of way, with investor oversight through their independent technical agents. The GSI performance risk will be shared by DC Water and the investors. Everything depends upon the volume of stormwater runoff reduction achieved. If runoff volume reductions are higher than forecast, DC Water will pay a 13.2% premium to investors. If runoff volume reductions are lower than forecast investors will pay a 13.2% risk-sharing payment to DC Water, and if runoff volumes are in expected ranges than no contingency payment will be made and the bond will be paid back at the nominal 3.43% discount rate.
2. Maryland’s Prince George’s County “First of its Kind” Public-Private-Partnership:  In March 2015, Corvias and the county signed a $100 million, 30-year partnership contract with great fanfare. Their “Clean Water Partnership” was created to assist the county to achieve federally mandated reductions in pollutant discharges in urban stormwater runoff to the Chesapeake Bay. The county will use its own traditional design-bid-build approach to deliver green stormwater retrofits on 2,000 acres of publicly owned land while Corvias will be responsible for delivering an additional 2,000 acres. This will allow a direct comparison of the speed, effectiveness, and overall costs of using both delivery methods.  The combined effort will achieve 50% of the federally mandated retrofit requirement of 8,000 acres, with the balance of the work to be completed later using the winning process. These details are from the program FAQ.
3. City of Baltimore and the Chesapeake Bay Foundation “Pay for Success” Model: In March 2018, the City of Baltimore, Quantified Ventures, and CBF announced that they will work together to create innovative Environmental Impact Bonds (EIB) to help pay for more than 90 green stormwater retrofit projects in the city. Baltimore will issue up to $6.2 million worth of EIB financing. The proceeds will be used to implement the retrofit projects and the repayment of the bonds would be based on the effectiveness of the projects.  The city is under a federal mandate to reduce the volume and pollutant loads of water flowing to the Chesapeake Bay.

All of these examples of private investment in green stormwater systems are successful because the private investors have a high degree of confidence that the revenue stream will continue and that they will be paid back, with interest.  The investors have a high confidence level because in all of these examples the green stormwater projects MUST be built because of regulatory mandate that is memorialized in a consent decree issued by a federal court.  This provides a much higher level of funding certainty than the normal annual political budgeting process that most municipal governments undertake.

The future revenue stream in the DC Water example is driven by a court-ordered mandate to mitigate combined sewer overflows. DC Water MUST reduce runoff volumes. Prince George’s County is subject to a settlement agreement stemming from a federal lawsuit over the Chesapeake Bay restoration, therefore, that revenue stream is all but certain. Baltimore also is subject to the terms and conditions of a federal combined sewer overflow mitigation consent order.

Does this revenue certainty exist in Houston?

In a word: no.

The ballot language for the city’s celebrated “lock-box” for streets and drainage that was producing about $400 million each year – known as “Rebuild Houston” – was defeated in court and now must be reaffirmed by voters in November 2018. The result of that election is not certain. Even if that election was a “sure thing,” the appropriation of funding to any particular green stormwater project, or set of projects, is still subject to the political process and, frankly, bureaucratic resistance to change.

The city is not subject to any type of stormwater quality mandate, other than to comply with its stormwater quality permit, which imposes only narrative provisions that don’t drive the construction of public green infrastructure projects.

The city also (thankfully) does not have a combined sewer system and, therefore, the city does not have any mandated need to invest in combined sewer overflow mitigation projects using green stormwater infrastructure.

So the challenge for Houston is this: Can we create a business model that produces a reasonable return on investment for green stormwater infrastructure project financing?

On June 21, 2018, Zurich Insurance Group released a new report called “Houston and Hurricane Harvey: A Call to Action.”  Prepared by The Institute for Social and Environmental Transition–International (ISET-International), the American Red Cross Global Disaster Preparedness Center, and the Zurich Insurance Group, the report includes a five-page executive summary along with sections summarizing hurricane event statistics, why Houston is so flood-prone, various methods of risk reduction, information about the region’s initial response and recovery, priorities and gaps in long-term recovery and resilience, lessons learned, and specific recommendations.

The report includes recommendations that relate to the social and cultural aspects of resilience that I thought were noteworthy. Regular readers know I normally discuss engineering or regulatory issues.

Buy Flood Insurance

The report calls for efforts to “make flood insurance more universally appealing for homeowners and businesses.” The report suggests that our communities should undertake “awareness campaigns” to increase the demand for flood insurance – even in lower risk areas, outside of the regulatory floodplain, where insurance is relatively inexpensive – to enable policyholders to recover more quickly and to thus be more resilient.  [A higher number of lower risk policyholders would also help with the ongoing fiscal defects in the National Flood Insurance Program.]

The term “appealing” is an interesting word choice – I’m not sure we could ever make buying insurance appealing, but maybe? There are probably some smart social scientists and public relations firms that could use the power “social norms” to increase the number of flood insurance policies purchased in this region, but that effort would need to be nearly continuous to influence all of the new people moving here each month.

I snapped a photo of this poster in the tunnel just outside 611 Walker, home of Houston Public Works, in July of 2017, before Hurricane Harvey:

This is at least one example of local communities making some effort to encourage citizens to purchase insurance. The report indicates that Harris County Flood Control District is planning to promote insurance coverage with a billboard campaign (p. 38).

