Texas DR-2017 Action Plan

State of Texas Plan for Disaster
Recovery: Amendment 3
Hurricane Harvey – Round 1
Published: March 21, 2019 Public

PREPARED BY
Comment Period: March 22 -
THE TEXAS GENERAL LAND OFFICE
April 20, 2019
COMMUNITY DEVELOPMENT & REVITALIZATION PROGRAM
HUD Approved: June 13, 2019
The Supplemental Appropriations for Disaster Relief Requirements, 2017

(Pub. L. 115–56), approved September 8, 2017 and Further Additional
Supplemental Appropriations for Disaster Relief Requirements Act, 2018 (Pub.
L. 115-123)
Table of Contents
1.1. Amendment 3: Summary of Changes ...................................................................................... 7
2.1. Executive Summary – State Action Plan ............................................................................... 13
2.2. Executive Summary – Harris County Local Action Plan ...................................................... 19
2.3. Executive Summary – City of Houston Local Action Plan ................................................... 21
2.4. Executive Summary – Total Allocation Budget .................................................................... 22
3.1. Needs Assessment – State Action Plan .................................................................................. 23
A. Cumulative Impact of Prior Disasters .................................................................................. 23
B. Impact of Hurricane Harvey ................................................................................................. 25
C. Resiliency Solutions and Mitigation Needs.......................................................................... 29
D. Demographic Profile of Impacted Counties ......................................................................... 31
E. Low- and Moderate-Income Analysis .................................................................................. 33
F. Social Vulnerability Index .................................................................................................... 33
G. Housing Impact .................................................................................................................... 35
1. Real Estate Market............................................................................................................. 35
2. Homelessness..................................................................................................................... 36
3. Social Services: 2-1-1 Texas Program............................................................................... 38
4. Interim Housing Assistance ............................................................................................... 41
5. Insurance ............................................................................................................................ 42
6. National Flood Insurance Program .................................................................................... 47
7. Texas Windstorm Insurance Association .......................................................................... 50
8. Small Business Assistance Disaster Home Loans ............................................................. 52
9. Public Housing Authority Data ......................................................................................... 54
10. FEMA Individual Assistance........................................................................................... 55
H. Infrastructure Impact ............................................................................................................ 65
1. Governor’s Commission to Rebuild Texas ....................................................................... 65
2. Texas Coastal Resiliency Study ........................................................................................ 66
3. FEMA Public Assistance ................................................................................................... 67
I. Economic Impact ................................................................................................................... 72
1. Employment....................................................................................................................... 72
2. Small Business Administration Business Disaster Loans ................................................. 72
3. Commercial Property Insurance ........................................................................................ 75
4. Agricultural Impacts .......................................................................................................... 76
5. Tourism .............................................................................................................................. 77
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6. Texas Economy ................................................................................................................. 77
3.2. Needs Assessment – Harris County Local Action Plan ......................................................... 79
A. Cumulative Impact of Prior Disasters .................................................................................. 79
B. Impact of Hurricane Harvey ................................................................................................. 79
C. Resiliency Solutions and Mitigation Needs.......................................................................... 81
D. Demographic Profile of Impacted Counties ......................................................................... 81
E. Low- and Moderate-Income Analysis .................................................................................. 82
F. Social Vulnerability Index .................................................................................................... 83
G. Housing Impact .................................................................................................................... 84
1. Real Estate Market............................................................................................................. 84
2. Homelessness..................................................................................................................... 88
3. Social Services: 2-1-1 Harris County Program ................................................................. 88
4. Interim Housing Assistance ............................................................................................... 90
5. Insurance ............................................................................................................................ 90
6. National Flood Insurance Program .................................................................................... 90
7. Texas Windstorm Insurance Association .......................................................................... 91
8. Small Business Assistance Disaster Home Loans ............................................................. 92
9. Public Housing Assistance Data ........................................................................................ 92
10. FEMA Individual Assistance........................................................................................... 92
11. Public Services ................................................................................................................ 96
12. Residential Buyout Program ............................................................................................ 96
13. Planning Activities .......................................................................................................... 98
H. Infrastructure Impact ............................................................................................................ 98
1. FEMA Public Assistance ................................................................................................... 99
2. Commercial Buyout ......................................................................................................... 100
3. Method of Distribution .................................................................................................... 100
I. Economic Impact ................................................................................................................. 100
J. Funding Resources............................................................................................................... 101
3.3. Needs Assessment – City of Houston Local Action Plan .................................................... 104
A. Cumulative Impact of Prior Disasters ................................................................................ 104
B. Impact of Hurricane Harvey ............................................................................................... 104
C. Demographic Profile of Impacted Counties ....................................................................... 107
D. Low- and Moderate Income Analysis ................................................................................ 109
E. Social Vulnerability Index .................................................................................................. 111
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F. Housing Impact ................................................................................................................... 113
1. Real Estate Market........................................................................................................... 113
2. Homelessness................................................................................................................... 114
3. Social Services: 2-1-1 Texas Program............................................................................. 115
4. Interim Housing Assistance ............................................................................................. 116
5. Insurance .......................................................................................................................... 116
6. National Flood Insurance Program .................................................................................. 117
7. Texas Windstorm Insurance Association ........................................................................ 117
8. Small Business Assistance Disaster Home Loans ........................................................... 118
9. Public Housing Authority Data ....................................................................................... 118
10. FEMA Individual Assistance......................................................................................... 122
11. City of Houston’s Floodplain Management Office ....................................................... 128
12. HCFCD Home Buyout Program.................................................................................... 129
13. Summary of Housing Unmet Need ............................................................................... 129
G. Infrastructure Impact .......................................................................................................... 129
1. FEMA Public Assistance ................................................................................................. 130
2. Texas Hazard Mitigation Grant Program ........................................................................ 131
3. Summary of Infrastructure Unmet Need ......................................................................... 131
H. Economic Impact ................................................................................................................ 132
1. Employment..................................................................................................................... 132
2. Small Business Administration Business Disaster Loans ............................................... 132
3. Summary of Economic Unmet Need ............................................................................... 133
4.1. General Requirements .......................................................................................................... 134
A. Rehabilitation/Reconstruction of Public Housing, Affordable Housing and other forms of
Assisted Housing ..................................................................................................................... 134
B. Housing for Vulnerable Populations .................................................................................. 135
C. Displacement of Persons and/or Entities ............................................................................ 135
D. Maximum Assistance ......................................................................................................... 136
E. Elevation Standards ............................................................................................................ 136
F. Planning and Coordination.................................................................................................. 137
G. Infrastructure Activities ...................................................................................................... 138
H. Leveraging Funds ............................................................................................................... 139
I. Protection of People and Property ....................................................................................... 139
1. Quality Construction Standards ....................................................................................... 139
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2. Housing Contractors Standards ....................................................................................... 140
J. Appeals Processes................................................................................................................ 140
K. Dam and Levee Requirements ........................................................................................... 140
L. Program Income .................................................................................................................. 141
M. Monitoring Standards ........................................................................................................ 141
N. Broadband Infrastructure.................................................................................................... 141
O. Disaster Recovery and Response Plan ............................................................................... 141
P. Section 3 Compliance ......................................................................................................... 142
5.1. State Administered Disaster Recovery Program.................................................................. 143
A. Action Plan ......................................................................................................................... 143
B. Direct Allocation ................................................................................................................ 143
C. Connection to Unmet Needs ............................................................................................... 144
D. Regional MOD ................................................................................................................... 148
E. Program Budget .................................................................................................................. 149
F. GLO Use of Funds .............................................................................................................. 151
1. Homeowner Assistance Program..................................................................................... 151
2. Local Buyout and Acquisition Program .......................................................................... 155
3. Homeowner Reimbursement Program ............................................................................ 159
4. Affordable Rental Program ............................................................................................. 161
5. Partial Repair and Essential Power for Sheltering Program ............................................ 163
6. Local Infrastructure Program........................................................................................... 164
7. Economic Revitalization Program ................................................................................... 169
8. Local, Regional and State Planning ................................................................................. 171
9. Administrative Funds ...................................................................................................... 174
G. Harris County Use of Funds ............................................................................................... 174
H. City of Houston Use of Funds ............................................................................................ 174
I. Location ............................................................................................................................... 175
J. Mitigation Measures ............................................................................................................ 175
K. National Objectives ............................................................................................................ 175
5.2. Harris County Administered Disaster Recovery Program ................................................... 176
A. Connection to Unmet Needs............................................................................................... 176
B. Harris County Quality of Construction .............................................................................. 179
C. Rehabilitation and Reconstruction Cost-Effectiveness ...................................................... 179
D. Harris County MOD ........................................................................................................... 179
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E. Program Budget .................................................................................................................. 180
F. Use of Funds ....................................................................................................................... 181
1. Harris County Homeowner Assistance Program ............................................................. 181
2. Harris County Residential Buyout Program .................................................................... 185
3. Single Family Affordable Housing Preservation Program .............................................. 186
4. Homeowner Reimbursement Program ............................................................................ 188
5. Affordable Rental Program ............................................................................................. 190
6. Harris County Single Family New Construction Program .............................................. 192
7. Local Infrastructure Program........................................................................................... 197
8. Harris County Planning ................................................................................................... 203
9. Administrative Funds ...................................................................................................... 204
10. National Objective ......................................................................................................... 204
5.3. City of Houston Administered Disaster Recovery Program ................................................ 206
A. Direct Allocation ................................................................................................................ 206
B. Connection to Unmet Needs ............................................................................................... 206
C. Houston Program Budget ................................................................................................... 209
D. Use of Funds ....................................................................................................................... 210
1. Homeowner Assistance Program (HoAP) ....................................................................... 210
2. Single Family Development Program ............................................................................. 215
3. Multifamily Rental Program ............................................................................................ 217
4. Small Rental Program ...................................................................................................... 219
5. Homebuyer Assistance Program ..................................................................................... 222
6. Buyout Program ............................................................................................................... 223
7. Public Services ................................................................................................................ 225
8. Economic Revitalization Program ................................................................................... 227
9. Planning ........................................................................................................................... 228
10. Administration ............................................................................................................... 229
6.1. Citizen Participation – State Action Plan............................................................................. 230
A. Publication .......................................................................................................................... 230
B. Consideration of Public Comments .................................................................................... 231
C. Citizen Complaints ............................................................................................................. 231
D. Substantial Amendment ..................................................................................................... 232
E. Non-substantial Amendment .............................................................................................. 232
F. Community Consultation .................................................................................................... 232
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G. Public Website.................................................................................................................... 233
1. City of Houston and Harris County Websites ................................................................. 233
2. COG Websites ................................................................................................................. 233
H. Waivers ............................................................................................................................... 233
6.2. Citizen Participation – Harris County Local Action Plan .................................................... 235
Policies Regarding the Project Recovery Website .................................................................. 236
Partnership with Harris County Flood Control District .......................................................... 236
Grievances and Appeals .......................................................................................................... 237
6.3. Citizen Participation – City of Houston Local Action Plan ................................................. 238
A. Community Consultation ................................................................................................... 238
B. Complaints .......................................................................................................................... 238
C. Public Website .................................................................................................................... 239
7.1. Appendix A: CDBG-DR Eligible and Most Impacted Counties and ZIP Codes ................ 240
8.1. Appendix B: Certifications – State of Texas ....................................................................... 242
9.1. Appendix C: Program Execution Timelines – State Action Plan ........................................ 245
10.1. Appendix D: Projected Expenditures and Outcomes – State Action Plan......................... 247
10.2. Appendix D: Projected Expenditures and Outcomes – Harris County Local Action Plan 251
10.3. Appendix D: Projected Expenditures and Outcomes – City of Houston Local Action Plan
..................................................................................................................................................... 253
11.1. Appendix E: Consultations – State of Texas ..................................................................... 257
11.2. Appendix E: Consultations – Harris County ..................................................................... 266
11.3. Appendix E: Consultations – City of Houston .................................................................. 268
12.1. Appendix F: Regional Methods of Distribution ................................................................ 272
A. State Housing Program Allocations ................................................................................... 272
B. Local Infrastructure Program Allocation ............................................................................ 278
13.1. Appendix G: City of Houston and Harris County Allocations – Initial Action Plan ........ 283
14.1. Appendix H: Public Comment – State of Texas ................................................................ 284
14.2. Appendix H: Public Comments – Harris County .............................................................. 376
14.3. Appendix H: Public Comment – City of Houston ............................................................. 412
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1.1. Amendment 3: Summary of Changes
This document constitutes the Third Amendment to the State of Texas Action Plan for Disaster
Recovery: Hurricane Harvey – Round 1, approved by HUD on June 22, 2018.
Action Plan Amendment 2 (APA 2) allocated additional Community Development Block Grant –
Disaster Recovery (CDBG-DR) funds provided by Public Law 115-123 to Harris County and the
city of Houston. In this amendment, APA 3, Harris County and the city of Houston allocate these
additional funds to their programs.
The following additional changes to the Action Plan are made in this Amendment:
 Adjustments to the Total Allocation Budget:
o For the State-administered programs;
 for State Local Buyout and Acquisition Progam due to the change in
classification of some State most impacted and distressed (MID) counties
to HUD MID counties;
 for State Local Infrastructure Program due to the change in classification of
some State MID counties to HUD MID counties;
 to reduce the Partial Repair and Essential Power for Sheltering (PREPS)
budget to $35,000,000;
 to increase the Affordable Rental Program budget to $487,675,000;
 to reduce state administration budget due to the increase of administration
budget for Harris County and the city of Houston. The administration
budgets for Harris County and the city of Houston each increased from 2
percent of their housing activity funds to 2.5 percent of their total program
funds.
o For the Harris County-administered programs;
 to increase the Homeowner Assistance Program budget to $270,359,499;
 to increase the Affordable Rental Program budget to $224,500,000;
 to increase the housing project delivery budget to $92,194,170;
 to increase the planning budget to $60,234,809;
 to increase the administration budget to $30,117,405.
o For the city of Houston-administered programs;
 to increase the Homeowner Assistance Program (HoAP) budget to
$427,900,063;
 to increase the Single Family Development program budget to
$222,269,086;
 to increase the Multifamily Rental Program budget to $350,050,472;
 to increase the Small Rental Program budget to $66,686,282;
 to increase the Homebuyer Assistance Program budget to $23,688,328;
 to increase the administration budget to $31,118,976.
 Revised languge in Section 4.1 on the “General Requirements”:

o Revised the language in Rehabilitation/Reconstruction of Public Housing,
Affordable Housing and other forms of Assisted Housing section to recognize that
Page 7 of 420
Harris County and city of Houston administration budgets are increased from 2
percent of their housing activity funds to 2.5 percent of their total program funds.
 Changes in Section 5.1 on the “State Administered Disaster Recovery Program” include:
o Revised language to change reference from 80 percent and 20 percent for the HUD-
identified Most Impacted and Distressed and other Most Impacted and Distressed
Areas as HUD MID and State MID;
o Revised language to modify the reallocation method for the Local Buyout and
Acquisition Program when eligible subrecipients decline all or a portion of their
local MOD allocation to direct declined funds to the Affordable Rental Program;
o Added language to allow planning as an eligible activity for up to 20% of a
subrecipient’s Local Buyout and Acqusition Program allocation and Local
Infrastructure program allocation, respectively, with Texas General Land Office
(GLO) approval;
o Increased the Affordable Rental Program budget to $487,675,000;
o Reduced the budget for PREPS to $35,000,000;
o Revised language to modify the reallocation method for PREPs to direct any
remaining funds to the Affordable Rental Program;
o Added language to the Local Infrastructure Program section to: 1) allow a
localmethod of distribution (MOD) amendment to reallocate declined allocation of
funds and 2) to direct any funds not reallocated through a MOD amendment,
declined funds, or deobligated fund to the Affordable Rental Program;
o Revised language regarding the HUD MID and State MID split for the local,
regional, and state planning program;
o Revised language in the Administrative Funds section to recognize that Harris
County and city of Houston administration budgets are increased from 2 percent of
their housing activity funds to 2.5 of their total program funds.
 Changes in Section 5.2. “Harris County Administered Disaster Recovery programs”

include:
o Updated Table 59: Harris County Summary of Total Unment Need;
o Updated Table 60: Total Allocation Budget-Harris County;
o Increased the Harris County Homeowner Assistance Program to $270,359,499;
o Increased the Affordable Rental Program budget to $224,500,000;
o Added language to the Harris County Single Family New Construction Program
clarifying that the affordability period for the homebuyer is 10 years and clarifying
the recapture provisions.
o Added language to the Harris County Single Family New Construction Program
that specifies eligible infrastructure costs related to housing development.
o Added language to the Local Infrastructure Program on promoting sound planning
principles, coordinating with local and regional planning efforts, integrating
mitigation measures, considering costs and benefits, ensuring activities do not
disproportionately impact vulnerable populations, ensuring activities create
opportunities to address economic inequities, aligning investments with other
planned improvements, and employing adaptable and reliable technologies;
Page 8 of 420
o Increased the Harris County planning budget to $60,234,809; and
o Increased the Harris County administriative funds budget to $30,117,405.
 Changes in Section 5.3. “City of Houston Administered Disaster Recovery programs”

include:
o Removed “Elevation” from the title of two HoAP options;
o Included estimated project delivery amounts in each estimated budget amount for
the HoAP;
o Added clarifying language to the HoAP Acquisition description;
o Added information about temporary relocation assistance available under two
HoAP options and added clarifying language to the interim mortgage assistance
option;
o Specified that costs should be reasonable and consistent with market costs for the
HoAP, Multifamily Rental Program, and Economic Revitalization Program;
o Aligned the maximum assistance amounts for HoAP and Single Family with
similar programs administered by the GLO and Harris County, respectively;
o Added clarifying information under HoAP’s homeowner eligibility criteria,
including information on the lien periods;
o Clarified recapture provisions for the Single Family Development Program, as
required in 83 FR 40314;
o Added clarifying language to the Single Family Development Program’s selection
criteria;
o Changed the minimum lien period for reconstruction from 15 years to 20 years for
the Multifamily Rental Program;
o Updated the Multifamily Rental Program language to use the Low-Income Housing
Credit rent limits, 26 U.S. Code § 42 (g)(2)(a), instead of High HOME rents to
accurately reflect the intent to charge rents according to determined need from the
Local Needs Assessment;
o Removed contradictory language in the Small Rental Program description and add
clarifying language about lien periods;
o Added clarifying language about homeowner eligibility for the Buyout Program;
o Added two national objectives to the Economic Revitalization Program;
o Specified that, within the Economic Revitalization Program, funds may not be
provided to a for-profit entity unless the project has been evaluated and selected in
accordance with the U.S. Department of Housing and Urban Development (HUD)
underwriting guidelines;
o Changed the name of the line item from “Housing Administration” to
“Administration” and update the percentage of administration to 2.5 percent, as
allowed by the GLO; and
o Specified that planning activities will promote sound, sustainable long-term
recovery planning informed by a post-disaster evaluation of hazard risk, especially
land-use decisions that reflect responsible flood plain management and take into
account future possible extreme weather events and other natural hazards and long-
term risks.
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 Revised language in Section 6.3 on the “Citizen Participation Houston Local Action Plan”
to remove language with the intention of streamlining Houston’s amendment process.
The following appendices have also been updated to reflect updated program information:
 Section 10.1. Appendix D: Projected Expenditures and Outcomes – State Action Plan;
 Section 10.2. Appendix D: Projected Expenditures and Outcomes – Harris County Local
Action Plan; and
 Section 10.3. Appendix D: Projected Expenditures and Outcomes – City of Houston Local
Action Plan.
Minor non-substantive edits, e.g. grammar/formatting, have also been made to this document.
APA 3 is considered substantial, as it substantially amends the action plan by allocating the
additional program funds allocated to Harris County and the city of Houston in APA 2 to their
programs. The following table summarizes modifications in allocated funding among the State of
Texas, Harris County, and City of Houston administered programs.
Page 10 of 420
Previous Allocation Change Revised Allocation
State of Texas – Total $3,189,357,706 ($23,659,338) $3,165,698,369
State of Texas –
$1,334,222,225 $0 $1,334,222,225
Homeowner Assistance
State of Texas – Local
$275,620,892 $0 $275,620,892
Buyout/Acquisition
State of Texas –
Homeowner $100,000,000 $0 $100,000,000
Reimbursement
State of Texas – Affordable
$450,000,000 $37,675,000 $487,675,000
Rental
State of Texas – PREPS $72,675,000 ($37,675,000) $35,000,000
State of Texas – Housing
$31,943,260 $0 $31,943,260
Project Delivery
State of Texas – Local
$413,431,338 $0 $413,431,338
Infrastructure
State of Texas – Economic
$100,000,000 $0 $100,000,000
Revitalization
State of Texas –
Infrastructure Project $27,537,089 $0 $27,537,089
Delivery
State of Texas – Planning $137,685,446 $0 $137,685,446
State of Texas – $246,242,456 $222,583,119
($23,659,338)
Administration
Harris County – Total $1,221,438,141 $13,375,449 $1,234,813,590
Harris County –
$214,000,000 $56,359,499 $270,359,499
Homeowner Assistance
Harris County – $175,000,000
$0 $175,000,000
Residential Buyout
Harris County –
SF Affordable Housing $25,000,000 $0 $25,000,000
Preservation
Harris County –
$15,000,000 $0 $15,000,000
Reimbursement
Harris County – Affordable
$204,500,000 $20,000,000 $224,500,000
Rental
Harris County – SF New
$119,888,035 0 $119,888,035
Construction
Harris County – Housing
$83,709,781 $8,484,389 $92,194,170
Project Delivery
Harris County –
$12,500,000 $0 $12,500,000
Commercial Buyout
Harris County – Method of
$120,000,000 $0 $120,000,000
Distribution (Local)
Page 11 of 420
Previous Allocation Change Revised Allocation
Harris County –
$76,668,492 $0 $76,668,492
Competitive Application
Harris County –
Infrastructure Project $13,351,180 $0 $13,351,180
Delivery
Harris County – Planning $55,769,342 $4,465,467 $60,234,809
Harris County –
$16,741,956 $13,375,449 $30,117,405
Administration
Harris County – Additional
$89,309,355 ($89,309,355) $0
Funding
City of Houston – Total $1,265,594,153 $10,283,888 $1,275,878,041
City of Houston –
Homeowner Assistance $392,729,436 $35,170,627 $427,900,063
(HoAP)
City of Houston – Single
$204,000,000 $18,269,086 $222,269,086
Family Development
City of Houston –
$321,278,580 $28,771,892 $350,050,472
Multifamily Rental
City of Houston – Small
$61,205,100 $5,481,182 $66,686,282
Rental
City of Houston –
$21,741,300 $1,947,028 $23,688,328
Homebuyer Assistance
City of Houston – Buyout $40,800,000 $0 $40,800,000
City of Houston – Public
$60,000,000 $0 $60,000,000
Services
City of Houston –
$30,264,834 $0 $30,264,834
Economic Revitalization
City of Houston – Planning $23,100,000 $0 $23,100,000
City of Houston –
$20,835,088 $10,283,888 $31,118,976
Administration
City of Houston –
$89,639,815 ($89,639,815) $0
Additional Funding
Total Allocation $5,676,390,000 $0 $5,676,390,000
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2.1. Executive Summary – State Action Plan
The hurricane season of 2017 proved to be the
most expensive in United States history,
impacting families from Puerto Rico to Florida
and across the Texas coast. Hurricane Harvey
made landfall on August 25, 2017, between Port
Aransas and Port O’Connor as a Category 4
hurricane with sustained winds over 130 mph.
After initial impact, Hurricane Harvey’s winds
began to decrease, but due to two high-pressure
systems to the east and west, it remained fixed
over the Texas coast for the next 4 days. During
this period, as much as 60 inches of rain fell over
the impacted area.
The GLO estimates the cost of damages from

Hurricane Harvey at $120 billion, making it the
costliest event in U.S. history. The hurricane shut
down ports, trade, tourism, oil and gas production,
Source: Weather.gov - Hurricane Harvey Satellite and
agricultural production, and general businesses Radar Landfall Image
across most of the Texas coast for almost a week
and, in some cases, significantly longer. The impact of these interruptions is difficult to quantify
at this time, but the effects of this disaster were felt across the nation, with commodities such as
gas increasing in price by $0.33 a gallon in the weeks following Hurricane Harvey. 1
Hurricane Harvey resulted in record rainfall totals of 34 trillion gallons of water. 2 Combining this
record rainfall together with the fact that Hurricane Harvey made landfall twice creates a three-
event narrative: the initial landfall in Aransas County; the unprecedented rainfall in the Houston
metroplex and surrounding areas; and Hurricane Harvey’s second landfall which caused massive
flooding in Southeast Texas. Following these three events, tens of thousands of homes that had
never been flooded took on water, and evacuations and rescues continued for days after landfall.
1
U.S. Energy Information Administration. 2018. “Petroleum & Other Liquids.” Webpage accessed January 8,
2018. https://www.eia.gov/petroleum/gasdiesel/
2
San Antonio Express-News. September 17, 2017. “Harvey Dumped Record-Setting 34 Trillion Gallons of Rain.”
Webpage accessed January 10, 2018. http://www.expressnews.com/news/local/article/Harvey-dumped-record-
setting-34-trillion-gallons-12204769.php
Page 13 of 420
The GLO estimates
over 1 million homes
were impacted by
Hurricane Harvey and
the state of Texas is
projected to spend
more than $2.6 billion
on response and
recovery, of which
almost $1.7 billion is
reported to be funded
by the federal
3
government. As of
June 8, 2018, the
Federal Emergency
Management Agency Source: www.weather.gov
(FEMA) Public
Assistance (PA) program estimates damage costs at approximately $7.96 billion. As of June 25,
2018, the FEMA Individuals and Households program (Total Housing Assistance and Total Other
Needs Assistance) received over 892,000 applications and has disbursed about $3.61 billion in
housing assistance and other related emergency disaster assistance. As of July 31, 2018, FEMA’s
National Flood Insurance Program (NFIP) received over 91,000 claims and disbursed more than
$8.8 billion to claimants. The Small Business Administration (SBA) has disbursed over $2.9
billion in home loans and almost $1.4 billion in business loans as of August 28, 2018.
On December 27, 2017, HUD in response to Hurricane Harvey allocated $57.8 million in
Community Development Block Grant – Disaster Recovery (CDBG-DR) funds to the state of
Texas through the publication of the Federal Register, Vol. 82, No. 247. HUD identified Harris
County as the “most impacted and distressed” area in the Federal Register notice and required that
at least 80 percent of the allocation must address unmet needs within the County. The GLO
allocated the remaining portion of the initial funds to Aransas, Nueces, and Refugio Counties for
an affordable rental program. The GLO developed an Action Plan for the $57.8 million allocation,
and submitted the Action Plan for approval to HUD on March 8, 2018.
HUD has allocated $5.024 billion in CDBG-DR funds to the state of Texas in response to
Hurricane Harvey, DR-4332, through the publication of the Federal Register, Vol. 83, No. 28,
Friday, February 9, 2018. This allocation was made available through the Continuing
Appropriations Act, 2018, and Supplemental Appropriations for Disaster Relief Act, 2017, that
allocated $7.4 billion in CDBG-DR funds in response to major disasters declared in 2017. HUD’s
notice in the Federal Register, Vol. 83, No. 157, August 14, 2018, allocated an additional
$652,175,000 to the state of Texas to address remaining unmet needs from Hurricane Harvey. The
GLO has been designated by the governor to administer CDBG-DR funds on behalf of the state of
Texas.
3
Legislative Budget Board. 2018. “Hurricane Harvey: Fiscal Analyses and Resources.” Webpage accessed
September 7, 2018. http://www.lbb.state.tx.us/Harvey.aspx
Page 14 of 420
This Action Plan will detail the proposed use of all funds, including criteria for eligibility and how
the use of these funds will address long-term recovery and restoration of infrastructure, housing,
and economic revitalization in the most impacted and distressed areas. The use of funds for this
allocation is limited to unmet recovery needs from Hurricane Harvey, DR-4332.
HUD has identified Aransas, Brazoria, Chambers, Fayette, Fort Bend, Galveston, Hardin, Harris,
Jasper, Jefferson, Liberty, Montgomery, Newton, Nueces, Orange, Refugio, San Jacinto, San
Patricio, Victoria, and Wharton Counties;, 75979, 77320, 77335, 77351, 77414, 77423, 77482,
77493, 77979, and 78934 ZIP Codes as the “most impacted and distressed” areas in the latest
Federal Register notice, Vol. 83, No. 157, August 14, 2018, and has required that at least 80 percent
of the allocation must address unmet needs within these areas. Up to 20 percent will address unmet
needs within the “most impacted and distressed” areas determined by the GLO to be the remaining
29 CDBG-DR eligible counties (in whole or in part) through the unmet needs assessment in
Section II of this Action Plan.
For the purpose of this Action Plan, the four counties (Bexar, Dallas, Tarrant, and Travis) that
received FEMA disaster declarations for emergency protective measures, including direct federal
assistance under the PA program, are not included in the 49 CDBG-DR eligible counties identified
on the map below.
There are 24 regional councils, also known as COGs, located within the State. The COGs are
comprised of city, county, and special district members working together to implement cost-
effective, results-oriented strategies that address statewide and local needs on a regional scale. The
49 CDBG-DR eligible counties are located within nine COGs: Alamo Area Council of
Governments (AACOG); Brazos Valley Council of Governments (BVCOG): Capital Area
Council of Governments (CAPCOG); Coastal Bend Council of Governments (CBCOG); Central
Texas Council of Governments (CTCOG); Deep East Texas Council of Governments (DETCOG);
Golden Crescent Regional Planning Commission (GCRPC); Houston-Galveston Area Council (H-
GAC); and South East Texas Regional Planning Commission (SETRPC). Each COG and the
CDBG-DR eligible county are identified on the map below.
Since 2005’s Hurricane Rita, COGs have been active partners with the State’s CDBG-DR
programs. The COGs have developed local MODs to local governments and entities for CDBG-
DR housing and infrastructure funds, and have implemented successful homeowner and rental
housing recovery programs. In addition to their work with the State’s CDBG-DR programs, the
COGs also work in programs and areas related to community and economic development,
emergency preparedness, emergency communications, and health and human services.
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Figure 1: DR-4332 49 CDBG-DR Eligible Counties and HUD’s Most Impacted Counties and
ZIP Codes (P.L. 115-123) (Updated in APA 2)
A summary of the State of Texas unmet need is identified in the table below. As required, a needs
assessment was completed to identify long-term needs and priorities for CDBG-DR funding
allocated as a result of Hurricane Harvey. The assessment takes into account a comprehensive set
of data sources that cover multiple geographies and sectors. The needs assessment includes
specific details about unmet needs within the eligible and most impacted and distressed
Page 16 of 420
communities, and includes details for housing, infrastructure, and economic revitalization. The
needs assessment is expected to be amended as additional information and funds are available or
updated.
Category Remaining Unmet Need % of Total Program % of Total

Unmet Allocation Program
Need Amount* Allocation
Housing $11,858,541,577 14% $4,197,645,609 80%
Infrastructure $62,331,560,509 72% $658,124,755 13%
Economic $12,451,439,074 14% $195,628,178 4%

Development
To be N/A N/A $178,949,170 3%
determined**
Total $86,462,591,990 100% $5,230,347,712 100%
*Allocation Amount includes project delivery costs and does not include administration and planning costs.
**Additional funds allocated to Harris County and the city of Houston through APA 2; Harris County and the city of
Houston will later identify the specific programs their additional funds will be allocated towards.
The city of Houston and Harris County have each received a direct allocation from the State’s
allocation at the direction of HUD. The amounts allocated to the city of Houston and Harris County
for the initial $5.024 billion were based on the amounts of unmet need calculated by HUD. The
same methodology was used by HUD to determine the amount of the $5.024 billion allocated to
the State of Texas. The amounts were adjusted to account for the prior allocation to Harris County,
the economic revitalization program, and state administration costs. Located in Appendix G
(Section 13.1) is a table that identifies the adjustments made in the Initial Action Plan.
APA 2 allocated an additional $652,175,000 in program funds provided by Public Law 115-123.
The GLO allocated the funds to Harris County, the city of Houston, and the State of Texas by
applying the same methodology used to allocate funds for the State HAP, as described in Section
12.1 Appendix F: Regional Methods of Distribution, but with Harris County and the city of
Houston included.
Because the city of Houston and Harris County have elected to develop their own local recovery
programs with the exception of the State’s economic revitalization program, each is required to
develop a local action plan. The local action plan must be developed in accordance with the
requirements HUD has outlined in the Federal Register Notice. These local action plans are
incorporated into this Action Plan as part of Amendment 1. The executive summaries for Harris
County and the City of Houston are provided in Sections 2.2 and 2.3; the Needs Assessments are
provided in Sections 3.2 and 3.3; and the respective Disaster Recovery Program information is
located in Sections 5.2 and 5.3.
Through this Action Plan, the GLO is proposing to implement several state-run housing programs.
These programs include the homeowner assistance program for rehabilitation and reconstruction
of primary residences, the homeowner reimbursement program for reimbursement to homeowners
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for repairs on their primary residences, and the affordable rental program to rehabilitate and
reconstruct multifamily developments.
The GLO will allocate funds to local governments for the local residential buyout/acquisition and
local infrastructure programs through MODs developed by the COGs.
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2.2. Executive Summary – Harris County Local Action Plan
HUD has allocated $5.024 billion in CDBG-DR funding to the State of Texas in response to
Hurricane Harvey, FEMA DR 4332, through the Federal Register, Vol. 83, No. 28 (83 FR 5844).
On August 14, 2018, a Federal Register, Vol. 83, No. 157 (83 FR 40314), was released allocating
additional CDBG-DR funding of $652,175,000 to the State of Texas. The Texas GLO is the State’s
administrating agency for these funds.
In the State of Texas Plan for Disaster Recovery: Hurricane Harvey – Round 1 CDBG-DR Action
Plan, which can be found at http://recovery.texas.gov/local-government/hud-requirements-
reports/hurricane-harvey/index.html on the GLO website, Harris County was identified as a “most
impacted and distressed” area and was allocated by the State, along with the City of Houston, a
direct allocation from the State’s CDBG-DR allocation at the direction of HUD of $1,204,696,185.
This included an additional $89,309,355 allocated in August 14, 2018 Federal Register (PL 115-
123), which will be used for housing recovery in Harris County. As Harris County and the City of
Houston elected to develop their own local recovery programs, both jurisdictions are required to
develop local supplemental action plans (SAPs) to be submitted as a substantial amendment under
the State of Texas Action Plan. This substantial amendment (APA 1) was submitted and approved
by HUD in December 2018.
In consultation with the GLO, Harris County has been given technical assistance to develop their
local SAP. The County’s SAP includes a needs assessment, community engagement efforts,
description of unmet needs, and county’s use of funds and program descriptions, and expenditure
timelines. The following document is Harris County’s local SAP.
During Hurricane Harvey, all 4.7 million people in Harris County were impacted directly or
indirectly during the flood. The peak total rainfall over a 4-day period from Harris County Flood
Control District (HCFCD) gages was 47.4 inches. This record rainfall was deadly and devastating
to county residents. Over 60,000 residents were rescued by government resources across the
county, most of them from their homes. Over 32,000 residents would be transported to one of 65
temporary shelters in Harris County, where most would wait days until the waters receded to return
to damaged homes. It is estimated that over 300,000 vehicles were flooded across Harris County.
The Harris County Medical Examiner’s Office confirms 36 flood related deaths in the county,
including several people drowning in their home or work place.
The resulting devastation of Hurricane Harvey has left the county with an unmet need of over
$12.9 billion in housing and infrastructure damage or failure to function. The following table
provides a summary of Harris County’s unmet needs. The county has elected to closely follow the
Federal Register and State Action Plan and provide 81 percent of funding to housing programs and
19 percent to infrastructure/non-housing programs. With the increased CDBG-DR allocation
under Public Law 115-123, the County will expand two housing programs, Homeowner Assistance
and Rental Housing Development. Due to the increase in funding, administration and planning
allocations will also increase. As a “most impacted and distressed” area, Harris County will expend
its allocation within the county, thus meeting the 80 percent rule to expend funds in a “most
impacted and distressed” area. It should be noted that the County will be participating in the State’s
Economic Development Program.
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Category Unmet Needs % of County Program Allocation % of County
Unmet Amount Program
Need Allocation
Housing $2,864,912,259 22.0% $921,941,704 81%
Infrastructure $9,960,039,307 77.2% $222,519,672 19%
Economic $84,846,950 0.8% ** **
Development
TOTAL $12,909,798,516 100% $1,144,461,376 100%
Note: Allocations do not include planning costs of $60,234,809. **The County will participate in the State’s
Economic Development Program.
There are additional gaps and unmet needs not reflected in the assessment. The County will
continue to gather and refine information, such as data and public input, which will continue to
inform the CDBG-DR process and program design.
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2.3. Executive Summary – City of Houston Local Action Plan
In response to Hurricane Harvey and the presidentially declared disaster, Congress appropriated
more than $5 billion to the State of Texas for recovery assistance. The Texas GLO is applying for
and administering these funds on behalf of the state. The GLO has made a direct allocation to the
City of Houston and Harris County at the direction of HUD, and therefore both the City of Houston
and Harris County must develop a local action plan.
The City of Houston has followed the GLO’s guidance and has created Houston specific
information to be incorporated into various sections of the GLO’s State of Texas Plan for Disaster
Recovery: Hurricane Harvey – Round 1 through a substantial amendment. The local information
in the City’s action plan includes local needs assessment, connection to unmet needs, local
programs and requirements, local consultation, and expenditure timelines.
A summary of the unmet needs assessment is identified in the following table. This needs
assessment aligns with the GLO’s assessment, as feasible.
% of Houston
CDBG-DR
Category Unmet Need % of Unmet Need Program
Investments*
Allocation
Housing $1,762,206,538 59% $1,191,394,231 98%
Infrastructure $109,829,427 4% $0 0%
Economic $1,099,849,484 37% $30,264,834 2%
Total $2,971,885,449 100% $1,221,659,065 100%
*Allocation amount does not include planning costs
There are additional gaps and unmet needs not reflected in this assessment. The City will continue
to gather and refine information, such as data and public input, which will continue to inform the
CDBG-DR process and programming.
Page 21 of 420
2.4. Executive Summary – Total Allocation Budget
The following table shows the combined total allocation budget for the State-administered
programs and the programs administered by Harris County and the City of Houston.
% of Total
HUD Most Impacted State Most Impacted % of Total
Programs LMI Amount Total Allocation by Total
Areas Areas Allocation
Program
Direct Allocation Programs
Direct Programs - Harris County
Homeowner Assistance Program $ 270,359,499 $ - $ 189,251,649 $ 270,359,499 4.76%
Residential Buyout Program $ 175,000,000 $ - $ 122,500,000 $ 175,000,000 3.08%
SF Affordable Housing Preservation Program $ 25,000,000 $ - $ 17,500,000 $ 25,000,000 0.44%
Harris County - Housing Reimbursement Program $ 15,000,000 $ - $ 10,500,000 $ 15,000,000 0.26% 16.24% $ 921,941,704
Affordable Rental Program $ 224,500,000 $ - $ 224,500,000 $ 224,500,000 3.95%
SF New Construction $ 119,888,035 $ - $ 119,888,035 $ 119,888,035 2.11%
Housing Project Delivery $ 92,194,170 $ - $ 64,535,919 $ 92,194,170 1.62%
Commercial Buyout Program $ 12,500,000 $ - $ 8,750,000 $ 12,500,000 0.22%
Harris County - Method of Distribution (Local) $ 120,000,000 $ - $ 84,000,000 $ 120,000,000 2.11%
3.92% $ 222,519,672
Infrastructure Competitive Application $ 76,668,492 $ - $ 53,667,944 $ 76,668,492 1.35%
Instructure Project Delivery $ 13,351,180 $ - $ 9,345,826 $ 13,351,180 0.24%
Harris County - Planning

1.59% $ 90,352,214
and Administration Harris County Planning $ 60,234,809 $ - N/A $ 60,234,809 1.06%
Harris County Admininstration $ 30,117,405 $ - N/A $ 30,117,405 0.53%
Harris County Subtotal $ 1,234,813,590 $ - $ 904,439,373 $ 1,234,813,590 21.75%

Direct Programs - City of Houston
Single Family Development Program $ 222,269,086 $ - $ 222,269,086 $ 222,269,086 3.92%
Multifamily Rental Program $ 350,050,472 $ - $ 350,050,472 $ 350,050,472 6.17%
City of Houston - Housing 19.93% $ 1,131,394,231
Small Rental Program $ 66,686,282 $ - $ 66,686,282 $ 66,686,282 1.17%
Homebuyer Assistance Program $ 23,688,328 $ - $ 7,264,351 $ 23,688,328 0.42%
Buyout Program $ 40,800,000 $ - $ 20,400,000 $ 40,800,000 0.72%
City of Houston -Public Public Services $ 60,000,000 $ - $ 60,000,000 $ 60,000,000 1.06%

Services and Economic 1.59% $ 90,264,834
Revitalization
Economic Revitalization Program $ 30,264,834 $ - $ 30,264,834 $ 30,264,834 0.53%
City of Houston - Planning

City of Houston Planning $ 23,100,000 $ - N/A $ 23,100,000 0.41% 0.96% $ 54,218,976
and Administration
City of Houston Admininstration $ 31,118,976 N/A $ 31,118,976 0.55%
City of Houston Subtotal $ 1,275,878,041 $ 1,003,745,316 $ 1,275,878,041 22.48%
Direct Allocation Subtotal $ 2,510,691,631 $ - $ 1,908,184,689 $ 2,510,691,631
GLO State Programs
Homeowner Assistance Program $ 1,198,024,378 $ 136,197,847 $ 948,955,558 $ 1,334,222,225 23.50%
AACOG $ - $ 6,000,000 $ 4,200,000 $ 6,000,000 0.450%
BVCOG $ - $ 11,091,055 $ 7,763,739 $ 11,091,055 0.831%
CAPCOG $ 33,032,736 $ 15,545,898 $ 34,005,044 $ 48,578,634 3.641%
CBCOG $ 138,996,767 $ 6,000,000 $ 101,497,737 $ 144,996,767 10.868%
CTCOG $ - $ 2,000,000 $ 1,400,000 $ 2,000,000 0.150%
DETCOG $ 132,280,713 $ 11,294,370 $ 100,502,558 $ 143,575,083 10.761%
GCRPC $ 37,424,878 $ 23,480,723 $ 42,633,921 $ 60,905,601 4.565%
H-GAC $ 550,915,781 $ 50,785,801 $ 421,191,107 $ 601,701,582 45.098%
SETRPC $ 265,373,503 $ - $ 185,761,452 $ 265,373,503 19.890%
HAP Public Service $ 40,000,000 $ 10,000,000 $ 50,000,000 $ 50,000,000 3.748%
Local Buyout/Acquisition Program $227,542,017.62 $48,078,874.38 $ 192,934,624 $ 275,620,892 4.86%
State Housing AACOG $ - $ 4,152,165 $ 2,906,515 $ 4,152,165 1.506% 39.89% $ 2,264,461,377
BVCOG $ - $ 5,840,778 $ 4,088,545 $ 5,840,778 2.119%
CAPCOG $ 8,913,617.62 $ 4,015,856.38 $ 9,050,632 $ 12,929,474 4.691%
CBCOG $ 30,011,342 $ 4,364,353 $ 24,062,987 $ 34,375,695 12.472%
CTCOG $ - $ 1,384,055 $ 968,838 $ 1,384,055 0.502%
DETCOG $ 27,633,673 $ 8,233,359 $ 25,106,922 $ 35,867,032 13.013%
GCRPC $ 8,606,577 $ 9,824,070 $ 12,901,453 $ 18,430,647 6.687%
H-GAC $ 100,689,194 $ 10,264,238 $ 77,667,402 $ 110,953,432 40.256%
SETRPC $ 51,687,614 $ - $ 36,181,330 $ 51,687,614 18.753%
Homeowner Reimbursement Program $ 80,000,000 $ 20,000,000 $ 5,000,000 $ 100,000,000 1.76%
Affordable Rental Program $ 390,140,000 $ 97,535,000 $ 487,675,000 $ 487,675,000 8.59%
PREPS Program $ 28,000,000 $ 7,000,000 $ - $ 35,000,000 0.62%
State Project Delivery $ 25,554,608 $ 6,388,652 $ 22,360,282 $ 31,943,260 0.56%
Local Infrastructure Program $353,618,787.13 $59,812,550.87 $ 289,401,937 $ 413,431,338 7.28%
AACOG $ - $ 1,530,000 $ 1,071,000 $ 1,530,000 0.370%
BVCOG $ - $ 3,007,825 $ 2,105,477 $ 3,007,825 0.728%
CAPCOG $ 929,021.13 $ 3,376,452.87 $ 3,013,832 $ 4,305,474 1.041%
CBCOG $ 125,703,593 $ 100,645 $ 88,062,967 $ 125,804,238 30.429%
State Infrastructure and CTCOG $ - $ 510,000 $ 357,000 $ 510,000 0.123%
9.53% $ 540,968,427
Economic Revitalization DETCOG $ 5,450,254 $ 2,013,970 $ 5,224,957 $ 7,464,224 1.805%
GCRPC $ 18,426,069 $ 17,618,520 $ 25,231,212 $ 36,044,589 8.718%
H-GAC $ 98,096,629 $ 31,655,138 $ 90,826,237 $ 129,751,767 31.384%
SETRPC $ 105,013,221 $ - $ 73,509,255 $ 105,013,221 25.400%
Economic Revitalization Program $ 80,000,000 $ 20,000,000 $ 100,000,000 $ 100,000,000 1.76%
State Planning $ 110,148,357 $ 27,537,089 N/A $ 137,685,446 2.43%
State Planning and 6.35% $ 360,268,565
Administration State Administration $ 178,066,495 $ 44,516,624 N/A $ 222,583,119 3.92%
State Allocation Subtotal $ 2,693,124,314 $ 472,574,055 $ 2,065,603,363 $ 3,165,698,369
Grand Total Allocation $ 5,203,815,945 $ 472,574,055 $ 3,973,788,052 $ 5,676,390,000 100% 100% $ 5,676,390,000
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3.1. Needs Assessment – State Action Plan
The State of Texas completed the following needs assessment to identify long-term needs and
priorities for CDBG-DR funding allocated as a result of Hurricane Harvey. This assessment takes
into account a comprehensive set of data sources that cover multiple geographies and sectors and
was completed according to guidelines set forth by HUD in Federal Register, Vol. 83, No. 28,
Friday, February 9, 2018. The information focuses on the statewide impacts and the impacts on
the 49 CDBG-DR eligible counties (see list in Appendix A). The information for the assessment
was compiled using federal and state sources, including information from FEMA, HUD, Texas
Division of Emergency Management (TDEM), SBA, Health and Human Services Commission
(HHSC), and other federal and state agencies. The GLO was able to work with these agencies to
gather information regarding the impacts of the hurricane, actions taken during and following the
storm, and unmet need.
This needs assessment includes specific details about unmet needs within the eligible and most
impacted and distressed communities. This includes details for housing, infrastructure, and
economic revitalization. This assessment takes into consideration pre-disaster needs in addition to
needs resulting from Hurricane Harvey. It discusses additional types of assistance that may be
available to affected communities and individuals, such as insurance, other federal assistance, or
any other possible funding sources. The unmet needs calculations for owner-occupied and renter-
occupied housing impacts is not reduced to account for need met through insurance because
insurance data cannot be tied to a specific FEMA IA registrant. Taking the above into
consideration, mitigation and resiliency measures to protect against future hazards are also to be
examined.
The GLO understands that additional information and clarity will come with time and anticipates
that as additional funds are allocated, there may be a different methodology for the distribution of
those funds. As further data becomes available, adjustments may be necessary in future allocation
MODs to account for data that does not exist as of today’s Action Plan. As indicated in prior
versions of the Action Plan, the needs assessment is amended as additional information is available
or updated. Updates were made in APA 2 to reflect the most recent available or attainable data and
information. The local needs assessments conducted by Harris County and the City of Houston are
provided in Sections 3.2 and 3.3.
At least eighty (80) percent of program funds, including planning activities, will benefit HUD-
identified “most impacted and distressed” areas (counties and ZIP codes). Sections 5.1, 5.2, and
5.3 outline the use of funds, including planning activities, for the State, Harris County, and the city
of Houston. Harris County and the city of Houston are located in the HUD MID.
A. Cumulative Impact of Prior Disasters
The state of Texas is vulnerable to various extreme weather events, typically those that cause or
exacerbate flooding. Recently, Texas experienced a historic drought that began in 2010. According
to the Office of the State Climatologist, the driest 12-month period on record for Texas was
Page 23 of 420
October 2010 to September 2011, with a statewide average of only 11.18 inches of rain. This led
to catastrophic wildfires that lasted from November 15, 2010, through October 31, 2011. A total
of 3.9 million acres and approximately 5,900 structures were damaged and/or destroyed during
this wildfire season. Many factors contributed to this record-breaking season, including the La
Niña weather pattern that caused extreme drought conditions, high winds from Tropical Storm
Lee, and unprecedented high temperatures. These weather conditions, combined with the
availability of large amounts of dry fuels that had built up over 5 years of drought, led to the
intensity of these wildfires.
The extended drought that Texas experienced made the state susceptible not only to wildfires but
to flash flooding as well. These drought factors contributed to the inability of soils to effectively
absorb water runoff. The 2011 wildfires also removed vegetation that usually work to slow down
and absorb rainfall.
In 2015 and 2016, the state received record amounts of rain —not once but multiple times. This
resulted in six Federal disaster declarations spread over 160 of the state’s 254 counties. The critical
infrastructure damage and already saturated grounds from the 2015 floods greatly enhanced the
devastation experienced by counties during the 2016 floods. These multiple events caused multiple
human fatalities and did severe damage across nearly half the state, or 134,000 square miles. To
date, the state of Texas still estimates $2 billion in unmet need from these events.
The below map highlights the counties that have been impacted by the last 3 years of disasters.
The majority of counties in the eligible area have been impacted by disasters in each of the last
three years. This further demonstrates the compounding impacts of recent disasters in Texas and
the impacts that these disasters are having on housing, infrastructure, and local economies along
the coast.
Page 24 of 420
Figure 2: Hurricane Harvey CDBG-DR Eligible Counties Impacted by 2015 Floods, 2016 Floods
and Harvey Declarations
B. Impact of Hurricane Harvey
In 2017, communities that had not yet had a chance to fully recover from the 2015 and 2016 floods
were impacted again. Hurricane Harvey, a regenerated tropical depression, made landfall on
August 25, 2017, as a Category 4 hurricane, bringing with it extreme wind gusts and, in some
places, up to 60 inches of rain in 5 days. The hurricane caused catastrophic flooding and at least
82 human fatalities,4 due in part to the weather system stalling over the Texas coast. The
windspeeds recorded over South Texas may have been underestimated, especially near the coast
and close to the eyewall of Hurricane Harvey, as many observation stations were disabled prior to
4
The Washington Post. “Texas officials: Hurricane Harvey death toll at 82, ‘mass casualties have absolutely not
happened.” Webpage accessed January 10, 2018. https://www.washingtonpost.com/national/texas-officials
-hurricane-harvey-death-toll-at-82-mass-casualties-have-absolutely-not-happened/2017/09/14/bff3ffea-9975-11e7
-87fc-c3f7ee4035c9_story.html?utm_term=.dfe744e2fbe8
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landfall of the eye of the hurricane; however, a peak wind gust of 150 mph was reported near
Rockport.5
According to the Texas Legislative Budget Board (LBB), the state of Texas reports over $2.6
billion in actual Hurricane Harvey related state expenditures in Fiscal Years (FY) 2017 and 2018,
of which almost $1.7 billion has been federally funded. Almost $1.9 billion in total State costs is
projected for FY 2018. These numbers do not account for potential significant state public school
finance expenses primarily driven by facility damage costs and property value declines. Included
in the FY 2018 number is the expenditure of $14.2 million of an emergency appropriation of $90
million from Solid Waste Disposal Fees to help local governments pay their required local match
for debris removal. Most of these expenses will require supplemental appropriations in FY 2019,
in order for agencies to remain solvent through the fiscal biennium. 6 In the meantime, this funding
was made available through emergency budget mechanisms and the transfer of funds from
intended uses and even from other agencies. In addition to these direct costs, the state estimates a
net loss in gross state product (GSP) in FY 2018 of $3.8 billion following Hurricane Harvey. 7
Figure 3: Hurricane Harvey Peak Wind Gusts
5
National Weather Service. “Major Hurricane Harvey - August 25-29, 2017.” Webpage accessed January 10,
2018. http://www.weather.gov/crp/hurricane_harvey
6
Texas Legislative Budget Board. 2018. “Hurricane Harvey: Fiscal Analyses and Resources.” Webpage accessed
September 7, 2018. http://www.lbb.state.tx.us/Harvey.aspx
7
Texas Comptroller of Public Accounts. “A Storm to Remember: Hurricane Harvey and the Texas Economy.”
Webpage accessed September 7, 2018. https://comptroller.texas.gov/economy/fiscal-notes/2018/special-edition/
Page 26 of 420
Hurricane Harvey made landfall twice and is viewed by many as three separate events: the initial
landfall in Aransas County; unprecedented rainfall in the Houston metroplex and surrounding
areas; and the second landfall on August 29, 2017, in southeast Texas near the cities of Orange,
Beaumont, and Port Arthur. These events caused not only wind damage but also widespread
flooding.
Figure 4: Track of Hurricane Harvey8
The 49 CDBG-DR eligible counties affected by Hurricane Harvey cover 15 percent or 39,496
square miles of land area in the state and contain approximately 32 percent of the state’s
population. The land area affected is roughly the size of the state of Kentucky. 9 Nearly 9 million
Texans live in the affected counties.
As can be seen in the following map, the initial landfall caused severe wind damage (demonstrated
by the number of windstorm damage insurance claims in red). This map also portrays the extent
of NFIP claims in the northern section of the coast, where storm rains caused severe flooding in
Houston and the surrounding areas. This graphic further demonstrates the two catastrophic
characteristics of Hurricane Harvey: (1) hurricane-force winds and (2) a slow-moving storm
bringing historic rainfall and flooding.
8
National Weather Service. “Major Hurricane Harvey - August 25-29, 2017.” Webpage accessed January 10,
2018. http://www.weather.gov/crp/hurricane_harvey
9
The United States Census Bureau. “QuickFacts Kentucky; UNITED STATES.” Webpage accessed January 10,
2018. https://www.census.gov/quickfacts/fact/table/KY,US/LND110210
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Figure 5: Residential and Commercial Windstorm and Flood Damage Insurance Claims
By the time the rain stopped, Hurricane Harvey had dumped almost a year’s worth of rainfall in
just a few days. So much rain fell during the hurricane that the National Weather Service had to
update the color charts on their graphics in order to effectively map it. Two additional shades of
purple were added to represent rainfall totals for 20-30 inches and “greater than 40 inches” ranges.
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Figure 6: National Weather Service’s 5 Day Point Rainfall in Inches
C. Resiliency Solutions and Mitigation Needs
Recognizing the state’s long and well-documented history of flooding, hurricanes, wildfires, and
droughts, as well as its ongoing efforts to mitigate future disaster effects in its most vulnerable
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areas, the GLO continues its commitment to rebuilding while prioritizing resiliency. In assessing
unmet needs, it is important to consider the additional costs of safeguarding housing and
community infrastructure investments from future disasters. As such, Texas will not only assess
projects and consider state-run programs that replace or repair lost property but will also seek to
invest resources in efforts that promise to mitigate damage from a wide range future disaster types.
Although this can increase costs initially, mitigating efforts can greatly reduce the cost of future
damages by a ratio of 6:1. The success of this long-term recovery practice was seen firsthand
during Hurricane Harvey. Resilient-enhanced projects from previous CDBG-DR efforts suffered
less damage from Hurricane Harvey: construction projects designed to prevent future flooding,
mitigate further loss, and decrease evacuation times.
Single family home resiliency solutions are expected to add approximately 10 to 15 percent to the
total cost per home; multi-family resiliency solutions add 15 to 20 percent to the total cost per
project; and infrastructure resiliency solutions add 15 to 20 percent to the total cost per project.
Resiliency solutions are varied and dependent on the respective area’s Threat and Hazard
Identification and Risk Assessment.
Single family home resiliency solutions may include elevating the first floor of habitable area;
breakaway ground floor walls; reinforced roofs; storm shutters; use of ENERGY STAR appliances
and fixtures; and mold and mildew resistant products. Multi-family resiliency solutions include
elevation; retention basins; fire-safe landscaping; firewalls; and landscaped floodwalls.
Buyout programs support hazard mitigation, floodplain management goals, and resiliency by
removing homeowners from the floodplain, thus eliminating vulnerability to future flooding
situations. After homes are purchased, the structures are demolished or relocated. The land reverts
to a natural floodplain, converts into a retention area, or is retained as green space for recreational
purposes. The buyout option serves multiple objectives and provides a resiliency option versus
rebuilding within a floodplain. Buyouts help prevent repetitive loss and extreme risk to human
health and safety. Buyouts conducted sooner rather than later prevent homeowners from making
repairs and investing funds in properties that they then may not want to sell.
In the case of infrastructure resiliency solutions, improvements may include:
 Elevating critical systems, facilities, and roadways above base flood elevation;
 Installing backup power generators for critical systems (water, sewer, etc.);
 Avoiding an increase in impervious cover by keeping projects in their original footprint
and encouraging the use of building practices that allow for more pervious coverage;
 Replanting with only native vegetation to preserve the natural environment;
 Storm water management including installing retention basins, larger culverts and debris
guards, erosion control solutions;
 Back-up communication systems; and
 Supporting local community efforts to enhance building codes and regulations.
The resiliency multiplier will be a standard 15 percent for both housing and infrastructure activities
to calculate unmet need, as has previously been applied in other Texas CDBG-DR programs.
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D. Demographic Profile of Impacted Counties
The demographic profile data was generated using a wide range of data sets from the U.S. Census
Bureau, unless otherwise noted. The 49 CDBG-DR eligible counties affected by Hurricane Harvey
cover 15 percent, or 39,496 square miles of the state, and contain approximately 32 percent of the
state’s population. This equals nearly 9 million Texans living in the eligible counties. These
counties have seen almost a 1 million person, or 12 percent, increase from 2010 to 2016.
Of the 3.4 million housing units in the eligible counties in 2016, 62.5 percent are owner-occupied
units. Some housing and income demographics are slightly different in the eligible counties versus
the statewide averages. The 49 eligible counties have an estimated median owner-occupied
housing unit value and median household income lower than the state as a whole. The median
value of owner-occupied housing units is $105,800 —almost $37,000 less than the statewide
median value of $142,700. The 49 eligible counties have a median household income of $50,145
– $4,582 less than the statewide average of $54,727. In addition to a lower median household
income, the per capita income is also lower than the state as a whole. Approximately 14.9 percent
of the population in the 49 eligible counties is living in poverty. This is just less than the statewide
average of 15.6 percent.
By percentage, the 49 eligible counties have a higher African-American population when

compared to the state as a whole. The 49 eligible counties have a 16.3 percent African-American
population—approximately 3.6 percent higher than the statewide total. The minority population as
a whole in all 49 eligible counties is approximately 60 percent —2.5 percent higher than the
statewide total.
In the 49 eligible counties, veterans account for 4.9 percent of the population; the elderly account
for 12.02 percent; and disabled persons under the age of 65 account for 7.54 percent of the
population. These numbers are in line with state averages.
49 CDBG-DR Eligible
Texas
Counties
Percent of
Fact Estimates Estimates
Area
32% of Texas
Population estimates, 2017 28,304,596 8,999,345
Population
Population, percent change - April
1, 2010, (estimates base) to July 1, 12.60% 14%
2017
7.24% of
Persons under 5 years, percent,
7.20% 651,207 Eligible
2017
Population
26.10% of
Persons under 18 years, percent,
26.00% 2,349,074 Eligible
2017
Population
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49 CDBG-DR Eligible
Texas
Counties
Percent of
Fact Estimates Estimates
Area
12.02% of
Persons 65 years and over, percent,
12.30% 1,082,155 Eligible
2017
Population
White alone, percent, 2017 79.20% 6,673,001 74.15%
Black or African American alone,
12.70% 1,467,075 16.30%
percent, 2017
American Indian and Alaska Native
1.00% 90,271 1.00%
alone, percent, 2017
Asian alone, percent, 2017 5.00% 586,911 6.52%
Native Hawaiian and Other Pacific
0.10% 9,040 0.10%
Islander alone, percent, 2017
Two or More Races, percent, 2017 2.00% 168,571 1.87%
Hispanic or Latino, percent, 2017 39.40% 3,340,948 37.12%
White alone, not Hispanic or
42.00% 3,551,047 39.46%
Latino, percent, 2017
Housing units, 2017 10,932,870 3,500,524
Owner-occupied housing unit rate, 62.5% of
61.90% 2,152,669
2012-2016 Housing Units
Median value of owner-occupied
$142,700 $105,800
housing units, 2012-2016
Median gross rent, 2012-2016 $911 $777
7.54% of
With a disability, under age 65
8.10% 678,268 Eligible
years, percent, 2012-2016
Population
Median household income (in 2016
$54,727 $50,145
dollars), 2012-2016
14.9% of
Persons in poverty, percent 15.60% Eligible
Population
Land area in square miles, 2010 261,231.71 39,496 15% of Texas
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E. Low- and Moderate-Income Analysis
The following map identifies census block groups that have a low- and moderate-income (LMI)
population of 51 percent or more for the 49 eligible counties using HUD’s 2018 LMI Summary
Data (LMISD) for the state of Texas.10
Figure 7: Percentage of LMI Population by Block Group (Updated in APA 2)
F. Social Vulnerability Index
An additional component to consider when looking at unmet needs for impacted counties in Texas
is what level of social vulnerability to natural hazards are they experiencing. The Social
Vulnerability Index (SoVI) measures the social vulnerability of counties across the United States
— in particular, their vulnerability to environmental hazards. This index, developed by the
University of South Carolina’s Hazards & Vulnerability Research Institute, synthesizes 29
socioeconomic variables which contribute to reduction in a community’s ability to prepare for,
respond to, and recover from hazards. SoVI is a comparative metric that facilitates the examination
of the differences in vulnerability among counties. It is a valuable tool because it graphically
10
HUD Exchange. “FY 2017 LMISD by State - All Block Groups, Based on 2006-2010 American Community
Survey.” Webpage accessed January 10, 2018. https://www.hudexchange.info/programs/acs-low-mod-summary-
data/acs-low-mod-summary-data-block-groups-places/
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illustrates the geographic variation in social vulnerability, which in turn contributes greatly to
response and recovery capabilities. SoVI shows where there is uneven capacity for disaster
preparedness and response, and where resources might be used most effectively to reduce pre-
existing vulnerability. The data sources for the development of SoVI come primarily from the
United States Census Bureau. The SoVI data combines the best available data from both the 2010
U.S. Decennial Census and five-year estimates from the American Community Survey (ACS). The
below map demonstrates the SoVI for the 49 CGBG-DR eligible counties in Texas. Additionally,
the SoVI scores at the Census Tract level provides a more granular assessment of vulnerability
within each county.
The SoVI details above are further explained by some of the characteristics at the individual level
that affect vulnerability. One of these characteristics is that of Socioeconomic Status which affects
the ability of a community to absorb losses and be resilient to hazard impacts. This is due to the
idea that wealth enables communities to absorb and recover from losses using insurance, social
safety nets, and entitlement programs. Other factors used in SoVI relate to gender as well as race
and ethnicity being that these factors impose language and cultural barriers and affect access to
post-disaster funding. Additional factors used in SoVI are special-needs populations, social
dependence (i.e. people who are totally dependent on social services for survival), education,
family structure, occupation, and other demographic characteristics that help to define social
vulnerability for communities and individuals.
Effectively addressing social vulnerability decreases both human suffering and the economic loss
related to providing social services and public assistance after a disaster. While a stand-alone
component when compared to total unmet need and other factors like per capita unmet need, the
SoVI contributes to the ultimate funding decision process by adding a layer that looks at the
components involved closely with an individual’s or community’s effort to recover from a disaster
event. The SoVI is then coupled with total unmet need and unmet need per capita to distribute
funds.
Counties with highest vulnerability when compared relatively to each other are Bee, Karnes,
Madison, and Jim Wells. Counties with some of the lowest vulnerability are Fort Bend, Brazoria,
and Chambers.
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Figure 8: County SoVI by Category
G. Housing Impact
1. Real Estate Market
The housing real estate market in Texas remains strong with a high housing demand and a tight
supply. As stated by Texas A&M’s Real Estate Center’s August 2017 report prior to Hurricane
Harvey, the months of inventory of Texas houses increased to 3.9 months for the first time
since 2014; this indicates strong housing demand and tight supply. Around 6 months of
inventory is considered a balanced housing market. Texas housing affordability continues to
worsen due to limited supply for homes under $300,000, along with increasing construction
Page 35 of 420
costs.11 In an already tight market, the loss of housing associated with Hurricane Harvey only
compounds affordability issues in the state.
The housing markets on the Gulf Coast dipped substantially in August due to Hurricane
Harvey; however, the market saw a large rebound in September. Housing sales that were
delayed because of Hurricane Harvey in August caused a 2.6 percent increase in September,
as those sales were executed post-storm. Third quarter increases in vacant, developed lots also
generated a 5.4 percent monthly increase in single family housing construction permits. This
increase was directly related to recovery efforts in places like Houston. 12
2. Homelessness
Based on the assessment regarding pre-disaster homeless persons and the GLO’s work with
other state agencies and organizations, the state is working to address the needs of pre-disaster
homeless persons.
In January 2017, Texas accounted for 4.25 percent of the nation’s total homeless population.
However, given the size and population of the state, Texas has seen one of the largest decreases
(30.8 percent decline) in homelessness from 2012 to 2017. The point-in-time count (PTI)
revealed that 23,548 persons in the state were physically counted as homeless in January
2017.13 From January 2016 to January 2017, there was a slight increase of 1.8 percent in the
Texas total homeless population.
The HUD 2017 Continuum of Care (CoC) data reports 29.05 percent of the total homeless
population in the state is comprised of households with one adult and at least one child under
the age of 18 years.14
Post-disaster homelessness information is not available at the time of drafting of this Action
Plan. The 2018 PTI count was conducted in January. The results of this count are not available.
A CoC is the group of representatives that takes on the coordination of homeless services and
homelessness prevention activities across a specified geographic area and that implements
community-wide, coordinated efforts for assessing and addressing the housing and service
needs of individuals and families that are homeless or at risk of homelessness.
a) State Homeless Support Services
11
Texas A&M Real Estate Center. “Outlook for the Texas Economy.” Webpage accessed January 10, 2018.
https://www.recenter.tamu.edu/articles/technical-report/outlook-for-the-texas-economy
12
Texas A&M Real Estate Center. “November 2017 Housing Reports by MSAs.” (data as of October 31, 2017)
13
HUD Exchange. “2007 – 2017 Point – Time Counts by CoC.” Webpage/Excel document accessed January 10,
2018. https://www.hudexchange.info/resources/documents/2007-2017-PIT-Counts-by-CoC.xlsx
14
HUD Exchange. “2017 Continuum of Care Homeless Assistance Programs Homeless Populations and
Subpopulations.” Webpage accessed January 10, 2018. https://www.hudexchange.info/resource/reportmanagement
/published/CoC_PopSub_CoC_OH-507-2017_OH_2017.pdf
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Texas has a fairly widespread and robust homeless support services program. The Texas
Homeless Network is a statewide nonprofit organization funded in part by the Texas
Department of Housing and Community Affairs (TDHCA) and the Texas Department of
State Health Service (DSHS). The Texas Homeless Network provides training and
technical assistance around the state to help service providers and communities better serve
the homeless population with the end goal of preventing and ending homelessness. 15
TDHCA’s Homeless Housing and Services Program (HHSP) provides funding to the eight
largest cities in support of services to homeless individuals and families. The cities
currently served through HHSP are Arlington, Austin, Corpus Christi, Dallas, El Paso, Fort
Worth, Houston, and San Antonio. For FY 2015, 2016, and 2017, $15 million has been
allocated to HHSP. The allowable activities include construction, development, or
procurement of housing for homeless persons; rehabilitation of structures targeted to
serving homeless persons or persons at risk of homelessness; provision of direct services
and case management to homeless persons or persons at risk of homelessness; or other
homelessness-related activities.
The Emergency Solutions Grants (ESG) program, formerly the Emergency Shelter Grants
Program, is a competitive grant that awards funds to private nonprofit organizations, cities,
and counties in the state of Texas to provide the services necessary to help persons that are
at risk of homelessness or homeless quickly regain stability in permanent housing. The
ESG program is funded by HUD and is administered by TDHCA. In 2016 and 2017,
TDHCA has awarded over $17 million to eligible subrecipients battling homelessness
across the state.
The Texas HOME Disaster Relief program is administered by TDHCA. The program is
available to local governments, nonprofit organizations, and public housing authorities
within a federal or state-declared county to serve households earning at or below 80 percent
Area Median Family Income (AMFI). Eligible activities include the HOMEowner
Rehabilitation Assistance Program, Tenant-Based Rental Assistance Program, and
HOMEbuyer Assistance Program. As of December 2017, over $10 million is available in
the Texas HOME Disaster Relief Program.16
Additionally, the Texas Interagency Council for the Homeless (TICH) was established in
1995 and coordinates the state’s resources and services to address homelessness. TICH
serves as an advisory committee to TDHCA. Representatives from 11 state agencies sit on
the council, along with members appointed by the governor, lieutenant governor, and
speaker of the house of representatives.17 The council’s duties include:
 Survey current resources for services for the homeless in the state;
 Assist in coordinating and providing statewide services for all homeless individuals;
15
Texas Homeless Network. Webpage accessed January 10, 2018. http://www.thn.org/
16
TDHCA. “HOME Disaster Relief Program.” Webpage accessed January 10, 2018.
http://www.tdhca.state.tx.us/home-division/disaster-relief.htm
17
TDHCA. “Texas Interagency Council for the Homeless” (TICH). Webpage accessed January 10, 2018.
http://www.tdhca.state.tx.us/tich/
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 Increase the flow of information among separate providers and appropriate authorities;
 Provide technical assistance to TDHCA in assessing the need for housing for
individuals with special needs in different localities; and
 Maintain a centralized resource and information center for homeless services.
The Department of State Health Services (DSHS) Projects for Assistance in Transition
from Homelessness (PATH) program provides outreach in the form of (1) screening,
diagnostic assessment, and treatment; (2) habitation and rehabilitation; (3) community
mental health services; (4) outpatient alcohol or drug treatment; (5) staff training and case
management; (6) referrals for primary health services, job training, educational services
(including HIV prevention activities), and relevant housing services; (7) assistance in
obtaining income support services including Social Security Income and representative
payee per appropriate regulations; (8) housing services including planning for housing; (9)
technical assistance in applying for housing assistance; and (10) improving coordination
of housing and services and the costs of matching individuals with appropriate housing and
services. The service areas are Amarillo, Austin, Beaumont, Conroe, Corpus Christi,
Dallas, El Paso, Fort Worth, Galveston, Harlingen, Houston, Laredo, Lubbock, San
Antonio, and Waco.
Additionally, the Community Services Block Grant program is administered by TDHCA.

For program years 2015 to 2018, over $120 million has been awarded to eligible entities
across Texas for the delivery of services to very low-income Texas residents. The services
are designed to eliminate poverty and foster self-sufficiency. 18
Even though data related to homelessness is still very preliminary, it seems apparent based
on the number of housing units damaged and destroyed, the already tight Texas housing
market, the number of Texans needing temporary sheltering assistance through FEMA that
there is a high likelihood of Texans continuing to struggle with housing needs.
3. Social Services: 2-1-1 Texas Program
The Texas HHSC 2-1-1 Texas program helps Texas citizens connect with state and local health
and human services programs service by phone or internet. THHSC works through 25 Area
Information Centers (AICs) across the state. 2-1-1 Texas is a free, anonymous, social service
hotline available 24-hours a day, 7 days a week, 365 days a year. State and local health and
human services programs address housing/shelter, employment, food/nutrition, veterans,
crisis/emergency, income/expenses, legal aid/victims, criminal justice, aging/disability,
health/medical, mental health, and child care/education.
According to information received by the GLO from the HHSC, 2-1-1 staff observed a 37
percent increase in call volume beginning Thursday, August 24, 2017. Top caller needs
included calls from the public requesting general evacuation information and evacuation
transportation and calls from city and county emergency services. On Friday, August 25, 2017,
18
TDHCA. “Community Services Block Grant (CSBG).” Webpage accessed January 10, 2018.
http://www.tdhca.state.tx.us/community-affairs/csbg/index.htm
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Texas Information and Referral Network (TIRN) staff created a new menu option that routed
callers with Hurricane Harvey needs to the first available agent statewide, thus prioritizing
those callers.
Between August 25 and October 31, 2017, the 2-1-1 TIRN received approximately 670,000
calls. The call summary below shows the volume of calls received pre-Harvey, during Harvey
(August 25–September 30) and post-Harvey.
The table below shows the approximate number of calls divided into time periods before,
during, and immediately following Hurricane Harvey, as well as post-Hurricane Harvey. In the
period during Hurricane Harvey and directly after, there was a large jump in State of Texas
Emergency Assistance Registry (STEAR) calls. STEAR is a free registry that provides local
emergency planners and emergency responders with additional information about the needs in
their local community. This program allows the public to add their information to the registry
if they feel they will require additional assistance during an emergency or disaster event.
Option 1, 4, 8 Option 5
Total
(TIRN Agents) (TIRN Agents)
Calls Pre-Hurricane Harvey:
154,509 N/A 154,509
August 1–24, 2017
Calls during Hurricane Harvey:
282,811 170,105 452,916
August 25–September 30, 2017
Calls post-Hurricane Harvey:
177,800 36,577 214,377
October 1–31, 2017
Legend:
 Option 1: Community Resources Information and Referral Calls.
 Option 4: STEAR Registration Calls.
 Option 5: Harvey-Related Disaster Calls.
 Option 8: Mental Health and Substance Abuses Information and Referral Calls.
The types of needs also varied during these time periods. Prior to Hurricane Harvey, the top
two needs TIRN agents addressed were calls about were electric service payment assistance
and rent payment assistance. During and directly following the hurricane, the top two needs
were disaster food stamps and electric payment assistance. Disaster food stamps were available
through Texas Health and Human Services Disaster Supplemental Nutrition Assistance
Program (D-SNAP) to provide short-term food assistance benefits to families recovering from
a disaster.19
The following chart shows top 10 needs of calls received and the volume of calls for the period
during and directly following Hurricane Harvey.
19
Texas Health and Human Services. “Disaster SNAP.” Webpage accessed January 10, 2018.
https://hhs.texas.gov/services/financial/disaster-assistance/disaster-snap
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Figure 9: Top 10 call types from August 23–September 30, 2017
The latest numbers, as of December 19, 2017, show that while calls have decreased somewhat,
TIRN is still experiencing a higher call volume than prior to Hurricane Harvey. Also, the types
of calls show that the call center is still receiving calls related directly to disaster recovery from
Hurricane Harvey, as seen in the following chart.
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Figure 10: Top 10 call types from November 1–December 19, 2017
The above 2-1-1 call data provides a helpful assessment on what needs and services are being
requested by callers statewide. The data is an indicator for the need for types of services, such
as utility and rental assistance. The data was not used to quantify funding decisions.
4. Interim Housing Assistance
On September 14, 2017, Governor Greg Abbott designated the GLO as the state lead for short-
term housing recovery programs in partnership with FEMA. These programs are intended to
provide direct housing solutions for permanent repairs and temporary solutions to applicants
deemed eligible by FEMA. The GLO will continue to administer these programs until February
25, 2019. Program descriptions include:
a) Multi-Family Lease and Repair
This program provides repairs to existing multi-family housing, such as apartments, in order
to provide more housing for eligible applicants. By accepting repairs, property owners must
agree to lease to eligible applicants for up to 18 months (February 2019) following the
disaster declaration. This program provides much needed housing for applicants, as well as
much needed repairs to multi-family housing units that may have been impacted during the
disaster. At the end of 18 months, the temporary assistance ends for the applicants.
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b) Direct Lease
This program allows the GLO and its subrecipients to enter into leases for properties.
Through the utilization of these properties, the program provides housing for eligible
applicants for up to 18 months (February 2019) following the disaster declaration. At the end
of 18 months, the temporary assistance ends for the applicants.
c) Manufactured Housing Options
This program places manufactured housing units, such as mobile homes and travel trailers,
on private land or commercial pads to temporarily house eligible applicants for up to 18
months (February 2019) following the disaster declaration. At the end of 18 months, the
temporary assistance ends for the applicants.
d) Direct Assistance for Limited Home Repair
This program provides permanent partial repairs to homes with significant damage. Repairs
cannot exceed the lesser of 50 percent of the home’s fair market value (FMV) or $60,000.
e) Partial Repair and Essential Power for Sheltering (PREPS)
This program provides temporary repairs of up to $20,000 for homes with less than $17,000
in damage. Temporary repairs may include window units, one (1) functional bathroom, and
small cooking appliances to ensure that the home can serve as a shelter for eligible
homeowners. PREPS requires 10 percent cost share from the state.
5. Insurance
The Texas Department of Insurance’s (TDI) April 12, 2018 presentation to the Texas House
Insurance Committee which uses data through October 31, 2017, is the most recent report on
the data collected from insurance companies, the financial impact of Hurricane Harvey, and
the monitoring of claims handling. 20
The TDI data request required companies to report the following: the number of reported
claims, the number of claims closed with payment (paid claims), the number of claims closed
without payment, the number of reopened claims, the number of claims with total losses, the
total amount of paid losses, and the total amount of claim reserves. The data request required
that companies report this data separately for following types of insurance: homeowners,
residential dwelling, mobile homeowners, farm owners, business owners, the business
interruption portion of commercial property, all other commercial property, personal
automobile, commercial automobile, federal flood – Write Your Own (does not include
policies written directly by the NFIP), private flood, and all other lines of insurance.
20
Texas Department of Insurance. “Hurricane Harvey Data Call — Presentation to the House Insurance
Committee.” April 12, 2018. https://www.tdi.texas.gov/reports/documents/harvey-house-data-call-04122018.pdf
Page 42 of 420
The data request included 58 counties in Governor Abbott’s August 28, 2017 disaster
proclamation, plus Williamson, Travis, Hays, and Hidalgo Counties. Milam and San Augustine
Counties, which Governor Abbott added in the September 14, 2017 disaster proclamation,
were not included.
Figure 11: Hurricane Harvey Data Call Counties - Region Map
More than 99 percent of the total property and automobile market in Texas — 930 insurance
companies — responded to the data request by either providing data or responding that they
have no Hurricane Harvey data to report. TDI requested that the data be submitted by insurance
companies by October 31, 2017, for data through September 30, 2017.
Number of Claims
A total of about 717,000 claims were filed with private insurers, TWIA, and the Texas Fair
Access to Insurance Requirement (FAIR) Plan Association (TFAIRPA) for all personal and
commercial lines of insurance. This included about 387,000 residential property claims and
207,000 automobile claims. Residential property consists of 246,000 homeowner claims,
123,000 residential dwelling claims, and 18,000 mobile homeowners claims.
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Insurance companies have made about $7.7 billion in claim payments (paid losses), and at the
time of TID’s report they estimate they would ultimately pay a total of $19.4 billion. The
amounts will change as more claims are reported, settled, and closed.
The majority of claims are for residential property insurance in the amount of $2.5 billion in
gross losses, and $1.4 billion in paid claims. However, most of the losses are from flood and
automobile claims. Automobile insurance commonly covers flood damage under
“comprehensive” coverage, while residential property insurance does not typically provide
coverage for flood damage.
Federal flood insurance – Write Your Own (does not include policies written directly by the
NFIP) and private flood insurance reported a total of $8.4 billion in gross losses and $3.1 billion
in losses paid.
Figure 12: Total Reported Claims, Amount of Losses Paid, and Estimated Ultimate Gross
Losses by Insurance Type (Updated in APA 2)21
Based on data from the insurers’ initial reporting for residential property, approximately 40
percent of residential property claims are paid (closed with a loss payment), 35 percent of
claims are closed without a loss payment, 25 percent of claims are still open, and 11 percent
of claims have been reopened for all types of insurance.
A claim that is open may involve partial payments, such as payments for additional living
expenses or business interruption, as well as payments for damage.
A claim without payment may have been closed due to the following: the damage fell below
the deductible, the damage resulted from a peril that was not covered under the policy, the
policyholder did not have a policy in effect at the time the damage occurred, or the claim was
a duplicate claim.
21
Texas Department of Insurance. “Hurricane Harvey Data Call — Presentation to the House Insurance
Committee.” April 12, 2018. https://www.tdi.texas.gov/reports/documents/Harvey-20180123.pdf
Page 44 of 420
Figure 13: Number of Claims by Settlement Status and Insurance Type (Updated in APA 2)
Residential Property
The following chart shows the number of residential property claims by settlement status and
area. For the counties included in area breakdown, refer to Figure 11: Hurricane Harvey Data
Call Counties - Region Map. Residential property insurance includes homeowners, mobile
homeowners, and residential dwelling insurance. More than 90 percent of residential property
claims resulting from Hurricane Harvey are in the Coastal Bend or Houston Area regions.
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Figure 14: Number of Residential Property Claims by Settlement Status and Area (Updated in
APA 2)
The Coastal Bend Region has a disproportionate amount loss – 51 percent – compared to the
overall percentage of claims – 24 percent. The Coastal Bend region also had the highest
average residential property loss when compared to other regions.
Figures 15: Residential Property Average Paid Loss and Average Incurred Loss by Area
(Updated in APA 2)
Page 46 of 420
6. National Flood Insurance Program
The NFIP is a FEMA program that works to provide affordable insurance to property owners
in participating communities and works to encourage communities to adopt and enforce
floodplain management regulations. In areas at high risk of flooding, Congress has mandated
that federally regulated or insured lenders require flood insurance on mortgaged properties. 22
The NFIP offers two types of flood insurance coverage for homeowners: building property
coverage up to $250,000; and personal property coverage (contents) up to $100,000. 23
The following information provided by FEMA as of July 31, 2018 shows the major increase
in NFIP claims in the state of Texas as a direct result of Hurricane Harvey. More than 91,000
claims were filed for losses incurred between August 23, 2017 and September 5, 2017. As of
July 31, 2018, 843 (less than 1 percent) of these claims remained active/open with more than
90,000 (over 99 percent) claims closed. There are approximately 15,000 (16 percent) claims
closed without payment. In total, more than $8.82 billion has been paid out on claims made
during this period with the average of all payments for closed claims with payments being
$115,906. With the data broken down daily during that time, a large jump in claims began on
August 25, the day Hurricane Harvey made landfall.
Figure 16: NFIP Claims Filed in Texas (June-Oct, 2017) By Date of Loss (as of July 31,
2018) (Updated in APA 2)
22
FEMA. “The National Flood Insurance Program.” Webpage accessed January 10, 2018.
https://www.fema.gov/national-flood-insurance-program
23
FEMA. “NFIP Summary of Coverage.” Webpage/PDF accessed January 10, 2018. https://www.fema.gov
/media-library-data /20130726-1620-20490-4648/f_679_summaryofcoverage_11_2012.pdf
Page 47 of 420
Figure 17: NFIP Claims Filed in Texas (Aug 23-Sept 5, 2017) By Date of Loss (Updated in
APA 2)
As the claims are broken down into geographic areas, it is even more evident that the claims
are Hurricane Harvey-related, as the biggest number of claims are coming from areas that are
included in the 49 eligible counties, with the largest number of claims coming from the
Houston area.
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Figure 18: NFIP Claims Filed Aug 23-Sept 5, 2017 by City (2,000 Claims or More) (Updated
in APA 2)
The NFIP data identifies insurance claims that fall into the Repetitive Loss (RL) category. An
RL property is any insurable building for which two or more claims of more than $1,000 were
paid. There are over 120,000 RL properties nationwide, with Texas having more than 27,000.
These RL structures strain the NFIP fund, and currently are the biggest draw on the fund. They
not only increase the NFIP’s annual losses (increasing the need for borrowing), but drain fund
reserves needed to address future catastrophic events. 24
Based on the most recent NFIP data provided to the GLO, Hurricane Harvey resulted in
approximately 13,826 NFIP claims designated as RL as of July 31, 2018. The vast majority of
these claims—9,050 or 65 percent—were made in Harris County. The following graph
highlights the counties with the largest numbers of RL properties that were reported during
this period (accounting for 96 percent of RL properties).
Figure 19: NFIP RL Homes by Select Counties Reporting Loss During Harvey (Updated in
APA 2)
Additionally, the following map shows the concentration of RL properties with Hurricane
Harvey claims by ZIP code. While there may be a correlation between ZIP codes and those RL
properties along rivers such as the Guadalupe River, there is a high concentration of RL
properties located throughout Harris County.
24
FEMA. “Repetitive Loss FAQ.” Webpage/Text accessed January 10, 2018.
https://www.fema.gov/txt/rebuild/repetitive_loss_faqs.txt
Page 49 of 420
Figure 20: NFIP RL Claims by ZIP Code (August 23 – September 5, 2017) (Updated in APA
2)
7. Texas Windstorm Insurance Association
The Texas Windstorm Insurance Association (TWIA) 25 was established by the Texas
Legislature in 1971 in response to regional market conditions following Hurricane Celia in
August 1970. TWIA’s purpose is to provide windstorm and hail insurance for the Texas
seacoast.
TWIA is the insurer of last resort and is not a direct competitor of the voluntary insurance
market. It provides coverage to residential and commercial properties in certain designated
25
https://www.twia.org/
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portions of the Texas seacoast territory. The designated catastrophe area is that portion of the
seacoast territory where the Commissioner of Insurance has found that windstorm and hail
insurance is not reasonably available.
The number of TWIA claims filed for Hurricane Harvey as of January 23, 2018 totaled 74,266,
with the highest number of claims, 24,967 or 34 percent, made in Nueces County. The map
below identifies the TWIA eligible counties along the Texas Gulf Coast within in the impacted
area and the number of claims within each TWIA eligible county. It should be noted that only
a small portion of Harris County is eligible for TWIA coverage. Total indemnity payments,
which are the losses paid or expected to be paid directly to an insured for first-party coverages,
totaled over $958 million. Paid expenses, which are expenses of adjusting claims that cannot
be charged against specific claims, totaled over $101 million. The highest total average paid
for claims is found in Aransas County with an average of $68,149 per claim. The lowest
average paid for claims was in Kleberg County with an average of $3,938 per claim. Kleberg
County also demonstrated the lowest number of new claims with 38.
New Closed Open % Paid Paid Average

County
Claims Claims Inventory Closed Indemnity Expense Paid
Aransas 7,078 5,623 1,455 79.4% $411,754,777 $17,477,609 $68,149
Brazoria 4,035 3,911 124 96.9% $10,328,579 $4,375,109 $6,484
Calhoun 2,553 2,391 162 93.7% $24,066,466 $3,848,723 $11,908
Cameron* 40 36 4 90.0% $872,656 $132,926 $58,177
Chambers 1,002 975 27 97.3% $3,442,032 $1,121,065 $7,931
Galveston 11,025 10,608 417 96.2% $34,920,052 $13,338,808 $7,474
Harris 593 565 28 95.3% $3,046,684 $744,287 $9,260
Jefferson 9,893 9,511 382 96.1% $29,189,030 $10,494,094 $6,197
Kleberg 38 38 - 100.0% $102,390 $36,200 $3,938
Matagorda 869 851 18 97.9% $3,743,109 $996,054 $6,830
Nueces 24,967 23,418 1,549 93.8% $327,009,711 $36,483,090 $16,247
Refugio 414 349 65 84.3% $15,996,605 $904,222 $45,705
San
6,710 6,188 522 92.2% $94,316,008 $11,590,970 $16,924
Patricio
No Policy
& 5,049 5,040 9 99.8% $0 $0 $0
Unverified
Grand
74,266 69,504 4,762 93.6% $958,788,099 $101,543,157 $17,994
Total
Page 51 of 420
Figure 21: TWIA Harvey Claims by County (as of January 23, 2018).
8. Small Business Assistance Disaster Home Loans
Another resource for homeowners that sustained damage from Hurricane Harvey is SBA
disaster loans. These loans are the basic form of federal disaster assistance for homeowners
whose private property sustained damage that is not fully covered by insurance. Homeowners
and renters whose property was damaged by a declared disaster can apply for an SBA low-
interest loan. Interest rates on these loans are determined by law and are assigned on a case by
case basis.
Specific to Hurricane Harvey assistance, interest rates are 1.75 percent if the applicant does
not have credit available elsewhere and 3.5 percent if credit is available elsewhere. The home
loans are limited to $200,000 for the repair or replacement of real estate and $40,000 maximum
to repair or replace personal property. 26
26
U.S. Small Business Administration Fact Sheet. November 7, 2017. “Disaster Loans, Texas Declaration #15274
and #15275.” https://smallbusiness.house.gov/uploadedfiles/attachment_1.pdf
Page 52 of 420
As of August 28, 2018, over $2.9 billion in home loans have been approved by the SBA. A
breakdown of the approved loans is categorized by county and COG in the table below.
County COG Total Home Loans

KARNES AACOG $ 297,000
Total AACOG $ 297,000
GRIMES BVCOG $ 134,100
Total BVCOG $ 134,100
BASTROP CAPCOG $ 1,105,500
CALDWELL CAPCOG $ 581,600
FAYETTE CAPCOG $ 4,180,600
LEE CAPCOG $ 135,500
Total CAPCOG $ 6,003,200
ARANSAS CBCOG $ 73,380,300
BEE CBCOG $ 1,866,000
KLEBERG CBCOG $ 259,200
NUECES CBCOG $ 69,292,700
REFUGIO CBCOG $ 10,537,300
SAN PATRICIO CBCOG $ 37,380,900
Total CBCOG $ 192,716,400
JASPER DETCOG $ 4,339,600
NEWTON DETCOG $ 6,527,200
POLK DETCOG $ 1,709,500
SABINE DETCOG $ 36,300
SAN JACINTO DETCOG $ 3,102,100
TYLER DETCOG $ 2,047,800
Total DETCOG $ 17,762,500
CALHOUN GCRPC $ 9,663,300
DEWITT GCRPC $ 1,520,400
GOLIAD GCRPC $ 2,115,400
GONZALES GCRPC $ 319,700
JACKSON GCRPC $ 1,303,000
LAVACA GCRPC $ 767,000
VICTORIA GCRPC $ 24,653,100
Total GCRPC $ 40,341,900
AUSTIN H-GAC $ 1,376,300
BRAZORIA H-GAC $ 127,415,700
CHAMBERS H-GAC $ 52,825,900
COLORADO H-GAC $ 962,700
FORT BEND H-GAC $ 288,298,400
GALVESTON H-GAC $ 233,625,600
Page 53 of 420
County COG Total Home Loans
HARRIS H-GAC $ 1,237,462,400
LIBERTY H-GAC $ 28,496,500
MATAGORDA H-GAC $ 6,294,900
H-GAC $ 58,620,000
MONTGOMERY
WALKER H-GAC $ 1,021,200
WALLER H-GAC $ 5,713,000
WHARTON H-GAC $ 18,732,200
Total H-GAC $ 2,060,844,800
HARDIN SETRPC $ 104,323,400
JEFFERSON SETRPC $ 268,239,700
ORANGE SETRPC $ 262,425,100
Total SETRPC $ 634,988,200
GRAND $ 2,953,088,100
TOTAL
9. Public Housing Authority Data
The impact on public housing authority units, Section 8, and Housing Choice Vouchers was
provided to the GLO by the HUD. In November 2017, HUD collected preliminary damage
estimates and the number of units impacted. The CBCOG, H-GAC, and SETRPC had the
highest number of public housing units impacted.
Current
Section 8 or Displaced
Housing (# of
Choice Total Household
Vouchers - Public Housing Impacted for PHA Damage
COG Impacted Units Impacted Units PIH/MF) Estimate
AACOG 0 46 46 0 $6,080
BVCOG 0 0 0 0 -
CAPCOG 0 8 8 0 $71,413
CBCOG 97 313 410 179 $8,663,600
DETCOG 2 19 21 2 $146,755
GCRPC 16 120 136 17 $1,347,300
H-GAC 345 234 579 399 $12,431,369
SETRPC 365 323 688 387 $2,924,300
Statewide 48 0 48 48 -
Grand Total 873 1,063 1,936 1,032 $25,590,817
Public housing authorities are eligible for FEMA PA. As of June 8, 2018, the following table
shows the FEMA PA projected costs provided by FEMA and unmet need for public housing
authorities by COG region. Due to the 90 percent federal cost share tied to the approximate
Page 54 of 420
cost amount, the total PA unmet need will be calculated from the remaining 10 percent of the
projected cost amount plus 15 percent of the approximate cost as a resiliency multiplier.
Estimates for permanent work will continue to be forthcoming over the next several months,
as shown between the damages estimated that HUD collected in November and the projected
costs that the public housing authorities have submitted to the FEMA PA program.
COG Projected Cost Unmet Need

CBCOG $1,510,995 $377,749
GCRPC $480,802 $120,201
H-GAC $49,311,183 $12,327,796
SETRPC $19,156,868 $4,789,217
Grand Total $70,459,848 $17,614,962
The Harris County Housing Authority (HCHA) and Houston Housing Authority (HHA)
account for 70 percent of the public housing authorities’ unmet needs. The city of Houston and
Harris County will develop their own programs to address the unmet needs for their public
housing authorities.
10. FEMA Individual Assistance
The Individual Assistance (IA) data received from FEMA and dated as of June 25, 2018, was
used to quantify all housing applicants impacted by Hurricane Harvey. This information was
then used to calculate the unmet need by county and COG and divided into renter and owner
subsets. More than 892,000 applications were received according to FEMA. Of that number,
FEMA verified that over 291,000 applicants had a FEMA Verified Loss (FVL) over $0.
The total number of owner-occupied applicants in the eligible counties with over $8,000 in
real property damage is 94,699. The total number of renter applicants in the eligible counties
with over $2,000 in personal property damage is 37,746.
Using the above thresholds to calculate unmet need, 94,699 (71.5 percent) of the 132,458
applicants are owner-occupied homes, while 37,746 (28.5 percent) are renters.
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Occupancy Type Total Applications FVL Over $0 Applicants with
Unmet Need
Owner 444,180 211,423 94,699
Renter 443,741 80,271 37,746
Not Specified 4,342 115 13
Totals 892,263 291,809 132,458
a. Total Unmet Needs
The GLO has compiled information from FEMA for individual assistance in order to
document estimated repair costs and unmet housing needs by eligible county. The
population structure used includes owner-occupied households and renter households. For
the purpose of this analysis, the GLO is utilizing certain components of HUD’s
methodology for unmet need for both types of households.
Owner-occupied Homes
To calculate the level of real property damage for owner-occupied homes, the following
criteria was used:
 Major-Low: $8,000 to $14,999 of FEMA verified loss.