Culture of Awareness

The report also calls for us to “build a culture of awareness around risk” and to “incentivize incremental small decisions by residents and businesses that collectively reduce exposure and risk…to reduce the surprise element of flooding.”  The report suggests installing public markers indicating previous flood inundation levels and road signs indicating that “You Have Entered a Flood Control Reservoir,” and similar measures (p. 40).  I’m not sure that this type of information disclosure would be embraced by the larger community.  According to Jim Blackburn, inundation level signs were installed in at least one Galveston Bay area neighborhood that is subject to storm surge; but the signs were removed after about 30 days due to complaints from realtors (see time-stamp 26-minutes, 50-seconds in this video).

The report suggest that the Houston region, like Galveston, “wear its [flood] battle scars with pride.” The authors suggest that homes that flooded should be encouraged to “mount a plaque … proclaiming: ‘This home survived Harvey; the water was x feet deep.’ ”

Business Continuity Plans

The report acknowledges that “even the best … grey infrastructure [and] green solutions … will never reduce flood risk to zero” and it goes on to encourage the development of business continuity plans and household level preparedness plans to help further reduce risks. The report includes a good overview of the key elements of a business continuity plan – which is intended to increase the likelihood that a business might stay in operation throughout a disaster or at least, get back to full operation more quickly. The main elements are:

1. Identify Key Assets: For a consulting firm, it might be ensuring that employees have continued remote access to all files and intellectual property. For a coffee shop, this might mean protecting the espresso machine.
2. Consider Preparedness as Business as Usual:  Incorporate a “disaster day” into the regular schedule of work. Run drills or practice days on a routine basis.
3. Implement Infrastructure Solutions: Install floodgates. Store documents and materials at a protected location. Relocate items after receiving notification.
4. Use Existing Assets: Use security systems to track and evaluate conditions in inaccessible work locations.
5. Assist with Employee Preparedness: Household preparedness plans help business employees return to work more quickly.  A robust communication system is needed to allow the business employer and employees to communicate updates to each other. Employers can prompt employee action with a series of awareness questions related to supplies, backup power, and backup lodging plans.
6. Purchase Insurance: Businesses should obtain insurance. They should consider the full range of options available after speaking with experts. Costs should be evaluated against the full cost of both damages and lost revenue during an extended closure.
7. Support Employees and Community with Recovery: Businesses should support both employees and the larger community with recovery. This might include providing equipment, foods, access to showers or facilities, assistance with clean out / muck out work, and offering paid time off for employee victims.

Recovery Priorities

The report provides an almost accurate picture of our current priorities. It correctly notes that Houston and Harris County both strengthened their floodplain regulations. It indicates that buyouts are underway, but are taking too long and are underfunded. It notes that we are having lots of discussion about a third reservoir to address the Cypress Creek overflow, but it does not fully acknowledge how that project was proposed to mitigate future development and not necessarily to reduce flood risks for downstream properties. The report points out the general lack of state funding for recovery, especially from the state’s “rainy day fund.” ($150 million has been provided for debris removal and to avoid a property tax hike.) The report accurately indicates how recovery support has been distributed inequitably. The report suggests that we are not talking about general drainage infrastructure improvements and maintenance.  I think this was likely just due to the timing of the report; they must have gone to press before the authors heard the announcement of the $2.5 billion Harris County Flood Control District Bond Election scheduled for August 25th and the placement of a reauthorization of the Rebuild Houston program back on the ballot this November.

Overall, the report is a good addition to the growing list of post-Harvey literature and studies. Worth a read.

The Urban Resilience Program of the Urban Land Institute (ULI) just published “Ten Principles for Building Resilience,” with funding from The Kresge Foundation and The New York Community Trust.

The report emerged from a workshop of ULI members who had previously participated in volunteer, pro-bono, group consulting assignments (called advisory panels) to help various communities with resiliency questions or challenges. Workshop participants included a multi-disciplinary group from around the country.

The publication provides the following ten principles:

1. Understand Vulnerabilities
2. Strengthen Job and Housing Opportunities
3. Promote Equity
4. Leverage (Existing) Community Assets
5. Redefine How and Where to Build
6. Build the Business Case (for Resilience)
7. Accurately Price the Cost of Inaction
8. Design with Natural Systems
9. Maximize Co-Benefits
10. Harness Innovation and Technology

It also includes a good definition of resilience, which states that resilience is:

the ability to prepare and plan for, absorb, recover
from, and more successfully adapt to adverse events.

When I read this definition my big take away was this: this definition acknowledges that some future adverse event WILL happen.  This definition does not shy away from the reality that we can’t reduce the risk of a future adverse event occurring to zero.

The graph below illustrates this point.  The horizontal axis is the amount of time you are willing to wait to see if a rare event will occur.  The vertical axis is the probability of that rare event occurring over during that time duration.  Each colored line indicates the annual chance of the adverse event occurring.

This graph illustrates that if the finished floor of the living room of your house is 1-inch below the 100-year floodplain water elevation (which has a 1% annual chance of happening – the red line) you have a 26% chance of having 1-inch of water in your home during a 30-year mortgage period.  If you read the horizontal axis of the graph over to the 30-year duration mark (the second line to the right of the 10-year mark on this log scale), you will see it intersects the red line at exactly 26% on the left axis.

I support resiliency planning and thinking about our response to Harvey and other adverse events as a risk reduction effort and as a process to reduce the negative outcomes. This approach is much better than the old-school thinking that suggests that we can use engineered infrastructure to “control” nature, flooding, or other adverse events from occurring in the first place.

We can use planning, engineering, and architecture to reduce risks, to prepare for adverse events, to stage recovery efforts ahead of time, and to adapt to the eventual (certain) arrival of the next adverse event.

We can use insurance, reinsurance, and catastrophe bonds to hedge against residual risks that are not possible to eliminate.

I think I like where this is going…