 Major-High: $15,000 to $28,800 of FEMA verified loss.
 Severe: Greater than $28,800 of FEMA verified loss.
Renter-occupied Homes
To calculate the level of personal property damage for renters, the following criteria was
used:

To calculate estimated unmet need, the GLO used multipliers provided by HUD. These
multipliers are based on the SBA median repair cost for the specific disaster category less
the weighted average of expected SBA and FEMA repair costs. Based on FEMA IA data
provided to the GLO, the estimated weighted average of expected SBA and FEMA total
repair costs for each category is represented in the following table.
Category Multiplier Amount

Major-Low $56,342
Major-High $75,414
Severe $101,390
Page 56 of 420
The following table provides a breakdown of total unmet needs for owner- and renter-
occupied households. It provides the damage category and the total count and unmet need
for those three categories as previously defined.
Total Owner-
Damage Owner- Total Owner
Total Occupied and Rental Total Rental
Category/ Occupied Occupied
Count Rental Unmet Count Unmet Needs
Multiplier Count Unmet Needs
Needs
Major-Low:
46,941 $2,644,749,822 33,657 $1,896,302,694 13,284 $748,447,128
$56,342
Major-High:
63,191 $4,765,486,074 43,374 $3,271,006,836 19,817 $1,494,479,238
$75,414
Severe:
22,,313 $2,262,315,070 17,668 $1,791,358,520 4,645 $470,956,550
$101,390
Total 132,445 $9,672,550,966 94,699 $6,958,668,050 37,746 $2,713,882,916
As defined by the table, the owner-occupied unmet need in dollars is $6.95 billion (72
percent) and the renter unmet need is $2.71 billion (28 percent), resulting in a total unmet
need of $9.67 billion. A breakdown of total unmet need by total cost per county is
represented in the following map.
Page 57 of 420
Figure 22: Total Housing Unmet Need by County (Updated in APA 2)
HUD requirements for this CDBG-DR allocation specify that the GLO must expend a
minimum of 70 percent to benefit LMI populations. The GLO used self-reported applicant
information provided by FEMA to calculate what percentage of the population in the
eligible counties falls into certain income categories. Approximately 46 percent of the
unmet need population is below 80 percent in the LMI category. The unmet need for the
LMI population is almost $4.47 billion. The unmet need by income category for all eligible
counties can be seen in the following table.
Page 58 of 420
% of
% of
Income Category Count Unmet Need Unmet
Count
Need
0-30% 27,994 $1,996,098,916 21.1% 20.6%
31-50% 13,661 $970,608,230 10.3% 10%
51-80% 20,390 $1,469,624,252 15.4% 15.2%
81%-120% 31,004 $2,292,637,312 23.4% 23.7%
Over 120% 22,929 1,728,796,878 17.3% 17.9%
Not Reported 16,480 $1,215,646,064 12.4% 12.6%
Total 132,458 $9,673,411,652 100% 100%
The below map provides an additional layer when looking at a community’s ability to
recover following a disaster. This is the consideration of unmet need per capita for total
owner-occupied and renter households. The amount of unmet need per capita is an
important factor when considering the ability for a community to recover. Unmet need per
capita allows for a more accurate depiction of impacts to rural counties, who may not have
the resources available to recover on their own. In the case of Hurricane Harvey, the ranges
for housing per capita unmet need for the most impacted counties ranges from $182
(Nueces) to $8,195 (Orange).
Page 59 of 420
Figure 23: Total Housing Unmet Need Per Capita (Updated in APA 2)
b. Owner-occupied Unmet Need
A breakdown of unmet need by total cost per county for owner-occupied homes is
represented in the following map.
Page 60 of 420
Figure 24: Owner-occupied Unmet Need by County (Updated in APA 2)
Approximately 39 percent of the owner-occupied unmet need is below 80 percent LMI

category. The unmet need for the LMI population is almost $2.6 billion for owners. The
unmet need by income category for owner-occupied households for all eligible counties
can be seen in the following table. This data informed the GLO on the development of the
Homeowner Assistance Program (HAP), Local Buyout and Acquisition Program, and the
Homeowner Reimbursement Program.
Page 61 of 420
Owner Unmet Need by Unmet Need
Count Unmet Need % of Count
Income Category %
0-30% 13,877 $982,731,782 15% 14%
31-50% 8,419 $597,152,178 9% 9%
51-80% 14,145 $1,016,171,742 15% 15%
81-120% 25,947 $1,926,600,122 27% 28%
Over 120% 20,530 1,553,867,436 22% 22%
Not Reported 11,781 $882,144,790 12% 12%
Total 94,699 $6,958,668,050 100% 100%
c. Renter-occupied Unmet Need
A breakdown of unmet need per county by total cost for rental applicants is represented in
the following map.
Page 62 of 420
Figure 25: Renter Unmet Need by County (Updated in APA 2)
The GLO calculated the percentage of population of renter households within LMI
categories. Approximately 68 percent of the unmet need is below the 80 percent LMI
category. The unmet need for the LMI population is almost $1.84 billion for renters. The
unmet need by income category for renters in all eligible counties can be seen in the
following table. This information informed the Affordable Rental Program which was
designed to provide funds for rehabilitation, reconstruction, and new construction of public
housing and affordable multi-family housing projects in areas impacted by Hurricane
Harvey.
Renters within Harris County and the city of Houston account for 61 percent of unmet need
for renter households. The city of Houston and Harris County will develop their own
programs to address the unmet needs for renters.
Page 63 of 420
Income Count Unmet Need % of Count % of Unmet
Category Need
0-30% 14,115 $1,013,254,450 37% 37%
31-50% 5,240 $373,343,368 14% 14%
51-80% 6,243 $453,320,754 17% 17%
81-120% 5,055 $365,905,434 13% 13%
Over 120% 2,398 $174,8783,100 6% 6
Not Reported 4,695 $333,185,810 12% 12%
Total 37,746 $2,713,882,916 100% 100%
d. Owners in a Floodplain with No Flood Insurance
The number of IA FEMA applicants that show an unmet need totals 132,458. The total
number of owners that are in a floodplain with no flood insurance totals 13,244 (10
percent). The total number of those that are not LMI is 3,949 (30 percent) with the total
being 7,504 (57 percent) that are in an LMI category.
As required by the Federal Register, Vol. 83, No. 28, February 9, 2018, grantees are
prohibited from providing CDBG-DR assistance for the rehabilitation or reconstruction of
a house if the combined households income is greater than 120 percent Area Median
Income (AMI) or the national median, the property was located in a floodplain at the time
of the disaster, and the property owner did not maintain flood insurance on the damaged
property, even when the property owner was not required to obtain and maintain such
insurance.
The table below provides a breakdown of owners in a floodplain with no flood insurance
by income category so that these determinations can begin to be made.
Income Category Count % of Count

0-30% 3,280 25%
31-50% 1,806 14%
51-80% 2,418 18%
81-120% 2,628 20%
Over 120% 1,323 10%
Not Reported 1,,788 14%
Total 13,243 100%
Page 64 of 420
H. Infrastructure Impact
Texas infrastructure all along the Gulf Coast was affected by Hurricane Harvey. This event caused
damage to roadways, bridges, sections of the coastline, and many other infrastructure systems still
being determined.
1. Governor’s Commission to Rebuild Texas
Governor Greg Abbott established the Governor’s Commission to Rebuild Texas (the
Commission) in the immediate aftermath of Hurricane Harvey for the swift and effective
restoration of damaged public infrastructure
throughout disaster impacted areas. As
stated in the Governor’s Proclamation on
September 7, 2017, for the establishment of
the Commission, the effective restoration of
damaged public infrastructure throughout
the disaster area is of paramount importance
to the Texas economy and to the people of
Texas who live and work in the communities
affected by Hurricane Harvey. The
Commission will assist local governmental
entities and nonprofit organizations to assess
and identify rebuilding needs and to
navigate state and federal resources
available for the rebuilding effort. The
Commission will advocate for the interests Source: HOU District Twitter feed – Aug 28, 2017
of state and local governments on matters (https://twitter.com/TxDOTHoustonPIO)
related to disaster response and provide
expertise and assistance to local governmental entities and nonprofit organizations throughout
the rebuilding process.27
The “October 31, 2017, Request for Federal Assistance Critical Infrastructure Projects"
reported $61 billion in projects identified at state and local levels. This amount does not include
current FEMA expenditures or CDBG-DR housing allocations. The $61 billion was compiled
based on information available in September and October from impacted communities that
identified and prioritized their needs. This amount is expected to increase as more information
becomes available.
The types of identified projects include restoration and mitigation projects for roads, bridges,
schools, government buildings, public facilities, as well as projects to protect coastal
27
Rebuild Texas: The Governor’s Commission to Rebuild Texas. “Proclamation.” Webpage accessed January 10,
2018. https://www.rebuildtexas.today/proclamation/
Page 65 of 420
infrastructure, homes, businesses, critical facilities, and national assets such as petrochemical
complexes. Over 60 percent of the projects identified were for flood control projects. 28
2. Texas Coastal Resiliency Study
With previous CDBG-DR funds, the GLO commissioned a Texas Coastal Resiliency Study to
identify critical infrastructure within a coastal multi-county project study area that would be
most vulnerable to future storm events. During this study, sites considered to be at risk were
identified and new projects were proposed to mitigate potential damage to vulnerable
infrastructure. As expected, many of these sites were impacted by Hurricane Harvey, but to
what degree is still being determined. The improvements identified in this study should provide
practical solutions that communities can quickly utilize for repairs and mitigation. This study
identified 2,256 projects in the coastal region. 29
Figure 26: Texas Coastal Resiliency Study Area
28
Ibid. “Request for Federal Assistance Critical Infrastructure Projects.” Webpage/PDF accessed January 10,
2018. https://www.documentcloud.org/documents/4164748-Rebuild-Texas-REQUEST-FOR-FEDERAL-
ASSISTANCE.html
29
The Texas General Land Office. “Texas Coastal Resiliency Study, Final Report.” Webpage/PDF accessed
January 10, 2018. http://www.glo.texas.gov/coastal-grants/_documents/grant-project/texas-coastal-resiliency-
study.pdf
Page 66 of 420
The Texas GLO is also responsible for all 367 miles of Texas beaches. In 2015, the GLO
started the Hurricane Preparedness and Planning initiative to pool local, state, and federal
resources to begin prioritizing efforts to build a resilient Texas coast. This initiative includes a
number of coast-wide studies such as: the Texas Coastal Resiliency Master Plan, Coastal Texas
Protection and Restoration Feasibility Study, the Storm Surge Suppression Study and the Texas
Regional Sediment Study.
3. FEMA Public Assistance
Due to the vast size of the impact area and different types of recovery that will be necessary,
the FEMA PA data is the best available data set to determine infrastructure need and also serves
as a statewide metric to begin the discussion on specific infrastructure needs. Each eligible
entity is at various stages of submitting their project worksheets and estimates for permanent
work will continue to be forthcoming over the next several months. For this Action Plan, given
the limited availability of data, housing unmet needs have been prioritized.
Due to the 90 percent federal cost share tied to the approximate cost amount, the total PA
infrastructure unmet need for these localities was calculated from the remaining 10 percent of
the projected cost amount plus 15 percent of the approximate cost as a resiliency multiplier.
The PA data received from FEMA dated as of June 8, 2018 was used to calculate the unmet
need. The below table provides a high-level approximation of total costs and total need for
each PA category as of June 8, 2018. As illustrated, the categories with the highest total need
are Roads and Bridges and Utilities with a total PA need of over $1.2 billion for the 49 counties.
15% Total Need

PA Category Approx. PA 10% Local
Resiliency on (Local Match +
(49 Counties) Cost Match
Approx. Cost Resiliency)
A - Debris Removal $405,998,547 $40,599,854 $60,899,782 $101,499,636
B - Emergency
Protective Measures $747,239,329 $74,723,932 $112,085,899 $186,809,832
C - Roads and
Bridges $2,241,433,550 $224,143,355 $336,215,032 $560,358,387
D - Water Control
Facilities $242,417,186 $24,241,718 $36,362,577 $60,604,296
E - Buildings and
Equipment $1,403,387,485 $140,338,748 $210,508,122 $350,846,871
F - Utilities $2,694,094,073 $269,409,407 $404,114,110 $673,523,518
G - Parks,
Recreational
Facilities, and Other
Items $177,407,156 $17,740,715 $26,611,073 $44,351,789
Page 67 of 420
15% Total Need
PA Category Approx. PA 10% Local
(49 Counties) Cost Match
Z - Direct
Administrative
Costs $46,763,729 $4,676,372 $7,014,559 $11,690,932
Grand Total $7,958,741,056 $795,874,105 $1,193,811,158 $1,989,685,263
The below map gives a high-level snapshot of each county’s preliminary PA need. Harris
county demonstrates the highest need with a total of more than $1.5 billion dollars, or over 78
percent of the total need for all 49 counties. This can be attributed to a variety of factors
including the significant impact to roads and bridges across Harris county, primarily in the City
of Houston. Other counties with high PA needs are Jefferson ($99.8 million), Nueces ($48.9
million), Orange ($40.4 million), Galveston ($37.7 million), Fort Bend ($36.6 million), and
Aransas ($30.7 million).
Page 68 of 420
Figure 27: Total Public Assistance Need by County (Updated in APA 2)
As stated above in the IA section, need per capita is a good indicator when looking at a
community’s ability to pay for recovery. The below map indicates the three counties with the
highest per capita PA need as Refugio ($2,001), Aransas ($1,193), Orange ($476), Jefferson
($392), and Harris ($341). The remaining counties show significantly less per capita PA needs
starting at $314.
Page 69 of 420
Figure 28: County Total PA Unmet Need Per Capita (Updated in APA 2)
Multiple agencies across the state of Texas also played a major role in recovery efforts
associated with Hurricane Harvey. The GLO accumulated an approximate PA cost of $1.62
billion. The majority of this approximate cost ($1.62 billion) comes from the federal and state
partnership on the emergency protective measure of the PREPS program. This program
performs emergency work and power restoration in disaster-damaged single-family owner-
occupied residences. PREPS provide temporary repairs and allows homeowners to remain in
their homes and their communities as they complete permanent repairs on their homes.
Page 70 of 420
Agency Approx. Cost
Lower Colorado River Authority (LCRA) $16,622,853.00
Office of the Attorney General $400,454.00
Texas A&M AgriLife Extension Service $182,957.28
Texas A&M Engineering Extension Service $4,317,594.53
Texas A&M Forest Service (TX A&M Forest Service) $3,654,800.00
Texas A&M University – Corpus Christi $982,562.65
Texas A&M University $22,658.56
Texas A&M University (Veterinary Emergency Team) $128,013.39
Texas A&M University at Galveston $1,272,306.00
Texas Alcoholic Beverage Commission $50,000.00
Texas Animal Health Commission $330,352.15
Texas Commission on Environmental Quality $1,027,280.00
Texas Department of Public Safety $31,530,583.77
Texas Department of State Health Services $31,095,657.07
TDEM $401,383,689.48
Texas Health & Human Services Commission $31,715,579.78
Texas Historical Commission $3,311,061.00
Texas Parks and Wildlife Department $16,522,556.01
The University of Texas at Austin $37,990,080.00
The University of Texas Medical Branch $6,374,022.01
The University of Texas Health Science Center at San
Antonio $71,829.00
Texas Department of Transportation $100,729,204.07
Texas GLO $1,622,999,772.09
Texas Military Department $75,548,469.24
Texas Youth Commission (Texas Juvenile Justice
Department) $140,073.80
GRAND TOTAL $2,388,404,408.88
Though impossible to determine at this time, future property valuations and the overall impact
of Hurricane Harvey on property values should be taken into consideration for the long‐term
struggle that communities will face as they continue to recover using their own resources.
While unmet housing needs will begin to be addressed, there still remains significant unmet
need in infrastructure and other non‐housing sectors, including future tax revenue loss due to
Hurricane Harvey. Projects affiliated with economic revitalization or infrastructure activities
will contribute to the long‐term recovery and restoration of housing in the most impacted and
distressed areas as well as ensure the ongoing viability of the impacted areas and beyond. The
above data and factors led the state to develop the Local Infrastructure program, that as part of
a comprehensive long-term recovery program, the repair and enhancements of local
Page 71 of 420
infrastructure and mitigation efforts are crucial components of community recovery and
support of housing.
I. Economic Impact
1. Employment
a. Statewide Statistics
As of August 2017, jobs had grown in the state from 12,035,300 to 12,328,400, according to
figures published by the Texas Workforce Commission. That is a 2.4 percent year-over-year
increase from August of 2016, a net increase of 293,100 new jobs. In addition, the statewide
unemployment rate for August 2017 decreased to 4.5 percent from 4.9 percent in 2016. In a
growing economy like Texas, long-term job growth and unemployment increases were
impacted by Hurricane Harvey, but to what extent is impossible to determine. The July 2018
figures show an unemployment rate of 4.0 percent and an increase in employment numbers
from 12,328,400 in August 2016 to 13,276,703 in July 2018. 30
b. County Level
Of the 49 eligible counties, almost all follow the statewide trend. There weretwo counties that
had higher unemployment rates following Hurricane Harvey according to the statistics
provided on the Texas Workforce Commission website. The unemployment rate in Aransas
County went up from 5.4 percent in August 2017 to 8.7 percent in October 2017 before
returning to 5.5 percent in July 2018, and Refugio County’s unemployment rate increased from
5.2 percent to 6.5 percent in the same time period before decreasing to 4.8 percent in July
2018.31
c. Disaster Unemployment Assistance
The Disaster Unemployment Assistance program, administered by FEMA and the Texas
Workforce Commission, provides unemployment benefits for individuals who lost their jobs
or are no longer working as a direct result of Hurricane Harvey. The application deadline for
applications was November 13, 2017. Through this program, a total of 24,758 claims were
received, and 12,997 people were approved for assistance totaling $11,201,909.
2. Small Business Administration Business Disaster Loans
The SBA offers Business Physical Disaster Loans and Economic Injury Disaster Loans (EIDL)
to businesses to repair or replace disaster-damaged property owned by the business, including
real estate, inventories, supplies, machinery, equipment, and working capital until normal
30
Texas Workforce Commission, “Labor Market Information”. Webpage and data accessed September 2018.
https://tracer2.com/cgi/dataanalysis/?PAGEID=94
31
Ibid.
Page 72 of 420
operations resume. Businesses of all sizes are eligible. Private, non-profit organizations such
as charities, churches, and private universities are also eligible. The law limits these business
loans to $2,000,000, and the amount cannot exceed the verified uninsured disaster loss. 32
Based on data provided by SBA as of August 28, 2018, the total verified loss for real estate
totaled more than $5.34 billion dollars and the total verified loss of business content was more
than $568.33 million. The total combined business verified loss of over $5.91 billion for
Hurricane Harvey. The SBA has approved over $1.38 billion in business loans as of August
28, 2018. Given the amount of business and EIDL loans, the remaining amount of loss totals
over $4.52 billion. This can be translated into a preliminary unmet need for businesses
impacted by Hurricane Harvey. The breakdown of total loans by county and COG can be seen
in the following table.
Given that the state must primarily consider and address its unmet housing recovery needs, and
demonstrate how its economic revitalization activities will contribute to long-term recovery
and restoration of housing in the most impacted and distressed areas, the state has developed
the Economic Revitalization Program. This program allocates $100 million in funds for
economic revitalization.
County COG Business/EIDL Loans

KARNES AACOG $ 412,800
Total AACOG $ 412,800
BURLESON BVCOG $ 25,000
Total BVCOG $ 25,000
BASTROP CAPCOG $ 20,000
FAYETTE CAPCOG $ 3,912,900
Total CAPCOG $ 3,932,900
ARANSAS CBCOG $ 124,569,900
BEE CBCOG $ 2,771,300
KLEBERG CBCOG $ 58,700
NUECES CBCOG $ 58,302,700
REFUGIO CBCOG $ 3,604,600
SAN PATRICIO CBCOG $ 51,893,000
Total CBCOG $ 241,200,200
NEWTON DETCOG $ 1,456,800
POLK DETCOG $ 695,000
JASPER DETCOG $ 511,100
SAN JACINTO DETCOG $ 405,900
Total DETCOG $ 3,068,800
CALHOUN GCRPC $ 18,775,800
GOLIAD GCRPC $ 120,700
32
U.S. Small Business Administration Fact Sheet. November 7, 2017. “Disaster Loans, Texas Declaration #15274
and #15275.”
Page 73 of 420
County COG Business/EIDL Loans
GONZALES GCRPC $ 175,200
JACKSON GCRPC $ 2,560,200
LAVACA GCRPC $ 9,400
VICTORIA GCRPC $ 51,392,300
Total GCRPC 73,033,600
AUSTIN H-GAC $ 231,400
BRAZORIA H-GAC $ 11,929,200
CHAMBERS H-GAC $ 17,392,300
COLORADO H-GAC $ 1,042,800
DEWITT H-GAC $796,200
FORT BEND H-GAC $ 30,944,300
GALVESTON H-GAC $ 81,769,200
HARRIS H-GAC $ 521,549,100
LIBERTY H-GAC $ 4,125,700
MATAGORDA H-GAC $ 3,021,100
MONTGOMERY H-GAC $ 24,573,500
WALKER H-GAC $ 265,200
WALLER H-GAC $ 1,440,200
WHARTON H-GAC $ 10,303,700
Total H-GAC $ 709,383,900
HARDIN SETRPC $ 15,732,600
JEFFERSON SETRPC $ 188,117,500
ORANGE SETRPC $ 149,335,000
Total SETRPC 353,185,100
GRAND TOTAL $ 1,384,242,300
The following table provides details from SBA as of January 1, 2018, on the application status
for the 11,701 business applications that have been received. The application period for
physical damages was scheduled to close on November 30, 2017, However, the SBA is
accepting applications postmarked (or submitted electronically) within 60 days of the
November 30 deadline without a justification requirement of the applicant. The deadline for
small businesses and most nonprofits to apply for economic injury (working capital) is May
25, 2018.
Application Type Amount Percent

Total Business Applications 11,701 100.00%
Processed Applications 10,502 89.75%
In-Process Applications 1,199 10.25%
Declined Applications 5,030 47.90%
Withdrawn Applications 2,670 25.42%
Approved Applications 2,802 26.68%
Page 74 of 420
3. Commercial Property Insurance
TDI’s data also includes claims and loss information for commercial property insurance.
Commercial property insurance includes coverage to commercial buildings (including some
multi-family rental properties) and their contents against fire, windstorm, and other perils. The
data collected by TDI also includes business owners and business interruption insurance.
Commercial property policies usually do not provide coverage for flood or rising waters.
The data request included 58 counties in Governor Abbott’s August 28, 2017, disaster
proclamation, plus Williamson, Travis, Hays, and Hidalgo Counties. Milam and San Augustine
Counties, which Governor Abbott added in the September 14, 2017, disaster proclamation,
were not included. Figure 11: Hurricane Harvey Data Call Counties - Region Map, shows how
TDI group counties by region.
The following chart shows the amount of claims that are paid (closed with a loss payment),
claims closed without a loss payment, open claims, and reopened claims for commercial
property by area.
Figure 29: Number of Commercial Property Claims by Settlement Status and Area (Updated
in APA 2)
The Coastal Bend and Houston area regions have the majority of commercial property
losses.
Page 75 of 420
Figure 30: Commercial Property Incurred Losses and Amount of Losses by Area (Updated in
APA 2)
4. Agricultural Impacts
Texas has a varied

agricultural industry across
the state. Agriculture
provides jobs, food
sources, trade, and port
facilities used in the
distribution of goods. This
industry experienced
serious loss from the rains
and winds of Hurricane
Harvey.
As of November 1, 2017,
Hurricane Harvey caused
more than $200 million in
crop and livestock losses,
according to Texas A&M Source: AgriLife Extension Twitter Feed; https://twitter.com/txextension
AgriLife Extension
Service economists.33
Estimated losses by commodity include $93 million in livestock loss; $100 million loss in
cotton crops; and $8 million in loss to the rice and soybean industry. While the livestock
33
Texas A&M Agrilife Extension. “Texas agricultural losses from Hurricane Harvey estimated at more than $200
million.” Webpage accessed January 10, 2018. . https://today.agrilife.org/2017/10/27/texas-agricultural-losses-
hurricane-harvey-estimated-200-million/
Page 76 of 420
numbers do include industry infrastructure such as fencing that must be repaired or replaced
and approximately 200,000 bales of hay lost,34 it does not include an estimated number of dead
livestock. These numbers are estimated to be in the tens of thousands. The reports also do not
include losses to the fishing industry, including decreased fishing activity and storm-related
damage to vessels and equipment. This estimate will not be available until after oyster season
ends in late spring 2018.35 These forthcoming numbers will cause the losses in the agriculture
industry to continue to increase.
5. Tourism
The Texas coast has many communities that rely on employment and income from tourism.
According to the governor’s 2018 report, The Economic Impact of Travel in Texas, the total
for direct travel spending in the state was $74.7 billion in 2017.
As such, the impacted counties along the coast are some of the long-established and most-
visited tourist destinations. 11.9 percent of the employment in Aransas County and 7.0 percent
in Galveston County is directly connected to travel and tourism. 36 Retail, hospitality, and
entertainment are venues that contribute to the local community as well as overall state
employment and business tax revenue. In 2017, the Gulf Coast region of Texas provided jobs
to over 4.5 million people.37
Although current figures are not available, it is expected that the tourism industry will lose
revenue as a direct result of Hurricane Harvey. Due to the timing of Hurricane Harvey, areas
that rely on tourism have already seen a decline in revenue over Labor Day 2017. It is expected
that the areas will also see losses during Spring Break 2018 and Summer 2018 due to the
ongoing recovery process. The impacts will continue to be seen until tourists choose to return
to the Texas coast they once frequented. The impact could be prolonged if tourists have a
misconception of the actual amount of damage. Even areas with little to no disaster damage
will likely see a decline in tourism based on public perception.
6. Texas Economy
In the Texas Comptroller of Public Accounts, February 2018 Fiscal Notes, “A Storm to
Remember: Hurricane Harvey and the Texas Economy,” the Texas Comptroller estimated the
loss in business productivity from the Hurricane resulted in a $16.8 billion decrease in GSP.
However, it is anticipated that gains to the GSP will be made resulting from recovery efforts
and increased construction activity. The Texas Comptroller estimated the net impact of
34
Texas Farm Bureau. “Hurricane Harvey ag losses top $200 million.” Webpage accessed January 10, 2018.
http://texasfarmbureau.org/hurricane-harvey-ag-losses-top-200-million/
35
The Texas Observer. “New Estimate Puts Harvey Agriculture Losses at $200 Million, One-Tenth of Irma.”
Webpage accessed January 10, 2018. https://www.texasobserver.org/agriculture-losses-estimated
-200-million-harvey/
36
Texas Tourism, Office of the Governor, Texas Economic Development & Tourism. The Economic Impact of
Travel in Texas.” August 2018. Webpage/PDF accessed August 30, 2018.
http://www.deanrunyan.com/doc_library/TXImp.pdf
37
Ibid.
Page 77 of 420
Hurricane Harvey will be a loss of $3.8 billion in GSP during the first year following the storm,
with a cumulative gain of approximately $800 million over three years. According to the Texas
Comptroller, it may be years before the full impact of Hurricane Harvey is known. 38 Based on
the uncertainty of the overall need but the obvious impact the GLO is creating an Economic
Revitalization Program that may be funded further from future Hurricane Harvey allocations.
38
Texas Comptroller of Public Accounts. “A Storm to Remember: Hurricane Harvey and the Texas Economy.”
Webpage accessed February 18, 2018. https://comptroller.texas.gov/economy/fiscal-notes/2018/special-
edition/impact.php
Page 78 of 420
3.2. Needs Assessment – Harris County Local Action Plan
Harris County has been impacted by six Presidential Declared Disasters in the last ten years. On
September 13, 2008, Hurricane Ike, a Category 2 storm, made landfall along the upper Texas gulf-
coast and was at the time the third most destructive hurricane and the third costliest U.S. hurricane.
Harris County took a direct hit from the storm with projected cost of $3.58 billion in residential
housing damage to over 230,502 housing units. Infrastructure damage was estimated at $582
million to repair critical infrastructure and facilities.
In 2015 and 2016, Harris County suffered four Presidential Declared Disasters: Memorial Day
floods (DR 4223) of 2015, October floods (DR 4245) of 2015, Tax Day floods (DR 4269) of 2016,
and May/June floods (DR 4272) of 2016. In the 2015 events, FEMA IA reported $10,553,227 in
housing damage. The 2016 events were higher in severity with $74,642,169 in FEMA reported
housing damage affecting 11,164 housing units. The unmet housing need was $37,553,806.
The cumulative impact of these past disaster and Hurricane Harvey has been devastating to local
residents, businesses, and institutions. Recovery from one disaster has been exacerbated by the
floods that followed.
Hurricane Harvey was the second most costly tropical cyclone impacting the United States. A
total of 1 trillion gallons of water fell across Harris County over the 4-day period, which would
fill NRG Stadium 1,472 times and cover Harris County’s 1,777 square miles with an average of
33.7 inches of water. This volume of water would also run Niagara Falls for 15 days. Disastrous
flooding occurred on many of the watersheds in the County and exceeded previous historical
flooding records, including the worst storm event ever recorded for a similar square mile area
in the state of Louisiana in August 1940 by 3.9 inches.
Harvey produced the largest and most devastating house flooding event ever recorded in Harris
County. The county was named a HUD-identified “most impacted and distressed” (MID) area
and all CDBG-DR programming will support projects within the County. Structure flooding
occurred from both overflowing creeks and bayous as well as internal drainage systems being
overwhelmed by the intense short duration rainfall rates. Both the Addicks and Barker
Reservoirs reached their peak on August 30, 2017, exceeding previous pool records. These two
Reservoirs combined impounded a total of 388,726 acre-feet of water at peak pool elevation or
126 billion gallons of water which would fill NRG Stadium 187 times. Widespread flooding of
homes and streets occurred within the pools upstream of Addicks and Barker Reservoirs as well
as flooding of major roadways within the reservoirs. Downstream of the reservoirs, the Corps
of Engineers made the decision to release a combined 16,000 cubic feet per second. This is the
highest release rate since the outlets were fully gated in 1963 due to flooding.
Page 79 of 420
Figure 31: Four Day Peak Rainfall Frequency, Harris County
In the three weeks after the storm several Federal relief agencies began to offer assistance. D-
SNAP is a short-term food assistance program to benefit families recovering from a disaster.
The Texas HHSC with the partnership of Harris County, opened D-SNAP assistance locations
in Harris County and reported the intake of over 678,000 D-SNAP applications.
FEMA also opened online and co-located with Harris County in Disaster Assistance Centers to
intake and offer application assistance to those affected by Hurricane Harvey. In viewing the
FEMA IA Data, in Harris County (outside the city of Houston), there were 160,695 households
registered with FEMA. Slightly over 53 percent were provided FEMA assistance for their
recovery. Of those, 178,627 applicants were eligible for Temporary Shelter Assistance as they
were displaced from their housing. 23,392 Harris County applicants checked into FEMA
lodging (i.e., hotels or rental units).
Page 80 of 420
Figure 32: Flood Inundation over 6 inches, Harris County
C. Resiliency Solutions and Mitigation Needs
Harris County will follow the State’s resiliency solutions as stated in the State of Texas Plan
for Disaster Recovery: Hurricane Harvey – Round 1.
D. Demographic Profile of Impacted Counties
The demographic profile data was generated using data sets from the U.S. Census Bureau and
HUD. Harris County population outside the city of Houston, including 33 small cities, is 2,285,540
persons, or 8.2 percent of the State’s population. The area’s population by race/ethnicity as seen in
the following table is 36.41 percent white; 15.18 percent Black; 6.35 percent Asian; 39.98 percent
Hispanic; and 1.91 percent other. There are over 787,507 housing units in the County (outside the
city of Houston).
Page 81 of 420
Harris County
Texas
(outside city of Houston)
Fact Estimates Estimates Percent
Population estimates, 2016 27,862,596 2,285,540 8.20% (of Texas)
Population, percent change - April 1, 2010,
10.80% 12.10%*
(estimates base) to July 1, 2016
Persons under 5 years, percent, 2016 7.20% 175,548 7.68%
Persons under 18 years, percent, 2016 26.20% 655,146 28.66%
Persons 65 years and over, percent, 2016 12.00% 213,624 9.35%
White alone, percent, 2016 79.40% 1,562,157 68.35%
Black or African American alone, percent, 2016 12.60% 346,959 15.18%
American Indian and Alaska Native alone,
1.00% 4,265 0.19%
percent, 2016
Asian alone, percent, 2016 4.80% 145,033 6.35%
Native Hawaiian and Other Pacific Islander
0.10% 2,272 0.10%
alone, percent, 2016
Two or More Races, percent, 2016 1.90% 37,000 1.62%
Hispanic or Latino, percent, 2016 39.10% 913,743 39.98%
White alone, not Hispanic or Latino, percent,
42.60% 832,131 36.41%
2016
Housing units, 2016 10,753,629 787,507
Owner-occupied housing unit rate, 2012-2016 61.90% 478,794 63.80%
Median value of owner-occupied housing units,
$142,700 $145,600*
2012-2016
Median gross rent, 2012-2016 $911 $937
With a disability, under age 65 years, percent,
8.10% 128,052 5.86%
2012-2016
Median household income (in 2016 dollars),
$54,727 $55,584*
2012-2016
Persons in poverty, percent, 2012-2016 15.60% 12.87%
Land area in square miles, 2010 261,231.71 1,103.89 0.42%
*Figure only available for all of Harris County.
E. Low- and Moderate-Income Analysis
The following figure identifies census block groups that have a LMI population of 51 percent or
more for Harris County using 2017 LMISD for the state of Texas, Harris County. 39
39
HUD Exchange. “FY 2017 LMISD by State - All Block Groups, Based on 2006-2010 American Community
Survey.” Webpage accessed January 10, 2018. https://www.hudexchange.info/programs/acs-low-mod-summary-
data/acs-low-mod-summary-data-block-groups-places/
Page 82 of 420
Figure 33: Harris County Low- to Moderate-Income Area Map
F. Social Vulnerability Index
An additional component to consider when looking at unmet needs is what level of social
vulnerability to natural hazards is the area experiencing. The SoVI measures the social
vulnerability of block groups in Harris County — in particular, their vulnerability to environmental
hazards. With the assistance of Rice University Kinder Institute, Harris County’s block groups
were examined based on socioeconomic variables, which contribute to reduction in a community’s
ability to prepare for, respond to, and recover from hazards. The following figure shows those
block groups with the highest vulnerability.
Page 83 of 420
Figure 34: Harris County SoVI by Block Group
G. Housing Impact
In a report by the Kinder Institute, Harris County median housing prices have seen a significant
jump in price (from $100,000 in 2012 to $141,000 in 2017), which hits low-income buyers
especially hard. Hurricane Harvey has only increased the scarcity of safe, affordable single-
family housing; post-Harvey median cost is estimated at $160,000. Although, the region has
seen an increase in housing sales a low percentage are affordable, priced at $200,000 and
below.
The scarcity of safe, quality affordable housing in Harris County has caused a severe housing
burden and disproportionate housing needs particularly among African American, Hispanic,
and large family (5+ persons) households.
Page 84 of 420
The owner-occupied housing market in the Harris County region came to a standstill after
Hurricane Harvey, as homeowners had to procure temporary accommodations while they
began the recovery and home rebuilding process. Many residents of single-family homes that
flooded repeatedly since 2015 decided to sell their properties to avoid rebuilding or further
flooding, leaving them also in need of affordable housing. Selling their properties also opened
the door for investors to turn them into rental units or perform a quick repair and flip of flooded
homes. Residential buyouts in LMI areas are particularly needed to assist homeowners in
repetitively high flood prone areas by relocating to areas that have a reduced flood risk without
additional financial burden.
Prior to Hurricane Harvey, the county had reduced its level of seriously delinquent loans and
real estate owned (REO) properties. With Harvey, County residents have the added housing
burdens of repairing their homes, finding and maintaining temporary housing with possible
rental fees, paying their mortgage, and replacing personal property such as furniture and
vehicles. This is combined with the loss of wages or jobs during the days and weeks of
Hurricane Harvey as businesses and schools were closed and left many households in financial
straits. In addition, rising mortgage rates, potential foreclosures for homeowners without
enough resources to repair, lack of flood insurance, and construction labor shortages have
further exacerbated the recovery of the owner-occupied housing market.
Since Hurricane Harvey, it stands to reason that prices have fallen in neighborhoods that
flooded. Many neighborhoods experienced significant flooding, and houses that once were
owner-occupied have become rentals. Other residents have remediated the water damage and
sold their homes for a fraction of what they were worth before the storm. Inventory, while still
tight, reached a 3.4-months supply in March 2018, its highest level so far this year (2018).
Lower-priced homes remain in high demand. The hot part of the housing market is the very
bottom,” said Gilmer, director of the Institute for Regional Forecasting at the University of
Houston. “If you could get a house on the ground for under $200,000, you can sell them all
day long.”
With the heavy flooding and damage these homes sustained, affected populations faced an
even greater need for affordable housing than before. In the Harris County Disaster Recovery
Service Area, 21.4 percent of housing units reported some type of damage to their dwelling
unit to FEMA. Homeowners reported between 6-36+ inches of flood water in their homes.
With so many existing owner-occupied housing affected by Hurricane Harvey and in need of
quality home repair, a construction labor storage, as well as fraudulent home repair companies
preying on flood victims have stressed the system. Repair costs are still rising 1 year after the
storm.
Hurricane Harvey produced the most devastating house flooding ever recorded in Harris
County. As seen in the map below, flood inundation levels at 3 feet or more included areas of
Harris County’s LMI areas in Bear Creek, Addicks, Sheldon, Cypress, Airline, Aldine, South
Houston, Pasadena, and Copperfield. These older, more densely populated neighborhoods
comprising generally smaller, less expensive homes in the Harris County region experienced
the worst of Hurricane Harvey’s impact, compared to those in newer suburban developments.
Page 85 of 420
Ditches in these older neighborhoods ended up overflowing due to 4 days of rainfall ranging
from 26 to 47 inches, leading to the accumulation of water in these older homes.
One year after Hurricane Harvey, many residents throughout Harris County remain essentially
homeless in their own homes. Many are still living in moldy, rotted, dusty, and unsafe homes
unfit for human habitation. Residents report they can afford only a fraction of the repairs
necessary to make their homes livable. Over 140 families 1 year after the storm are still living
in FEMA-assisted temporary housing in Harris County with an assistance end date of February
28, 2019. Expenses such as for drywall, bathroom and kitchen replacement, electricity, and
plumbing, can run tens of thousands of dollars. New regulations for new single-family home
construction may further exacerbate the affordable housing crisis in Harris County. These new
regulations require the elevation of new homes located outside the floodplain to 1 foot above
the floodplain and those located inside the floodplain to 2 feet above the floodplain. This will
prove costly, as the addition of elevated concrete slabs to these homes can total up to an
additional $50,000, ultimately decreasing affordability in Harris County.
Figure 35: FEMA Valid Registrations in Harris County by Flood Inundation Map
The reality of Harvey recovery has been monumentally slow due to nearly 80 percent of
households affected by Harvey not receiving enough, or in some cases no assistance at all.
Page 86 of 420
Many residents lack the funds for repairs or did not have flood insurance, according to FEMA
IA data. As a result, many are living in partially repaired homes, or are still displaced and living
in temporary housing, or on a friend or relative’s sofa, and some are now homeless. Affordable-
housing advocates call Harvey one of the largest housing disasters in American history, next
to only Hurricane Katrina, which overwhelmed New Orleans in 2005.
Page 87 of 420
2. Homelessness
Working with our surrounding jurisdictions, Harris County has been actively working to
reduce the incidence of homelessness for over 15 years. The County have utilized our HUD
entitlement funding of CDBG, Emergency Solutions Grant and HOME Investment
Partnerships Program (HOME) grant plus local funding to provide social services and case
management, housing and housing stabilization, healthcare and mental healthcare, and other
services to vulnerable populations who are or are endangered of becoming homeless.
In Harris County, the Coalition for the Homeless of Houston/Harris County provides
community coordination and planning for a regional homeless services system and is the lead
agency for the area’s CoC and conducts a PIT count of shelter and unsheltered persons in
Houston, Harris County, Fort Bend County, and Montgomery County. For the past 7 years, the
Count has shown a decrease from 8,538 to 3,412 persons. However, in the most recent Count
released on May 23, 2018, there was an increase in the Count of 15 percent. It is assumed that
this increase was from Harvey, with almost one in five of the unsheltered homeless individuals
reporting Hurricane Harvey as their reason for being homeless.
As a part of the closing of the NRG and George R. Brown shelters, the Coalition, City of
Houston, and Harris County worked with FEMA to create a non-congregant shelter program,
which assisted those families and individual who did not have the resources to leave the shelter
unaided by temporary shelter assistance. This population included families with children,
elderly persons, couples, and single individuals – many of whom had special needs including
chronic health conditions, mobility limitations, and mental illness. Based on preliminary
information, most shelter guests are low or very-low income. At the Non-Congregant Shelter
Program’s height, there were approximately 500 households in the Program that received rental
assistance and case management. Currently, roughly 200 households are still enrolled and
benefiting from case management services.
3. Social Services: 2-1-1 Harris County Program
The United Way of Greater Houston serves as Harris County’s 2-1-1 program administer.
The 211 system helps Harris County residents connect with local health and human services
and disaster resources programs by phone or internet. 2-1-1 is a free, anonymous, social service
hotline available 24-hours a day, 7 days a week, 365 days a year. State and local health and
human services programs address housing/shelter, employment, food/nutrition, veterans,
crisis/emergency, income/expenses, legal aid/victims, criminal justice, aging/disability,
health/medical, mental health, and child care/education.
Between August 25 and September 30, 2017, the 2-1-1 system received approximately
100,000 calls. The call summary below shows the top ten calls received pre-Harvey and during
Harvey (August 25–September 30).
Page 88 of 420
Top 10 2-1-1 Calls Pre Harvey
MEDICAID APPLICATIONS 41,756
FOOD STAMPS/SNAP APPLICATIONS 39,808
ELECTRIC SERVICE PAYMENT ASSISTANCE 16,549
RENT PAYMENT ASSISTANCE 14,603
FOOD PANTRIES 5,794
MEDICARE SAVINGS PROGRAMS 4,881
CHIP PROGRAMS 3,330
CHILD CARE EXPENSE ASSISTANCE 1,986
HOUSING SEARCH ASSISTANCE 1,921
HOUSING AUTHORITIES 1,748
Figure 36: Top 10 2-1-1 Calls Pre-Harvey
Top 10 2-1-1 Calls Aug 25-Sept 30, 2017

DISASTER FOOD STAMPS 12,262
FOOD PANTRIES 8,241
FOOD STAMPS/SNAP APPLICATIONS 7,012
ELECTRIC SERVICE PAYMENT ASSISTANCE 6,718
RENT PAYMENT ASSISTANCE 5,004

FEMA DISASTER ASSISTANCE ONLINE/TELE-
4,609
REGISTRATION
DISASTER UNEMPLOYMENT ASSISTANCE 3,708
MASS CARE SHELTERS 3,504
UNDESIGNATED TEMPORARY FINANCIAL ASSISTANCE 1,826
311 SERVICES 757
Figure 37: Top 10 2-1-1 Calls Aug. 25 to Sept. 30, 2017
Page 89 of 420
The Houston-Galveston Area Council operates the FEMA Direct Housing Program-
Manufactured Housing Option in Harris County. Harris County Community Services
Department staff have been contracted to provide case management services for those
approximately 200 households in the program.
5. Insurance
TDI issued a report on Hurricane Harvey related claims on April 12, 2018. TDI issued a
Hurricane Harvey data call for data through October 31, 2017 to all insurance companies,
TWIA, and the Texas FAIR Plan (see Table 24). Data included number of reported claims,
paid claims, claim closed without payment, claims reopened, claims with total losses, total
amount paid losses, and total amount of claim reserved. As of October 31, 2017, 251,757
claims were reported in Harris County including all cities within the county with total
amount of losses paid of $1,411,214,085.
Number of Claims Total Amount of Total Amount of

Losses Paid Losses Incurred
Personal Line of 251,757 $1,411,214,085 $1,644,387,050
Insurance
Other Line of 59,646 $2,220,459,246 $5,122,382,647
Insurance
According to data from the NFIP in January 2018, in Harris County (outside the city of
Houston) there were 21,800 NFIP claims of which 17,081, or 78.4 percent, were paid claims.
The total claims paid was $1,894,715,877 with an average claim of $110,925.35.
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NFIP CLAIMS IN HARRIS COUNTY SERVICE
AREA
LMI Area Service Area
2,270 2,449 17,081
342 351 3,568
TOTAL CLAIMS TOTAL CLAIMS (W/O TOTAL CLAIMS CLOSED

(ACTIVE/PENDING) PAYMENT)
Figure 38: NFIP Claims in Harris County (outside City of Houston)
NFIP PAID CLAIMS IN HARRIS COUNTY

SERVICE AREA
LMI Area Service Area
$110,925.35
$1,894,715,877.00
$81,439.95
$290,577,738.00
TOTAL PAID AVERAGE PAID
Figure 39: NFIP Paid Claims in Harris County (outside City of Houston)
In the county’s low- to moderate-income (LMI) areas there were 4,261 claims, which
represents 19.5 percent of all claims in Harris County. The total claims paid in LMI areas was
3,568 or 20.9 percent of paid claims with the total claims paid of $290,577,738. The average
claim paid in LMI areas was $81,439.95. While LMI households made up over 70 percent of
the FEMA IA applicants in the county, only about 20 percent of NFIP resources went to LMI
areas. This indicates that LMI households were likely under-represented in the NFIP claims
due to inability to afford flood insurance and high claims denial rates by NFIP.
TWIA was established by the Texas Legislature in 1971 in response to regional market
conditions following Hurricane Celia in August 1970. TWIA’s purpose is to provide
windstorm and hail insurance for the Texas seacoast. Although in Harris County damage was
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mostly a flooding event, some wind damage was reported along the coastline. In Harris County,
there were 593 new claims with a total indemnity paid of $3,046,684 and an average paid of
$9,260.
Within Harris County (outside the city of Houston), SBA Disaster Home Loans to those who
could avail totaled $67,065,960 as of December 2017. The average loan disbursed by
December 2017 was $21,324 and tended to be awarded to those of gross incomes higher than
area median. The gross income of those to whom SBA Disaster Home Loans had been
disbursed averaged $117,192 as of December 2017. Only 15 percent of these loans were
written to renters.
9. Public Housing Assistance Data
The HCHA did report damage to property and is currently reviewing cost estimates for that
damage. Preliminary reports estimate $933,384 in damage costs with 251 units affected by
Hurricane Harvey over 7 properties. This does not account for tenant temporary relocation
costs as units are repaired. The greatest damage was to Magnolia Estates Seniors property.
Four buildings (24 units) flooded with 18 inches of water. The lift station on this property
had its 5 HP pump burned out after an electrical surge. Other properties experienced minor
roof leaks in units and offices, damaged fencing, and water intrusion around doors and
windows.
Total Harris County (unincorporated area and all 34 cities) contained 36 percent (323,155) of
all FEMA Registrants in Texas, and 39 percent of FEMA Registered homeowners affected by
Hurricane Harvey. The area’s FEMA Registrants included 171,622 owner-occupied
households and 150,221 renter-occupied households. For Harris County (outside the city of
Houston), there are 61,828 applicants with a FVL of over $0. Of these, 45,634 (73.8 percent)
were owners and 16,175 (26.2 percent) were renters.
Total Applications in Applicants with Unmet

Occupancy Type Harris County FVL over $0 Need
Owner 94,208 45,634 23,948
Renter 65,922 16,175 8,740
N/A 565 19 0
Totals 160,695 61,828 32,688
It should be noted that the FEMA IA for Harris County (outside the city of Houston) listed
only 4,460 total applicants who were age 60 and over with only 958 applicants with a FVL
over $0 and who received some FEMA assistance. Harris County has more than 300,000
residents over the age of 60. The county believes based on anecdotal accounts of canvassers,
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case management agencies, and rebuilding organizations that the FEMA numbers for seniors,
who had a FVL over $0 and received some assistance, significantly underestimate the unmet
needs of seniors in Harris County.
a. Total Unmet Needs
To calculate estimated unmet need, Harris County used the same methodology as the GLO,
using multipliers provided by HUD and level of damage criteria. These multipliers, as seen
in the table below, are based on SBA median repair cost for the specific disaster category
less the weighted average of expected SBA and FEMA repair costs. Based on FEMA IA
data provided to the GLO, the estimated weighted average of expected SBA and FEMA
total repair costs for each category is represented in the following table.

Major-Low $58,956
Major-High $72,961
Severe $102,046
The FEMA IA data was used to compute all housing applicants impacted by Hurricane
Harvey and calculate the unmet needs for housing. The unmet need for the LMI population
is over $895 million for owners. The unmet need by income category for owner-occupied
households in Harris County can be seen in the table below. The following table provides
a breakdown of total unmet needs for owner- and renter-occupied households. It provides
the damage category and the total count and unmet need for those three categories as
previously defined.
Damage Total Count Total of Owner- Owner- Total Owner Rental Count Total Rental
Category/ Occupied and Occupied Occupied Unmet Unmet Needs
Multiplier Rental Unmet Count with Needs
Needs Unmet Need
Major- 12,587 $742,079,172 9,551 $563,088,756 3,036 $178,990,416

Low:
$58,956
Major- 14,980 $1,092,955,780 10,415 $759,888,815 4,565 $333,066,965
High:
$72,961
Severe: 5,121 $522,577,566 3,982 $406,347,172 1,139 $116,230,394
$102,046
Totals 32,688 $2,357,612,518 23,948 $1,729,324,743 8,740 $628,287,775
HUD requirements for this CDBG-DR allocation specify that the GLO and thus Harris
County must expend a minimum of 70 percent to benefit LMI populations. In Harris
County, approximately 59.8 percent of the unmet need population is below 80 percent in
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the LMI category. The unmet need by income category for Harris County can be seen in
the following table.
Income Category Count Unmet Need % of Count % of Unmet Need
0-30% 9,582 $ 686,167,397 29.3% 29.1%

31-50% 4,498 $ 319,751,533 13.8% 13.6%
51-80% 5,452 $ 389,463,677 16.7% 16.5%
Not LMI 13,156 $ 962,229,911 40.2% 40.8%
Not Reported 0 0 0 0
Totals 32,688 $ 2,357,612,518 100.0% 100.0%
b. Owner-occupied Unmet Need
To calculate the level of real property damage for owner-occupied homes, the following
criteria was used:

In Harris County, approximately 52.5 percent of the owner-occupied unmet need based on
FEMA IA is below 80 percent LMI category. The unmet need for the LMI population is
over $895 million for owners. The unmet need by income category for owner-occupied
households for Harris County can be seen in the following table.
0-30% 5,922 $ 425,034,847 24.7% 24.6%

31-50% 2,805 $ 197,603,740 11.7% 11.4%
51-80% 3,838 $ 272,585,298 16.0% 15.8%
Not LMI 11,383 $ 834,100,858 47.5% 48.2%
Totals 23,948 $ 1,729,324,743 100.0% 100.0%
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c. Renter-occupied Unmet Need
Rental units are determined to be the most impacted if they have real property damage of
$2,000 or more. To calculate the level of personal property damage for renters, the
following criteria was used:

In Harris County, approximately 79.7 percent of the unmet need based on FEMA IA is
below 80 percent LMI category. The unmet need for the LMI population is over $500
million for renters. The unmet need by income category for renters in Harris County can
be seen in the following table.
0-30% 3,660 $ 261,132,550 41.9% 41.6%

31-50% 1,693 $ 122,147,793 19.4% 19.4%
51-80% 1,614 $ 116,878,379 18.5% 18.6%
Not LMI 1,773 $ 128,129,053 20.3% 20.4%
Totals 8,740 $ 628,287,775 100.0% 100.0%
d. Owners in a Floodplain with No Flood Insurance
a house if the combined households income is greater than 120 percent AMFI or the
national median, the property was located in a floodplain at the time of the disaster, and
the property owner did not maintain flood insurance on the damaged property, even when
the property owner was not required to obtain and maintain such insurance.
Low- to Moderate-income applicants in Harris County comprise 65.1 percent of the total
owners with unmet needs in a floodplain with no flood insurance. Whereas those over 120
percent of AMFI are 20.8 percent of the total owners with unmet needs in a floodplain with
no flood insurance.
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Income Category Count % of Count
0-30% 1,320 32.0%

31-50% 678 16.4%
51-80% 690 16.7%
81-120% 579 14.0%
Over 120% 859 20.8%
Not Reported 0 0%
Totals 4,126 100.0%
11. Public Services
Programs, such as those discussed in the Use of Funds section (5.2.D), can be difficult to
navigate without assistance. Applicants are likely to need support throughout the process.
Applicants may have suffered significant losses and emotional hardships. In order to provide
housing and non-housing programs to the public, particularly vulnerable populations, services
such as case management, housing counseling, legal counseling, transportation services, and
housing navigation will be needed to assist households to successfully navigate the programs.
12. Residential Buyout Program
HCFCD has operated the Harris County Residential Buyout Program since 1985 and acquired
and removed approximately 3,000 houses that are hopelessly deep in the floodplain where
flood damage reduction projects, like channel improvements or storm water detention basins,
are not cost effective and/or beneficial. Once bought out, these parcels are returned to their
beneficial function aiding in the storage of floodwaters. Those homeowners who are bought
out are assisted to move to an area with a reduced flood risk.
HCFCD has identified 43 areas in unincorporated Harris County or in one of the county’s small
cities that fits the above definition. These areas contain approximately 3,300 parcels to acquire.
Of the 43 buyout interest areas, the county has identified 13 areas that are in low- to moderate-
income areas and/or in Social Vulnerable areas (shown in Figure 40). Seven of the 13 areas
have an average home market value of under $85,000. The lowest average home market value
was $27,105 in the community of Allen Field. As stated in the above section G.1. Real Estate
Market, median home price in Harris County is $160,000. The low market value of the homes
to be bought out to the higher median home price may place a severe cost burden on low-
income and vulnerable populations to find safe, quality affordable replacement housing.
Additional housing incentives, the creation of new affordable housing, and homebuyer
assistance programs will be needed to alleviate this burden.
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Figure 40: Harris County Buyout Areas in Harris County Low- to Moderate-Income Areas
Page 97 of 420
13. Planning Activities
Well-thought-out and inclusive planning paves the way for effective and efficient
implementation of projects and activities. The planning process is iterative, with each phase
overlapping and informing the others. Harris County will invest sufficient planning funds to
accurately identify unmet needs, which will ensure that projects are implemented in a manner
to achieve successful completion. As Harris County is a HUD-identified “most impacted and
distressed” area, planning activities will enhance programs, operations, and knowledge for
recovery. The County may also work with other local jurisdictions, universities, and advocates
on various types of planning projects. Additional information is available in the Use of Funds
for Harris County in Section 5.2.D.
H. Infrastructure Impact
County infrastructure was affected by Hurricane Harvey. This event caused damage to roadways,
bridges, sections of the coastline, and many other infrastructure systems that are still being
assessed. Disastrous flooding occurred in many of the watersheds in Harris County. Historical
records held by previous massive floods in October 1994, Tropical Storm Allison, and April 2016
(Tax Day) were exceeded by Harvey at many locations. Based on house flooding assessments by
the County, the estimated total number of homes flooded within Harris County is 154,170. Public
facilities and infrastructure that serve those neighborhoods were also affected by the flooding.
Public buildings, such as libraries, courtrooms, jury assembly buildings, county annexes, and
healthcare facilities were damaged by Harvey. During the storm, 44 area hospitals and other health
facilities evacuated over 1,500 patients, estimates the Southeast Texas Regional Advisory Council,
who coordinated the regional response during Harvey. One of these hospitals has completely
closed. Damage to infrastructure was also reported. Several roadways to LMI neighborhoods
reported collapse or were severely damaged, making recovery difficult. Many neighborhood roads
in high-impact LMI areas, such as Aldine, Airline, Sheldon, Cloverleaf, Pine Trails, and Normandy
Crossing, and in cities such as South Houston, Pasadena, and Humble were flooded just as homes
were on those streets. Roadways around the two reservoirs, including Clay Road, North Eldridge
Parkway, State Highway 6, Groeschke Road, Patterson Road, Westheimer Parkway, and South
Barker Cypress Road were flooded for weeks and, in the case of Patterson Road, over a month.
According to a study by the Texas Association of Water Board Directors (AWBD) of the Houston
Metropolitan Statistical Area’s (MSA) 945 utility districts, 253 districts had some flooding in their
service areas. Seventy-six (76) Harris County districts issued a boil water notice, and 3 (of 627)
wastewater treatment plants located in the County were completely destroyed. Without these
utilities operating at full capacity, recovery of damaged neighborhoods will be delayed.
HCFCD estimates the total need in Harris County for flood risk reduction projects is $25 billion
to achieve a 1 percent (100-year) level of service in Harris County. The project list developed by
HCFCD includes projects that address documented flooding issues in the 22 watersheds – issues
that come into play any time excessive rainfall takes place in those watersheds. By reducing the
future flood risk, the County, particularly the housing department, will be better prepared for the
next storm.
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In order to assist the County and small cities within the County to provide recovery efforts to their
neighborhoods and protect housing recovery investments, the County will set-aside 21 percent of
CDBG-DR funding for improvement to damaged infrastructure and mitigation projects to protect
against furture storms and flooding. Any remaining unmet housing need will be addressed with
other sources both private and public.
The below table provides a high-level approximation of total costs and total need for each PA
category as of June 1, 2018 for Harris County and 33 small cities. Harris County and HCFCD
are self-insured, thus did not receive private insurance proceeds for infrastructure projects. As
illustrated in the following table, the categories with the highest total need are Buildings and
Equipment then Emergency Protective Measures showing a total PA need for the County. It
should be noted that PA project worksheets are still under development by the local
jurisdictions and under review by FEMA and TDEM. These amounts are expected to increase.
PA Category Total Need (Local

10% Local 15% Resiliency on
Approx. PA Cost Match +
(49 Counties) Match Approx. Cost
Resiliency)
A - Debris
$ 65,629,614.39 $ 6,562,961.44 $ 9,844,442.16 $ 16,407,403.60
Removal
B - Emergency
Protective $ 200,492,321.33 $ 20,049,232.13 $ 30,073,848.20 $ 50,123,080.33
Measures
C - Roads and
$ 715,534.17 $ 71,553.42 $ 107,330.13 $ 178,883.54
Bridges
D - Water Control
$ 72,069,272.47 $ 7,206,927.25 $ 10,810,390.87 $ 18,017,318.12
Facilities
E - Buildings and
$ 339,883,959.96 $ 33,988,396.00 $ 50,982,593.99 $ 84,970,989.99
Equipment
F - Utilities $ 30,061,407.49 $ 3,006,140.75 $ 4,509,211.12 $ 7,515,351.87
G - Parks,
Recreational
$ 7,419,760.39 $ 3,741,976.04 $ 5,612,964.06 $ 9,354,940.10
Facilities, and
Other Items
Z - Direct
Administrative $ 9,184,044.43 $ 918,404.44 $ 1,377,606.66 $ 2,296,011.11
Costs
Grand Total $755,455,914.63 $75,545,591.46 $113,318,387.19 $188,863,978.66
As stated above in the IA section, need per capita is a good indicator when looking at a
community’s ability to pay for recovery. The three counties with the highest per capita PA need
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are Harris ($1,412), Aransas ($1,296), and Refugio ($1,100) according to the State’s Action
Plan.
2. Commercial Buyout
As discussed in section G.11 Residential Buyout, Harris County has been involved in
residential buyouts since 1985. HCFCD has identified 43 areas in unincorporated Harris
County or in one of the county’s small cities that fits the buyout definition. These areas contain
approximately 3,300 parcels to acquire. Some of these parcels are partial home business and
small business that will also need buyout and relocation as we relocate the residents around
these businesses. The county has identified in its 13 low-income buyout areas approximately
87 commercial and industrial parcels with a 2017 market value for the parcel of roughly $10
million. A Commercial Buyout Program is needed and will purchase commercial properties,
where the owner has voluntarily agreed to sell, in communities that have suffered from multiple
disasters or are at a high risk of suffering from additional disasters, such as properties in the
100-year floodplain. In any proposed program for Commercial Buyout, Harris County will
follow the URA, if required, and will provide relocation payments and assistance to displaced
businesses. Harris County will attempt, as much as possible, to help relocate communities in
close proximity to original locations to preserve community character and financial structure.
3. Method of Distribution
A MOD of CDBG-DR funding allocated to Harris County will be established to assist the
County and its small cities most impacted by Hurricane Harvey with their recovery. Due to the
limited amount of CDBG-DR funding available to address the overall unmet need, the MOD
encourages a focus on key systems, which will have an affect to correct damage, alleviate
future disasters, particularly flooding, and/or increase public safety and mitigation. The County
will complete a MOD submission for GLO approval that outlines priorization and method for
distributing CDBG-DR funding.
I. Economic Impact
Data obtained for Harris County from August 1, 2017, through December 7, 2017, tracked the
businesses within Harris County that received SBA loans for property and content losses. The total
of loans for approximately 70 businesses amounted to $39,287,300 throughout the unincorporated
County. Since this program loans only for businesses that may have difficulty in obtaining
conventional loans, it represents only a portion of the impacts to businesses from Hurricane
Harvey. It also does not include additional costs that are more difficult to quantify, such as business
interruption impacts and other types of lost income. However, since it is a loan program and not a
grant program, the loans obtained should be considered the minimum economic business impact
from this event.
In addition to the commercial businesses applying for SBA loans, Harris County provided an
assessment of commercial properties impacted by Hurricane Harvey. A methodology similar to
the one used to establish damages to residential properties was used for establishing business
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properties inundated by Harvey. The Army Corps of Engineers Damage Assessment Curves were
applied to establish the level of damages of 437 properties. The total amount of assessed damage
to these properties was $62,346,950. It should be noted this is an assessment of property damage
only and does not account for lost revenue and other business interruption impacts. Accordingly,
it should be assumed the total economic losses to businesses can be assessed at $101,634,250.
Commercial buyout is also needed within the 13 buyout areas discussed under residential buyout.
Within the 13 areas, there are 789 commercial parcels with an average assessed value of
approximately $25,000. The commercial property types range in average assessed value from the
2 industrial properties with an average assessed value of $650,000 to the 630 vacant lots at an
average assessed value of $12,924. There are 85 occupied commercial parcels with an average
assessed value of $100,500. The estimated cost to buyout these properties is approximately $20
million, plus relocation costs at an additional $15 million. This creates an unmet need of
approximately $80 million (which is less than the SBA assistance and planned CDBG-DR Round
1 funding).
J. Funding Resources
Hurricane Harvey, FEMA DR 4332, through the Federal Register, Vol. 83, No. 28 (PL 115-56).
The Texas GLO is the State’s administrating agency for these funds. On August 14, 2018, a Federal
Register, Vol. 83, No. 157 (PL 115-123), was released allocating additional CDBG-DR funding
of $652,175,000 to the State of Texas.
Harris County was identified as a “most impacted and distressed” area and was allocated by the
State, along with the city of Houston, a direct allocation of $1,204,696,185 from the State’s CDBG-
DR allocation, including an additional $89, 309,355 in CDBG-DR from the August 2018 Federal
Register (PL 115-123). These funds are allocated to existing, housing programs (identified in the
Use of Funds – Harris County section) Homeowner Assistance and Rental Housing Development
programs, to assist with unmet recovery needs.
The resulting devastation of Hurricane Harvey has left the County with an unmet need of over
$12.8 billion in housing and infrastructure damage or failure to function. The following table
provides a summary of Harris County’s unmet needs. The County has elected to follow the Federal
Register and State Action Plan and provide 81 percent of funding to housing programs and 19
percent to infrastructure/non-housing programs. It should be noted that the County will be
participating in the State’s Economic Development Program.
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Category Unmet Needs % of Unmet County Program % of County
Need Allocation Program
Amount Allocation
Housing $2,864,912,259 22% $921,941,704 81%
Infrastructure and $10,044,886,257 78% $222,519,672 19%
Economic
Development
TOTAL $12,909,798,516 100% $1,144,461,376 100%
Note: Allocations do not include planning costs.
Under the Housing category, the County will administer a Homeowner Assistance Program and
Reimbursement Program, a Single Family New Construction Program, a Rental Housing
Development Program, and a Residential Buyout/Acquisition Program. The County’s
Supplemental Action Plan is available on the Harris County Community Services department
website at https://csd.harriscountytx.gov/Pages/DisasterRecovery.aspx.
For the Homeowner Assistance Program, the County has allocated $214,000,000 to assist
homeowners to repair their damaged home. Based on FEMA IA data, the funding targets by
income category shown in the two tables below have been determined. The data represents FEMA
valid owner registrants with a reported gross income. As not all registrants reported a valid gross
income, the total number of registrants is less than the total number of owner registrants reported
in earlier sections.
Income Category Count* % of Count Minimum Target Maximum

Greater of 0-30% AMI or
Federal Poverty Level 2,016 11.00% 11.00%
31-50% AMI 2,227 12.15% 12.15%
51-80% AMI 3,384 18.46% 18.46%
0-80% AMI (Non-Targeted) 28.39%
Above 80% AMI 10,701 58.39% 30.00%
Total 18,328 100.00% 70.00% 30.00%
Total LMI 7,627 41.61% 70.00% 100.00%
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Minimum Target Maximum
HAP Budget $270,359,499.00
Greater of 0-30% AMI or Federal
Poverty Level $29,738,364.80
31-50% AMI $32,850,862.30
51-80% AMI $49,917,969.48
0-80% AMI (Non-Targeted) $76,744,452.72
Above 80% AMI $81,107,849.70
Total $189,251,649.30 $81,107,849.70
Total LMI $189,251,649.30 $270,359,499.00
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3.3. Needs Assessment – City of Houston Local Action Plan
Houston’s flat terrain and topography make it vulnerable to flooding. Over the past decade,
Houston has experienced several major flood events from hurricanes and storms. Hurricane Ike
was a strong Category 2 storm when it made landfall in Galveston in 2008. Many residents lost
power for several days, with approximately 95 percent of CenterPoint Energy’s 2.26 million
customers losing power40.
In 2015 and 2016, the region received unprecedented rainfall from several storms, which led to
many neighborhoods experiencing flooding multiple times in a two-year period. During Memorial
Day weekend and Halloween weekend in 2015, Houston experienced severe flooding from storms
that impacted the wider Gulf Coast area. The President declared both events major disasters. In
April and June 2016, Houston once again received record-breaking rainfall and experienced severe
flooding. The President also declared these two flood events major disasters. Almost one third of
the 16,000 buildings damaged in the 2015 and 2016 flood events were located outside the FEMA
floodplains.
These flood events were followed by Hurricane Harvey in 2017. The cumulative impact of these
disasters has been devastating in Houston and the scale of damage is unprecedented. Thousands
of residential and commercial buildings have been damaged. Infrastructure has been overwhelmed
or destroyed, and there has been loss of life and property. According to estimates, no other area in
the country has experienced this level of devastation from flooding and the cost associated with
the impact of these disasters is at an extraordinary scale not experienced before.
Hurricane Harvey made landfall on the Texas coast as a category 4 hurricane on August 25, 2018,
and as it moved inland, it slowed and stalled over the Houston area. A heavy rain band developed
over Fort Bend and Brazoria counties and spread into Harris County. The Houston area received
unprecedented levels of rainfall in the next two days as the system remained stalled, dumping over
50 inches of rain in the area, according to the National Weather Service, making it a 1-in-1,000-
year flood event. According to the National Hurricane Center, Harvey’s rainfall is the highest-ever
recorded rainfall for a tropical storm in the continental United States since rainfall records began
in 1880.
While Hurricane Harvey did not cause extensive wind damage and power outages to Houston, it
brought on prolonged and widespread flooding. The flood event initially lasted several days, and
thousands of Houstonians had to evacuate their homes. Areas in Houston had flood water levels
between 1 foot and 6 feet. According to HoustonRecovers.org, there were more than 8,500 calls
to 911 on just one day, August 27, 2018, approximately 3,000 more than in an average day. Many
Houstonians were rescued by emergency responders. Others were rescued by volunteers with
40
State Impact. (September 2013). Restoring Power: What Houston Learned from Ike.
https://stateimpact.npr.org/texas/2013/09/12/restoring-power-what-houston-learned-from-ike
Page 104 of 420
access to large trucks and boats, including an ad hoc volunteer group of private boat owners known
as the Cajun Navy. Neighborhoods in the Memorial and Energy Corridor area in West Houston,
which is downstream from the Addicks and Barker reservoirs, remained under water for almost
two weeks. Homes in these neighborhoods had flood water levels of 5 feet and over as water was
released from the dams downstream into Buffalo Bayou over a period of several days.
An estimated 29 percent of the city’s population was likely affected by Hurricane Harvey through
damage to their homes from floodwaters. Over 24,000 families were displaced from their homes
according to estimates of FEMA-funded hotel room statistics 41. This number vastly under-
represents the actual number of families displaced, as many people found shelter with family or in
local shelters in religious community centers, rented units or recreational vehicles. It also excludes
people who did not or could not seek FEMA’s help. The days after the storm saw an estimated
37,000 people sheltering in over 270 Red Cross and partner facilities in Houston. There were
11,000 people sheltering at the George R Brown Convention Center alone 42.
After the flooding subsided, the massive cleanup began. The City and its contractors removed over
2 million cubic yards of debris from gutted homes, buildings and ravaged neighborhoods, which
is the amount that would fill 622 Olympic size swimming pools. Houstonians, as well as people
from around the country, donated supplies and volunteer time to assist with short-term recovery
efforts. The City and nonprofit organizations used Crisis Cleanup, an online collaborative disaster
work order management platform, to coordinate volunteer efforts, assisting thousands of residents
with cleaning out their homes to prevent mold and other indoor hazards.
Harvey’s impact is not limited to loss of life, property and infrastructure. There has been loss of
economic activity and disruption to schools. The Houston Independent School district suffered
damage to several schools, some of which had to close for the year, affecting 6,500 students. As
floodwaters have receded, concerns about environmental impact of damaged petrochemical plants
to the air and water quality in the city have also emerged.
The city of Houston is located in the HUD-identified most impacted and distressed areas (Harris
County, Fort Bend County, and Montgomery County). City of Houston CDBG-DR funded
programs, including planning activities, will support the City’s housing, community development,
and resiliency, and therefore will benefit HUD-identified most impacted and distressed areas.
The following figure shows flooding above 1 foot in Houston during Hurricane Harvey.
41
Kinder Institute of Urban Studies, (December 2017). What’s Next for Houston After Harvey?
https://kinder.rice.edu/2018/01/08/whats-next-for-houston-after-harvey
42
Fox News. (August 2017). Tropical Storm Harvey Evacuees Surge to Houston Shelter.
http://www.foxnews.com/us/2017/08/30/houston-shelters-including-sports-stadiums-mosques-swell-with-harvey-
evacuees.html
Page 105 of 420
Figure 41: Hurricane Harvey 1-Foot Inundation Map
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C. Demographic Profile of Impacted Counties
Houston has a population of 2.2 million and is part of the fastest growing and most ethnically and
culturally diverse metropolitan area in the country43. Houston comprises more than one fourth of
the combined population of the 49 CDBG-DR Eligible Counties. The median household income
for Houston is lower than Texas, but the median rent and median value of owner-occupied units is
almost equal to Texas. This combination of low-incomes and high housing costs mean that housing
affordability is an even greater challenge for Houston than other areas in the state.
According to the 2016 ACS estimates, over 22 percent of the population is African American,
almost 7 percent is Asian, 58 percent is White, and 12 percent is two or more races or some other
race. Close to 45 percent of Houston’s population is Hispanic or Latino. The population identifying
as Hispanic or Latino/a are the racial/ethnic majority in Houston, which differs from the State and
combined 49 Eligible Counties.
Houston’s population is changing and almost one third of Houston’s residents are immigrants. An
estimated 14 percent of all households, or 116,473 households, in Houston have limited English
proficiency. This means that these residents face a language barrier and may require additional
support during the recovery process. They may also have not been able to apply for immediate
assistance from FEMA and therefore, may not be represented in the FEMA IA data, which is used
in this document to determine housing needs in Houston.
Approximately 22 percent of adults in Houston lack a high school diploma, which is much higher
than the percentage of adults in Texas who lack a high school diploma. The median household
income in Houston is $47,010. Poverty is defined each year by the U.S. Department of Health and
Human Services; in 2017, families of four making below $24,600 in the 48 contiguous states were
identified as in poverty. Nearly 22 percent of people live below the poverty line in Houston
compared to only 16 percent in the state.
The following table provides a summary of the demographic and housing information in Houston
in comparison with demographic and housing information from Texas.
43
Kinder Institute of Urban Studies, (2018). The 2018 Kinder Houston Area Survey.
https://kinder.rice.edu/sites/g/files/bxs1676/f/documents/Kinder%20Houston%20Area%20Survey%202018.pdf
Page 107 of 420
Texas City of Houston
Fact Estimates Estimates Percent of Area
Population, 2016 27,862,596 2,240,582 8% of Texas Population

Population, percent 10.80% 7%
change – April 1,
2010, (estimates base)
to July 1, 2016
Persons under 5 years, 7.20% 175,167 7.8% of City

percent, 2016
Persons under 18 26.20% 567,297 25.3%
years, percent, 2016
Persons 65 years and 12.00% 219,012 10.0%
over, percent, 2016
White alone, percent, 79.40% 1,305,482 58.3%
2016
Black or African 12.60% 511,398 22.8%
American alone,
percent, 2016
American Indian and 1.00% 8,047 0.4%
Alaska Native alone,
percent, 2016
Asian alone, percent, 4.80% 149,265 6.7%
2016
Native Hawaiian and 0.10% 1,256 0.1%
Other Pacific
Islander alone,
percent, 2016
Two or More Races, 1.90% 44,986 2.0%
percent, 2016
Hispanic or Latino, 39.10% 992,886 44.3%
percent, 2016
White alone, not 42.60% 562,237 25.1%
Hispanic or Latino,
percent, 2016
Housing units, 2016 10,753,629 937,245
Owner-occupied 61.90% 359,118 38.0% of Housing Unit
housing unit rate,
2012-2016
Median value of $142,700 $140,300
owner-occupied
housing units, 2012-
2016
Median gross rent, $911 $898
2012-2016
Page 108 of 420

Fact Estimates Estimates Percent of Area

With a disability, 8.10% 136,693 6.0%
under age 65 years,
percent, 2012-2016
Median household $54,727 $47,010
income (in 2016
dollars), 2012-2016
income for owner-
occupied units (in
2016 dollars), 2012-
2016
income for renter-
occupied units (in
2016 dollars), 2012-
2016
Persons in poverty, 15.60% 21.9%
percent
Cost burdened owner- 21.17% 84,246 23.46% of owner-occupied
occupied units, 2012- units
2016
Cost burdened renter- 44.35% 223,952 47.44% of renter-occupied
occupied units, 2012- units
2016
Land area in square 261,231.71 600 6.7% of Metro Area
miles, 2010
Source: City of Houston from ACS 2012-2016.
D. Low- and Moderate Income Analysis
The following map identifies census block groups that have a LMI population of 51 percent or
more in the City of Houston using HUD’s 2017 LMISD. It also shows the Racial and Ethnically
Concentrated Areas of Poverty (R/ECAPs), defined by HUD as census tracts where more than half
the population is non-White and 40 percent or more of the population is in poverty.
Page 109 of 420

Figure 42: Percentage of LMI Population by Block Group with R/ECAPs
Page 110 of 420

E. Social Vulnerability Index
The following map of the City of Houston identifies the communities that will most likely need
support before, during, and after a hazardous event, as determined by the SoVI. This index,
developed by the University of South Carolina’s Hazards and Vulnerability Research Institute,
synthesizes 29 socioeconomic variables that contribute to reduction in a community’s ability to
prepare for, respond to, and recover from hazards. Census tracts that rank in the top 80 percent
nationally are communities marked as having a “High” social vulnerability. In Houston, areas with
high vulnerability somewhat correspond with LMI areas and areas that are predominately minority,
including R/ECAPs.
Page 111 of 420

Figure 43: SoVI with R/ECAPs for City of Houston
Page 112 of 420

F. Housing Impact
One of the strongest areas of the Houston economy is the real estate sector. Total property sales
have been increasing steadily in recent years. According to the ACS, there are over 930,000
housing units in Houston with a homeowner vacancy rate of 1.9 and a rental vacancy rate of
7.7. The median price for an owner-occupied home is $140,300. Hurricane Harvey caused
home sales to fall somewhat in August 2017, however, the market rebounded immediately and
saw increases in home sales from the same period the previous year 44. According to the Texas
A&M Real Estate Center, Houston continues to lead nationally in the number of permits issued
for single family home building. In 2018, single family construction permits are estimated to
increase by 14 percent. The average annual growth rate of single family construction permits
has been close to 6 percent from 1991 to 2017.
Despite having a strong market for residential homes, Houston is a majority renter city with
almost 57 percent of Houstonians renting homes. The median gross rent is $898 and almost
half of all renters are housing cost burdened, meaning over 30 percent of their household
income is spent on housing. While home sales have been robust and over 99 percent of homes
have complete plumbing and kitchen facilities, most of the housing stock in the city is aging.
Over half (56 percent) of all the homes in Houston were built before 1979. That is a
significantly large percentage compared to the housing stock in the rest of the state, where
approximately 41 percent of the homes are built before 1979.
The demand for housing, especially affordable homes, in Houston was high even before
Hurricane Harvey impacted the city. Since Hurricane Harvey, the housing supply has
decreased due to uninhabitable, flooded homes. This, in turn, has further decreased the already
limited supply of affordable homes as a growing number of renters and buyers compete for a
reduced supply of units.
Over half of the 830,000 households were housing cost burdened in the years leading up to
Harvey.45 This number is expected to rise even higher in 2018 as a result of Harvey’s impact
on housing affordability in Houston. Renters in Houston are far more cost burdened than
owners – 23 percent of owner-occupied housing units have cost burdened residents whereas
47 percent of renter-occupied housing units have cost burdened residents. A person is
considered housing cost burdened when they spend more than 30 percent of their income on
housing expenditures such as rent or mortgage.
The decreasing number of available units and heightened demand means that the gap between
the supply of and demand for housing is greater than it was prior to Hurricane Harvey.
44
Greater Houston Partnership Research, (2017). Houston Economic Highlights.
http://www.houston.org/assets/pdf/economy/Economic-Highlights-2017-web.pdf
45
Houston Chronicle, February (2017). Putting numbers on Houston’s demand for more affordable housing.
https://www.chron.com/business/texanomics/article/Putting-a-number-on-Houston-s-affordable-housing-
10945884.php
Page 113 of 420
The Houston metro area also has a higher square footage per housing unit than the state.
According to U.S. Census, American Housing Survey (AHS), 2015, the Houston-The
Woodlands-Sugar Land, MSA has a higher median square footage per housing unit than Texas,
with a median square footage of 1,800 for the Houston MSA compared to the median of 1,600
square feet for Texas. According to the AHS, 35 percent of homes in the Houston MSA are
2,000 square feet or more, compared to 28 percent of Texas homes. With a larger proportion
of homes having higher square footage in the Houston MSA, it is anticipated that repair costs
per unit will likewise be higher in the Houston MSA than the remainder of the state.
Neighborhoods of all incomes and housing values have been affected by flooding because of
Hurricane Harvey. Many homes in the Memorial and Briar Forest Super Neighborhoods, that
have higher square footage and median home value compared to the city’s and state’s average,
were impacted by severe flooding for weeks after the storm, as water was released from Barker
and Addicks reservoirs into Buffalo Bayou. Both renter- and owner-occupied homes in the
area were impacted by floodwaters as high as 6 feet for over two weeks. According to the
Houston Planning and Development Department, in 2015, the median housing value in Briar
Forest was $222,903 and in Memorial it was $366,629; both median values were much higher
than the city’s median value, at $131,700. In addition, with amendments to Chapter 19 of the
Code of Ordinances, which includes the City’s Floodplain Ordinance, many homes in need of
minor repairs from flood damage may now need more extensive repairs related to elevation to
comply with the new regulations. While most of these homes will not need to be reconstructed,
they will need extensive repair, which will be more expensive due to the larger size and higher
median value of these homes compared to the rest of the city and state.
2. Homelessness
The City of Houston has been working to reduce homelessness over the past several years. The
City has utilized various sources of funds to undertake programs that help vulnerable
populations at risk of becoming homeless and persons who are homeless and need shelter and
public services. Recently, the City has partnered with HHA to administer a tenant based rental
assistance program funded by the HOME program, which has helped households at risk of
becoming homeless stay in their homes. Several public service activities, such as health care
services for the homeless, day shelter programs, and other homeless shelter programs funded
through CDBGs, have helped provide homeless persons access to shelter and needed services.
The City continues to utilize the Emergency Solutions Grant (ESG) to fund housing relocation
and stabilization services for rapid-rehousing, prevent homelessness through providing rent
and utilities assistance, and provide emergency shelter services.
Along with HOME, CDBG, and ESG funds, Houston has also utilized the Housing
Opportunity for Persons with AIDS (HOPWA) and HHSP Program funds to help homeless
persons and families and those at risk of becoming homeless through rental assistance, housing
placement and shelter services, and healthcare services. Since 2012, the City has worked
closely with community partners to create and provide permanent supportive housing.
The Coalition for the Homeless of Houston/Harris County (Coalition) provides leadership in
the development, advocacy, and coordination of community strategies to prevent and end
Page 114 of 420

homelessness. It also serves as the lead agency for the Houston/Harris County Continuum of
Care and conducts a PIT Count of sheltered and unsheltered persons experiencing
homelessness in Houston, Harris County, Fort Bend County, and Montgomery County area
once a year over a three-day period. The purpose of the PIT Count is to determine the number
of persons experiencing homelessness, as defined by HUD.
From 2011 to 2017, the number of sheltered and unsheltered homeless persons in Houston,
Harris County, and Fort Bend County decreased by 60 percent, from 8,538 to 3,412 persons,
according to the Coalition. In addition, unsheltered chronic homelessness decreased by 82
percent. In 2017, 39 percent of the unsheltered homeless individuals had a high school diploma
or GED; 21 percent had some college or a college degree or higher; 25 percent of unsheltered
homeless individuals reported no income; and 20 percent reported panhandling for income.
On May 23, 2018, the Coalition released the PIT Count for 2018. It shows the number of
homeless has increased by 15 percent in one year, from 3,605 to 4,143 persons. While the PIT
counts have increased in the Gulf Coast region and other areas in Texas between 2017 and
2018 counts, the increase has been the highest in the Houston region. This increase in the
number of homeless persons in the Houston area is assumed to be a direct impact of Hurricane
Harvey. Almost one in five (18 percent) of unsheltered homeless individuals reported
Hurricane Harvey as their reason for being homeless. It is important to note that the homeless
count does not take into consideration those living in a temporary housing situation, such as
staying with family or friends. The homeless count likely underestimates the total number of
homeless persons.
Although few units of homeless housing were damaged due to Hurricane Harvey, there is a
great need for additional resources for homeless housing and services since the disaster. First,
the number of homeless persons has increased for the first time in seven years, as seen in the
PIT Count. Second, some families and individuals who found temporary housing, such as those
living with family or friends after Hurricane Harvey, are at risk of becoming homeless over
the next year as their temporary housing becomes unavailable or inadequate. Finally, the
housing market has tightened, leaving even fewer units than before available as housing for
the homeless or those at-risk of becoming homeless.
3. Social Services: 2-1-1 Texas Program
The United Way of Greater Houston operates the 2-1-1 helpline for the area. Between August
28 and October 10, 2017, 136,000 residents called 2-1-1, and a total of 51,596 unique callers
requested service referrals due to the impact of Hurricane Harvey. 46 The month after the storm
had the greatest number of calls with 21,233 in the first week declining to 1,801 for a week
about one and a half months after the storm. Most calls requested referrals or information for
D-SNAP and other food assistance, temporary financial aid, shelter, and disaster
unemployment assistance.
46
Kinder Institute Research, (November 2017). Map: 211 Calls During and After Harvey.
https://kinder.rice.edu/2017/11/09/map-211-calls-during-and-after-harvey/
Page 115 of 420
In the months after Hurricane Harvey, the city of Houston has managed three Direct Housing
Assistance Programs (DHAP) designed to provide temporary relief to impacted residents while
they determine ways to fully repair their homes. These programs are funded by FEMA and
administered by the State of Texas. As a subrecipient of FEMA, Houston manages the DHAPs
in Houston. Eligible households include those registered with FEMA and have a FEMA-
verified loss of at least $17,000. These programs help provide safe, sanitary, and secure
housing to residents who qualify for the programs. All three programs end on February 25,
2019, at which time applicants can no longer benefit from them.
The Direct Assistance for Limited Home Repair Program provides home repair to eligible,
impacted residents and has benefitted approximately 185 households. The Manufactured
Home Units and Recreational Vehicles Program and the Direct Lease Program provide
alternate housing options while the residents are repairing their homes and has benefitted
approximately 113 households.
5. Insurance
TDI made a presentation to the Texas Senate Business and Commerce Committee in January
2018 about insurance and Hurricane Harvey. TDI compiled information from private insurers,
TWIA, and the Texas FAIR Plan Association (TFPA) for all personal and commercial lines of
insurance, but this information was reported only by county. Although the City of Houston is
in Harris, Fort Bend, and Montgomery counties, the majority of Houston’s 2.2 million residents
reside in Harris County. In this section, Harris County, including Houston, is used to represent
the need in Houston, in the absence of Houston only information.
The following table includes information about Hurricane Harvey insurance claims in Harris
County. Personal lines include homeowner’s insurance, residential dwelling insurance, mobile
homeowner’s insurance, and personal automobile insurance. Other lines include other types of
insurance like business, commercial, and crop insurance.
Number of Claims Amount of Losses Amount of Losses

Paid Incurred
Personal Line of
234,168 $1,136,071,404 $1,556,882,087
Insurance
Other Lines of
49,461 $1,000,655,816 $4,002,476,765
Insurance
TFPA provides limited coverage for one- and two-family residential dwellings, townhouse
units, and condominium units that meet certain underwriting standards. TFPA provides
residential property insurance to Texas residents in areas designated by the Commissioner of
Insurance as underserved. TFPA policy counts grew 12 percent annual from 2010 to mid-2015,
especially in the greater Houston area, as insurance companies reevaluated their exposure to
catastrophes.
Page 116 of 420
The following TFPA information from May 2018 is a subset of the information reported from
TDI. The total indemnity payments in Houston related to Hurricane Harvey, which are the
losses paid or expected to be paid directly to an insured for first-party coverages, totaled over
$14 million. Paid expenses, which are expenses of adjusting claims that cannot be charged
against specific claims, totaled over $8 million. The average paid claim was $1,106 in Houston.
New Closed Open Percent Paid Paid Average

Claims Claims Inventory Closed Indemnity Expense Paid
Houston 8,221 8,121 100 99% $14,857,961 $8,345,920 $1,106
Insurance is one way that many households begin to recover from a disaster. But, many
Houstonians don’t have insurance, and those that do may not have filed a claim or closed the
claim without payment because the damage fell below the deductible or the damage was not
covered by the policy.
The following information was provided to Houston by FEMA in May 2018. Similar to the
statewide NFIP claims, there was an increase in NFIP claims in Houston as a direct result of
Hurricane Harvey. More than 882 (3 percent) of claims remained active/open with more than
21,374 (83 percent) claims closed. There are approximately 3,419 (13 percent) of claims that
are closed without payment. The total assessed damage for NFIP claims was more than $2.957
billion. In total, more than $2.743 billion has been paid out on claims made during August to
December 2017 with the average of all payments being $107,359.
August September October November December Total

Claims 6,609 61 4 0 0 6,674
with RL
Total 25,515 351 17 6 7 25,896
Claims
For Houston, the impacts from Harvey were mostly from flooding, and because the wind
intensity had subsided after Hurricane Harvey hit the coast of Texas, only a minimal number
of households had damage due to wind. There were no TWIA claims in the City of Houston,
as Houston falls outside of the coverage area.
Page 117 of 420

Homeowners and renters whose property was damaged by a declared disaster can apply for a
Small Business Assistance (SBA) low-interest, disaster related home loan. The GLO provided
SBA Disaster Home Loan data from January 28, 2018 to the City of Houston in May 2018.
For the damaged properties in Houston, the total approved loan amount was $718,372,700, and
the total amount of applicants’ verified loss was $1,541,774,861.
9. Public Housing Authority Data
HHA provided the following information to the City of Houston in May 2018. Hurricane
Harvey damaged approximately 18 percent of units owned by HHA. The following tables give
details of Hurricane Harvey’s impact to HHA properties.
Page 118 of 420

Type of
Type of
Damages in
Number and Number Damages in
Total Common
Public Type of Units of Damaged
Number Areas/ Office/
Housing Damaged Units
of Units Other
Tax Units
Public
Credit/ Flood Leaks Flood Leaks
Housing
Market
Clayton
296 296 0 112 112 0 0 0
Homes
Forest Green 100 100 0 84 84 0 1 1
Irvinton
318 318 0 23 10 13 0 0
Village
Allen
Parkway
500 500 0 80 0 80 1 4
Village/HOA
PV
Historic
Rental 40 40 0 1 0 1 0 0
Initiative
Bellerive 210 210 0 0 0 0 0 0
Cuney Homes 553 553 0 18 0 18 0 9
Ewing
40 40 0 0 0 0 0 0
Apartments
Fulton Village 108 108 0 38 0 38 0 0
Heatherbrook 176 53 123 27 0 27 0 0
Kelly Village 270 270 0 0 0 0 0 1
Kennedy
108 108 0 17 0 17 0 2
Place
Lincoln Park 250 200 50 27 0 27 0 0
Lyerly 199 199 0 0 0 0 0 0
Oxford Place 250 230 20 16 0 16 0 0
Victory 100 100 0 27 0 27 0 0
Total 3,518 3,325 193 470 206 264 2 17
Page 119 of 420

Number Type of Damages in
Total Type of Damages in
Tax Credit of Common
Number Damaged Units
Property Damaged Areas/Office/Other
of Units
Units Flood Leaks Flood Leaks
2100 Memorial 197 197 0 TBD 1 0
Mansions at
252 71 44 27 5 1
Turkey Creek
Sweetwater 260 73 0 73 0 0
Uvalde Ranch 244 74 74 0 1 0
Peninsula Park 280 52 0 52 0 0
Pinnacle 250 0 0 0 0 0
Villas at
234 172 0 172 0 0
Winkler
Willow Park 260 0 0 8 0 0
Total 1,977 6399 118 332 7 1
Type of Damages in Damaged

Total Number Number of
PBV Property Units
of Units Damaged Units
Flood Leaks
Long Drive 100 12 0 12
Telephone Road 200 0 0 0
Total 300 12 0 12
In summary, HHA had a total of 1,121 damaged units, and 392 families using tenant-based
vouchers were displaced from their homes. After Hurricane Harvey, HHA inspected 910
housing units in the Housing Choice Voucher Program of which 392 units, or 47 percent of
the housing units in the Housing Voucher Choice Program, failed inspection and the family
had to move out. Furthermore, HHA has paid over $1.2 million on 268 units at 17 properties
for Housing for Harvey, a collaboration between the City, Harris County, and other partners to
provide non-congregate shelter for Harvey impacted families. Due to the strain put on the
Voucher Program, the housing authorities from Oklahoma City, Oklahoma, and Cambridge,
Massachusetts have helped Houston by lending vouchers to Harvey-impacted families.
Number of Displaced
Number of Units Damaged
Families
Public Housing 206 470
Tax Credit 118 639
Multifamily Project Based 0 12
Voucher
Tenant Based Voucher 392 392
Families Displaced
Total 716 1,513
Page 120 of 420
Besides damage to living quarters, many properties also had extensive damage to common
areas and non-residential buildings (administrative, maintenance, etc.), which are essential to
the functioning of a housing development. Total estimated amount of damages for HHA alone
is about $50 million. Damage to many units and buildings are extensive and will require
reconstruction. Therefore, the unmet need estimates for repair underestimates the real need of
rebuilding housing units that have been damaged repeatedly over the past several years.
Property Estimated Repair Cost

APV/HOAPV $464,000.00
Bellerive $5,000.00
Clayton Homes $14,445,300.00
Cuney Homes $55,000.00
Forest Green $3,972,146.75
Fulton Village $185,000.00
Heatherbrook $288,500.00
Historic Oaks $250,000.00
HHA $516,000.00
Irvinton Village $1,936,000.00
Kennedy Place $125,000.00
Lincoln Park $160,000.00
Oxford Place $85,000.00
Sweetwater Point $1,399,500.00
Victory Place $40,000.00
Total $23,926,446.75
Property Estimated Repair Cost

2100 Memorial $16,013,400.00
Long Drive $63,860.00
Mansions at Turkey Creek $3,644,500.00
Peninsula Park $59,500.00
Pinnacle on Wilcrest $11,500.00
Telephone Road $12,000.00
Uvalde Ranch $3,257,000.00
Villas on Winkler $2,383,500.00
Willow Park $15,595.00
Total $25,460,855.00
HHA has applied for FEMA PA in the amount of the damages illustrated above. The
following calculation, prescribed by the GLO, shows the need for HHA.
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15 percent
PA Category Approx. PA 10 percent Total Need (Local
Resiliency on
(HHA) Cost Local Match Match + Resiliency)*
Approx. Cost
E – Buildings
$49,387,302 $4,938,730 $7,408,095 $12,346,826
and Equipment
Total $49,387,302 $4,938,730 $7,408,095 $12,346,826
*The total need in this table does not reflect the actual needs of HHA because it does not take into account severe
damage to some HHA properties that now need demolition and reconstruction.
The need for HHA is much greater than just the repair costs due to Hurricane Harvey damage.
In addition to the impacts from Hurricane Harvey, some of HHA’s units were impacted by
flooding events in 2015 and 2016, as well. This has depleted many developments’ reserves for
repair. Due to flooding impacts, some developments may need to be reconstructed to prevent
future flooding. These costs have not been included above. The unmet needs of public housing
will be prioritized, and further information will be detailed in program guidelines.
FEMA IA data from February 2, 2018, received from the GLO in May 2018, was used to
quantify all housing applicants impacted by Hurricane Harvey. This information was then used
to calculate the unmet needs for housing, based on the same methodology that the GLO used.
According to HUD, only the most impacted homes are to be included in calculations for unmet
housing needs. Owner-occupied homes are determined to be most impacted if they have real
property damage of $8,000 or more. Rental units are determined to be most impacted if they
have personal property damage of $2,000 or more. The FVL amount was used as a proxy for
real property damage and personal property damage, as the data received from the GLO was
limited to the FVL. The following are the HUD determined categories of FEMA inspected
most impacted homes.
Owner-occupied Homes
 Major-Low: $8,000 to $14,999 of FEMA verified loss
 Major-High: $15,000 to $28,800 of FEMA verified loss
 Severe: Greater than $28,800 of FEMA verified loss
Renter-occupied Homes
 Major-Low: $2,000 to $3,499 of FEMA verified loss
 Major-High: $3,500 to $7,499 of FEMA verified loss
 Severe: Greater than $7,500 of FEMA verified loss
To calculate the unmet housing need, the number of housing units determined as the most
impacted are multiplied by the multiplier amount corresponding to that category. Houston used
multipliers provided by HUD. These multipliers were determined using SBA estimated median
repair costs in each of the Major-Low, Major-High, and Severe categories less assumed
assistance from FEMA and SBA.
Page 122 of 420
Major-Low $58,956
Major-High $72,961
Severe $102,046
Approximately 258,437 applicants in Houston applied to FEMA for assistance. This is

approximately 28.8 percent of the total applicants for FEMA assistance in Texas. Almost 20
percent of all owner applicants in Texas were in Houston, and almost 38 percent of all the renter
applicants in Texas were in Houston. Of the total number of applicants in Houston, 75,887 had a
FVL over $0, which is 26 percent of those applicants with FVL over $0 in Texas.
The total number of owner-occupied applicants in Houston with over $8,000 in FVL is 22,476.
The total number of renter applicants in Houston with over $2,000 in FVL is 14,878. Over half (51
percent) of the owner applicants received a FVL over $0, which is much higher than the number
of renter applicants receiving a FVL over $0, at only 18 percent. This may indicate that renter
needs are under-represented in FEMA IA estimates.
Applicants with Unmet

Occupancy Type Total Applications FVL Over $0
Need
Owner 88,282 45,084 22,476
Renter 168,723 30,765 14,878
N/A 1,432 28 0
Total 258,437 75,877 37,354
a. Total Unmet Need
The following table provides a breakdown of total unmet needs for owner- and renter-
occupied households using GLO’s methodology to calculate unmet need. It provides the
damage category and the total count of unmet need for those three categories as previously
defined.
Total Owner-
Damage Owner- Total Owner
Total Occupied and Rental Total Rental
Category/ Occupied Occupied Unmet
Count Rental Unmet Count Unmet Needs
Multiplier Count Need
Needs
Major-
Low: 12,598 $742,727,688 7,392 $435,802,752 5,206 $306,924,936
$58,956
Major-
High: 18,364 $1,339,855,741 10,370 $756,605,570 7,994 $583,250,234
$72,961
Severe:
$102,046
6,392 $652,278,032 4,714 $481,044,844 1,678 $171,233,188
Total 37,354 $2,734,862,524 22,476 $1,673,453,166 14,878 $1,061,408,358
Page 123 of 420

As defined by the table, the owner-occupied unmet need in dollars is $1.67 billion (61
percent) and the renter unmet need is $1.06 billion (39 percent), resulting in a total unmet
need of $2.73 billion.
Approximately 49 percent of the unmet need population is in the LMI category. The unmet
need for the LMI population is over $1.3 billion. The unmet need by income category for
Houston applicants can be seen in the following table.
Income Percent of Percent of

Count Unmet Need
Category Count Unmet Need
0-30% 8,723 $619,561,377 23% 23%
31-50% 4,575 $322,882,375 12% 12%
51-80% 5,480 $388,017,580 15% 14%
Above 80% 12,964 $987,774,019 35% 36%
Not Reported 5,612 $416,632,607 15% 15%
Total 37,354 $2,734,861,524 100% 100%
b. Owner Occupied Unmet Need
Approximately 35 percent of the owner-occupied unmet need is in the LMI category. For
owners, the unmet need for the LMI population is over $596 million. The unmet need by
income category for owner-occupied households for Houston can be seen in the following
table. Findings from this data have helped Houston better develop programs for
homeowners, such as Homeowner Assistance, Single Family Development, Homebuyer
Assistance, and Housing Buyout.

Count Unmet Need
0-30% 3,194 $222,356,274 14% 13%
31-50% 2,230 $156,016,730 10% 9%
51-80% 3,095 $217,915,740 14% 13%
Above 80% 10,428 $806,736,918 46% 48%
Not Reported 3,529 $270,427,504 16% 16%
Total 22,476 $1,673,453,166 100% 100%
The following map shows this unmet need for owners in the City of Houston by census
tract.
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Figure 44: Owner Unmet Need by Income Category for City of Houston
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c. Renter Occupied Unmet Need
The percentage of renter households within LMI categories was analyzed and
approximately 69 percent of the unmet need is in the less than 80 percent LMI category.
The unmet need for the LMI population is over $734 million for renters. The unmet need
by income category for renters in Houston is illustrated in the following table. This
information informed the Multifamily Rental Program and the Small Rental Program,
which are designed to provide funds for rehabilitation, reconstruction, and new
construction of affordable rental homes for residents or in areas impacted by Hurricane
Harvey. It also informed the Single Family Development and Homebuyer Assistance
Programs, as some renters may transition into homeownership.

Count Unmet Need
0-30% 5,529 $397,198,669 37% 37%
31-50% 2,345 $166,865,645 16% 16%
51-80% 2,385 $170,101,840 16% 16%
Above 80% 2,536 $181,037,101 17% 17%
Not Reported 2,083 $146,205,103 14% 14%
Total 14,878 $1,061,408,358 100% 100%
The following map shows this unmet need for renters in the City of Houston by census
tract.
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Figure 45: Renter Unmet Need by Income Category for City of Houston
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d. Total Unmet Need Using HUD’s Methodology
a house if the combined households income is greater than 120 percent AMI or the national
median, the property was located in a floodplain at the time of the disaster, and the property
owner did not maintain flood insurance on the damaged property, even when the property
owner was not required to obtain and maintain such insurance.
HUD, through the Federal Register, indicates how to calculate unmet need for owners and
renters. HUD specifies that owners have an unmet need if they have a real property flood
value loss of $8,000 or greater and either 1) live outside of a floodplain without flood
insurance or 2) live inside a floodplain without flood insurance and have a household
income of less than 120 percent AMI. HUD identifies renters with an unmet need as those
households with a personal property flood value loss of greater than $2,000 and have a
household income less than 50 percent AMI. The dollar amounts used are for HUD’s
calculation of unmet need and do not impact eligibility of the program.
The following table provides a breakdown of owners in a floodplain with no flood

insurance by income category. The number of FEMA IA applicants that show an unmet
need totals 37,354. The total number of most impacted owners that are in a floodplain with
no flood insurance totals 2,994 (8 percent). Most owners living in the floodplain without
insurance are families making below 120 percent AMI, with the total number households
above 120 percent AMI at 520 and the total of owners below 120 percent AMI at 1,980.

Count Unmet Need
0-30% 659 $47,052,274 22% 22%
31-50% 425 $30,405,015 14% 14%
51-80% 560 $40,055,395 19% 18%
81-120% 336 $24,031,081 11% 11%
Above 120% 520 $39,942,135 17% 18%
Not Reported 494 $37,423,554 17% 17%
Total 2,994 $218,909,454 100% 100%
11. City of Houston’s Floodplain Management Office
The City of Houston’s Floodplain Management Office is responsible for administering the
provisions in the City’s Floodplain Ordinance, which includes making determinations
regarding substantially damaged buildings in the 100-year floodplain in the city limits of
Houston. A home is considered substantially damaged when the cost to repair it is more than
50 percent of the market value of the home. As of May 2018, approximately 1,944 homes in
Houston were considered substantially damaged.
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The City will not issue permits for repairs to homes considered to be substantially damaged
unless the owner demonstrates how the home will be in compliance with the City’s Floodplain
Ordinance. To comply, these homes must be elevated or reconstructed at a higher elevation.
Although substantially damaged homes may have received assistance from FEMA or other
sources, because there are additional requirements from the City, for safety reasons, there is an
additional unmet need for these property owners who must elevate or rebuild, rather than just
repair damages.
12. HCFCD Home Buyout Program
The HCFCD is a special purpose district that provides flood damage reduction projects in
Harris County, including in the City of Houston. HCFCD administers a Home Buyout Program
to reduce flood damages by purchasing and removing homes located several feet deep in the
floodplain where flood damage reduction projects are not cost effective or beneficial. HCFCD
has 24 Buyout Areas of Interest within the city limits of Houston, where homes are considered
hopelessly deep in the floodplain. Once these homes are purchased, HCFCD will demolish the
homes and keep the areas for flood mitigation. As of May 2018, there are 2,033 privately
owned parcels within these 24 areas. Of these, there are 1,398 parcels with structures and 629
parcels are vacant lots. There is a need to purchase these parcels to remove these households
from areas that are flooding hazards.
13. Summary of Housing Unmet Need
The City of Houston is still analyzing the best available data to determine unmet housing need.
Based on the information in this section, the City of Houston is showing a need that is much
more than the City’s current allocation of CDBG-DR funds. The City is working with
consultants to analyze more detailed data from a variety of sources. The analysis will be
available at a later date and will be considered during the development of program guidelines.
G. Infrastructure Impact
Hurricane Harvey has impacted Houston’s infrastructure and caused damage to water system
facilities, roads, bridges, and parks. In addition to direct damage to infrastructure caused by
flooding, aging or under-sized infrastructure can also lead to flooding in residential homes and
other structures. Houston Public Works (HPW) has inspected various infrastructure systems in the
city since Harvey and continues to monitor these systems and facilities for needed repairs.
Additional assessments of the infrastructure system are planned in the future. These assessments
will include mitigation needed to protect from damages caused by future flooding events and
adaptation for future infrastructure.
Like the GLO, Houston has prioritized housing unmet need in this Action Plan. The City
anticipates receiving additional federal funds in 2019, specifically additional CDBG-DR funds as
referenced in Public Law 115-123, to address a variety of activities related to mitigation, which is
anticipated to be used to address a variety of unmet needs including infrastructure.
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The FEMA PA data is the best available data set to determine infrastructure need after
Hurricane Harvey. The City of Houston used the GLO’s methodology to calculate
infrastructure unmet need by adding the local match and resiliency cost of projects assisted
through FEMA’s PA. The Local Match is 10 percent of the approximate PA cost and
Resiliency is 15 percent of the approximate PA cost. The following PA cost estimates and
unmet need calculations are based on data from the FEMA Grants Portal Damage Inventory
on December 4, 2017.
15 percent Total Need

PA Category (City of Approx. PA 10 percent
Houston) Cost* Local Match
A – Debris Removal $259,459,255 $25,945,926 $38,918,888 $64,864,814
B – Emergency
$140,307,363 $14,030,736 $21,046,104 $35,076,840
Protective Measures
C – Roads and Bridges TBD TBD TBD TBD
D – Water Control
TBD TBD TBD TBD
Facilities
E – Buildings and
$78,467,346 $7,846,735 $11,770,102 $19,616,837
Equipment
F – Utilities $80,560,302 $8,056,030 $12,084,045 $20,140,075
G – Parks, Recreational
Facilities, and Other $32,000,000 $3,200,000 $4,800,000 $8,000,000
Items
Z – Direct
TBD TBD TBD TBD
Administrative Costs
*Costs based on 12/4/17 data for the FEMA Grants Portal Damage Inventory. Total PA Assistance is
estimated to be $2.4 billion.
As of the end of May 2018, the City of Houston had received $163,016,399 from FEMA for
two PA categories, A – Debris Removal and B – Emergency Protective Measures. It is
anticipated that in the future the City of Houston will submit additional damages for FEMA
PA grant assistance in the following categories: C – Roads and Bridges, D – Water Control
Facilities, and Z – Direct Administrative Costs. It is estimated the total PA costs will be 2.4
billion. The total need in the PA category of $147,698,568 is an underestimation of the total
infrastructure need in Houston.
The City has also received $100 million in insurance proceeds, which will be used to address
damage to City owned buildings and assets caused by Hurricane Harvey. An apportionment
and allocation methodology was submitted to FEMA on May 29, 2018, and upon approval,
these proceeds will be used for City facility repairs and business interruption reimbursements.
In addition, the City received a grant award from the Office of the Governor in the amount of
$50 million. These funds are budgeted for local, non-federal cost share of debris removal cost
for Category A FEMA PA for $25 million, the purchase of additional flood insurance for $10
million, and deductible payments on current insurance policy for damage to municipal property
for $10 million.
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2. Texas Hazard Mitigation Grant Program
The City of Houston has submitted Notice of Intents to the Texas HMGP for various mitigation
projects with an estimated total cost of $703 million. These projects include constructing
detention basins and diversion channels; reconstructing streets and utilities; removing
structures from the floodplain through buyouts, elevations, and rebuilding; and dredging of
waterways. The City will be submitting full applications for these projects soon. The HMGP
provides assistance for 75 percent of the project cost and requires a local match for the
remaining costs. This means that Houston will have to provide a match of or has an unmet
need of approximately $175 million for infrastructure mitigation projects.
Unmet Need
Cost Funding Source
(25% Local Match)
Hazard Mitigation
$703,000,000 FEMA-HMGP $175,750,000
Projects
3. Summary of Infrastructure Unmet Need
The current estimated infrastructure unmet need for Houston, as calculated by the method
suggested by GLO, is $198,448,568. This does not include all infrastructure unmet need in
Houston related to Hurricane Harvey.
Houston’s unmet infrastructure need also includes a variety of unfunded but needed
infrastructure projects. This includes unfunded local drainage projects that are crucial to
reducing damage from future flooding in Houston’s neighborhoods. These projects are
identified through a data-driven analysis of the storm water infrastructure in the city. These
drainage projects are critical to improving storm water drainage systems in local
neighborhoods and are one component to achieving resiliency in Houston’s neighborhoods and
reducing flood risks to homes and businesses.
In addition, the City of Houston is looking at ways to upgrade its infrastructure systems, and
not just repair infrastructure that will likely get damaged again in a future flood event. One
example is the wastewater consolidation projects, which will remove wastewater lift stations
above ground and construct new underground infrastructure through gravity-fed pipes. Local
communities want to remove damaged lift stations from their neighborhoods. These
wastewater consolidation projects will not only help these neighborhoods eliminate lift stations
from their surroundings but will also provide more resilient underground infrastructure.
The City continues to further assess its infrastructure and determine ways to incorporate
mitigation and resilience strategies to protect the current infrastructure from and also adapt
infrastructure to future flooding events.
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H. Economic Impact
Houston’s economy is the 6th largest in the country and is expected to double its current Gross
Domestic Product (GDP) by 2040 with an estimated GDP growth rate of 3.1 percent 47. According
to the Texas Workforce Commission, the unemployment rate for the City of Houston in April 2018
was 4.2 percent. The industries that employ the greatest number of people are educational services,
health care and social assistance (18.9 percent); professional, scientific, and management (14.4
percent); construction (10.2 percent); and retail trade (10.5 percent) followed by arts, entertainment
and recreation (9.7 percent); manufacturing (8.6 percent); transportation and warehousing (5.6
percent); and other services (6.1 percent). Overall, Houston’s economy was robust before Harvey
and is expected to continue to remain strong through the recovery from Harvey.
Houston’s economy was impacted by the recent energy industry downturn and by several flooding
disasters, including Hurricane Harvey in 2017. Since the Houston metropolitan area is rapidly
growing and the city has a robust economy, Hurricane Harvey is not expected to cause a major
economic downturn in Houston. However, job creation, as reported in March 2018, has fallen
below the long-term average for the month of March 48. Even though the unemployment rate was
lower than the rate from previous years at 4.1 percent after Harvey, the labor force has shrunk by
31,900 from May 2015 to February 2017 49.
1. Employment
Most of Houston’s employment growth in the past decade can be attributed to the following
four sectors: health care and social assistance; leisure and hospitality; professional and business
services; and trade, transportation, and utilities. Jobs in the health care sector and professional
and business services sectors are well-paying but also require advanced degrees or specialized
trainings that are usually out of reach for LMI individuals. Jobs in the leisure and hospitality
sector and trade, transportation, and utilities sector do not necessarily require advanced degrees
or specialized training but also have lower median wages. The impact on wages and
employment in these sectors after Harvey is still under investigation. However, based on active
claimants for unemployment benefits filed in October 2017, approximately 6,182 individuals
lost their jobs and filed for unemployment benefits in the City of Houston. In January 2018,
the number of active claimants for unemployment benefits was reduced to approximately
5,156.
2. Small Business Administration Business Disaster Loans
The GLO provided SBA business disaster loan data from January 28, 2018 to the City of
Houston in May 2018. Businesses of all sizes as well as private, non-profit organizations, are
47
Greater Houston Partnership, (2017). Houston’s Economy.
http://www.houston.org/pdf/research/quickview/Most_Current_Talking_Points.pdf
48
Greater Houston Partnership, (May 2018). The Economy at A Glance Houston.
http://www.houston.org/pdf/research/quickview/Economy_at_a_Glance.pdf
49
Greater Houston Partnership, (December 2017). Economic Highlights, 2017.
http://www.houston.org/assets/pdf/economy/Economic-Highlights-2017-web.pdf
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eligible for SBA business disaster loans. Loans can be used to repair or replace disaster-
damaged property owned by the business.
The total verified loss for real estate totaled more than $1.2 billion and the total verified loss
of business content was more than $146 million in Houston. The total combined business
verified loss in Houston was over $1.4 billion for Hurricane Harvey. The SBA has approved
over $271 million, as of January 2018. The remaining amount of loss totals over $1.1 billion.
Following the methodology used by the GLO, the City uses the remaining amount of loss totals
as the preliminary unmet need for businesses impacted by Hurricane Harvey.
3. Summary of Economic Unmet Need
Overall, the Houston economy is strong post-Harvey. However, the economy of certain
neighborhoods, such as those with flooded homes that remain vacant, may continue to see
impacts with fewer residents in the area for business or retail. Some neighborhoods have real
estate values that have plummeted, while in others it has increased. Recovery in some
neighborhoods will take many years. Economic recovery also differs from household to
household. Individuals with lower educational attainment or employment skills may be less
resilient than others to recover from a major storm event. So, although the economy is strong
at the macro level, many households struggle to recapture what they had before Hurricane
Harvey because of a lost job, lost pay, or lost property, and they do not have the ability to
increase their income to cover the cost of their recovery.
In addition, Hurricane Harvey has affected certain sectors more than others, such as the
construction industry. With damaged homes in need of repair, elevation, or reconstruction,
there has been a significant increase in construction demand, beginning in the fall of 2017.
This demand has led to a labor shortage and higher costs for residents in need of home repair.
The community input received so far has confirmed the struggle for families in finding
reasonably priced contractors to complete needed repairs on their flood-damaged properties in
a timely manner.
Policy changes spurred by Hurricane Harvey’s impacts on life and property may also impact
the economy. In April 2018, Houston City Council approved a rule for new home and other
building developments in the floodplain to be elevated above a certain level. Many argued
against this change saying it may drive up prices and stifle development. The new policy comes
into effect on September 1, 2018, and any impacts are yet to be determined. If other City or
State rules are passed in response to Harvey impacts, these may also have effects on Houston’s
economy.
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4.1. General Requirements
A. Rehabilitation/Reconstruction of Public Housing, Affordable Housing and other forms
of Assisted Housing
The GLO will identify and address the rehabilitation, reconstruction, and replacement of the
following types of housing affected by Hurricane Harvey: public housing (including administrative
offices); HUD-assisted housing; affordable housing; McKinney-Vento Homeless Assistance Act-
funded shelters and housing for the homeless including emergency shelters and transitional and
permanent housing for the homeless; private market units receiving project-based Section 8
assistance and tenants participating in the Section 8 Housing Choice Voucher Program.
All proposed projects will undergo Affirmatively Furthering Fair Housing (AFFH) review by the
GLO before approval. Such review will include assessments of (1) a proposed project’s area
demography, (2) socioeconomic characteristics, (3) housing configuration and needs, (4)
educational, transportation, and health care opportunities, (5) environmental hazards or concerns,
and (6) all other factors material to the AFFH determination. Applications will show that projects
are likely to lessen area racial, ethnic, and low-income concentrations, and/or promote affordable
housing in low-poverty, nonminority areas in response to natural hazard-related impacts.
The GLO will retain the full 5 percent allocated for administrative costs associated with the
CDBG-DR allocation for purposes of oversight, management, and reporting. The only exception
is an allowance for up to 2.5 percent of program amounts for administration costs in the Harris
County and city of Houston programs. Additionally, all subrecipients, including Harris County
and Houston, are allowed to spend up to 10 percent of program amounts for costs directly related
to implementation of housing activities and 6 percent for non-housing and infrastructure type
activities for CDBG-DR grant awards $1 million or greater. For non-housing and infrastructure
grant awards less than $1 million refer to GLO guidance found on the website,
http://recovery.texas.gov/. Once program level allocations are identified by Harris County and
Houston, administrative costs will be outlined in subsequent Action Plan Amendment budgets.
Engineering and design activities will be capped at 15 percent of the total project award unless
special services are necessary; subject to GLO approval. The GLO, Harris County, and the city of
Houston will limit planning costs to 5 percent of each respective allocation to complete projects
as defined in 24 Code of Federal Regulations (CFR) 570.205.
The GLO will create policies and procedures to assess the cost-effectiveness of each proposed
project whose goal is to assist a household under any residential rehabilitation or reconstruction
program. These policies and procedures will include criteria that determine whether the
rehabilitation or reconstruction of the unit will be cost-effective relative to other means of assisting
the property owner such as buyout or acquisition of the property or construction of area-wide
protective infrastructure. Additionally, the GLO will offer, as appropriate, other housing
alternatives that are more-cost effective, such as manufactured housing options.
On a case-by-case basis, the GLO will consider exceptions to these comparison criteria and will
describe:
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• The process used to analyze the circumstances under which an exception is necessary;
• How reasonable accommodations were made to provide accessibility for an occupant
with a disability;
• How the amount of assistance is necessary and reasonable, per 2 CFR part 200, subpart
E—Cost Principles.
B. Housing for Vulnerable Populations
The GLO will promote housing for vulnerable populations, including a description of activities
that will address the following: the transitional housing, permanent supportive housing, and
permanent housing needs of individuals and families that are homeless and at-risk of
homelessness; the prevention of low-income individuals and families with children (especially
those with incomes below 30 percent of the area median) from becoming homeless; the special
needs of persons who are not homeless but require supportive housing (e.g., elderly, persons with
disabilities, persons with alcohol or other drug addiction, persons with HIV/AIDS and their
families, and public housing residents, as identified in 24 CFR 91.315(e)).
The GLO and subrecipients administering programs related to direct housing assistance, in
consultation with affected citizens, stakeholders, local governments, and public housing
authorities, will conduct needs assessments. The local needs assessment and analysis of
HUD/FEMA demographic IA data will recommend the proportions of funding that should be set
aside to benefit each LMI and non-LMI economic group. The needs assessment will determine the
activities to be offered, the demographics to receive concentrated attention, and target areas to be
served. The needs assessment will set goals within the income brackets similar to the damage units
within the impacted areas. Deviations from goals must be approved by the GLO before the
subrecipient may move forward.
The GLO and subrecipients administering programs related to direct housing assistance are
committed to AFFH through established affirmative marketing policies. The GLO and
subrecipient will coordinate with HUD-certified housing counseling organizations. Affirmative
marketing efforts will include an affirmative marketing plan, based on the HUD regulations. The
goal is to ensure that outreach and communication efforts reach eligible homeowners from all
groups including, but not limited to, racial, ethnic, national origin, religious, familial status, the
disabled, "special needs", and gender groups.
C. Displacement of Persons and/or Entities
To minimize the displacement of persons and/or entities that may be affected by the activities
outlined in this Action Plan, the GLO will coordinate with other state agencies, local governments,
and local non-profit organizations to ensure minimal displacement. However, should any proposed
projects cause the displacement of people, the GLO will ensure the requirements set forth under
the Uniform Relocation Assistance (URA) and Real Property Acquisition Policies Act, as
amended, are met.
The relocation assistance requirements at section 104(d)(2)(A) of the Housing and Community
Development Act (HCDA) and 24 CFR 42.350 are waived to the extent that they differ from the
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requirements of the URA and implementing regulations at 49 CFR part 24, as modified by the
notice for activities related to disaster recovery. Without this waiver, disparities exist in relocation
assistance associated with activities typically funded by HUD and FEMA (e.g., buyouts and
relocation). Both FEMA and CDBG funds are subject to the requirements of the URA; however,
CDBG funds are subject to Section 104(d), while FEMA funds are not. The URA provides that a
displaced person is eligible to receive a rental assistance payment that covers a period of 42
months. By contrast, Section 104(d) allows a lower-income displaced person to choose between
the URA rental assistance payment and a rental assistance payment calculated over a period of 60
months. This waiver of the Section 104(d) requirements ensures uniform and equitable treatment
by setting the URA and its implementing regulations as the sole standard for relocation assistance
under the federal register notice.
The GLO will follow its Residential Anti-displacement and Relocation Assistance Plan (RARAP).
The GLO will take the following steps and require subrecipients and developers to minimize the
direct and indirect displacement of persons from their homes: Plan construction activities to allow
tenants to remain in their units as long as possible, by rehabilitating empty units or buildings first;
where feasible, give priority to rehabilitation of housing, as opposed to demolition, to avoid
displacement; adopt policies to identify and mitigate displacement resulting from intensive public
investment in neighborhoods; adopt tax assessment policies, such as deferred tax payment plans,
to reduce impact of increasing property tax assessments on lower income owner-occupants or
tenants in revitalizing areas; or target only those properties deemed essential to the need or success
of the project.
D. Maximum Assistance
The maximum amount of assistance available to subrecipients under the GLO’s disaster recovery
program will be the maximum allocated to the HUD most impacted and distressed areas. For all
housing and buyout programs, the GLO’s housing guidelines establish housing assistance
maximums. Each subrecipient will set the maximum amount of assistance available to a
beneficiary under its program to be equal to or less than the GLO’s housing assistance maximums.
A waiver request must be submitted to the GLO if a subrecipient’s housing assistance maximums
exceed the GLO amounts. The GLO will evaluate each housing assistance waiver request for cost
effectiveness.
E. Elevation Standards
The GLO will apply the following elevation standards to new construction, repair of substantial
damage, or substantial improvement of structures located in an area delineated as a flood hazard
area or equivalent in FEMA’s data source identified in 24 CFR 55.2(b)(1). All structures, as
defined under 44 CFR 59.1, designed principally for residential use and located in the 100-year
(or 1 percent annual chance) floodplain that receive assistance for new construction, repair of
substantial damage, or substantial improvement, as defined under 24 CFR 55.2(b) (10), must be
elevated with the lowest floor, including the basement, at least 2 feet above the annual floodplain
elevation. Mixed-use structures with no dwelling units and no residents below the annual
floodplain must be elevated or floodproofed in accordance with FEMA floodproofing standards
under 44 CFR 60.3(c)(3)(ii) or successor standard, at least 2 feet above the annual floodplain.
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Applicable state, local, and tribal codes and standards for floodplain management that exceed these
requirements, including elevation, setbacks, and cumulative substantial damage requirements, will
be followed.
The GLO has established elevation costs caps at $60,000 for elevation of single-family homes in
coastal counties, and $35,000 for non-coastal counties. These elevation costs caps were established
considering elevation costs associated with past GLO CDBG-DR housing
rehabilitation/reconstruction programs. Elevation costs higher than these established caps will
require a waiver request to the GLO. Elevation requirements are taken into consideration when
determining whether to rehabilitate or reconstruct a home. Generally, a home will be reconstructed
when home repair costs are greater than $65,000, an exception to this may include a home that has
been determined eligible on the National Register of Historic Places. The GLO may re-evaluate
its elevation costs caps during the implementation of the HAP based on average costs associated
with elevating single-family homes and on a case by case basis as needed.
Nonresidential structures must be elevated to the standards described in this paragraph or

floodproofed, in accordance with FEMA floodproofing standards at 44 CFR 60.3(c)(3)(ii) or
successor standard, up to at least two feet above the 100-year (or 1 percent annual chance)
floodplain. All Critical Actions, as defined at 24 CFR 55.2(b)(3), within the 500-year (or 0.2
percent annual chance) floodplain must be elevated or floodproofed (in accordance with the FEMA
standards) to the higher of the 500-year floodplain elevation or three feet above the 100- year
floodplain elevation. If the 500-year floodplain or elevation is unavailable, and the Critical Action
is in the 100- year floodplain, then the structure must be elevated or floodproofed at least three feet
above the 100-year floodplain elevation. Critical Actions are defined as an ‘‘activity for which
even a slight chance of flooding would be too great, because such flooding might result in loss of
life, injury to persons or damage to property.’’ For example, Critical Actions include hospitals,
nursing homes, police stations, fire stations and principal utility lines.
The GLO has not established elevation cost caps for multifamily rental developments and
infrastructure (public facilities, public improvements, and/or nonresidential structures). To
evaluate reasonable elevation costs, the GLO will rely on licensed engineers responsible for project
budget justification, construction code requirements, and CDBG-DR project funding maximums.
The GLO will encourage subrecipients to consider the costs and benefits of the project when
selecting CDBG-DR eligible projects.
F. Planning and Coordination
The GLO’s recovery projects will be developed in a manner that considers an integrated approach
to address long-term recovery and restoration of infrastructure, housing, and economic
revitalization in the most impacted and distressed areas.
The GLO will continue to work with state and local jurisdictions to provide guidance on promoting
sound short- and long-term recovery plans in the affected areas by coordinating available resources
to help in the restoration and recovery of damaged communities. Disaster recovery presents
affected communities with unique opportunities to examine a wide range of issues such as drainage
and flood control, housing quality and availability, road and rail networks, environmental issues,
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and the adequacy of existing infrastructure. The GLO will support long-term plans put in place by
local and regional communities that promote sound, sustainable, long-term recovery planning
informed by a post-disaster evaluation of hazard risk, especially land-use decisions that reflect
responsible floodplain management and take into account future possible extreme weather events
and other natural hazards and long-term risks.
The GLO will coordinate as much as possible with local and regional planning efforts to ensure
consistency, to promote community-level and/or regional (e.g., multiple local jurisdictions) post-
disaster recovery and mitigation, and to leverage those efforts. As detailed later in this Action Plan,
the GLO will utilize partnerships with the Texas universities and/or vendors (term which shall
include, but not limited to, governmental entities, non-profit and for profit firms, entities, and
organizations) in order to further coordinate planning, studies and data analysis.
The GLO will obtain formal agreements with State Historic Preservation Officer, Fish and Wildlife
Service, and National Marine Fisheries Service, for compliance with section 106 of the National
Historic Preservation Act (54 U.S.C. 306108) and section 7 of the Endangered Species Act of 1973
(16 U.S.C. 1536) when designing a reimbursement program. The GLO will notify HUD when
these agreements have been executed.
G. Infrastructure Activities
The GLO will encourage subrecipients to integrate mitigation measures into rebuilding activities
and the extent to which infrastructure activities funded through this grant will achieve objectives
outlined in regionally or locally established plans and policies that are designed to reduce future
risk to the jurisdiction. By being informed by future, ongoing, and previously conducted regional
studies, the GLOwill ensure better coordination of projects between localities to address recovery
and mitigation in a more holisticmanner.
The GLO will encourage subrecipients to consider the costs and benefits of the project when
selecting CDBG-DR eligible projects. Each infrastructure activity must demonstrate how it will
contribute to the long-term recovery and restoration of housing.
The GLO will seek to ensure that infrastructure activities will avoid disproportionate impact on
vulnerable populations (as referenced in paragraph A.2.a(4) of section VI in the Federal Register
Notice, Vol. 83, No. 28, Tuesday, February 9, 2018) and will ensure, to the extent practicable, that
activities create opportunities to address economic inequities facing local communities. All project
applications will undergo an AFFH review by the GLO before approval. AFFH application
reviews will include assessments of a proposed project’s (1) area demography, (2) socioeconomic
characteristics, (3) housing configuration and needs, (4) educational, transportation, and health
care opportunities, (5) environmental hazards or concerns, and (6) all other factors material to the
AFFH determination.
The GLO will coordinate with federal, state, local, private, and nonprofit sources to assist
subrecipients to align investments with other planned state or local capital improvements and
infrastructure development efforts. The GLO will also work with subrecipients to identify
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additional infrastructure funding from multiple sources, including both existing state and local
capital improvement projects as well as the potential for private investment.
The GLO will rely on professional engineers procured by subrecipients to employ adaptable and
reliable technologies to guard against premature obsolescence of infrastructure.
H. Leveraging Funds
The GLO will encourage subrecipients to leverage CDBG-DR funds with funding provided by
other federal, state, local, private, and nonprofit sources to utilize the limited CDBG-DR funds to
the fullest possible extent. The GLO will report on leverage funds in the Disaster Recovery Grant
Reporting System (DRGR) system.
The GLO anticipates leveraging CDBG-DR funds with the work by GLO and FEMA for the short-
term housing recovery through the Direct Assistance for Limited Home Repair program and
PREPS program. The GLO and subrecipients also anticipate collaborating with local governments,
local long-term recovery groups, local non-profit organizations, and vulnerable populations
advocacy groups.
Funds may be used for matching requirements, share, or contribution for any other Federal
program when used to carry out an eligible CDBG–DR activity. This includes programs or
activities administered by the FEMA or USACE. By law, (codified in the HCD Act as a note to
105(a)), the amount of CDBG–DR funds that may be contributed to a USACE project is $250,000
or less.
I. Protection of People and Property
1. Quality Construction Standards
The GLO will require both quality inspections and code compliance inspections on all projects.
Site inspections will be required on all projects to ensure quality and compliance with building
codes. The GLO will encourage and support subrecipients’ efforts to update and strengthen
local compliance codes to mitigate hazard risks due to sea level rise, high winds, storm surge,
and flooding where applicable. In the project application, subrecipients will submit an
explanation of both current and future planned codes to mitigate hazard risks. The GLO will
provide technical guidance on hazard mitigation code examples.
All rehabilitation (meets the definition of substantial improvement), reconstruction, or new

construction must meet an industry-recognized standard that has achieved certification under
at least one of the following programs: (1) ENERGY STAR (Certified Homes or Multifamily
High-Rise), (2) Enterprise Green Communities, (3) LEED (New Construction, Homes,
Midrise, Existing Buildings Operations and Maintenance, or Neighborhood Development), or
(4) ICC– 700 National Green Building Standard. For rehabilitation of non-substantially
damaged residential buildings, the GLO will follow the guidelines to the extent applicable as
specified in the HUD CPD Green Building Retrofit Checklist. For infrastructure projects, the
GLO will encourage, to the extent practicable, implementation of green building practices.
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2. Housing Contractors Standards
The GLO will establish standards in the request for qualifications for housing contractors and
will encourage subrecipients to do the same. The standards will include, but are not limited to,
information on the company’s (1) organizational structure and capabilities, (2) ability to
perform, (3) recent construction projects completed or underway over the past 5 years, (4)
performance and payment bond capacity, (5) financial statements for the past two years, (6)
evidence of insurance coverage, and (7) business registrations, certifications, and licenses.
To ensure full and open competition, subrecipients are required to follow federal procurement
and contract requirements outlined in 2 CFR 200.318 – 200.326. The GLO will monitor
subrecipient procurement. The GLO will require a warranty period post-construction for
housing; all work performed by the contractor will be guaranteed for a period of 1 year.
J. Appeals Processes
The GLO responds to complaints and appeals in a timely and professional manner to maintain a
quality level of operations. The GLO’s appeals processes apply to appeals received from
homeowners, contractors, cities, counties, housing authorities, and other entities. The GLO will
respond to homeowners by coordinating with the applicable subrecipient and/or housing contractor
to resolve issues.
A record of each complaint or appeal that the GLO receives is kept in an information file. When a
complaint or appeal is received, the GLO will respond to the complainant or appellant within 15
business days where practicable. For expediency, the GLO will utilize telephone communication
as the primary method of contact; email and postmarked letters will be used as necessary to
document conversations and transmit documentation.
Information about the complainant’s rights and how to file a complaint shall be printed on all
program applications, guidelines, the GLO public website, and subrecipients’ websites in all local
languages, as appropriate and reasonable. Procedures for appealing a GLO decision on a complaint
shall be provided to complainants in writing as part of the complaint response.
K. Dam and Levee Requirements
As stated in the Federal Register, Vol. 83, No. 28, Friday, February 9, 2018, CDBG-DR funds are
prohibited from being used to enlarge a dam or levee beyond the original footprint of the structure
that existed prior to the disaster event. The GLO will ensure that if subrecipients use CDBG-DR
funds for levees and dams, the subrecipients will (1) register and maintain entries regarding such
structures with the U.S. Army Corps of Engineers (USACE)National Levee Database or National
Inventory of Dams, (2) ensure that the structure is admitted in the USACE PL 84–99 Program
(Levee Rehabilitation and Improvement Program), and (3) ensure the structure is accredited under
the FEMA NFIP. The GLO will upload into the DRGR system the exact location of the structure
and the area served and protected by the structure and maintain file documentation demonstrating
that the grantee has conducted a risk assessment prior to funding the flood control structure and
that the investment includes risk reduction measures.
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L. Program Income
Any program income earned as a result of activities funded under this grant will be subject to
alternate requirements of 24 CFR 570.489(e), which defines program income. Program income
generated under individual contracts with the subrecipients will be returned to the GLO. At the
GLO’s discretion, program income could be allowed to remain with a community to continue
recovery efforts.
M. Monitoring Standards
The GLO provides program-wide oversight and monitoring activities for all applicable CDBG and
related federal requirements in its administration of the CDBG-DR Program. The GLO will
provide technical assistance to recipients from the application stage through the completion of the
projects to ensure that funds are appropriately used for the CDBG-DR activities, as well as meeting
one of the national objectives.
The GLO will monitor all contract expenditures for quality assurance and to prevent, detect, and
eliminate fraud, waste, and abuse as mandated by Executive Order (EO) RP 36, signed July 12,
2004, by the Governor of Texas. The GLO will particularly emphasize mitigation of fraud, abuse,
and mismanagement related to accounting, procurement, and accountability which may also be
investigated by the State Auditor’s Office (SAO). In addition, the GLO and the grantees are subject
to Uniform Guidance Standards of 2 CFR 200, which encompasses the review of compliance with
program requirements and the proper expenditure of funds by an independent Certified Public
Accountant (CPA) or by the SAO. Reports from the SAO’s office will be sent to the Office of the
Governor, the Legislative Committee, and the GLO.
The GLO has an internal audit staff that performs independent internal audits of programs and can
perform such audits on these programs and grantees. The GLO also has an independent auditing
staff that reports directly to the Commissioner of the GLO and the Chief Clerk. The GLO will
utilize a monitoring plan to specifically ensure that the recovery allocation is carried out in
accordance with state and federal laws, rules, and regulations, as well as the requirements set forth
in the Federal Register Notices. The monitoring plan will also include duplication of benefits
review to ensure compliance with the Stafford Act.
N. Broadband Infrastructure
As required by the Federal Register, Vol. 83, No. 28, Friday, February 9, 2018, any new
construction or substantial rehabilitation, as defined by 24 CFR 5.100, of a building with more
than four rental units will include installation of broadband infrastructure, as defined in 24 CFR
5.100, except where the grantee documents that: (1) the location of the new construction or
substantial rehabilitation makes installation of broadband infrastructure infeasible; (2) the cost of
installing broadband infrastructure would result in a fundamental alteration in the nature of its
program or activity or in an undue financial burden; or (3) the structure of the housing to be
substantially rehabilitated makes installation of broadband infrastructure infeasible.
O. Disaster Recovery and Response Plan

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In addition to working with universities and and/or vendors on the development of local, regional,
and state planning activities, the GLO will develop a comprehensive disaster recovery and
response plan that addresses long-term recovery and pre-and post-disaster hazard mitigation
through the consolidation and enhancement of current plans.
P. Section 3 Compliance
For applicable funded programs, the GLO and its subrecipients will ensure compliance with all
pertinent Section 3 regulations to the greatest extent possible, including providing training,
employment, contracting, and other economic opportunities to low-income and very low-income
persons, especially recipients of government assistance for housing and to businesses that provide
economic opportunities to low- and very low-income persons. Additional details can be found in
Section 3 policy and procedures.
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5.1. State Administered Disaster Recovery Program
A. Action Plan
As required by the Federal Register, Vol. 83, No. 28, Friday, February 9, 20187, and Vol. 83, No.
157, Tuesday, August 14, 2018, this Action Plan must describe the MOD of funds and the
descriptions of specific programs or activities the GLO will carry out directly. The needs
assessment, Section II, of this plan was conducted for the development and prioritization of
recovery activities. In addition, the GLO consulted with affected citizens, stakeholders, local
governments, and public housing authorities to assess needs.
This Action Plan will outline the following: the eligible affected areas and subrecipients; criteria
for eligibility; the methodology used to distribute funds to those subrecipients; activities for which
funding may be used; and program requirements, including non-duplication of benefits. The
Action Plan will also define how the uses of this allocation address necessary expenses related to
disaster relief, long-term recovery and restoration of infrastructure, and housing and economic
revitalization.
B. Direct Allocation
The city of Houston and Harris County have each received a direct allocation from the State’s
allocation at the direction of HUD. The amounts allocated to the city of Houston and Harris County
for the initial $5.024 billion were based on the amounts of unmet need calculated by HUD. The
same methodology was used by HUD to determine the amount of the $5.024 billion allocated to
the rest of the State of Texas. The amounts were adjusted to account for the prior allocation to
Harris County, the economic revitalization program, and state administration costs. Located in
Appendix G (Section 13.1) is a table that identifies the adjustments made in the Initial Action Plan.
APA 2 allocated an additional $652,175,000 in program funds provided by Public Law 115-123.
The GLO allocated the funds to Harris County, the city of Houston, and the State of Texas by
applying the same methodology used to allocate funds for the State HAP, as described in Section
12.1 Appendix F: Regional Methods of Distribution, but with Harris County and the city of
Houston included.
Because the city of Houston and Harris County have elected to develop their own local recovery
programs, with the exception of the State’s economic revitalization program, each were required
to develop a local action plan. The local action plans have been developed in accordance with the
requirements HUD has outlined in the Federal Register Notice. At a minimum the action plans
submitted by the city of Houston and Harris County must include the following: needs assessment;
connection to unmet needs, local programs and requirements, local consultation, and expenditure
timelines. At least 70 percent of the CDBG-DR program funds must be used to support activities
that benefit LMI persons.
These local action plans were included in APA 1 and are included herein.
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The GLO is required under the Federal Register Notice to certify that its subrecipients currently
have or will develop and maintain the capacity to carry out disaster recovery activities in a timely
manner. The city of Houston and Harris County are required to provide Financial Management
and Grant Compliance certification, Implementation Plan, and Capacity Assessment with
supporting documents. The GLO, through an independent third party, will review the capacity
certifications.
The city of Houston and Harris County will execute Subrecipient Agreements with the GLO and
be responsible for the implementation of their local program in their jurisdictions.
C. Connection to Unmet Needs
As required by the Federal Register, Vol. 83, No. 28, February 9, 2018, and Vol. 83, No. 157,
Tuesday, August 14, 2018, the GLO will allocate at least 80 percent of the funds to address unmet
needs within HUD-identified “most impacted and distressed” (HUD MID) areas:
Aransas, Brazoria, Chambers, Fayette, Fort Bend, Galveston, Hardin, Harris, Jasper,
Jefferson, Liberty, Montgomery, Newton, Nueces, Orange, Refugio, San Jacinto, San
Patricio, Victoria, and Wharton Counties; 75979, 77320, 77335, 77351, 77414, 77423, ,
77482, 77493, 77979, , and 78934 ZIP Codes.
Up to 20 percent of the allocation may only be used to address unmet disaster needs in those
counties that received a Hurricane Harvey presidential major disaster declaration (DR-4332), State
“most impacted and distressed” (State MID) areas.
This Action Plan primarily considers and addresses unmet housing needs with 80 percent of the
state program funds addressing unmet needs directly related to housing. Through the assessment
of needs, the GLO developed the following housing programs: Homeowner Assistance Program
(HAP); local buyout/acquisition program; a homeowner reimbursement program; and affordable
rental housing program. In addition, the GLO has allocated funds for the state cost share for the
PREPS program. The programs were developed to meet CDBG-DR, federal and state requirements
and regulations, and to implement the long-term recovery of housing as efficiently and
expeditiously as possible. It is anticipated that public service type activities may need to be utilized
to complement these housing programs. Public service activities may include, but are not limited
to, housing counseling, legal counseling, job training, mental health, and general health services.
The majority of the funds have been allocated to assist homeowners through the reimbursement of
repairs, and rehabilitation and reconstruction of their homes. Funds have been allocated for
residential buyouts and acquisition to remove homes from harm’s way.
The Affordable Rental program will address the need for affordable rental units as a result of the
impact of Hurricane Harvey. The program will allow for rehabilitation, reconstruction, and the
new construction of multi-family developments. The purpose of the rental program is to repair
restore and increase the affordable rental stock for LMI households.
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The GLO anticipates leveraging CDBG-DR funds with the work underway by GLO and FEMA
for the short-term housing recovery through the Direct Assistance for Limited Home Repair
program and PREPS program. The GLO and subrecipients also anticipate collaborating with local
governments, local long-term recovery groups, local non-profit organizations, and vulnerable
populations advocacy groups.
Although there are remaining unmet housing needs due to the limitation of funds available, the
GLO recognizes that as part of a comprehensive long-term recovery programInfrastructure
activities are vital not only for the long-term recovery and restoration of housing but for the long-
term recovery, protection, and viability of communities. Twenty-one (21) percent of the funds will
address unmet needs related to infrastructure and economic development.
The GLO has allocated five (5) percent for planning activities. Because of the vast nature of
Hurricane Harvey disaster and the recurring nature of disasters in the region, the GLO will
concentrate on regional approaches in addition to specific local solutions to promote sound,
sustainable long-term recovery planning informed by a post-disaster evaluation of hazard risk,
especially land-use decisions that reflect responsible flood plain management and take into account
future possible extreme weather events and other natural hazards and long-term risks.
The GLO has allocated five (5) percent for administrative costs, including contract administration,
compliance monitoring, and the provision of technical assistance to applicants and sub-recipients.
Based on experience, it is expected that some subrecipients will need direct support implementing
their programs; therefore, the GLO is allocating two percent for project delivery. The GLO
providing direct support to subrecipients will help ensure that the program is implemented as the
efficiently and expeditiously as possible.
At least 70 percent of all program funds will benefit LMI persons.
A summary of the State of Texas unmet need is identified in the table below. As required, a needs
communities and includes details for housing, infrastructure, and economic revitalization. The
needs assessment is expected to be amended as additional information is available or updated. The
summary of unmet needs has been updated to include Harris County and City of Houston based
on their needs assessments provided in sections 3.2. and 3.3.
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CDBG-DR Other Known Remaining
Category Losses/Gap Investments* Investments Unmet Need
Housing $29,379,225,450 ($4,377,797,312) ($13,323,038,264) $11,678,389,874
Owner-Occupied Housing** $6,958,668,050 $6,958,668,050
Residential Property Insurance $2,454,674,305 ($1,386,924,741) $1,067,749,564
Private Flood and Federal Flood -

Write Your Own $8,355,507,533 ($3,058,562,923) $5,296,944,610
National Flood Insurance Program $8,820,724,462 ($8,820,724,462) $0
State Housing Programs ($2,264,461,377) ($2,264,461,377)
Rental-occupied Housing** $2,713,882,916 $2,713,882,916
Public Housing Authority Housing $75,768,184 ($56,826,138) $18,942,046
Harris County Buyout Program
(Pub L. 115-31) ($43,465,600) ($43,465,600)
Other MI Counties (Pub L. 115-31) ($10,866,400) ($10,866,400)
Harris County Housing Programs ($921,941,704) ($837,097,816)
City of Houston Housing Programs ($1,191,394,231) ($1,041,754,416)
Infrastructure $68,958,741,056 ($658,124,755) ($7,162,866,950) $62,331,560,509
FEMA Public Assistance $7,958,741,056 ($7,162,866,950) $795,874,106
Infrastructure Resilience/Mitigation $1,193,811,158
Rebuild Texas Commission $61,000,000,000 $61,000,000,000
State Local Infrastructure Program ($435,605,083) ($435,605,083)
Harris County Infrastructure
Programs ($222,519,672) ($222,519,672)
City of Houston Infrastructure
Programs $0 $0
Economic $14,848,838,581 ($195,628,178) ($2,201,771,329) $12,451,439,074
SBA Business/EIDL Loans $5,910,381,954 ($1,384,938,700) $4,525,443,254
Agriculture Losses $200,000,000 $200,000,000
Gross State Product $3,800,000,000 $3,800,000,000
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CDBG-DR Other Known Remaining
Category Losses/Gap Investments* Investments Unmet Need
Disaster Unemployment Assistance ($11,201,909) ($11,201,909)
Commercial Property Insurance $4,938,456,627 ($805,630,720) $4,132,825,907
State Economic Revitalization
Program ($105,363,344) ($105,363,344)
Harris County Economic
Revitalization Programs $0 $0
City of Houston Economic
Revitalization Programs ($90,264,834) ($90,264,834)
Totals $113,186,805,087 ($5,230,347,712) ($22,687,676,54) $86,462,591,990
*CDBG-DR investments include project delivery costs.

**Does not exclude or discount the estimated loss for those identified as having homeowners and/or flood insurance in FEMA’s IA data.
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D. Regional MOD
The GLO understands that additional information and clarity will come with time and anticipates
that as additional funds are allocated, there may be a different methodology for the distribution of
those funds. The GLO partnered with the University of Texas at Austin to develop the regional
MOD for housing (HAP and Local Buyout/Acquisition Program) and infrastructure. The MOD
for these allocations used census data, FEMA IA data, FEMA PA data, SoVI, and other data
sources that demonstrate the impact of Hurricane Harvey, to distribute funds. In both housing and
infrastructure, the MOD establishes a balance between the total unmet need, the ability to recover,
and the relative population of impacted areas. As further data becomes available, adjustments may
be necessary in future allocation MODs to account for data that does not exist as of today’s Action
Plan. Each of these variables plays a factor in the recovery process and is reflected in the
distribution models. The methodology for the distribution and calculation is located in section
12.1, Appendix F. Updates to the regional MOD used to allocate the additional funds allocated to
the State HAP are described in the revised section 12.1, Appendix F. The regional MODs do not
include the city of Houston and Harris County.
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E. Program Budget
% of Total
HUD Most Impacted State Most Impacted % of Total
Programs LMI Amount Total Allocation by Total
Areas Areas Allocation
Program
Direct Allocation Programs
Direct Programs - Harris County
Residential Buyout Program $ 175,000,000 $ - $ 122,500,000 $ 175,000,000 3.08%
SF Affordable Housing Preservation Program $ 25,000,000 $ - $ 17,500,000 $ 25,000,000 0.44%
Harris County - Housing Reimbursement Program $ 15,000,000 $ - $ 10,500,000 $ 15,000,000 0.26% 16.24% $ 921,941,704
Affordable Rental Program $ 224,500,000 $ - $ 224,500,000 $ 224,500,000 3.95%
SF New Construction $ 119,888,035 $ - $ 119,888,035 $ 119,888,035 2.11%
Housing Project Delivery $ 92,194,170 $ - $ 64,535,919 $ 92,194,170 1.62%
Commercial Buyout Program $ 12,500,000 $ - $ 8,750,000 $ 12,500,000 0.22%
Harris County - Method of Distribution (Local) $ 120,000,000 $ - $ 84,000,000 $ 120,000,000 2.11%
3.92% $ 222,519,672
Infrastructure Competitive Application $ 76,668,492 $ - $ 53,667,944 $ 76,668,492 1.35%
Instructure Project Delivery $ 13,351,180 $ - $ 9,345,826 $ 13,351,180 0.24%
Harris County - Planning

1.59% $ 90,352,214
and Administration Harris County Planning $ 60,234,809 $ - N/A $ 60,234,809 1.06%
Harris County Admininstration $ 30,117,405 $ - N/A $ 30,117,405 0.53%
Harris County Subtotal $ 1,234,813,590 $ - $ 904,439,373 $ 1,234,813,590 21.75%

Direct Programs - City of Houston
Single Family Development Program $ 222,269,086 $ - $ 222,269,086 $ 222,269,086 3.92%
Multifamily Rental Program $ 350,050,472 $ - $ 350,050,472 $ 350,050,472 6.17%
City of Houston - Housing 19.93% $ 1,131,394,231
Small Rental Program $ 66,686,282 $ - $ 66,686,282 $ 66,686,282 1.17%
Homebuyer Assistance Program $ 23,688,328 $ - $ 7,264,351 $ 23,688,328 0.42%
Buyout Program $ 40,800,000 $ - $ 20,400,000 $ 40,800,000 0.72%
City of Houston -Public Public Services $ 60,000,000 $ - $ 60,000,000 $ 60,000,000 1.06%

Revitalization
Economic Revitalization Program $ 30,264,834 $ - $ 30,264,834 $ 30,264,834 0.53%
City of Houston - Planning

City of Houston Planning $ 23,100,000 $ - N/A $ 23,100,000 0.41% 0.96% $ 54,218,976
and Administration
City of Houston Admininstration $ 31,118,976 N/A $ 31,118,976 0.55%
City of Houston Subtotal $ 1,275,878,041 $ 1,003,745,316 $ 1,275,878,041 22.48%
Direct Allocation Subtotal $ 2,510,691,631 $ - $ 1,908,184,689 $ 2,510,691,631
GLO State Programs
Homeowner Assistance Program $ 1,198,024,378 $ 136,197,847 $ 948,955,558 $ 1,334,222,225 23.50%
AACOG $ - $ 6,000,000 $ 4,200,000 $ 6,000,000 0.450%
BVCOG $ - $ 11,091,055 $ 7,763,739 $ 11,091,055 0.831%
CAPCOG $ 33,032,736 $ 15,545,898 $ 34,005,044 $ 48,578,634 3.641%
CBCOG $ 138,996,767 $ 6,000,000 $ 101,497,737 $ 144,996,767 10.868%
CTCOG $ - $ 2,000,000 $ 1,400,000 $ 2,000,000 0.150%
DETCOG $ 132,280,713 $ 11,294,370 $ 100,502,558 $ 143,575,083 10.761%
GCRPC $ 37,424,878 $ 23,480,723 $ 42,633,921 $ 60,905,601 4.565%
H-GAC $ 550,915,781 $ 50,785,801 $ 421,191,107 $ 601,701,582 45.098%
SETRPC $ 265,373,503 $ - $ 185,761,452 $ 265,373,503 19.890%
HAP Public Service $ 40,000,000 $ 10,000,000 $ 50,000,000 $ 50,000,000 3.748%
Local Buyout/Acquisition Program $227,542,017.62 $48,078,874.38 $ 192,934,624 $ 275,620,892 4.86%
State Housing AACOG $ - $ 4,152,165 $ 2,906,515 $ 4,152,165 1.506% 39.89% $ 2,264,461,377
BVCOG $ - $ 5,840,778 $ 4,088,545 $ 5,840,778 2.119%
CAPCOG $ 8,913,617.62 $ 4,015,856.38 $ 9,050,632 $ 12,929,474 4.691%
CBCOG $ 30,011,342 $ 4,364,353 $ 24,062,987 $ 34,375,695 12.472%
CTCOG $ - $ 1,384,055 $ 968,838 $ 1,384,055 0.502%
DETCOG $ 27,633,673 $ 8,233,359 $ 25,106,922 $ 35,867,032 13.013%
GCRPC $ 8,606,577 $ 9,824,070 $ 12,901,453 $ 18,430,647 6.687%
H-GAC $ 100,689,194 $ 10,264,238 $ 77,667,402 $ 110,953,432 40.256%
SETRPC $ 51,687,614 $ - $ 36,181,330 $ 51,687,614 18.753%
Homeowner Reimbursement Program $ 80,000,000 $ 20,000,000 $ 5,000,000 $ 100,000,000 1.76%
Affordable Rental Program $ 390,140,000 $ 97,535,000 $ 487,675,000 $ 487,675,000 8.59%
PREPS Program $ 28,000,000 $ 7,000,000 $ - $ 35,000,000 0.62%
Local Infrastructure Program $353,618,787.13 $59,812,550.87 $ 289,401,937 $ 413,431,338 7.28%
AACOG $ - $ 1,530,000 $ 1,071,000 $ 1,530,000 0.370%
BVCOG $ - $ 3,007,825 $ 2,105,477 $ 3,007,825 0.728%
CAPCOG $ 929,021.13 $ 3,376,452.87 $ 3,013,832 $ 4,305,474 1.041%
CBCOG $ 125,703,593 $ 100,645 $ 88,062,967 $ 125,804,238 30.429%
State Infrastructure and CTCOG $ - $ 510,000 $ 357,000 $ 510,000 0.123%
9.53% $ 540,968,427
Economic Revitalization DETCOG $ 5,450,254 $ 2,013,970 $ 5,224,957 $ 7,464,224 1.805%
GCRPC $ 18,426,069 $ 17,618,520 $ 25,231,212 $ 36,044,589 8.718%
H-GAC $ 98,096,629 $ 31,655,138 $ 90,826,237 $ 129,751,767 31.384%
SETRPC $ 105,013,221 $ - $ 73,509,255 $ 105,013,221 25.400%
Economic Revitalization Program $ 80,000,000 $ 20,000,000 $ 100,000,000 $ 100,000,000 1.76%
State Planning $ 110,148,357 $ 27,537,089 N/A $ 137,685,446 2.43%
State Planning and 6.35% $ 360,268,565
Administration State Administration $ 178,066,495 $ 44,516,624 N/A $ 222,583,119 3.92%
State Allocation Subtotal $ 2,693,124,314 $ 472,574,055 $ 2,065,603,363 $ 3,165,698,369
Grand Total Allocation $ 5,203,815,945 $ 472,574,055 $ 3,973,788,052 $ 5,676,390,000 100% 100% $ 5,676,390,000
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Programs LMI Amount Total
Harris County $ 904,439,373 $ 1,144,461,376
Direct Programs
City of Houston $ 1,003,745,316 $ 1,221,659,065
Homeowner Assistance Program $ 948,955,558 $ 1,334,222,225
Local Buyout/Acquisition Program $ 192,934,624 $ 275,620,892
Homeowner Reimbursement Program $ 5,000,000 $ 100,000,000
State Housing Programs
Affordable Rental Program $ 487,675,000 $ 487,675,000
PREPS Program $ - $ 35,000,000
State Project Delivery $ 22,360,282 $ 31,943,260
Local Infrastructure Program $ 289,401,937 $ 413,431,338
State Infrastructure and
Economic Revitalization Program $ 100,000,000 $ 100,000,000
Economic Revitalization
State Project Delivery $ 19,275,962 $ 27,537,089
Program Subtotal $ 3,973,788,052 $ 5,171,550,245
State Planning N/A $ 137,685,446
State Administration N/A $ 222,583,119
Planning and Harris Planning N/A $ 60,234,809
Administration Harris Administration N/A $ 30,117,405
Houston Planning N/A $ 23,100,000
Houston Administration N/A $ 31,118,976
Grand Total: $ 5,676,390,000
*70% LMI Requirement = $3,620,085,172
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F. GLO Use of Funds
The GLO will implement several state-run programs. These programs include the homeowner
assistance program for rehabilitation and reconstruction of primary residences, the homeowner
reimbursement program for reimbursement to homeowners for repairs on their primary residences,
the affordable rental program to rehabilitate and reconstruct multifamily developments, and
economic revitalization that will fund businesses directly impacted by Hurricane Harvey.
The GLO will allocate funds to local governments for the local residential buyout/acquisition and
local infrastructure programs through MODs developed by the COGs.
The programs the GLO have selected to implement are intended to address the rehabilitation,
reconstruction, replacement, and new construction of housing and shelters needs in the areas
affected by Hurricane Harvey.
The city of Houston and Harris County will develop their own local programs, and will be
responsible for the implementation of their programs in their jurisdictions.
1. Homeowner Assistance Program
The HAP will rehabilitate and reconstruct owner-occupied single family homes damaged by
Hurricane Harvey.
As recommended by HUD, the GLO will utilize a state-run model for the HAP. The GLO will
regionalize the eligible areas for housing programs and stand up multiple programs within this
activity. Regions will be established based on proximity and damage type. Considerations for
construction costs and types, number of units, and total funds available may also be considered.
The GLO may directly administer the programs in these areas or use the support of outside
parties to serve the homeowner assistance needs. The only exception to this state-run model is
related to the city of Houston and Harris County. The city of Houston and Harris County will
develop their own local housing programs, and will be responsible for the implementation of
their programs in their jurisdictions. Homeowners located within the city of Houston and
Harris County will be ineligible for participation in the state-run HAP. Allocations by region
and to most impacted areas as outlined in Table 57 will be upheld.
The GLO will administer the state-run program in partnership with the impacted COG regions
as they have direct knowledge of the needs in their areas. COGs will be consulted on the
development of all the needs assessments and housing guidelines.
a. Allocation Amount: $1,334,222,225

i. At least eighty (80) percent of funds must address unmet need in the HUDMID
areas (counties and ZIP codes).
ii. Up to twenty (20) percent of funds may address unmet need in the State MID
counties minus their HUD MID ZIP codes.
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b. Reallocation:
i. After all eligible applicants have been served, any remaining funds within the State
MID impacted counties minus their HUD MID ZIP codes will be reallocated to the
HUDMID (counties and ZIP codes) for redistribution to the COG regions.
c. Maximum assistance:
i. Rehabilitation: Local composite builder bid amount and not greater than $65,000.
ii. Reconstruction: Local composite builder bid amount based on procured builders
and the builder’s house plans based on household size.
d. Eligible Activities: Housing activities allowed under CDBG-DR; HCDA Section

105(a)(1), 105(a)(3-4), 105(a)(8) 105(a)(11), 105(a)(18), and 105(a)(25), include but are
not limited to:
i. Single family owner-occupied rehabilitation and/or reconstruction;
ii. Repair and replacement of manufactured housing units;
iii. Hazard mitigation;
iv. Elevation;
v. Relocation Assistance;
vi. Demolition only;
vii. Public service within the 15 percent cap (e.g., housing counseling, legal
counseling, job training, mental health, and general health services); and
viii. Other activities associated with the recovery of single family housing stock
impacted.
e. Ineligible Activities:
i. Forced mortgage payoff;
ii. Incentive payments to households that move to disaster-impacted floodplains;
iii. Properties that served as second homes at the time of the disaster, or following the
disaster, are not eligible for rehabilitation assistance or housing incentives;
iv. Rehabilitation/reconstruction of homes located in the floodway;
v. Rehabilitation/reconstruction of a house in which:
1. The combined household income is greater than 120 percent AMI or the
national median;
2. The property was located in a floodplain at the time of the disaster; and
3. The property owner did not maintain flood insurance on the damaged
property, even when the property owner was not required to obtain and
maintain such insurance.
vi. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
U.S.C. 5154a) states that no Federal disaster relief assistance made available in a
flood disaster area may be used to make a payment (including any loan assistance
payment) to a person for ‘‘repair, replacement, or restoration’’ for damage to any
personal, residential, or commercial property if that person at any time has received
Federal flood disaster assistance that was conditional on the person first having
obtained flood insurance under applicable Federal law and the person has
subsequently failed to obtain and maintain flood insurance as required under
applicable Federal law on such property. The program may not provide disaster
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assistance for the repair, replacement, or restoration of a property to a person who
has failed to meet this requirement.
vii. Homeowners located within the city limits of Houston and/or within Harris County
are ineligible to participate in the State HAP. The City of Houston and Harris
County are developing and implementing their own programs
f. Eligibility Criteria for Assistance:

i. Home must have been owner-occupied at the time of the storm;
ii. Home must have served as primary residence;
iii. Home must be located in a CDBG-DR eligible county;
iv. Home must have sustained damage from Hurricane Harvey;
v. Duplication of benefits review;
vi. Costs for rehabilitation, reconstruction, and new construction are reasonable and
consistent with market costs at the time and place of construction;
vii. All applicants and co-applicants must be current on payments for child support;
viii. Applicant must furnish evidence that property taxes are current, have an approved
payment plan, or qualify for an exemption under current laws;
ix. Home must be environmentally-cleared;
x. Property owners receiving disaster assistance that triggers the flood insurance
purchase requirement have a statutory responsibility to notify any transferee of the
requirement to obtain and maintain flood insurance in writing and to maintain such
written notification in the documents evidencing the transfer of the property, and
the transferring owner may be liable if he or she fails to do so.
xi. Subrogation Agreement: Assisted homeowners must agree to a limited subrogation
of any future awards related to Hurricane Harvey to ensure duplication of benefits
compliance. This is an agreement to repay any duplicative assistance if other
disaster assistance for the same purpose later is received.
xii. Unsecured Forgivable Promissory Note:
1. Assisted homeowners are required to maintain principal residency in the
assisted property for three years. Cash-out refinancing, home equity loans or
any loans utilizing the assisted residence as collateral are not allowed for three
years. A violation of this policy will activate the repayment terms of the Note.
2. Taxes are to be paid and in good standing for the properties assisted.
Homeowners may be on a payment plan, but it needs to be submitted to the
subrecipient or State as applicable.
3. Insurance must be maintained at the assisted property. Hazard, flood (if
applicable), and windstorm (if applicable) will be monitored for the three-year
note period.
g. National Objectives: LMI and urgent need. At least 70 percent of these program funds by
region and Subrecipient must be spent on LMI eligible projects.
h. Housing Guidelines: The GLO and its subrecipients will develop minimum housing
guidelines that provide operational details on the eligibility requirements, housing
assistance caps, construction standards, accessibility requirements, visitability standards,
reporting requirements, and other program requirements. Subrecipients will produce their
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own guidelines. Housing guidelines will be posted for public comment before use. The
GLO must approve all guidelines.
i. Needs Assessment: The GLO and subrecipients administering the Program will conduct
needs assessment. The local needs assessment and analysis of HUD/FEMA demographic
IA data will recommend the proportions of funding that should be set aside to benefit each
LMI and non-LMI economic group. The GLO in partnership with the University of Texas
at Austin will conduct a housing needs survey over the entire disaster impacted counties.
The survey will assess remaining unmet housing needs resulting from Hurricane Harvey.
The needs assessment will determine the activities to be offered, the demographics to
receive concentrated attention, identify disabled, “special needs”, and vulnerable
populations, and target areas to be served. The needs assessment will also include an
assessment of the types of public services activities that may be needed to complement the
program, such as housing counseling, legal counseling, job training, mental health, and
general health services. The needs assessment should set goals within the income brackets
similar to the housing damage sustained within the impacted areas. Deviations from goals
must be approved by the GLO before the Program may move forward.
j. Affirmative Marketing Outreach Plan: The GLO and subrecipients administering the
Program are committed to AFFH through established affirmative marketing policies. The
GLO and subrecipients will coordinate with HUD-certified housing counseling
organizations in this effort. Affirmative marketing efforts will include an affirmative
marketing plan, based on HUD regulations. The goal is to ensure that outreach and
communication efforts reach eligible homeowners from all racial, ethnic, national origin,
religious, familial status, the disabled, "special needs", gender groups, and vulnerable
populations.
k. HAP Public Services: The GLO and other State Agencies or nonprofits having experience
with homelessness prevention will administer the HAP public services activities. The
public service will consist of three primary activities with the sole purpose of preventing
homelessness in the region following Hurricane Harvey. This public service will be limited
only to LMI households.
i. Allocation for public service activities: $50,000,000
1. At least eighty (80) percent of funds must address unmet need in the HUD-MID
areas (counties and ZIP codes);
2. Up to twenty (20) percent of funds may address unmet need in the State MID
counties and counties minus their HUD MIDZIP codes.
ii. Eligible Activities HCDA Section 105(a)(8) and 105(a)(20):

1. Short-term Mortgage Assistance – The Short-Term Mortgage Assistance may
deliver up to $10,000 to assist LMI households with mortgage payments on
their primary residence. Mortgage assistance may not exceed 20 months. This
program is intended to prevent foreclosure or predatory, low value buyouts of
homes in the impacted areas and ensure that households can continue down the
road to recovery without the imminent threat of homelessness.
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2. Utility Assistance – Utility Assistance Program will provide assistance up to
$1,000 to LMI households to meet immediate utility needs. Utility assistance
may include electricity, gas, wastewater, water and other utility bills and
deposits.
3. Tenant-Based Rental Assistance – Tenant-Based Rental Assistance will deliver
rental assistance to LMI households in need of housing. This program may
include up to 3 months of rental assistance, including security deposit and utility
deposit. This program will be administered using HUD-published Fair Market
Rent (FMR), and the maximum award amount per household will be tied to
FMR.
iii. Eligibility Criteria: Further guidance will be available in the guidelines.
iv. Ineligible: Activities located within the city limits of Houston and/or within Harris
County are ineligible. The City of Houston and Harris County are developing and
implementing their own programs.
v. National Objective: LMI
l. The program will undergo AFFH review. Such review will include assessments of (1) a
proposed project’s area demography, (2) socioeconomic characteristics, (3) housing
configuration and needs, (4) educational, transportation, and health care opportunities, (5)
environmental hazards or concerns, and (6) all other factors material to the AFFH
determination. Applications should show that projects are likely to lessen area racial,
ethnic, and low-income concentrations, and/or promote affordable housing in low-poverty,
nonminority areas in response to natural hazard-related impacts.
m. Timeline: The proposed program start date is immediately after HUD’s approval of this
Action Plan. The proposed end date is three years from the start date of the program.
2. Local Buyout and Acquisition Program
The Local Buyout and Acquisition Program will remove homes from harm’s way. Due to the
nature of this activity, this program will be administered by subrecipients (local units of
government and entities with the power of eminent domain authority). Subrecipients are
encouraged to use buyouts and acquisition strategically as a means of acquiring contiguous
parcels of land for uses compatible with open space, recreational, natural floodplain functions,
wetlands management practices, or other ecosystem restoration..
The term ‘‘buyouts’’ as referenced in the Federal Register notice refers to the acquisition of
properties with the intent to reduce risk from future flooding, or the acquisition of properties
in Disaster Risk Reduction Areas as designated by the subrecipient.
Subrecipients that undertake a buyout program have the discretion to determine the appropriate
valuation method, including paying either predisaster or post-disaster FMV. In most cases, a
program that provides pre-disaster FMV to buyout applicants provides compensation at an
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amount greater than the post-disaster FMV. Any CDBG–DR funds in excess of the FMV are
considered assistance to the seller, thus making the seller a beneficiary of CDBG–DR
assistance. If the seller receives assistance as part of the purchase price, this may have
implications for duplication of benefits calculations or for demonstrating national objective
criteria, as discussed below. However, a program that provides post-disaster FMV to buyout
applicants merely provides the actual value of the property; thus, the seller is not considered a
beneficiary of CDBG– DR assistance.
Regardless of purchase price, all buyout activities are a type of acquisition of real property (as
permitted by 42 U.S.C. 5305(a)(1)). However, only acquisitions that meet the definition of a
‘‘buyout’’ are subject to the post-acquisition land use restrictions imposed by this notice
(subparagraph b. below). The key factor in determining whether the acquisition is a buyout is
whether the intent of the purchase is to reduce risk of property damage in a floodplain or a
Disaster Risk Reduction Area. When acquisitions are not acquired through a buyout program,
the purchase price must be consistent with applicable uniform cost principles (and the
predisaster FMV may not be used).
Subrecipients may redevelop an acquired property if the property is not acquired through a
buyout program and the purchase price is based on the property’s post-disaster value,
consistent with applicable cost principles (the pre-disaster value may not be used). In addition
to the purchase price, subrecipients may opt to provide relocation assistance or housing
incentives to the owner of a property that will be redeveloped if the property is purchased by
the subrecipient through voluntary acquisition, and the owner’s need for additional assistance
is documented. If the property is purchased through the use of eminent domain, the ultimate
use of that property may not benefit a particular private party and must be for a public use. In
addition, acquisition of real property through eminent domain is subject to the requirement of
the Uniform Relocation Assistance (URA) Act incuding the requirements found in 49 CFR 24,
subpart B. In carrying out acquisition activities, subrecipients must ensure they are in
compliance with their long-term redevelopment plans.
Under the Local Buyout and Acquisition Program, each impacted COG has been allocated
funds through the housing MOD. Each COG will develop a local MOD to allocate these funds
to local units of government. The city of Houston, Harris County, local governments located
within Harris County and entities located within Harris County are ineligible to receive an
allocation through the MOD.
The MOD developed through the COGs allows for local control of the distribution of funds.
Given the size of the impacted area and how Hurricane Harvey impacted each region
differently, local control through a regional approach is vital to long-term recovery.
The GLO will provide training, written guidance, and forms to the impacted COGs for the
development of the local MODs. Each COG will be provided data sets produced by the GLO
in partnership with the University of Texas at Austin to inform MOD. Variances from these
data sets will be allowable. Data sets provided by the GLO may contain information at the
county, city, and/or ZIP code level. Applicant-specific data will not be available.
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Local MOD guidelines will require that each COG follow a citizen participation process. Each
COG is required to publish notice of any public hearings prior to holding the hearings. Notices
shall be published in all newspapers of record for all eligible counties in the region, posted on
the COG website and provided to all eligible cities and counties in the region. Hearings must
fully comply with Texas Open Meetings Act.
The final MOD shall be posted on the COG’s website for public comment prior to submission
to the GLO. The public comment period shall be no less than 14 days. Each comment shall be
responded to, and any changes made to the final MOD shall be noted in the response section
for GLO review. The MODs must be completed 60 days from the GLO submission of the
Action Plan to HUD or by a GLO-approved date.
Upon completion, the GLO will review and approve MOD submissions by each COG. All
MODs will be wholly reviewed to ensure that each COG provides a detailed description of the
methodology used to allocate and prioritize funds within their regions. If the MOD is not
approved, the GLO will provide feedback including any specific issues to the COG.
a. Local MOD Requirements:

i. Each COG will facilitate a MOD process with support of the GLO;
ii. Establish objective criteria for allocation of funds to eligible entities or activities
(distribution based on, but not limited to, unmet need);
iii. Citizen participation process:
1. Develop a citizen participation plan;
2. Conduct a minimum of two (2) public hearings prior to finalizing the MOD;
3. One (1) public hearing shall be a “Public Planning Meeting;”
4. Ensure a public comment period of at least 14 days.
iv. Implement a minimum of $1,000,000 in CDGB-DR funds to any local entity
receiving funding through the MOD;
v. Ensure a minimum percentage of funds are allocated to HUD MID Counties and
ZIP Codes;
vi. Facilitate local prioritization through the MOD;
vii. A plan to meet the 70 percent LMI benefit requirement;
viii. Establish any additional parameters for eligibility beyond what is required by
HUD or the GLO.
b. Allocation Amount: $275,620,892

i. At least eighty (80) percent of funds must address unmet need in the HUD-MID
counties and counties minus its HUD MID ZIP codes.
c. Reallocation: Declined local MOD allocations and deobligated funds will be reallocated
to the Affordable Rental Program.
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d. Eligible Entities: Units of local government and entities with the power of eminent
domain authority.
e. Eligible Activities, HCDA Section 105(a)(1), 105(a)(7-8), 105(a)(24-25)

i. Buyouts;
ii. Acquisition;
iii. Relocation Assistance with buyout or acquisition activities;
iv. Down-payment Assistance with buyout or acquisition activities;
v. Demolition with buyout or acquisition activities;
vi. Housing incentives
vii. Activities designed to relocate families outside of floodplains;
viii. Public service within the 15 percent cap (e.g., housing counseling, legal
counseling, job training, mental health, and general health services);
ix. FEMA Hazard Mitigation Grant Program (HMGP) cost share;
x. Planning (up to 20% of local MOD allocation with GLO approval).
f. Ineligible Activities:
i. Incentive payments to households that move to disaster-impacted floodplains.
ii. Activities located within the city limits of Houston and/or within Harris County are
ineligible to participate in the program. The City of Houston and Harris County are
developing and implementing their own programs.
g. Program Guidelines: Each subrecipient will develop guidelines in accordance with

CDBG-DR requirements and regulations to set maximum assistance amounts, target area
locations, Disaster Risk Reduction Area, and additional eligibility requirements.
Guidelines must be posted for public comment before use. The GLO must approve all
guidelines. Subrecipients are required to develop and follow a RARAP.
To conduct a buyout in a Disaster Risk Reduction Area, the subrecipient must establish
criteria in its policies and procedures to designate the area subject to the buyout, pursuant
to the following requirements:
i. The hazard must have been caused or exacerbated by the Presidentially declared
disaster for which the grantee received its CDBG–DR allocation;
ii. The hazard must be a predictable environmental threat to the safety and well-being
of program beneficiaries, as evidenced by the best available data (e.g. FEMA RL
Data) and science; and
iii. The Disaster Risk Reduction Area must be clearly delineated so that HUD and the
public may easily determine which properties are located within the designated
area. The distinction between buyouts and other types of acquisitions is important,
because subrecipient may only redevelop an acquired property if the property is not
acquired through a buyout program (i.e., the purpose of acquisition was something
other than risk reduction).
iv. In carrying out acquisition activities, subrecipient must ensure they are in
compliance with their long-term redevelopment plans.
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h. National Objectives: LMI, elimination of slum/blight, urgent need, low/mod buyout
(LMB), and low/mod incentive.
i. All proposed buyout or acquisition programs will undergo AFFH review by the GLO
before approval. Such review will include assessments of (1) a proposed project’s area
demography, (2) socioeconomic characteristics, (3) housing configuration and needs, (4)
educational, transportation, and health care opportunities, (5) environmental hazards or
concerns, and (6) all other factors material to the AFFH determination.
j. Timeline: The proposed program start date is 30 days after HUD’s approval of this Action
Plan. The proposed end date is three years from the start date of the program.
3. Homeowner Reimbursement Program
The GLO will administer the Homeowner Reimbursement Program for eligible expenses
incurred by homeowners for repairs to a primary residence prior to application for these funds.
Up to $50,000 per household may be reimbursed.
a. Allocation Amount: $100,000,000

i. At least eighty (80) percent of funds must address unmet need in the HUDMID areas
(counties and ZIP codes);
ii. Up to twenty (20) percent of funds must may address unmet need in the State MID
counties and counties minus its HUD MID ZIP codes;
iii. The program will first be available to LMI households before being made available to
non-LMI households.
b. Reallocation:
i. Any remaining funds within the State MID counties and counties minus its HUD MID
ZIP codes funds will be reallocated to the HUD MID areas (counties and ZIP codes)
for the applicable region;
ii. Any remaining funds will be reallocated to the HAP to the HUD MID areas (counties
and ZIP codes) for redistribution to the COG regions.
c. Maximum Award: $50,000
d. Eligible Activities, HCDA Section 105(a)(4):

i. Expenses incurred by homeowners for repairs to a primary residence prior to
application for these funds.
iv. Rehabilitation/reconstruction of a homes located in the floodway;
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national median;
3. The property owner did not maintain flood insurance on the damaged property,
even when the property owner was not required to obtain and maintain such
insurance.
i. Section 582 of the National Flood Insurance Reform Act of 1994, as
amended, (42 U.S.C. 5154a) states that no Federal disaster relief
assistance made available in a flood disaster area may be used to make
a payment (including any loan assistance payment) to a person for
‘‘repair, replacement, or restoration’’ for damage to any personal,
residential, or commercial property if that person at any time has
received Federal flood disaster assistance that was conditional on the
person first having obtained flood insurance under applicable Federal
law and the person has subsequently failed to obtain and maintain flood
insurance as required under applicable Federal law on such property.
The program may not provide disaster assistance for the repair,
replacement, or restoration of a property to a person who has failed to
meet this requirement.
vi. Homeowners located within the city limits of Houston and/or within Harris County
are ineligible to participate in the program. The City of Houston and Harris County
are developing and implementing their own programs.
f. Eligibility Criteria for Assistance:

iii. Home must be located in a CDBG-DR eligible county, with the exception of
homes located within the city limits of Houston and/or within Harris County;
vi. All applicants and co-applicants must be current on payments for child support;
vii. Applicant must furnish evidence that property taxes are current, have an approved
viii. Home must be environmentally-cleared;
ix. Property owners receiving disaster assistance that triggers the flood insurance
x. Subrogation Agreement: Assisted homeowners must agree to a limited subrogation
compliance. Assisted homeowners must agree to repay any duplicative assistance
if they later receive other disaster assistance for the same purpose.
xi. Unsecured Forgivable Promissory Note:
assisted property for one year. Cash-out refinancing, home equity loans
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or any loans utilizing the assisted residence as collateral are not allowed
for one year. A violation of this policy will activate the repayment terms
of the Note.
Homeowners may be on a payment plan, but it needs to be submitted to
the Subrecipient.
applicable), and windstorm (if applicable) will be monitored for the one-
year period.
g. National Objective: LMI and urgent need.
h. The program will undergo AFFH review. Such review will include assessments of (1) a
proposed project’s area demography, (2) socioeconomic characteristics, (3) housing
configuration and needs, (4) educational, transportation, and health care opportunities, (5)
environmental hazards or concerns, and (6) all other factors material to the AFFH
determination.
i. Timeline: The proposed program start date is immediately after HUD’s approval of this
4. Affordable Rental Program
The GLO will administer the Affordable Rental Housing Program. The program has been
designed to provide funds for rehabilitation, reconstruction, and new construction of public
housing and affordable multi-family housing projects in areas impacted by Hurricane Harvey.
The GLO’s Notice of Funding Availability (NOFA)/Request for Proposals (RFP) will establish
the application process and acceptance period, threshold criteria (including applicable building
codes), selection criteria, and the award process. Developments located within the city limits
of Houston and/or within Harris County are ineligible for Affordable Rental Program. The City
of Houston and Harris County are developing and implementing their own affordable rental
programs.
a. Allocation for Activity: $487,675,000

areas (counties and ZIP codes).
counties and counties minus their HUD MID ZIP codes.
b. Maximum Award: $25 million per development
c. Eligible Applicants: Acting individually or as participants in a limited partnership (LP) or

limited liability corporation (LLC):
i. For-profit Developers/ Borrowers;
ii. Public housing authorities;
iii. Units of local governments;
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iv. Not-for-profit Developers/ Borrowers.
d. Eligible Activity, HCDA Section 105(a)(1), 105(a)(4), 105(a)(9), 105(a)(11), and

105(a)(14-15):
i. Rehabilitation, reconstruction, and new construction of affordable multi-family
housing projects.
e. Eligibility Criteria:
i. Development must meet CDBG-DR eligibility requirements;
ii. Development must be located in a CDBG-DR eligible county, with the exception
of developments located within the city limits of Houston and/or within Harris
County;
iii. A minimum of 51 percent of the units must be restricted for a minimum
affordability period of fifteen (15) years for the rehabilitation or reconstruction of
multifamily rental projects with eight or more units, and a minimum affordability
period of twenty (20) years for the new construction of multifamily rental units with
five or more units for LMI individuals earning 80 percent or less of the AMFI at
affordable rents. If a rental project that requires rehabilitation or reconstruction is
subject to existing affordability requirements associated with other funding sources,
the 15-year affordability period may run concurrently (or overlap) with the
affordability requirements associated with such other funding;
iv. Projects with eight (8) or more units must ensure construction costs are reasonable
and consistent with market costs at the time and place of construction;
v. The affordable rents must comply with High HOME Rents and other existing Land
Use Restriction Agreement (LURA) restrictions, if applicable;
vi. Property Types: Multifamily rental development is eight or more rental units under
common ownership;
vii. The Affordable Rental Program NOFA/RFP will clearly establish the application
process and acceptance period, threshold criteria (including applicable building
codes), selection criteria and the award process;
viii. Property owners receiving disaster assistance that triggers the flood insurance
the transferring owner may be liable if he or she fails to do so;
ix. Project construction must be completed within 18 months of the effective date of
the contract, unless otherwise extended.
f. Ineligible:
i. Developments located within the city limits of Houston and/or within Harris
County are ineligible. The City of Houston and Harris County are developing and
implementing their own programs;
ii. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
U.S.C. 5154a) prohibits flood disaster assistance in certain circumstances. In
general, it provides that no Federal disaster relief assistance made available in a
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Federal flood disaster assistance that was conditioned on the person first having
applicable Federal law on such property. No disaster assistance may be provided
for the repair, replacement, or restoration of a property to a person who has failed
to meet this requirement.
g. Selection Criteria:
i. Located in High Opportunity Zones;
ii. Targets extremely low-income (30 percent AMFI);
iii. Exceeds the number of LMI units eligibility requirement;
iv. Serves persons with disabilities beyond minimum requirements;
v. Leverages public and private financing;
vi. Activity type; and
vii. Cost-effectiveness.
h. National Objective: Low- and moderate-income
i. All proposed developments will undergo AFFH review by the GLO before approval. Such
review will include assessments of (1) a proposed project’s area demography, (2)
socioeconomic characteristics, (3) housing configuration and needs, (4) educational,
transportation, and health care opportunities, (5) environmental hazards or concerns, and
(6) all other factors material to the AFFH determination. Applications should show that
projects are likely to lessen area racial, ethnic, and low-income concentrations, and/or
promote affordable housing in low-poverty, nonminority areas in response to natural
hazard-related impacts.
j. Timeframe: The proposed program start date is immediately after HUD’s approval of this
5. Partial Repair and Essential Power for Sheltering Program
The PREPS Program is currently administered by the GLO under FEMA PA. The program
provides immediate, temporary repairs to homes that sustained less than $17,000 in FEMA-
Verified Loss. FEMA determines applicants eligible for the PREPS program. FEMA closed
the application period for FEMA IA assistance at the end of November 2017. As a PA program,
FEMA will cover 90 percent of the expenses, and the GLO will use up to $35,000,000 of this
allocation to cover repairs conducted on homes.

counties and counties minus their HUD “MID ZIP codes.
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b. Reallocation:
i. Any remaining funds within the State MID counties and counties minus its HUD
MID ZIP codes funds will be reallocated to the HUD MID (counties and ZIP
codes);
ii. Any remaining funds will be reallocated to the Affordable Rental Program.
c. Eligible Applicants: Approved FEMA Project Worksheet.
d. Eligible Activity: Payment of non-Federal share required in connection with a Federal

grant-in-aid program; HCDA Section 105(a)(9)
e. National Objective: Urgent Need.
f. Timeframe: The program ended at the end of June 2018.
6. Local Infrastructure Program
The GLO recognizes that as part of a comprehensive long-term recovery program, the repair
and enhancements of local infrastructure and mitigation efforts are crucial components.
Infrastructure activities are vital not only for the long-term recovery and restoration of housing
but for the long-term recovery and viability of communities. The local infrastructure program
will provide disaster relief, long-term recovery, and restoration of infrastructure for local
communities impacted by Hurricane Harvey. Each infrastructure activity must demonstrate
how it will contribute to the long-term recovery and restoration of housing.
Due to the nature of this activity, this program will be administered by the GLO, with local
units of governments (cities and counties) as subrecipients.
Under the local infrastructure program, each impacted COG region has been allocated funds
through the infrastructure MOD. Each COG will develop a local MOD for allocation of funds
to local units of government. The GLO encourages the prioritization of infrastructure for direct
repair of damaged facilities, FEMA cost share and mitigation, and water and flood control
facilities due to the limitations of funds available in this allocation. The city of Houston, Harris
County and local governments wholly located within the Harris County are ineligible to receive
an allocation through the MOD.
The MOD developed through the COGs allows for the opportunity for local control for the
distribution of funds. Given the size of the impacted area and how Hurricane Harvey impacted
each region differently, local control through a regionally approach is vital to long-term
recovery.
The GLO will provide training, written guidance, and forms to the impacted COGs for the
development of the local MODs. Each COG will be provided data sets produced by the GLO
in partnership with the University of Texas at Austin to inform MOD. Variances from these
data sets will be allowable. Data sets provided by the GLO may contain information at the
county, city, and/or ZIP code level.
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Local MOD guidelines will require that each COG follow a citizen participation process. Each
COG is required to publish notice of any public hearings prior to holding the hearings. Notices
shall be published in all newspapers of record for all eligible counties in the region, posted on
the COG website, and provided to all eligible cities and counties in the region. Hearings must
fully comply with Texas Open Meetings Act.
The final MOD shall be posted on the COG’s website for public comment prior to submission
to the GLO. The public comment period shall be no less than 14 days. Each comment shall be
responded to and any changes made to the final MOD shall be noted in the response section
for GLO review. The MODs must be completed 60 days from the GLO submission of the
Action Plan to HUD or a GLO-approved date.
Upon completion, the GLO will review and approve MOD submissions by each COG. All
MODs will be wholly reviewed to ensure that each COG provides a detailed description of the
methodology used to allocate and prioritize funds within their regions. If the MOD is not
approved, the GLO will provide feedback to the COG, including specific issues.
a. Local MOD Requirements:

i. Each COG will facilitate the MOD process with GLO support;
2. Conduct a minimum of two (2) public hearings prior to finalizing the MOD;
3. One (1) public hearing shall be a “Public Planning Meeting;”
iv. Implement a minimum of $100,000 in CDGB-DR funds to any local entity
receiving funding through the MOD;
v. Ensure a minimum percentage of funds are allocated to HUD MID Counties and
ZIP codes;
vi. Facilitate local prioritization through the MOD;
vii. A plan to meet the 70 percent LMI benefit requirement;
viii. Establish any additional parameters for eligibility beyond what is required by HUD
or the GLO.

i. At least eighty (80) percent of funds must address unmet need in the HUD MID
areas (counties only) for applicable region;
ii. Up to twenty (20) percent of funds may address unmet need in the remaining State
MID counties.
c. Reallocation:
i. Local MOD Amendment: Declined intial local MOD allocations will be reallocated
through a MOD amendment developed by the COGs. The GLO will provide
training, written guidance, and forms to the impacted COGs for the development of
the local MOD amendment, including the following requirements:
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a. Citizen participation process:
i. Conduct a minimum of two (2) public hearings prior to finalizing
the MOD.
ii. One (1) public hearing shall be a “Public Planning Meeting”.
iii. Ensure a public comment period of at least 30 days.
b. Establish objective criteria for allocation of funds to eligible entities or
activities (distribution based on, but not limited to, unmet need).
c. Cities or counties that have declined their initial allocation are ineligibile to
receive an allocation through the MOD amendment.
ii. Reallocation to Affordable Rental Program:
a. If the COG is unable to reallocate all or a portion of the decline funds
through the MOD amendment because of lack of interest or demand from
units of local government, the remaining declined funds will be allocated to
the Affordable Rental Program;
b. Declined local MOD amendment allocations and deobligated funds will be
reallocated to the Affordable Rental Program.
d. Eligible Entities: Units of local government (cities and counties)
e. Eligible Activities: Economic revitalization or infrastructure activities must contribute to

the long-term recovery and restoration of housing. All activities allowed under CDBG-DR;
HCDA Section 105(a)(1-5), 105(a)(7-9), and 105(a)(11), including but not limited to:
i. Flood control and drainage repair and improvements, including the construction or
rehabilitation of storm water management system;
ii. Restoration of infrastructure (such as water and sewer facilities, streets, provision
of generators, removal of debris, bridges, etc.);
iii. Demolition, rehabilitation of publicly or privately-owned commercial or industrial
buildings, and code enforcement;
iv. Economic development (such as microenterprise and small business assistance,
commercial rehabilitation, and special economic development activities, including
prioritizing assistance to businesses that meet the definition of a small business).
Any projects funding for-profit entities must be evaluated and selected in
accordance with guidelines (established in Appendix A to 24 CFR part 570)
developed by HUD and comply with HUD underwriting guidance;
v. Public service (such as job training and employment services, healthcare, child
care, and crime prevention within the 15 percent cap).
vi. Planning (up to 20% of local MOD allocation with GLO approval).
vii. Nonresidential structures must be elevated to the standards described in this
paragraph or floodproofed, in accordance with FEMA floodproofing standards at
44 CFR 60.3(c)(3)(ii) or successor standard, up to at least two feet above the 100-
year (or 1 percent annual chance) floodplain. All Critical Actions, as defined at 24
CFR 55.2(b)(3), within the 500-year (or 0.2 percent annual chance) floodplain must
be elevated or floodproofed (in accordance with the FEMA standards) to the higher
of the 500-year floodplain elevation or three feet above the 100- year floodplain
elevation. If the 500-year floodplain or elevation is unavailable, and the Critical
Action is in the 100- year floodplain, then the structure must be elevated or
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floodproofed at least three feet above the 100-year floodplain elevation. Critical
Actions are defined as an ‘‘activity for which even a slight chance of flooding
would be too great, because such flooding might result in loss of life, injury to
persons or damage to property.’’ For example, Critical Actions include hospitals,
viii. Cost Verification Controls must be in place to assure that construction costs are
reasonable and consistent with market costs at the time and place of construction.
f. Ineligible Activities:
i. CDBG–DR funds may not be used to enlarge a dam or levee beyond the original
footprint of the structure that existed prior to the disaster event. CDBG–DR funds
for levees and dams are required to:
1. Register and maintain entries regarding such structures with the USACE
National Levee Database or National Inventory of Dams;
2. Ensure that the structure is admitted in the USACE PL 84–99 Rehabilitation
Program (Rehabilitation Assistance for Non-Federal Flood Control Projects);
3. Ensure the structure is accredited under the FEMA NFIP;
4. Maintain file documentation demonstrating a risk assessment prior to funding
the flood control structure and documentation that the investment includes risk
reduction measures.
ii. Funds may not be used to assist a privately-owned utility for any purpose. A private
utility, also referred to as an investor-owned utility, is owned by private investors
and is for-profit as opposed to being owned by a public trust or agency (e.g., a co-
op or municipally-owned utility);
iii. Funds may not be provided to a for-profit entity for an economic development
project under section 105(a)(17) of the HCDA unless such project has been
evaluated and selected in accordance with guidelines developed by HUD pursuant
to section 105(e)(2) of the HCDA for evaluating and selecting economic
development projects;
iv. Buildings and facilities used for the general conduct of government (e.g., city halls,
courthouses, and emergency operation centers);
v. No disaster recovery assistance will be considered with respect to any part of a
disaster loss that is reimbursable by FEMA, the USACE, insurance, or another
source due in part to the restrictions against duplication of benefits outlined in this
Action Plan. An activity underway prior to the Presidential Disaster Declaration
will not qualify unless the disaster directly impacted said project;
vi. By law, (codified in the HCD Act as a note to 105(a)), the amount of CDBG–DR
funds that may be contributed to a USACE project is $250,000 or less;
vii. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
Page 167 of 420
to meet this requirement;
viii. If the property is purchased through the use of eminent domain, the ultimate use of
that property may not benefit a particular private party and must be for a public use;
ix. Activities located within the city of Houston and Harris County and local
governments located wholly within the Harris County are ineligible. The City of
Houston and Harris County are developing and implementing their own programs.
g. National Objectives: LMI, elimination of slum/blight and urgent need.
h. All proposed projects must:

i. Promote sound, sustainable longterm recovery planning informed by a post-disaster
evaluation of hazard risk, especially land-use decisions that reflect responsible
flood plain management and take into account future possible extreme weather
events and other natural hazards and long-term risks;
ii. Coordinate with local and regional planning efforts to ensure consistency, and
promote community-level and/or regional (e.g., multiple local jurisdictions)
postdisaster recovery and mitigation planning;
iii. Integrate mitigation measures into rebuilding activities and achieve objectives
outlined in regionally or locally established plans and policies that are designed to
reduce future risk to the jurisdiction;
iv. Consider the costs and benefits of the project;
v. Ensure that activities will avoid disproportionate impact on vulnerable populations
such as, but not limited to, families and individuals that are homeless or at risk of
homelessness, the elderly, persons with disabilities, persons with alcohol or other
drug addiction, persons with HIV/AIDS and their families, and public housing
residents.
vi. Ensure that activities create opportunities to address economic inequities facing
local communities;
vii. Align investments with other planned state or local capital improvements and
infrastructure development efforts, and work to foster the potential for additional
infrastructure funding from multiple sources, including existing state and local
capital improvement projects in planning, and potential private investment;
viii. Employ adaptable and reliable technologies to guard against premature
obsolescence of infrastructure.
i. All proposed projects will undergo AFFH review by the GLO before approval. Such review
will include assessments of (1) a proposed project’s area demography, (2) socioeconomic
characteristics, (3) housing configuration and needs, (4) educational, transportation, and
health care opportunities, (5) environmental hazards or concerns, and (6) all other factors
material to the AFFH determination. Applications should show that projects are likely to
lessen area racial, ethnic, and low-income concentrations, and/or promote affordable
housing in low-poverty, nonminority areas in response to natural hazard-related impacts.
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j. Timeline: The proposed program start date is 30 days after HUD’s approval of this Action
Plan. The proposed end date is four years from the start date of the program.
7. Economic Revitalization Program
The major flood and wind damage caused by Hurricane Harvey continues to significantly
impact millions of Texans, particularly thousands of small businesses, many of which are still
struggling to maintain the capital necessary to remain open for business, the long-term effects
of this storm have yet to be seen. Businesses who were not located in flood plains, like homes,
were flooded. Areas were without access, power, and necessary utilities which prevented
businesses not directly flooded from opening their doors for weeks in some cases. Whole
communities were impacted thus changing the client base for many small neighborhood
businesses.
For the first time, the GLO will directly implement an economic revitalization program that
will provide interim assistance to businesses impacted by Hurricane Harvey through deferred
forgivable loans and loans in exchange for job creation or retention for LMI employees. The
GLO will initiate a notice of funds availability and select a provider(s) with the appropriate
background to serve businesses impacted by Hurricane Harvey.
The GLO recognizes that as part of a comprehensive long-term recovery program, economic
revitalization is a crucial component. Economic revitalization activities are vital not only for
the long-term recovery and restoration of housing through job creation and retention but for
the long-term recovery and viability of communities and households. Each economic
revitalization activity must demonstrate how it will contribute to the long-term recovery and
restoration of housing.

i. At least eighty (80) percent of funds must address unmet need in the HUD MID
impacted counties and counties minus its HUD MID ZIP codes.
b. Reallocation:
i. Any remaining funds within the twenty (20) percent State MID counties and
counties minus its HUD ZIP codes funds will be reallocated to the eighty (80)
percent HUD MID areas (counties and ZIP codes);
ii. Any remaining funds will be reallocated to the Local Infrastructure Program to the
HUD MID areas (counties only) for redistribution to the COG regions.
c. Maximum assistance: No business may receive more than $250,000
d. Eligible Activities:
i. Economic Revitalization activities allowed under CDBG-DR include, HCDA
Section 105(a)(14-15), 105(a)(17), 105(a)(19), and 105(a)(22) but are not limited
to deferred forgivable loans or loans to small businesses as defined the SBA at 13
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CFR part 121 or businesses engaged in “farming operations” that meet the U.S
Department of Agriculture Farm Service Agency criteria described at 7 CFR
1400.500. Economic revitalization activities must contribute to the long-term
recovery and restoration of housing.
ii. Nonresidential structures must be elevated to the standards described in this
paragraph or floodproofed, in accordance with FEMA floodproofing standards at
44 CFR 60.3(c)(3)(ii) or successor standard, up to at least two feet above the 100-
year (or 1 percent annual chance) floodplain. All Critical Actions, as defined at 24
CFR 55.2(b)(3), within the 500-year (or 0.2 percent annual chance) floodplain must
be elevated or floodproofed (in accordance with the FEMA standards) to the higher
of the 500-year floodplain elevation or three feet above the 100- year floodplain
elevation. If the 500-year floodplain or elevation is unavailable, and the Critical
Action is in the 100- year floodplain, then the structure must be elevated or
floodproofed at least three feet above the 100-year floodplain elevation. Critical
Actions are defined as an ‘‘activity for which even a slight chance of flooding
would be too great, because such flooding might result in loss of life, injury to
persons or damage to property.’’ For example, Critical Actions include hospitals,
iii. Cost Verification Controls must be in place to assure that construction costs are
reasonable and consistent with market costs at the time and place of construction.
i. Assistance to businesses not defined as small businesses;
ii. Assistance to any privately-owned utility;
iii. Funds may not be provided to a for-profit entity for an economic development
project under section 105(a)(17) of the HCDA unless such project has been
evaluated and selected in accordance with guidelines developed by HUD pursuant
to section 105(e)(2) of the HCDA for evaluating and selecting economic
development projects;
iv. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
f. Eligible Applicants:
i. Small business located in CDBG-DR eligible county;
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ii. Small businesses as defined the SBA at 13 CFR part 121 or businesses engaged in
“farming operations” that meet the U.S Department of Agriculture Farm Service
Agency criteria described at 7 CFR 1400.500;
iii. Property owners receiving disaster assistance that triggers the flood insurance
g. National Objectives: LMI
h. All proposed projects will undergo AFFH review by the GLO before approval. Such
review will include assessments of (1) a proposed project’s area demography, (2)
socioeconomic characteristics, (3) housing configuration and needs, (4) educational,
transportation, and health care opportunities, (5) environmental hazards or concerns, and
(6) all other factors material to the AFFH determination. Applications should show that
projects are likely to lessen area racial, ethnic, and low-income concentrations, and/or
promote affordable housing in low-poverty, nonminority areas in response to natural
hazard-related impacts.
i. Timeline: The proposed program start date is 30 days after HUD’s approval of this Action
Plan. The proposed end date is three years from the start date of the program.
8. Local, Regional and State Planning
In addition to enhancing the state’s Disaster Recovery and Response Plan previously
mentioned, the GLO has committed to the purposes of planning in the impacted area and the
completion of some of the projects identified as a result of the studies. Because of the vast
nature of the current disaster and the recurring nature of disasters in the region, the GLO may
concentrate on regional approaches in addition to specific local solutions to promote sound
long-term recovery. In order to provide an efficient and effective method of selecting and
executing planning studies following Hurricane Harvey, the GLO will work with Texas
universities and/or vendors (term which shall include, but not limited to, governmental entities,
non-profit and for profit firms, entities, and organizations) to conduct studies with CDBG-DR
funds. The GLO will utilize a local community survey process to include public meetings,
requests for information, listening sessions, and written surveys to better determine the specific
needs for planning studies. The GLO has set up an email account and is actively inviting
communities to submit their planning needs to add to a comprehensive list of projects needed.
Once surveys have been gathered from local communities, the GLO will compile a total list of
study needs in the impact area. Opportunities for regionalization will be considered and the
GLO will work with the universities and/or vendors to identify qualified experts for specific
tasks identified. This process and the availability of planning funds will standardize methods
through regional coordination and planning at a level that has not yet been achieved through
CDBG-DR funds in Texas.
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The GLO may solicit responses from local governmental entities through more than one survey
to determine local and regional priorities. Studies may include, but not limited to, flood control,
drainage improvement, resilient housing solutions, homelessness, surge protection, economic
development, infrastructure improvement or other efforts to further recovery from Hurricane
Harvey, mitigate future damages, and establish plans for comprehensive recovery efforts.
Through further amendments to this Action Plan, the GLO may make a portion of these
planning funds available for a competitive application process allowing local governmental
entities to apply for specific studies of their choosing. Additionally, further amendments may
convert a portion of these planning funds to other eligible expenses to execute specific projects
contemplated or developed through the planning process.
Communities may recommend studies to be completed, but all planning funds will be
administered by the GLO. The GLO will make all final determinations regarding planning
studies and coordinate with universities and/or vendors to identify scopes, the parameters of
the planning efforts, and the type of data that they will gather. This approach will ensure
planning studies that are conducted in different regions can be consolidated and analyzed. This
will help to ensure that consistency and accuracy in data gathering is achieved.
The State will develop and maintain a secure database system that documents the impact of
past disasters and provides analytical data assessing natural hazard risks, including anticipated
effect of future extreme weather events and other natural hazards. This will enable the State to
improve its disaster information, analytics capabilities, and foster communication,
collaboration, and information gathering amongst relevant state agencies that have a role in
disaster response and recovery. Additionally, the data gathered will inform both the state and
local communities of possible solutions that plan for and create a more resilient landscape in
the state of Texas.

i. At least eighty (80) percent of funds must benefit HUD MID and distressed” areas
(counties);
ii. Up to twenty (20) percent of funds may benefit the State MID counties.
b. Eligible Activities: Eligible planning, urban environmental design, and policy‐planning‐

management‐capacity building activities as listed in 24 CFR 570.205, HCDA 105(a)(12)
c. Ineligible Activities: Planning activities located within the city of Houston, Harris County
and local governments located within the Harris County. The City of Houston and Harris
County are developing and implementing their own planning activities.
d. Timeline: The proposed program start date is immediately after HUD’s approval of this
Action Plan. The proposed end date is six years from the start date of the program.
e. Planning activities should:
i. Promote sound, sustainable longterm recovery planning informed by a post-disaster

evaluation of hazard risk, especially land-use decisions that reflect responsible
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flood plain management and take into account future possible extreme weather
events and other natural hazards and long-term risks;
ii. Coordinate with local and regional planning efforts to ensure consistency, and
promote community-level and/or regional (e.g., multiple local jurisdictions)
postdisaster recovery and mitigation planning;
iii. Integrate mitigation measures into rebuilding activities and achieve objectives
outlined in regionally or locally established plans and policies that are designed to
reduce future risk to the jurisdiction;
iv. Consider the costs and benefits of the project;
v. Ensure that activities will avoid disproportionate impact on vulnerable populations
such as, but not limited to, families and individuals that are homeless or at risk of
homelessness, the elderly, persons with disabilities, persons with alcohol or other
drug addiction, persons with HIV/AIDS and their families, and public housing
residents.
vi. Ensure that activities create opportunities to address economic inequities facing
local communities;
vii. Align investments with other planned state or local capital improvements and
infrastructure development efforts, and work to foster the potential for additional
infrastructure funding from multiple sources, including existing state and local
capital improvement projects in planning, and potential private investment;
viii. Employ adaptable and reliable technologies to guard against premature
obsolescence of infrastructure.
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9. Administrative Funds
State administrative costs including subrecipient administration costs will not exceed five (5)
percent, $283,819,500. Planning and administrative costs combined will not exceed 20 percent.
The provisions outlined under 42 U.S.C. 5306(d) and 24 CFR §570.489(a)(1)(i) and (iii) will
not apply to the extent that they cap state administration expenditures and require a dollar-for-
dollar match of state funds for administrative costs exceeding $100,000. Pursuant to 24 CFR
§58.34(a)(3), except for applicable requirements of 24 CFR §58.6, administrative and
management activities are exempt activities under this Action Plan. Once contracted, the GLO
will allow the drawdown of pre-agreement costs associated with eligible disaster recovery
activities dating back to the date of the disaster for subrecipients and the GLO with appropriate
documentation.
The GLO will retain the full 5 percent allocated for administrative costs associated with the
CDBG-DR allocation for purposes of oversight, management, and reporting. The only
exception is an allowance for up to 2.5 percent of program amounts for costs that require
administrative type activities in the Harris County and city of Houston programs. Additionally,
all subrecipients, including Harris County and Houston, are allowed to spend up to 10 percent
of program amounts for costs directly related to implementation of housing activities and 6
percent for non-housing and infrastructure type activities for CDBG-DR grant awards $1
million or greater. For non-housing and infrastructure grant awards less than $1 million refer
to GLO guidance found on the website, http://recovery.texas.gov/. Once program level
allocations are identified by Harris County and Houston, administrative costs will be outlined
in subsequent Action Plan Amendment budget. Engineering and design activities will be
capped at 15 percent of the total project award unless special services are necessary; subject to
GLO approval. The GLO, Harris County, and the city of Houston will limit planning costs to
5 percent of each respective allocation to complete projects as defined in 24 CFR 570.205.
G. Harris County Use of Funds
Harris County received a direct allocation from the State’s allocation at the direction of HUD.
Because Harris County has elected to develop their own local recovery programs with the
exception of the State’s economic revitalization program, Harris County has developed a local
plan and submitted it to the GLO for HUD approval.
Harris County’s local programs and requirements are outlined in section 5.2.
H. City of Houston Use of Funds
The City of Houston received a direct allocation from the State’s allocation at the direction of
HUD. Because the City of Houston has elected to develop their own local recovery programs with
the exception of the State’s economic revitalization program, the City has developed a local plan
for and has submitted it to the GLO for HUD apprvoal.
The City’s local programs and requirements are outlined in section 5.3.
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I. Location
All CDBG-DR funded activities under this Action Plan will occur within the disaster-declared
counties of FEMA DR-4332. For the purpose of this Action Plan, counties that received FEMA
disaster declarations for emergency protective measures, including direct federal assistance, under
the FEMA PA program are not included in the 49 CDBG-DR eligible counties.
J. Mitigation Measures
The GLO will require subrecipients to incorporate preparedness and mitigation measures into
rebuilding activities. This helps to ensure that post-recovery communities are safer and stronger
than prior to the disaster. Incorporation of these measures also reduces costs in recovering from
future disasters. Subrecipients must describe how mitigation measures will be integrated into
rebuilding activities and the extent to which infrastructure activities funded through this grant will
achieve objectives outlined in regionally or locally established plans and policies that are designed
to reduce future risk.
K. National Objectives
All CDBG program national objectives are expected to be utilized in the execution of Hurricane
Harvey recovery efforts. For urgent need activities, each subrecipient receiving CDBG-DR funds
will document how all activities or projects funded under the urgent need national objective
respond to a disaster-related impact, identified by the subrecipients as the CDBG certification
requirements for documentation of urgent need, located at 24 CFR 570.483(d), are waived for the
grants under Federal Register Notice, Vol. 83, No. 23, Friday, February 8, 2018..
At least 70 percent of the aggregate of CDBG-DR program funds will be used to support activities
that benefit LMI persons.
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5.2. Harris County Administered Disaster Recovery Program
A. Connection to Unmet Needs
Harris County was HUD identified as one of the “most impacted and distressed” areas in the State’s
Action Plan and Federal Register, Vol. 83, No. 28, February 9, 2017. This local SAP primarily
considers and addresses unmet housing by allocating 81 percent of CDBG-DR funding to housing
related activities. Harris County has developed its program categories based on need and the
County’s public consultation process. Housing programs include: homeowner assistance program;
buyout, affordable single-family housing preservation program; homeowner reimbursement
program; affordable rental program; and single-family new construction program. The programs
were developed to meet CDBG-DR, federal and state requirements and regulations, and to
implement the long-term recovery of housing as efficiently and expeditiously as possible. It is
anticipated that public service type activities may need to be utilized to complement these housing
programs. Public service activities may include, but are not limited to, case management, housing
counseling, legal counseling, job training, mental health, and general health services.
The majority of the funds have been allocated to assist renters through the affordable rental
program (acquisition, rehabilitation, and new construction of affordable rental units) and
homeowners through the reimbursement of repairs, rehabilitation, and reconstruction of their
homes. Funds have been allocated for residential buyouts and acquisition to remove homes from
harm’s way and to compliment the removal of unsafe housing, the construction of new single-
family housing, and the acquisition/rehabilitation of existing single-family housing.
Through Harris County’s continued work with homeless populations and in partnership with the
Coalition for the Homeless of Houston/Harris County, the county recognizes the need for homeless
services to include homelessness prevention and housing of homeless populations. Based on
Hurricane Harvey’s impact, homelessness in the county has and will continue to rise without these
services, short-term mortgage assistance, utility assistance, and tenant-based rental assistance.
Although there are remaining unmet housing needs due to the limitation of funds available, Harris
County recognizes that as part of a comprehensive long-term recovery program, the repair and
enhancements of local infrastructure and mitigation efforts are crucial components. Infrastructure
activities are vital not only for the long-term recovery and restoration of housing but for the long-
term recovery, protection, and viability of communities. Especially drainage improvements
projects in channels and bayous as well as local neighborhood drainage systems are needed to
reduce the flood risk of these areas. Nineteen percent of the funds will address unmet needs related
to infrastructure and economic development.
Harris County has allocated five percent for planning activities. The county will seek to develop
studies on the need for affordable housing post-Harvey including market analysis, countywide
sewer and drainage improvement, and mitigation study, among others.
A summary of Harris County’s unmet need is identified in the table below. As required, a needs
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communities, and includes details for housing, infrastructure, and economic revitalization. The
needs assessment is expected to be amended as additional information is available or updated.
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CDBG-DR Other Known
Category Losses/Gap Remaining Unmet Need
Investments* Investments
Housing $7,458,498,829 $921,941,704 $3,671,644,866 $2,864,912,259

Owner-Occupied Housing $1,729,324,743 $1,729,324,743
Residential Property Insurance/TX Windstorm 1,644,387,050 $1,411,214,085 $233,172,965
National Flood Insurance Program $1,894,715,877 $1,894,715,877 $0
Other Housing and Disaster Related Expenses $760,850,000 $65,000,000 $695,850,000
Rental-occupied Housing $628,287,775 $628,287,775
Public Housing Authority Housing $933,384 $714,904 $218,480
Harris County Buyout Program (Pub L. 115-31) $800,000,000 $300,000,000 $500,000,000
Infrastructure $10,868,969,302 $210,019,672 $698,910,323 $9,960,039,307
FEMA PA $868,774,302 $102,500,000 $679,910,323 $86,363,979
Rebuild Texas $10,000,195,000 $120,019,672 $19,000,000 $9,861,175,328
Economic Development $136,634,250 $12,500,000 $39,287,300 $84,846,950
SBA loans $39,287,300 39,287,300 $0
Business loss $62,346,950 $62,346,950
Commercial Buyout $35,000,000 $12,500,000 $22,500,00
Grand Total
$18,464,102,381 $1,144,461,376 $4,409,842,489 $12,909,798,516
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B. Harris County Quality of Construction
Harris County will require both quality inspections and code compliance inspections on all
construction projects. Site inspections will be required on projects to ensure quality and
compliance with the Harris County Affordable Housing Standards and any building codes. The
county will encourage local subrecipients’ efforts to update and strengthen local compliance codes
to mitigate hazard risks due to sea level rise, high winds, storm surge, and flooding where
applicable.
All rehabilitation (meets the definition of substantial improvement), reconstruction, or new

construction of housing must meet the requirements outlined in the Harris County Affordable
Housing Standards, which includes but is not limited to standards for overall construction, green
building requirements, environmental and hazard mitigation, accessible design, and local building
code compliance. The Standards can be found on the Harris County Community Services
Department website at:
https://csd.harriscountytx.gov/Pages/HCAffordableHoustingStandards.aspx.
C. Rehabilitation and Reconstruction Cost-Effectiveness
Cost-effectiveness will be considered for all residential rehabilitation and reconstruction projects
relative to other alternatives. The County will establish policies and procedures to assess the cost-
effectiveness of each proposed project undertaken to assist a household under any residential
rehabilitation or reconstruction program. The policies and procedures will address criteria for
determining when the cost of rehabilitation or reconstruction of the unit will not be cost-effective
relative to other means of assisting the property owner, such as buyout or acquisition of the
property, or the construction of area-wide protective infrastructure, rather than individual building
mitigation solutions designed to protect individual structures. These policies and procedures will
follow the Federal Register Vol. 83, No 157 regarding Rehabilitation and Reconstruction Cost-
Effectiveness.
D. Harris County MOD
Under the local infrastructure program, Harris County will conduct a County level) MOD process.
Harris County will encourage the prioritization of infrastructure for direct repair of damaged
facilities, FEMA cost share and mitigation, and water and flood control facilities due to the
limitations of funds available in this allocation. A methodology for the distribution and calculation
to local small cities within Harris County will be established for CDBG-DR infrastructure funding.
For those cities that are partially in Harris County, only the portion of the city that resides within
Harris County will be eligible for the MOD. The MOD will balance relative impact of Hurricane
Harvey on the jurisdiction’s population, percentage of the jurisdiction’s population that is low-to-
moderate-income, and the ability to recover and total unmet need. The MOD is further discussed
in Section IV.E.7.B of this document.
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E. Program Budget
HUD Most State Most LMI Amount % of Total

% of Total
Program Impacted Areas Impacted Areas (70% of Total Total Allocation by Total
Allocation
Allocation) Program
Homeowner Assistance Program $ 270,359,499 - $ 189,251,649 $ 270,359,499
22.44%
Buyout /Homebuyer Asst $ 175,000,000 - $ 122,500,000 $ 175,000,000 14.53%
SF Affordable Housing Preservation

$ 25,000,000 $ 17,500,000 $ 25,000,000 2.08%
Program
74.66% $921,941,704
Harris County Housing Reimbursement Program $ 15,000,000 - $ 10,500,000 $ 15,000,000 1.25%
Affordable Rental Program $ 224,500,000 - $ 224,500,000 $ 224,500,000 18.64%
SF New Construction $ 119,888,035 - $ 119,888,035 $ 119,888,035 9.95%
Housing Project Delivery $ 92,194,170 - $ 64,535,919 $ 92,194,170 7.65%
Commercial Buyout Program $ 12,500,000 - $ 8,750,000 $ 12,500,000 1.04%
Harris County Method of Distribution (Local) $ 120,000,000 - $ 84,000,000 $ 120,000,000 9.96%

18.02% $ 222,519,672
Infrastructure
Competitive Application $ 76,668,492 - $ 53,667,944 $ 76,668,492 6.36%
Instructure Project Delivery $ 13,351,180 - $ 9,345,826 $ 13,351,180 1.11%
Harris County Planning Harris County Planning $ 60,234,809 - N/A $ 60,234,809 5.00%
7.32% $ 90,352,214
Harris County Housing
Harris County Administration $ 30,117,405 N/A $ 30,117,405 2.50%
Administration
Harris County Allocation Subtotal (before admin) $ 1,204,696,185 - $ 904,439,374 $1,204,696,185
Harris County Allocation Subtotal (after admin) $1,234,813,590 - $ 904,439,374 $ 1,234,813,590
Page 180 of 420

F. Use of Funds
Hurricane Harvey, FEMA DR 4332, through the Federal Register, Vol. 83, No. 28 (PL 115-56).
Harris County was identified as a “most impacted and distressed” area and was allocated by the
State, along with the City of Houston, a direct allocation from the State’s CDBG-DR allocation at
the direction of HUD of $1,204,696,185. This includes an additional $89,309,355 allocated in
August 14, 2018 Federal Register (PL 115-123), which will be used for housing recovery in the
county. Harris County will allocate not less than 70 percent of the aggregate of CDBG-DR program
funds to be used to support activities benefitting low- to moderate-income persons.
As the county is a HUD identified “most impacted and distressed” area and all funding will be
used in the county, Harris County will meet the requirement to spend 80 percent of funds in a HUD
identified “most impacted and distressed” area. With the increased CDBG-DR allocation under
Public Law 115-123, the county will expand the following housing programs: 1) Homeowner
Assistance and 2) Rental Housing Development, to will address the long-term need of improved
affordable housing. Administration (2.5 percent of funding) and planning (5 percent of funding)
allocations have also increased (see Table 60 Harris County Total Allocation Budget). The
eligibility criteria for these programs is unchanged f and is consistent with the program
requirementss for use of funds described below.
1. Harris County Homeowner Assistance Program
The Harris County Homeowner Assistance Program (HCHAP) will rehabilitate and
reconstruct owner-occupied single-family homes damaged by Hurricane Harvey.
Harris County will develop local housing programs, and will be responsible for the
implementation of each program. Homeowners located within the city limits of Houston and
outside of Harris County will be ineligible for participation in the HCHAP.
Harris County will administer the HCHAP in accordance with the latest needs assessment and
housing guidelines. This program will include owner-occupied housing rehabilitation and
reconstruction. Harris County will also provide temporary financial assistance to homeowners
to prevent homelessness where such homeowners are still displaced due to the disaster or are
in the process of completing repairs to their primary residence to meet habitability standards.
The activity will consist of two primary services with the sole purpose of preventing
homelessness in the region following Hurricane Harvey. This activity will be limited only to
LMI households.
Harris County has established standards for housing contractors in its Homeowner Assistance
Program Guidelines found on the County’s disaster recovery website at
http://harriscountycommunitycorner.org/guidelines/ under Section 6: Building Contractor
Procurement & Selection Process. Builders will submit a proposal under a Request of
Proposals competition. To ensure a full and open competition, the County will follow federal
procurement and contract requirements outlined in 2 CFR 200.318–200.326.
Page 181 of 420

Owner-Occupied Housing Rehabilitation and Reconstruction

i. The program will first be available to FEMA/GLO temporary direct housing
participants and LMI homeowners prior to being made available to non-LMI
homeowners.
b. Maximum assistance:
i. Rehabilitation: Assistance will be based on the home evaluation work write-up
estimate, but not greater than $80,000. Harris County has selected to have a
maximum assistance cap that is higher than the State’s rehabilitation maximum
assistance as median housing price and repair costs will be higher than the average
of the State as the county’s average square foot per home is higher. The County has
submitted a waiver and justification to the GLO to increase the maximum
assistance.
ii. Reconstruction: Standardized cost estimate based on household size. Local

composite builder bid amount based on procured builders and the procured house
plans. The maximum amount allowable for reconstruction is $160,000, excluding
elevation. Eligible applicants that require elevation may qualify for up to an
additional $40,000 for elevation as a part of reconstruction.
iii. Additional information on assistance can be found in Harris County’s Homeowner

Assistance Program Guidelines.
c. Eligible Activities: Housing activities allowed under CDBG-DR; HCDA Section

105(a)(1), 105(a)(3-4), 105(a)(8), 105(a)(11), 105(a)(20), 105(a)(25), and 83 FR 5844,
paragraph VI.B.32 (42 U.S.C. 5305(a) and 24 CFR 570.207(b)(3) is waived and alternative
requirements adopted to the extent necessary to permit new housing construction) include
but are not limited to:
i. Single family owner-occupied rehabilitation, reconstruction, and/or new
construction;
ii. Repair and replacement of manufactured housing units;
iii. Hazard mitigation for recovery activities;
iv. Elevation;
v. Relocation Assistance;
vi. Demolition only;
vii. Public service within the 15 percent cap (such as housing counseling, legal
counseling, job training, mental health, and general health services); as well as
mortgage and utilities assistance for homeowners impacted by Hurricane Harvey
and enrolled in the HCHAP as follows;
o Short-term Mortgage Assistance – The Short-Term Mortgage Assistance
will deliver up to $10,000 to assist LMI households impacted by Hurricane
Harvey with mortgage payments on their primary residence. Mortgage
assistance may not exceed 20 months. This program is intended to prevent
foreclosure or predatory, low-value buyouts of homes in the impacted areas
Page 182 of 420
and ensure that households can continue down the road to recovery without
the imminent threat of homelessness. Applicants must demonstrate a
financial need to prevent foreclosure, or delinquency on current mortgage
for their primary residence.
o Utility Assistance – Utility Assistance Program will provide assistance up
to $1,000 to LMI households impacted by Harvey Hurricane to meet
immediate utility needs. Utility assistance may include electricity, gas,
wastewater, water, and other utility bills and deposits. Assistance will be
provided for current and future bills but not those in arrears.
The County will insure that these programs are made accessible to individuals
having wide-ranging disabilities including mobility, sensory, developmental,
emotional, and other impairments. Intake and program servicing and meeting
facilities will be accessible per the Americans with Disabilities Act (ADA). In
accordance with 24 CFR 8.6, the County will indicate on correspondence materials
disseminated to clients and prospective clients how to access information through
alternative means if they have an impairment, disability, or language barrier, etc.
Additionally, written communication will ask clients and prospective clients
whether they need assistance for mobility impairments, visual or hearing
impairments, or other disabilities. Additional information is available in the Harris
County Housing Guidelines.
viii. Other activities associated with the recovery of single-family housing stock
impacted.
d. Ineligible Activities:
national median;
3. The property owner did not maintain flood insurance on the damaged
property, even when the property owner was not required to obtain and
maintain such insurance.
Page 183 of 420

vii. Homeowners located within the city limits of Houston and/or outside of Harris
County are ineligible to participate in the HCHAP.
e. Eligibility Criteria for Assistance/Selection Criteria:

iii. Home must be located in Harris County outside the City of Houston;
vii. Applicant must be a U.S. Citizen or eligible resident;
viii. Applicant must furnish evidence that property taxes are current, have an approved
compliance. This is an agreement to repay any duplicative assistance if other
disaster assistance for the same purpose later is received.
xii. Deferred Payment Loan/Forgivable Promissory Note:
assisted property for five years. Cash-out refinancing, home equity loans or any
loans utilizing the assisted residence as collateral are not allowed for five years.
A violation of this policy will activate the repayment terms of the Note.
2. Deferred payment loan offered at zero interest only payments and are to be
forgiven at a prorated monthly rate over the five-year term, and secured by a
deed of trust.
applicable), and windstorm (if applicable) will be monitored for the five-year
note period.
f. National Objectives: LMI and urgent need. At least 70 percent of these program funds by
region and Subrecipient must be spent on LMI eligible projects.
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g. Housing Guidelines: Harris County will develop minimum housing guidelines that provide
operational details on the eligibility requirements, housing assistance caps, construction
standards, accessibility requirements, visitability standards, reporting requirements, and
other program requirements. Housing guidelines will be posted for public comment before
use. The GLO must approve all guidelines.
h. Needs Assessment: Harris County will conduct needs assessment. The local needs
assessment and analysis of HUD/FEMA demographic IA data will recommend the
proportions of funding that should be set aside to benefit each LMI and non-LMI economic
group. The needs assessment will determine the activities to be offered, the demographics
to receive concentrated attention, and target areas to be served. The needs assessment
should set goals within the income brackets similar to the housing damage sustained within
the impacted areas. Deviations from goals must be approved by the GLO before the
Program may move forward.
i. Affirmative Marketing Outreach Plan: Harris County is committed to AFFH through

established affirmative marketing policies. Harris County will coordinate with HUD-
certified housing counseling organizations in this effort. Affirmative marketing efforts will
include an affirmative marketing plan, based on HUD regulations. The goal is to ensure
that outreach and communication efforts reach eligible homeowners from all racial, ethnic,
national origin, religious, familial status, the disabled, "special needs", and gender groups.
j. Timeline: The proposed program start date is immediately after HUD’s approval of this
Amendment to the Action Plan. The proposed end date is 6 years from the date of the grant
agreements between HUD and the GLO (see Appendix D).
2. Harris County Residential Buyout Program
The Residential Buyout Program will purchase from a voluntary homeowner and remove
homes from areas of severe flood risk and that are hopelessly deep in the floodplain to assist
homeowners to move out of harm’s way. Purchased properties will be used for flood
management and not be redeveloped for residential or commercial use. This program may
generate program income for which Harris County has requested to retain for continued
recovery programming.
Due to the nature of this activity, this voluntary buyout program will be administered by Harris
County and HCFCD.
b. Eligible Entities: Harris County and will operate this program in partnership with
HCFCD.
c. Eligible Activities, HCDA Section 105(a)(1), 105(a)(7-8), and 105(a)(24-25)

i. Buyouts;
Page 185 of 420
ii. Relocation Assistance with buyout activation (URA required).
iii. Down-payment Assistance, which can be combined with buyout activities;
iv. Demolition only;
v. Housing incentives
vi. Activities designed to relocate families to a location of reduced flood risk;
vii. Public service within the 15 percent cap (e.g., housing counseling, legal counseling,
job training, mental health, and general health services). The County will insure
that these programs are made accessible to individuals having wide-ranging
disabilities including mobility, sensory, developmental, emotional, and other
impairments. Intake and program servicing and meeting facilities will be accessible
per the ADA. In accordance with 24 CFR 8.6, the County will indicate on
correspondence materials disseminated to clients and prospective clients how to
access information through alternative means if they have an impairment,
disability, language barrier, etc. Additionally, written communication will ask
clients and prospective clients whether they need assistance for mobility
impairments, visual or hearing impairments, or other disabilities. Additional
information is available in the Harris County Housing Guidelines; and
viii. FEMA HMGP cost share.
d. Ineligible Activities: Incentive payments to households that move to disaster-impacted

floodplains with equal or greater risk than their original location. Activities located within
the city limits of Houston and/or outside of Harris County are ineligible to participate in
the program.
e. Program Guidelines: Harris County will develop guidelines in accordance with CDBG-DR
requirements and regulations to set maximum assistance amounts, target area locations,
and additional eligibility requirements. Guidelines must be posted for public comment
before use. The GLO must approve all guidelines.
f. National Objectives: LMI, elimination of slum/blight, urgent need, low/mod buyout

(LMB), and low/mod housing incentive (LMHI).
i. Residential properties located in Harris County but outside the city of Houston.
ii. Residential properties in identified CDBG-DR Buyout areas.
iii. Priority will be given to LMI households.
h. Timeline: The proposed program start date is 30 days after HUD’s approval of this
3. Single Family Affordable Housing Preservation Program
The Single Family Affordable Housing Preservation Program will acquire single family
housing properties, rehabilitate them, and resell to eligible households. This program seeks to
Page 186 of 420
preserve the supply of affordable housing as affordable units are removed from the housing
supply chain due to severe damage; buyout; foreclosure; predatory investors who buy cheap,
flip, and sell at a high profit; and abandonment. Additional information will be in the County’s
Single Family Affordable Housing Preservation Program (AHPP) Guidelines. This program
may generate program income for which Harris County has requested to retain for continued
recovery programming.
a. Allocation Amount: $25,000,000.
b. Eligible Entities: Harris County will operate this program.
c. Eligible Activities, HCDA Section 105(a)(1), 105(a)(7-8), and 105(a)(24-25).

i. Acquisition;
ii. Relocation Assistance with acquisition activation (URA required);
iii. Down-payment Assistance, which can be combined with acquisition activities;
v. Rehabilitation and Reconstruction; and
vi. Public service within the 15 percent cap (e.g., housing counseling, legal counseling,
and other housing services). The County will insure that these programs are made
accessible to individuals having wide-ranging disabilities including mobility,
sensory, developmental, emotional, and other impairments. Intake and program
servicing and meeting facilities will be accessible per the ADA. In accordance with
24 CFR 8.6, the County will indicate on correspondence materials disseminated to
clients and prospective clients how to access information through alternative means
if they have an impairment, disability, language barrier, etc. Additionally, written
communication will ask clients and prospective clients whether they need
assistance for mobility impairments, visual or hearing impairments, or other
disabilities. Additional information is available in the Harris County Housing
Guidelines.
d. Ineligible Activities: Activities located within the city limits of Houston and/or outside of
Harris County are ineligible to participate in the program.
f. National Objectives: LMI, elimination of slum/blight, and urgent need.
i. Residential properties located in Harris County but outside the city of Houston
ii. Residential properties in High Opportunty areas and revitalization areas with
significant CDBG, HOME, or other federal, state, or local investment by the state,
county, or local city.
Page 187 of 420

iii. Priority will be given to LMI households for resale.
4. Homeowner Reimbursement Program
Harris County will administer the Homeowner Reimbursement Program for eligible expenses
incurred by homeowners for repairs to a primary residence prior to application for these funds.
Up to $50,000 per household may be reimbursed.
a. Allocation Amount: $ 15,000,000

i. The program will first be available to LMI households before being made available
to non-LMI households.
b. Maximum Award: $50,000
c. Eligible Activities, HCDA Section 105(a)(4):

i. Expenses incurred by homeowners for repairs to a primary residence prior to
application for these funds.
national median;
3. The property owner did not maintain flood insurance on the damaged property,
insurance.
Page 188 of 420

vii. Homeowners located within the city limits of Houston and/or outside of Harris
County are ineligible to participate in the program.
e. Eligibility Criteria for Assistance/Selection Criteria:

iii. Home must be located within Harris County and outside the city limits of
Houston;
vii. Applicant must furnish evidence that property taxes are current, have an approved
viii. Applicant must be a U.S. Citizen or eligible resident;
compliance. Assisted homeowners must agree to repay any duplicative assistance
if they later receive other disaster assistance for the same purpose.
xii. Deferred Payment Loan/ Forgivable Promissory Note:
assisted property for five years. Cash-out refinancing, home equity loans or any
loans utilizing the assisted residence as collateral are not allowed for five years.
A violation of this policy will activate the repayment terms of the Note.
2. Deferred payment loan offered at zero interest only payments and are to be
forgiven at a prorated monthly rate over the five-year term, and secured by a
deed of trust.
applicable), and windstorm (if applicable) will be monitored for the five-year
note period.
f. National Objective: LMI and urgent need.
Page 189 of 420

g. Timeline: The proposed program start date is immediately after HUD’s approval of this
Amendment to the Action Plan. The proposed end date is 6 years from the date of the
grant agreements between HUD and the GLO (see Appendix D).
5. Affordable Rental Program
Harris County will administer the Affordable Rental Housing Program.
The program has been designed to provide funds for acquisition, 50 rehabilitation,
reconstruction, and new construction of affordable multi-family housing projects in areas
impacted by Hurricane Harvey, as well as case management services for displaced renter
households. Harris County’s NOFA/Request for Proposals will establish the application
process and acceptance period, threshold criteria (including applicable building codes),
selection criteria, and the award process. Case management services will be delivered by Harris
County directly. This program may generate program income for which Harris County has
requested to retain for continued recovery programming.
a. Allocation for Activity: $224,500,000.
b. Maximum Award: $25 million per development (Harris County may request a waiver to
exceed on a case by case basis).
c. Eligible Applicants: Acting individually or as participants in a LP or LLC:

iii. Units of local governments;

105(a)(14-15) and 83 FR 5844, paragraph VI.B.32:
i. Rehabilitation, reconstruction, and new construction of affordable multi-family
housing projects.
ii. Public Services within the 15 percent cap (e.g., housing counseling, housing
navigation and case management). These services are to assist those who were
displaced by Hurricane Harvey find safe, quality rental housing, and promote
housing stabilization. The County will insure that these programs are made
accessible to individuals having wide-ranging disabilities including mobility,
sensory, developmental, emotional, and other impairments. Intake and program
servicing and meeting facilities will be accessible per the ADA. In accordance with
24 CFR 8.6, the County will indicate on correspondence materials disseminated to
clients and prospective clients how to access information through alternative means
if they have an impairment, disability, language barrier, etc. Additionally, written
50
Acquisition funding will be made available under the Acquisition Program, and may be combined with the
Affordable Rental Program for certain projects.
Page 190 of 420
communication will ask clients and prospective clients whether they need
assistance for mobility impairments, visual or hearing impairments, or other
disabilities. Additional information is available in Harris County Housing
Guidelines.
i. Development must meet CDBG-DR eligibility requirements.
ii. Development must be located within Harris County and outside the city limits of
Houston except in certain cases where the City and County partner on projects that
provide housing.
iii. A minimum of 51 percent of the units must be restricted for an affordability period
of fifteen (15) years for a rehabilitation/reconstruction projects and twenty (20) or
more years for new construction for LMI individuals earning 80 percent or less of
AMFI at affordable rents.
iv. The affordable rents must comply with High/Low HOME Rents and additional
rental limits for tenants that are extremely low income as described in Harris
County’s Affordable Rental Housing Program Guidelines, and other existing
LURA restrictions, if applicable.
v. Property Types: Multi-family rental development is eight or more rental units under
common ownership.
vi. The Harris County Affordable Rental Program NOFA/RFP will clearly establish
the application process and acceptance period, threshold criteria (including
applicable building codes), selection criteria, and the award process.
vii. Project construction must be completed within 18 months of the effective date of
viii. Provide a set-aside of supportive housing of at least 5 units.
ix. Property owners receiving disaster assistance that triggers the flood insurance
x. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
f. Ineligible: Developments located outside of Harris County are ineligible.

Developments located inside the City of Houston are also ineligible except in the case
Page 191 of 420
stated above under Eligibility Criteria: item ii regarding partnerships between the
jurisdictions.
g. Primary Selection Criteria:

i. Located in High Opportunity Zones; and areas of revitalization as demonstrated
by other public and/or private investments in such areas; 51
ii. Targets extremely low-income (30 percent AMFI or less);
iv. Serves persons with disabilities beyond minimum Section 504 requirements,
providing more accessible units;
v. Provides supportive housing, particularly to persons with disabilities;
vi. Leverages public and private financing; (may request waiver to fully fund certain
developments to expedite project completion);
vii. Activity type; and
viii. Cost-effectiveness.
h. National Objective: LMI.
i. Timeframe: The proposed program start date is immediately after HUD’s approval of
this Amendment to the Action Plan. The proposed end date is 6 years from the date of
the grant agreements between HUD and the GLO.
6. Harris County Single Family New Construction Program
Harris County struggled to keep pace with housing demand pre-Hurricane Harvey, and now
the ability to provide a comprehensive single family focused development solution, associated
with Hurricane Harvey recovery is even more exacerbated. Over the next 4 years, Harris
County in partnership with HCFCD, will be acquiring approximately 2,000 homes through a
buyout program funded by Hazard Mitigation Grants and CDBG-DR. In a period where the
local housing stock is low or in flood prone areas, quality replacement homes, especially
affordable homes, will be impossible to find in Harris County. This could be exacerbated by
the dismantling of whole communities after a buyout program.
The Harris County Single Family New Construction Program will replace affordable single-
family housing stock by developing new housing in areas of reduced risk of flooding. To meet
this challenge, Harris County will implement innovative solutions for promoting and
partnering with local homebuilders to create new inclusive communities that offer a wide
variety of housing choice and construction solutions that lends toward resilience investments.
As a public/private partnership approach, Harris County will build on national community

development and housing finance models that promote quality larger scale neighborhood
development for LMI families that is context sensitive and aims toward implementing mixed-
51
As directed by HUD, Harris County will pursue a balanced approach in investing in both High Opportunity
areas as well as constructing and improving multi-family affordable housing stock in revitalization areas that may be
located near buyout interest areas as a means of improving and preserving community stability.
Page 192 of 420
income/mixed use development styles. LMI families affected by flooding especially those
experiencing repetitive flooding, will enjoy opportunities to relocate with their neighbors from
these flood prone areas, thus preserving community cohesion, sustaining the local tax base,
and local institutions such as schools, and other community assets.
The program will specifically link new single-family construction investments with LMI
families, and the CDBG-DR eligibility requirements associated with benefiting LMI
individuals earning 80 percent or less of the annual AMFI levels. Further, a new residential
subdivision development would qualify for CDBG-DR eligible investment (e.g., land
acquisition, infrastructure for residential development) if 51 percent or greater of the units in a
single development will be occupied by LMI households, thus qualifying under the LMI
national objective, just as a multifamily complex would qualify where 51 percent or greater of
the total units are dedicated for LMI households. Harris County will leverage its success with
public/private partnerships by identifying and qualifying developer/builder interests that have
the prerequisite development experience and financial capacity to mix financing, such as
private equity and other non-CDBG-DR funding, for the development of property and the
construction of homes above the 80 percent of AMFI limits.
In cases where subsidies for the construction of homes are provided to builders/developers,
individual housing units will be sold to LMI homebuyers. This will apply with both in-fill and
new development projects. In-fill development will help enhance and strengthen existing
neighborhoods located in reduced flood risk areas by creating more opportunities for new
affordable housing while also improving the local housing stock.
As a separate initiative under this program, the county will identify LMI target areas in need
of community revitalization and that were highly impacted by Hurricane Harvey and other
recent disaster events. These areas will need a comprehensive approach to improve housing,
infrastructure, and facilities to achieve reduced future flood loss and improve resilience. It is
the county’s intent as we improve housing through rehabilitation, reconstruction, and new
construction to also improve the neighborhood’s drainage and other infrastructure that serve
those homes in the LMI target area. If the drainage and infrastructure issues are not corrected,
any repairs or new construction of housing will be flooded in the next disaster event in the
same manner as these homes were affected by the 2016 Floods and Hurricane Harvey.
Additionally, this approach will be aligned with the referenced “Balanced Approach” that will
invest in both High Opportunity areas as well as improving affordable housing stock in
revitalization areas that may be located near Hurricane buyout interest areas as a means of
improving and preserving community stability and cohesion. Besides the private housing
market, LMI households seeking housing will have access to a larger market of affordable
housing both in high opportunity and revitalization areas with this program.
Comprehensive Single Family Development
The program will include a spectrum of activities, depending on the selected development
model (refer to models described below), that involves a partnership between the Community
Services and the County Engineering Department – and developer/builder interests – where
Page 193 of 420
the Engineering Department identifies land in consultation with CSD, and if approved and the
project meets feasibility criteria, a contractor is procured to develop the infrastructure (streets,
sidewalks, water, sanitary sewer, storm sewer, and detention) for the property (Engineering is
the designated department lead for infrastructure and site development), and builders are
selected to construct homes, with Harris County (Community Services lead) marketing and
selling the homes to qualified families. Alternatively, a comprehensive developer model would
entail 1) a “turn-key model” that may involve a developer proposing a site for department
consideration followed by construction services and marketing and sale of homes; or, 2) Harris
County identifying and delivering the land to the project, and a developer is selected through
an RFP process to develop the property, construct homes, and market and sell homes to a
combination of LMI families, and to families above the 80 percent AMI threshold. Separately,
families qualifying under Urgent Need would income qualify from 81-120 percent AMI.
The comprehensive approach would involve: predevelopment site, neighborhood, and market
analysis to determine the feasibility of market demand and housing type preferences; property
acquisition; subdivision land planning; infrastructure development; marketing and sale of lots
to qualified builders; construction of homes and home sales to LMI families and market-rate
homes. Downpayment subsidies, conventional financing, or alternative financing
consideration for families that may not meet the current credit score, or debt vs. income
underwriting, and credit and homebuyer counseling are program facets of this comprehensive
single family development and construction program.
Downpayment Assistance Program
Qualified applicants may be eligible to receive financial assistance in the form of a forgivable loan
to be used towards a downpayment on a new or existing home, including eligible prepaids
and/or closing costs. Assistance amount will be limited to the amount necessary to achieve
homeownership. Assistance will be provided in the form of a deferred forgivable loan, secured
by a deed of trust with a ten (10) year affordability period.
Single Family Development and Construction Models
Harris County shall implement the program under several models to ensure the necessary
flexibility required to deliver the maximum number of units within the funding timeframe.
These eligible development models include but are not limited to the following:
Model 1
 Harris County acquires suitable and feasible land for single family development,
related amenities (partner relationship between CSD and Engineering Department);
 Harris County Engineering Department through the bid process obtains an A&E firm
to develop the land’s infrastructure; and
 Developer(s) procured by Harris County will build and sell the homes.
Model 2
 Harris County acquires land;
 Developer procured by Harris County will:
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a. Develop the infrastructure;
b. Build the homes; and
c. Sell the homes.
Model 3
 Harris County acquires land;
 Harris County Engineering Department through the bid process obtains an A&E firm
to develop the land’s infrastructure;
 Harris County hires a contractor to build the homes; and
 Harris County markets and sells the homes.
Program Funding, Eligibility, and Program Income
Eligible activities include those permissible under section 105(a) of the Act (Title I of the
Housing and Community Development Act of 1974) and the federal regulations at 24 CFR
Part 570 which govern the repair, rehabilitation, reconstruction, or new construction (including
acquisition, demolition, site clearance, and remediation) under the Single Family New
Construction Program. CDBG funds may be used for the construction of housing assisted
under section 17 of the United States Housing Act of 1937. This program may generate
program income for which Harris County has requested to retain for continued recovery
programming.
b. Maximum Award: $25 million per development/developer (Harris County may request
waiver to exceed on a project by project basis)
c. Eligible Applicants: Applicants acting individually or as participants in a nonprofit

corporation, a LP or LLC, other legally formed entity eligible to apply for CDBG-DR
funding:

iii. Units of local governments; or

105(a)(14-15); A waiver eligible under 83 FR 5844 permits new housing construction:
i. New construction of affordable single-family housing.
ii. Infrastructure for housing development. Infrastructure for housing development to
include design and construction of water and wastewater lines, connects and
facilities; utilities, storm sewer; detention; SWPPP; irrigation; mitigation (sound,
floodplain, etc.); fencing; streets, streetlights, signage and sidewalks; landscaping;
trenching; and other concrete work.
iii. Down Payment Assistance.
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iv. Public Services within the 15 percent cap (e.g., housing counseling, credit clean-
up, legal services). These services are to assist LMI homebuyers to access
homeownership opportunities being created in the developments. The County will
insure that these programs are made accessible to individuals having wide-ranging
disabilities including mobility, sensory, developmental, emotional, and other
impairments. Intake and program servicing and meeting facilities will be accessible
per the ADA. In accordance with 24 CFR 8.6, the County will indicate on
correspondence materials disseminated to clients and prospective clients how to
access information through alternative means if they have an impairment,
disability, language barrier, etc. Additionally, written communication will ask
clients and prospective clients whether they need assistance for mobility
impairments, visual or hearing impairments, or other disabilities. Additional
information is available in the Harris County Housing Guidelines.
e. Eligibility Criteria
i. Development must meet CDBG-DR eligibility requirements;
ii. Development must be located within Harris County and outside the city limits of
Houston except in certain cases where the City and County may partner on projects
that are adjacent to the city/county line and will serve both City and County
residents;
iii. A minimum of 51 percent of the units must be restricted for LMI individuals
earning 80 percent or less of the AMFI at affordable rents.
iv. The sales price for each single-family residence will not exceed the HOME and
Housing Trust Fund (HTF) Homeownership Value Limits for LMI homebuyers;
v. Property Types: Single-family development and in-fill development.
vi. The Harris County Single Family Development Program NOFA/RFP will clearly
establish the application process and acceptance period, threshold criteria
(including applicable building codes), selection criteria and the award process.
vii. The affordability period for the homebuyer is 10 years. The homebuyer must
occupy the home as his/her principal residence throughout the affordability period.
Recapture is triggered by a transfer of ownership, either voluntary or involuntary,
during the established affordability period. Harris County will enforce the provision
through an agreement with the homebuyer and a recorded deed of trust and note.
viii. Project construction must be completed within 24 months of the effective date of
f. Ineligible: Developments located outside of Harris County are ineligible. Developments

located inside the City of Houston are also ineligible except in the case stated above under
Eligibility Criteria: item ii regarding partnerships in projects along the city/county line.
g. Primary Selection Criteria (for contiguous developments):

i. Located in High Opportunity Zones and areas of revitalization as demonstrated by
other public and/or private investments.52
52
As directed by HUD, Harris County will pursue a balanced approach in investing in both High Opportunity
areas as well as improving affordable housing stock in revitalization areas that may be located near buyout interest
areas as a means of improving and preserving community stability.
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ii. Includes targets for extremely low-income (30 percent AMFI) homebuyers;
iii. Meets the number of LMI units eligibility requirement;
v. Leverages public and private financing;
h. National Objectives: LMI
i. Timeline: The proposed program start date is immediately after HUD’s approval of this
Amendment to the Action Plan. The proposed end date is 6 years from the date of the
grant agreements between HUD and the GLO (see Appendix D).
7. Local Infrastructure Program
Harris County recognizes that as part of a comprehensive long-term recovery program the
repair and enhancements of local infrastructure and mitigation efforts 53 are crucial
components. Infrastructure activities are vital not only for the long-term recovery and
restoration of housing, but also for the long-term recovery and viability of communities. The
local infrastructure program will provide disaster relief, long-term recovery, and restoration of
infrastructure for Harris County communities impacted by Hurricane Harvey. Each
infrastructure activity must demonstrate how it will contribute to the long-term recovery and
restoration of housing. Harvey floodwaters observed no political or demographic boundaries,
but their impact on our vulnerable and economically distressed communities was especially
devastating. The majority of the projects we will undertake are in disadvantaged communities
and seek to alevate historical inequities and disproportionate impacts. Harris County
anticipates that the improvements to the infrastructure in these areas will foster a compounding
positive influence far beyond the physical improvements that will support continued recovery
and encourage future investment and development in those communities for years to come.
The County will ensure to the best extent possible that mitigation measures are integrated into
rebuilding activities and infrastructure activities will achieve objectives outlined in regionally
or locally established plans and policies that are designed to reduce future risk to the
jurisdiction. Harris County will ensure that mitigation, planning, and policy objectives are
considered for all projects. Generally, the County’s intent is to deliver projects that will harden
and protect infrastructure against future risks. Specifically, mitigation measures will
concentrate on reducing the risk of structural flooding.
The County is keenly aware that we will be delivering projects using taxpayer funds, and
appreciate that opportunity. The County makes it a priority to be fiscally responsible and
considers costs andbenfits, which includes ensuring that project spending is appropriate,
reasonable, and provides the best benefit possible for our constituents. The County is taking
53
Mitigation efforts - Harris County will take measures to acquire commercial properties located in areas in which
Harris County intends to preserve open space or establish flood storage/overflow. This is part of holistic community
approach to help relocate residents and businesses to areas in close proximity to original locations to preserve
community character and financial structure.
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advantage of multiple investment resources to address our infrastructure needs, including but
not limited to bond funds approved by Harris County voters, FHWA funds, and FEMA funds.
We will continue to actively seek funding and partnership opportunities as we progress toward
full recovery from Harvey and a more resilient future.
Premature obsolescence would be an unacceptable condition for any project the County
delivers, regardless of the source of funds. This situation can be avoided by using sound state
of the art engineering and/or architectural practices in the development and design of projects.
Specifying appropriate materials and technologies for the work and conditions and ensuring
construction is completed as required by plans and specifications is also critically important.
Harris County routinely delivers the design and construction of dozens of infrastructure
projects, from routine to highly complex, annually. Our constituents expect and deserve
projects that will serve their intended purpose well, do not require excessive repair or
modification during their lifespan, and do not need to be replaced before their intended
lifecycle completion due to failure to consider and avoid factors that contribute to premature
obsolescence.
Harris County will operate its local infrastructure program as a subrecipient to the GLO.
Activity 1: Harris County Commercial Buyout Program
Harris County Commercial Buyout Program will purchase commercial properties, where the
owner has voluntarily agreed to sell, in communities that have suffered from multiple disasters
or are at a high-risk of suffering from additional disasters, such as properties in the 100-year
floodplain. As with residential buyouts, properties targeted for commercial buyout will be
located in areas in which Harris County intends to preserve open space or establish flood
storage/overflow. This is part of a holistic community approach to help relocate residents and
businesses that have been devastated by Hurricane Harvey. Harris County will follow the
URA, if required, and will provide relocation payments and assistance to displaced businesses.
Harris County will attempt, as much as possible to help relocate communities in close
proximity to original locations to preserve community character and financial structure.
b. Eligible Entities: Harris County will operate this program in partnership with HCFCD.
c. Eligible Activities, HCDA Section 105(a)(1), 105(a)(7-8), and 105(a)(11)

i. Buyouts;
ii. Relocation Assistance;
iii. Assistance with buyout activities;
v. Activities designed to relocate businesses outside of floodplains; and
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d. Ineligible Activities: Activities located within the city limits of Houston and/or outside of
Harris County are ineligible to participate in the program.
f. National Objectives: LMI, elimination of slum/blight, and urgent need.
i. Commercial properties located in Harris County but outside the city of Houston.
ii. Commercial properties in identified CDBG-DR buyout areas.
iii. Priority will be given to LMI households.
Activity 2: Harris County MOD
Under the local infrastructure program, Harris County will conduct a County level MOD
process. Harris County will encourage the prioritization of infrastructure for direct repair of
damaged facilities, FEMA cost share and mitigation, and water and flood control facilities due
to the limitations of funds available in this allocation.
Harris County will follow a citizen participation process as a part of the MOD development.
Harris County is required to publish notice of any public hearings prior to holding the hearings.
Notices shall be published in all newspapers of record for all eligible cities, posted on the
Harris County Community Services Department’s website, and provided to all eligible cities
in the MOD. Hearings must fully comply with Texas Open Meetings Act.
The final MOD shall be posted on the Harris County Community Services Department’s
website for public comment prior to submission to the GLO. The public comment period shall
be no less than 14 days. Each comment shall be responded to and any changes made to the
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final MOD shall be noted in the response section for GLO review. The MODs must be
completed 60 days from the GLO submission of the Amendment to the Action Plan to HUD.
Upon completion, Harris County shall submit MOD to the GLO for review and approval.
a. Harris County MOD Requirements:

i. Harris County will facilitate the MOD process with GLO support;
2. Conduct a minimum of two public hearings prior to finalizing the MOD;
3. One of the public hearings shall be identified as a “Public Planning Meeting;”
4. Personal and website notice must be sent at least five days prior to each public
hearing;
5. Public notice of each hearing must be published in at least one regional
newspaper three or more days in advance of the hearing.
iv. Implement a damage level threshold of $1,500,000 in CDGB-DR funds to any local
entity receiving funding through the MOD;
v. Facilitate local prioritization through the MOD;
vi. Any funding not applied for or used by the entity allocated funding will be returned
to Harris County to be used in their allocation;
vii. Any amendments reallocating funding will be published on the Harris County
Community Services Department’s website for at least 14 days and submitted to
GLO for approval. If Harris County cannot expend the funding, the funding will be
returned to the State for re-allocation;
viii. Reallocation of funds from de-obligated funds and/or cost savings from completed
projects will be the discretion of Harris County within cities in Harris County and
outside the city limits of Houston;
ix. A plan to meet the 70 percent LMI benefit requirement;
x. Establish any additional parameters for eligibility beyond what is required by HUD
or the GLO.
c. Eligible Entities: Units of local government (cities and Harris County)
d. Eligible Activities: Infrastructure activities must contribute to the long-term recovery and
restoration in support of housing. All activities allowed under CDBG-DR; HCDA Section
105(a)(1-5), 105(a)(7-9), and 105(a)(11), including but not limited to:
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of generators, removal of debris, bridges, etc.) in support of housing;
iii. Demolition, rehabilitation of publicly or privately-owned commercial or industrial
buildings, and code enforcement;
prioritizing assistance to businesses that meet the definition of a small business);
1. Register and maintain entries regarding such structures with the USACE
National Levee Database or National Inventory of Dams;
reduction measures.
ii. Funds may not be used to assist a privately-owned utility for any purpose;
iii. Buildings and facilities used for the general conduct of government (e.g., city halls,
iv. No disaster recovery assistance will be considered with respect to any part of a
disaster loss that is reimbursable by FEMAUSACE, insurance, or another source
due in part to the restrictions against duplication of benefits outlined in this Action
Plan. An activity underway prior to the Presidential Disaster Declaration will not
qualify unless the disaster directly impacted said project.
v. By law, (codified in the HCD Act as a note to 105(a)), the amount of CDBG–DR
funds that may be contributed to a USACE project is $250,000 or less.
vi. Activities located outside of Harris County or within the city limits of Houston are
ineligible.
f. National Objectives: LMI, elimination of slum/blight and urgent need.
i. Priority will be given to projects that benefit LMI households or communities.
ii. Priority will be given to the repair and improvement of Harvey-affected homeless
shelter facilities, critical infrastructure, public safety buildings and drainage
facilities.
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h. Timeline: The proposed program start date is 30 days after HUD’s approval of this Action
Plan. The proposed end date is 6 years from the date of the grant agreements between HUD
and the GLO (see Appendix D).
Activity 3: Harris County Competitive Request for Proposal Program
The Harris County competitive RFP program will solicit proposals from Harris County and
affiliated small cities to repair and rebuild infrastructure/facilities impacted by Hurricane
Harvey. The intent of the RFP is to provide funding for local infrastructure improvements to
include:
 Improvements to storm-water/drainage
 Expansion of water and wastewater facilities to serve underserved areas of the County
 Construction of roads
 Rehabilitation, reconstruction, or construction of emergency shelters and public facilities
 Traffic signal resilience and
 Other critical infrastructure/facilities repairs and enhancements
After the damage caused by Hurricane Harvey, much needed repairs and enhancements will
dramatically improve public, residential, and commercial concerns by mitigation flooding,
rescuing storm water on roadways and properties, coveting storm water into the appropriate
channels, as well as provide shelter to displaced residents.
b. Eligible Entities: Units of local government (excluding the city of Houston), Independent
School Districts, non-profits, and publicly-owned utilities within Harris County boundaries
c. Eligible Activities: Infrastructure activities must contribute to the long-term recovery and
restoration of housing. All activities allowed under CDBG-DR; HCDA Section 105(a)(1-
5), 105(a)(7-9), and 105(a)(11), including but not limited to:
of generators, removal of debris, bridges, etc.);
iii. Demolition, rehabilitation of publicly or privately-owned commercial or
institutional or industrial buildings, and code enforcement;
prioritizing assistance to businesses that meet the definition of a small business);
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1. Register and maintain entries regarding such structures with USACE National
Levee Database or National Inventory of Dams;
reduction measures.
ii. Funds may not be used to assist a privately-owned utility for any purpose;
iii. Buildings and facilities used for the general conduct of government (e.g., city halls,
iv. No disaster recovery assistance will be considered with respect to any part of a
disaster loss that is reimbursable FEMA, USACE, insurance, or another source due
in part to the restrictions against duplication of benefits outlined in this Action Plan.
An activity underway prior to the Presidential Disaster Declaration will not qualify
unless the disaster directly impacted said project.
v. By law, (codified in the HCD Act as a note to 105(a)), the amount of CDBG–DR
funds that may be contributed to a USACE project is $250,000 or less.
vi. Activities located outside of Harris County or within the city limits of Houston are
ineligible.
vii. National Objectives: LMI, elimination of slum/blight, and urgent need.
viii. Timeline: The proposed program start date is 30 days after HUD’s approval of this
Action Plan. The proposed end date is 6 years from the date of the grant agreements
between HUD and the GLO (see Appendix D).
e. Selection Criteria
i. Priority will be given to projects that benefit LMI households or communities.
ii. Priority will be given to the repair and improvement of Harvey affected homeless
shelter facilities, critical infrastructure, public safety buildings and drainage
facilities.
iii. Projects will provide at least 20 percent leveraging funding to the project.
8. Harris County Planning
Well-thought-out and inclusive planning paves the way for effective and efficient
implementation of projects and activities. The planning process is iterative, with each phase
overlapping and informing the others. Harris County will invest sufficient planning funds to
accurately identify unmet needs, which will ensure that projects are implemented in a manner
to achieve successful completion.
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b. Eligible Activities: Eligible planning, urban environmental design, and policy‐planning‐

management‐capacity building activities as listed in 24 CFR 570.205, HCDA 105(a)(12)
c. Ineligible Activities: Planning activities located outside of Harris County or within the city
limits of Houston except where such studies intersect hazard mitigation and drainage
improvements related to the assets maintained by HCFCD.
d. Timeline: The proposed program start date is immediately after HUD’s approval of this
Amendment to the Action Plan. The proposed end date is six years from the start date of
the program.
e. Prioritization of Activities: Planning activities will be priorized as follows:

i. Activities for planning and operations of disaster response and recovery programs,
including policy-planning and management-capacity building.
ii. Planning Studies including but not limited to studies or plans for flood control,
drainage improvement, affordable housing and fair housing, emergency
management/operations, disaster response and recovery, health, infrastructure
improvements, or other efforts to further recovery from Hurricane Harvey or
mitigate future disasters and establish plans for comprehensive response and
recovery efforts.
9. Administrative Funds
Harris County administrative costs will not exceed 2.5 percent, $30,117,405 of the total
allocation, which will be provided from the State’s Administrative Funds set-aside. This is in
compliance with the State’s plan. The GLO will allow up to 10 percent of program amounts
for costs directly related to implementation of housing activities and 6 percent of
infrastructure/non-housing activities. The GLO has capped engineering and design activities
at 15 percent of the total project award, unless special services are necessary and are subject to
GLO approval. The proposed program start date is immediately after HUD’s approval of this
action plan amendment. The proposed end date is 5 years from program start date.
Harris County intends to utilize, expend and seek reimbursement for Pre-Award cost, in
compliance with 570.200(h), for planning, purchase and expansion of software systems,
standing up of intake and call centers for housing programs, program management and
administrative functions.
10. National Objective
It is expected all the national objectives will be utilized in the execution of the Hurricane
Harvey recovery effort. For urgent need activities, each subrecipient receiving CDBG-DR
funds will document how all activities or projects funded under the urgent need national
objective respond to a disaster-related impact identified by the subrecipients. The CDBG
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certification requirements for documentation of urgent need, located at 24 CFR 570.483(d),
are waived for the grants under this notice.
At least 70 percent of the aggregate of CDBG-DR program funds will be used to support
activities that benefit LMI persons.
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5.3. City of Houston Administered Disaster Recovery Program
A. Direct Allocation
Because the City of Houston and Harris County have been awarded a direct allocation from the
State, the GLO directed each to develop a local action plan. Houston has followed GLO’s guidance
in submitting a local action plan, which is incorporated into various sections of the GLO’s Action
Plan. The local information in the City’s action plan includes local needs assessment, connection
to unmet needs, local programs and requirements, local consultation, and expenditure timelines.
B. Connection to Unmet Needs
The entire City of Houston is located in an area HUD identified as “most impacted and distressed”.
Therefore, 100 percent of funds spent in Houston will address the unmet needs of the most
impacted and distressed areas in Texas. The GLO’s assessment and the City’s local assessment of
unmet needs are the basis for the development and prioritization of recovery activities in Houston.
The City has consulted with affected citizens, stakeholders, and the HHA to assess needs. As
additional data becomes available and as additional community and stakeholder engagements take
place, the unmet needs and activities to address them through CDBG-DR funds may be updated.
Through these funds, Houston primarily intends to address unmet housing needs with
approximately 90 percent of funds addressing unmet needs directly related to housing. Using
available data and input from stakeholders and residents, the City has developed the following
housing programs: Homeowner Assistance Program, Single Family Development Program,
Multifamily Rental Program, Small Rental Program, Homebuyer Assistance Program, and Buyout
Program. The programs will address the long-term recovery of housing in Houston as efficiently
as possible.
One third of these funds are allocated to assist homeowners through the repair, rehabilitation, and
reconstruction of their homes. Almost one third of the funds will also be used to repair, rehabilitate,
reconstruct, or develop new rental homes, both multifamily and single family. The remaining
housing funds, available to assist both renters and homeowners, will be used to build new,
affordable single family homes, assist homebuyers in purchasing homes, and removing residents
from homes in areas that are likely to flood again.
Houston’s CDBG-DR funds will primarily address unmet housing needs. However, the City
recognizes that a comprehensive and effective long-term recovery program involves a broader
approach. Houston’s housing programs will be complemented with public service activities to help
stabilize families or prepare families for permanent housing solutions. Public service activities
may include, but are not limited to, homeless prevention and services, housing counseling, legal
counseling, job training, mental health, and general health services. The City has also developed
an Economic Revitalization Program to create and retain jobs in the community, helping
households stabilize through employment or by increasing their income.
The City has allocated two percent for planning activities to support and promote a comprehensive
long-term recovery effort that will tie into the regional planning efforts, as appropriate. The City
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will allocate two and a half percent of program funds for administrative costs, as allowed by the
GLO. These costs will include compliance monitoring and other administrative activities to
support the programs. At least 70 percent of all program funds will benefit LMI persons.
The City has included preparedness and mitigation measures into this analysis to ensure that
Houstonians are safer and more resilient than they were before Hurricane Harvey and can recover
faster when future disasters occur. The City will strive to incorporate preparedness and mitigation
measures into its activities. These efforts will be detailed in program guidelines as they are
developed. In addition, the City will use these funds and design its programs with the goal of
increasing affordability and equity within Houston.
A summary of Houston’s unmet need is identified in the table below. This information is both a
subset of and additional information for the GLO’s Summary of Total Unmet Need.
CDBG-DR Other Known Remaining Unmet

Category Losses/Gap
Investments* Investments Need
Housing $5,741,049,341 ($1,191,394,231) ($2,787,448,572) $1,762,206,538
Owner-Occupied Housing $1,673,453,681 ($427,900,063) $1,245,553,618
National Flood Insurance

$2,956,800,000 ($2,743,000,000) $213,800,000
Program
Renter-Occupied Housing $1,061,408,358 ($416,736,754) $644,671,604
FEMA PA – HHA $49,387,302 ($44,448,572) $4,938,730
Houston Single Family

Development and Homebuyer ($245,957,414) ($245,957,414)
Assistance Programs
Houston Buyout Program ($40,800,000) ($40,800,000)
Houston Public Services ($60,000,000) ($60,000,000)
Infrastructure $1,293,794,266 $0 ($1,183,964,839) $109,829,427
FEMA PA $590,794,266 ($531,714,839) $59,079,427
HMGP Projects $703,000,000 ($527,250,000) $175,750,000
Insurance Proceeds and Office

($125,000,000) ($125,000,000)
of the Governor’s Grant
Economic $1,401,319,818 ($30,264,834) ($271,205,500) $1,099,849,484
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CDBG-DR Other Known Remaining Unmet
Category Losses/Gap
Investments* Investments Need
SBA Business/EIDL Loans
$1,401,319,818 ($271,205,500) $1,130,114,318
Houston Economic
Revitalization Program ($30,264,834) ($30,264,834)
Grand Total $8,436,163,425 ($1,221,659,065) ($4,242,618,911) $2,971,885,449

* CDBG-DR investments include activity delivery costs.
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C. Houston Program Budget
HUD Most State Most LMI Amount % of Total

% of Total
Program Impacted Areas Impacted Areas (70% of Total Total Allocation by Total
Allocation
Allocation)* Program
City of Houston
Programs
Homeowner Assistance Program $ 427,900,063 - $ 246,810,291 $ 427,900,063 7.54%

City of Houston Housing
Single Family Development Program $ 222,269,086 - $ 222,269,086 $ 222,269,086 3.92%
Multifamily Rental Program $ 350,050,472 - $ 350,050,472 $ 350,050,472 6.17%
19.93% $ 1,131,394,231
Small Rental Program $ 66,686,282 - $ 66,686,282 $ 66,686,282 1.17%
Homebuyer Assistance Program $ 23,688,328 - $ 7,264,351 $ 23,688,328 0.42%
Buyout Program $ 40,800,000 - $ 20,400,000 $ 40,800,000 0.72%
City of Houston Public Public Services $ 60,000,000 - $ 60,000,000 $ 60,000,000 1.06%

Revitalization Economic Revitalization Program $ 30,264,834 - $ 30,264,834 $ 30,264,834 0.53%
City of Houston Planning Houston Planning $ 23,100,000 - N/A $ 23,100,000 0.41%
City of Houston $
$ 0.96%
Administration Houston Administration $ 31,118,976 N/A 0.55% 54,218,976
- 31,118,976
City of Houston Allocation Subtotal (before admin) $ - $ 1,003,745,316 $ 1,244,769,065

244,769,065
City of Houston Allocation Subtotal (after admin) $ 1,275,878,041 - $ 1,003,745,316 $ 1,275,878,041
*This illustrates an estimated LMI amount and may change as applications are accepted.
**
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D. Use of Funds
Program Guidelines: Houston’s Housing and Community Development Department (HCDD)

will develop program guidelines that provide details on eligibility requirements, reporting
requirements, and other program information. All program guidelines will be approved by the
GLO and posted for public comment, before use. These programs will help accomplish actions
set forth in the City’s Analysis of Impediments by preserving and expanding housing and
economic opportunities in Houston. Program guidelines will be developed in ways that will
address fair housing impediments and promote a recovery that is equitable. It is intended that
programs will utilize the program income restrictions as listed in 83 FR 5844 for its programs, as
applicable. Also, under this Federal Register, HUD has waived certain program income
requirements. No applicant can receive more assistance than the cap listed for the program in the
guidelines, and no applicant can receive assistance in excess of the total amount allocated for the
total program.
Affirmative Marketing Outreach Plan: HCDD is committed to AFFH through established

affirmative marketing policies. Affirmative marketing efforts will include an affirmative
marketing plan, based on HUD regulations. The goal is to ensure that outreach and communication
efforts reach eligible homeowners and renters from all racial, ethnic, national origin, religious,
familial status, the disabled, "special needs", and gender groups. The outreach plan will give
detailed information about how the City plans for effective outreach to all groups of homeowners
and renters mentioned above, as well as how the application and enrollment process for programs
will be suitable for persons with limited English proficiency, persons with disabilities, and those
with special needs.
AFFH Review: All proposed housing projects will undergo AFFH review. Such review will
include assessments of a proposed project area’s (1) demography, (2) socioeconomic
characteristics, (3) housing configuration and needs, (4) educational, transportation, and health
care opportunities, (5) environmental hazards or concerns, and (6) all other factors material to the
AFFH determination. Applications should show that projects are likely to lessen area racial, ethnic,
and low-income concentrations, and/or promote affordable housing in low-poverty, nonminority
areas in response to natural hazard-related impacts.
Cost Effectiveness: The City will look at the cost‐effectiveness of each program for an eligible
applicant’s property and determine what options are available to applicants including rehabilitation
with elevation compared to other options such as reconstruction.
Leveraging: The city of Houston intends to leverage CDBG-DR funds with funding provided by
other federal, state, local, and non-profit sources to utilize the limited CDBG-DR funds to the
fullest possible extent to generate a more effective and comprehensive recovery. As applicable,
leveraging requirements may be added to program guidelines, applications, or NOFA/RFPs.
1. Homeowner Assistance Program (HoAP)
HCDD will provide five program options to assist eligible homeowners with their
rehabilitation and reconstruction needs. This includes City Managed Rehabilitation and
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Reconstruction; Reimbursement; Acquisition; Homeowner Managed Rehabilitation; and
Reconstruction; and Interim Mortgage Assistance. The City will select the option(s) available
for each homeowner based on where they are in the recovery process and the condition of their
home. Program options are as follows:
City Managed Rehabilitation and Reconstruction: The City will manage and complete the
construction process for the rehabilitation (including elevation) or reconstruction of damaged
homes on behalf of homeowners. The City will contract with a firm(s) to provide design and
construction services to manage and perform the rehabilitation or reconstruction of damaged
properties. The estimated budget for this option, including project delivery, is $195,943,212
Reimbursement: Homeowners who have completed partial or full repairs on their home before
applying to the program may be eligible for reimbursement of eligible expenses incurred, prior
to application to the program, for work performed to minimum program standards, following
an environmental clearance. Xactimate or a similar industry standard tool will be used to ensure
cost reasonableness and the work will be verified through an on-site inspection by program
staff. The estimated budget for this option, including project delivery, is $164,117,633.
Acquisition: The City may elect to voluntarily acquire single family homes for rehabilitation,
reconstruction, or new construction. The home acquired may then be reconstructed through the
Single Family Development Program or rehabilitated or reconstructed by the City or their
subrecipients. These homes would then be offered for sale to LMI homebuyers or to another
homeowner with a damaged home. Homeowners whose properties are acquired may also be
eligible to participate in the Single Family Development program to purchased a new home.
The estimated budget for this option, including project delivery, is $8,558,001.
Homeowner Managed Rehabilitation and Reconstruction: The City will assist homeowners
to manage their own rehabilitation process (including elevation) and will provide construction
advisory services for these homeowners. Homeowners will select their own licensed and
insured contractor(s) and contract verifications will be performed for all contractors. Xactimate
or a similar industry standard tool will be used to ensure cost reasonableness and the work will
be verified through an on-site inspection by program staff. Homeowner managed
rehabilitation, elevation, and reconstruction will only be available to homeowners who have
initiated the repair process and are under contract with a contractor at the time of application.
Program guidelines will fully address program details, including minimum construction
standards, environmental compliance, program controls, and circumstances under which this
option may be provided. The estimated budget for this option, including project delivery, is
$46,444,217.
As a part of HoAP, the City will provide Interim Mortgage Assistance (IMA) and Temporary
Relocation Assistance (TRA) as additional services to be accompanied by participation in the
City Managed program and the Homeowner Managed program options. The TRA funds are to
assist in easing the temporary displacement burden experienced by homeowners as a result of
construction. TRA funding is included in the budget for HoAP City Managed and Homeowner
Managed options as an eligible activity.
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Interim Mortgage Assistance: Interim Mortgage Assistance may be provided as an additional
service to homeowners determined eligible under the City Managed or the Homeowner
Managed program options. These homeowners may be eligible to receive up to 20 months of
assistance. This option may be considered at the time an applicant is determined eligible for
the rehabilitation or reconstruction of the damaged home. This assistance will help to ease the
financial hardship homeowners may face during the post disaster recovery period and prevent
homeowners from going into foreclosure. Determination of reasonable and necessary award
amounts, including duplication of benefits calculation, retroactive eligibility, and specific
performance milestones for the rehabilitation/reconstruction of homes, will be established in
the program guidelines. The estimated budget for this option, including project delivery, is
$12,837,000.
b. Maximum Assistance: The following outlines the maximum assistance for each option in
HoAP. Applicants can combine some options with other options in HoAP and may also be
eligible for assistance in other programs. No beneficiary can receive more than maximum
for each program or option they participate in.
i. City Managed Rehabilitation and Reconstruction Option: For rehabilitation, the local
composite builder bid amount cannot be greater than $80,000 per unit for
rehabilitation. This exceeds GLO’s amount because it is anticipated that Houston
will have a higher proportion of homeowners with larger homes with higher median
home values, that have remaining unmet need and also have a need for repair and
not reconstruction, compared to other impacted areas in the state. The amount of
reconstruction and repair with elevation costs is the local composite builder bid
amount based on procured builders and the builder’s house plans based on
household size and not greater than $200,000. Additional allocations may be
allowed for improvements, environmental factors, neighborhood requirements,
resiliency measures, and accessibility needs, at the discretion of the City based on
factors outlined in the program guidelines. The maximum amount of assistance per
household for base rehabilitation is $80,000, and the maximum amount for
reconstruction is $200,000. These maximums do not include additional allocations
such as elevation (for rehabilitation only), environmental factors, resiliency
measures, and accessibility needs, all of which are at the discretion of the City based
on factors outlined in the guidelines.
ii. Reimbursement Option: Maximum amount of reimbursement funds for a
household will not exceed $80,000. Additional criteria for maximum amount of
assistance to eligible households based on income is included in the guidelines.
This maximum does not include additional allocations such as elevation (for
rehabilitation only), environmental factors, resiliency measures, and accessibility
needs, all of which are at the discretion of the City based on factors outlined in the
guidelines.
iii. Homeowner Managed Rehabilitation and Reconstruction Option: The Homeowner
Managed Rehabilitation and Reconstruction Option’s maximum assistance is
$80,000 for rehabilitation and $200,000for reconstruction. These maximums do not
include additional allocations such as elevation (for rehabilitation only),
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environmental factors, neighborhood requirements, resiliency measures, and
accessibility needs, at the discretion of the City based on factors outlined in the
guidelines.
iv. Acquisition Option: Eligible acquisition beneficiaries will receive monetary
compensation for properties using post-disaster fair market value. Additional
incentives may be offered to participating applicants. Additional incentives may be
offered to eligible applicants whose homes are acquired. Such incentives may
include, but are not limited to, Relocation Assistance, Enhanced Buyout Area
Relocations, and others, as applicable, to be determined upon creation of the
program Standard Operating Procedures. The maximum amount of assistance is
$200,000.
v. Interim Mortgage Assistance: This assistance may be available to applicants who
are determined eligible to participate in the City Managed Rehabilitation and
Reconstruction Option and Homeowner Managed Rehabilitation and
Reconstruction Option. Homeowners may be eligible to receive up to 20 months of
assistance to pay their mortgage on the Harvey-damaged home.
c. Eligible Activities: Housing activities allowed under CDBG-DR; HCDA Section

105(a)(1), 105(a)(3-4), 105(a)(8) 105(a)(11), 105(a)(18), and 105(a)(25), 24 CFR
570.201(g) including but are not limited to:
i. Single family owner-occupied rehabilitation and reconstruction
ii. Hazard mitigation
iii. Relocation assistance
iv. Demolition only
v. Other activities associated with the recovery of impacted single family
housing stock
vi. Payment of non-federal share
A waiver eligible under 83 FR 5844 permits housing incentives and other requirements
for one-for-one replacement housing, relocation, and real property acquisition
requirements. A modification to the limitation on emergency grant payments for interim
mortgage assistance will also be used as stated in the same Federal Register.
i. Forced mortgage payoff
ii. Incentive payments to households that move to disaster-impacted floodplains
iii. Properties that served as second homes at the time of the disaster, or following
the disaster, are not eligible for rehabilitation assistance or housing incentives
iv. Rehabilitation/reconstruction of homes located in the floodway
v. Rehabilitation/reconstruction of a home where:
1. the combined household income is greater than 120 percent AMI or
the national median, and
2. the property was located in a floodplain at the time of the disaster, and
3. the property owner did not maintain flood insurance on the damaged property,
insurance.
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vi. Assistance for the repair, replacement, or restoration of a property to a person who
has failed to meet Section 582 of the National Flood Insurance Reform Act of
1994, as amended, (42 U.S.C. 5154a), which states that no Federal disaster relief
assistance made available in a flood disaster area may be used to make a payment
(including any loan assistance payment) to a person for ‘‘repair, replacement, or
restoration’’ for damage to any personal, residential, or commercial property if
that person at any time has received Federal flood disaster assistance that was
conditional on the person first having obtained flood insurance under applicable
Federal law and the person has subsequently failed to obtain and maintain flood
e. Eligibility Criteria for Assistance:

Property
i. Not located in a floodway
ii. Owner-occupied at the time of the storm
iii. Served as homeowner’s primary residence
iv. Sustained damage from Hurricane Harvey
v. Environmentally cleared
vi. Costs for rehabilitation, reconstruction, and new construction are reasonable and
consistent with market costs at the time and place of construction;
Homeowner
i. All homeowner applicants and co-applicants must be current on payments for child
support or under an approved payment plan.
ii. Homeowner applicants must furnish evidence that property taxes are current,
under an approved payment plan, or that they have an exemption under current
laws.
iii. Homeowner applicants must agree to a limited subrogation of any future awards
related to Hurricane Harvey, to ensure duplication of benefits compliance.
iv. Assistance will be provided in the form of a grant or zero-interest forgivable loan.
Homeowner applicants are required to maintain principal residency in the assisted
property throughout the length of the lien period. Cash-out refinancing, home
equity loans, or any loans utilizing the assisted property as collateral must be
approved during the compliance period, and considerations for this are in the
program guidelines. A violation of this policy will activate the loan repayment
terms.
v. Homeowner applicants must agree to lien requirements, as applicable. The lien
period for homes will be based on the amount of assistance provided (not
including the additional allocations allowed for improvements):
For Rehabilitation
a. No lien for assistance less than $20,000*.
b. 5-year lien period for $20,000 to $40,000 of assistance*.
c. 10-year lien period for $40,001 to $80,000 of assistance*.
*Assistance to determine lien period does not include additional site-specific
allocation
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For Reconstruction
a. 20-year lien period for reconstruction; for reconstruction requiring $80,000 or
less in assistance (excluding site-specific allocations), the lien period shall be
10 years.
The lien on the property will be removed upon completion with the terms and
conditions of all documents related to the program and completion of the lien
period. Should the homeowner sell or otherwise convey their ownership interest
in the property during the lien period, the remaining prorated amount of assistance
will become immediately due and payable.
vi. Homeowner applicants must maintain required insurance for the assisted
property.
vii. Where disaster assistance triggers the flood insurance purchase requirement,
assisted homeowners will notify any transferee of the requirement to obtain and
maintain flood insurance, in writing, and to maintain such written notification in
the documents evidencing the transfer of the property, and that the transferring
owner may be liable, if he or she fails to do so.
viii. Additional eligibility criteria for each option is included in the guidelines. The
homeowner may be eligible for multiple options, and in some circumstances, a
homeowner may combine options. Exclusions in the combination of options will
ensure that benefits do not overlap.
f. Selection Criteria: Funding priorities have been established to assist vulnerable

populations and low- and moderate-income households. The applicant prioritization
sequence for funding is based on the following criteria.
i. Elderly (62 years or older) or disabled households at or below 80 percent AMI
ii. Households at or below 80 percent AMI with children
iii. Households at or below 50 percent AMI
iv. Households at or below 80 percent AMI
The remainder of the funding will be provided on a first-come, first-served basis.
g. Award Methodology: The City will assist homeowners in identifying the best option to
meet their needs based on their eligibility for each option, the condition of their home,
and where they are in the recovery process. After the City has made its eligibility
determination for each option for each applicant, a case manager will work with the applicant
to explain the options they can choose from, if eligible for multiple options.
h. National Objectives: LMI benefit; Urgent need.
i. Timeframe: The proposed program start date is immediately after HUD’s approval of this
action plan amendment. The proposed end date is 5 years from the program start date.
2. Single Family Development Program
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The devastation to the City of Houston’s housing stock resulting from Hurricane Harvey
included an unprecedented number of flooded homes. Many of these homes were destroyed or
remain uninhabitable. This has forced many residents to relocate either temporarily or
permanently. Even before this disaster, many communities had vacant lots in need of infill
development. New construction of single family homes will help restore neighborhoods
impacted by the storm and improve neighborhoods in need of new, infill development.
The Single Family Development Program will provide new affordable single family homes for
LMI homebuyers. HCDD will work with for-profit and non-profit contractors and
organizations to implement the program. Properties or lots for new construction will be
identified from a variety of sources, including the Houston Land Bank, HCDD’s Homeowner
Assistance Program, and other organizations that have existing land available.
HCDD will enforce recapture provisions through a lien should a homeowner convey their
ownership interest in the property during the compliance period, except in the event of a
homeowner death where a low-income heir may assume the remaining lien and compliance
period.
The lien period for homes purchased will be based on the amount of assistance provided (not
including additional allocations for site-specific conditions):
 a 5-year lien period for assistance less than $40,000
 a 10-year lien period for $40,000 to $80,000 of assistance
 a 20-year lien period for assistance greater than $80,000.
The assistance is provided in the form of a zero-interest forgivable loan, secured by a lien.
Forgiveness of the loan provided will be prorated over the course of the lien period. The lien
on the property will be removed upon completion with the terms and conditions of all
documents related to the program and completion of the lien period. Should the Homeowner
sell or otherwise convey their ownership interest in the property during the lien period the
remaining prorated amount of assistance will be recaptured and become immediately due and
payable.
This program will give opportunity to residents to move out of areas that are prone to repetitive
flooding. It will also give homeowners that need substantial repairs or reconstruction the
immediate opportunity to move to a new home offered for sale through this program. This
program will work in conjunction with other recovery programs to provide housing options for
those directly impacted by Hurricane Harvey and those indirectly impacted due to the resulting
shortage of available housing.
b. Maximum Award:
The construction cost is limited to $200,000 per home, however additional allocations, above
the $200,000 threshold may be provided to address certain site-specific conditions including
accessibility needs environmental issues, resiliency/mitigation measures, municipal
ordinances, and neighborhood requirements. Additional allocations may be allowed based on
the submitted application, onsite inspection and additional requirements that will be outlined
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in the Standard Operating Procedure. The City will work with applicants who require ADA
accommodations to select properties that satisfy their ADA needs; and/or will incorporate
ADA construction for new homes built on empty lots. The maximum award of assistance was
estimated utilizing information from existing repair and reconstruction programs.
c. Eligible Activity: New construction is eligible based on information provided in the

Federal Register waiving the requirements of 42 U.S.C.(a) HCDA Section 105 (a)(1),
105(a)(4), 105(a)(7-8), 105(a)(11), 105(a)(14-15); A waiver eligible under 83 FR 5844
permits new housing construction.
d. Ineligible Activity: Properties to be developed cannot be in a floodway or Special Flood

Hazard Area
e. National Objective: LMI benefit
f. Selection Criteria:
Properties
HCDD may consider eligible properties owned by the City of Houston including those
acquired through the HoAP Acquisition option, the Land Assemblage Redevelopment
Authority (dba the Houston Land Bank), or other partners for new home construction.
Construction will be prioritized to areas that are not at risk of future flooding and that do
not pose a current or future environmental hazard. Additional program details, including
any targeted areas, will be identified in the program guidelines.
Beneficiaries
The beneficiaries of this Program will be LMI households. The applicant prioritization
sequence for funding is based on the following criteria:
1. Applicants that participated in either the HoAP Acquisition option or the Housing
Buyout Program;
2. Applicants living in the floodway; and
3. Applicants living outside the floodway and have a home that is deemed infeasible
for reconstruction at the site of the Harvey damaged property.
The remaining applicants will be served on a first-come, first-served basis. The City or its
subrecipient will retain ownership until the applicant is transferred the title.
g. Timeframe: The proposed program start date is immediately after HUD’s approval of this
3. Multifamily Rental Program
This program will address both direct and indirect impacts of Hurricane Harvey on Houston’s
affordable rental housing stock. The shortage of affordable rental housing units available to
meet the needs of renters in Houston was exacerbated by Hurricane Harvey. The development
of new multifamily rental housing, the acquisition and/or rehabilitation of flood-damaged
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multifamily rental housing, and strategic land acquisition for multifamily development aims to
address this shortage and meet the needs of disaster impacted rental households, including
those in public housing. This program will also provide housing designed to meet the needs of
special populations.
b. Maximum Award: $40,000,000 per development
c. Eligible Applicants: Acting individually or as participants in a LP or LLC:

i. For-profit developers/borrowers
ii. Public housing authorities – HCHA and HHA
iii. Not-for-profit developers/borrowers
iv. Units of general local government
d. Eligible Activity: Rehabilitation, Reconstruction, New Construction, and Acquisition.

HCDA Section 105 (a)(1), 105(a)(3-4), 105(a)(7-8), 105(a)(11), and 105(a)(14-15). A
waiver eligible under 83 FR 5844 permits new housing construction.
i. Project must meet CDBG-DR eligibility requirements
ii. Development must be located within the city limits of Houston, except in certain
cases where the City and County partner on projects that provide housing
iii. At a minimum, 51 percent of the units rehabilitated or developed will be reserved
under a lien period for LMI households earning 80 percent or less of the AMFI at
affordable rents. For rehabilitation, the lien period will be a minimum of 15 years;
and for reconstruction or new construction, the lien period will be a minimum of
20 years.
iv. Lien periods will be established and affordable rents with the Low-Income Housing
Credit rent limits, 26 U.S. Code § 42 (g)(2)(a), and other existing Land Use
Restriction Agreement (LURA) restrictions, as applicable. Housing Tax Credit
(HTC) rent limits will be used to identify rents for target AMFI levels to align with
the Local Needs Assessment.
v. Any substantial rehabilitation, as defined by 24 CFR 5.100, or new construction of
a building with more than four rental units will include installation of broadband
infrastructure, as required.
vi. Projects with eight (8) or more units must ensure construction costs are reasonable
and consistent with market costs at the time and place of construction;
vii. Property owners receiving disaster assistance that triggers the flood insurance
viii. Section 582 of the National Flood Insurance Reform Act of 1994, as amended, (42
general, it provides that no Federal disaster relief assistance in a flood disaster area
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may be used to make a payment (including any loan assistance payment) to a person
for ‘‘repair, replacement, or restoration’’ for damage to any personal, residential, or
commercial property if that person at any time has received Federal flood disaster
assistance that was conditioned on the person first having obtained flood insurance
under applicable Federal law and the person has subsequently failed to obtain and
maintain flood insurance as required under applicable Federal law on such property.
No disaster assistance may be provided for the repair, replacement, or restoration of
a property to a person who has failed to meet this requirement.
f. Selection Criteria: The selection criteria will likely include, but is not limited to, the
following:
a. Housing types
b. Organizational experience
c. Project location information
d. Neighborhood, development and site amenities
e. Financial analysis
Applications or proposals providing housing to certain populations, including but not

limited to permanent supportive housing, Section 811, previously homeless persons, or
extremely low-income households, will be prioritized.
g. National Objective: LMI benefit
h. Property Types: Multifamily rental housing of eight or more rental units under common
ownership.
i. Project Selection: Projects will be selected through an application or NOFA/RFP process.

The application or NOFA/RFP will clearly establish the process and acceptance period,
threshold criteria (including applicable building codes), selection criteria, and the award
process. Selected projects must be completed within 18 months of the effective date of the
contract, unless otherwise extended by Houston. Additional project selection criteria and
process information will be established in the program guidelines. To address the unmet
public housing needs, there will be an application process for the Houston Housing
Authority. This process is addressed in the multifamily guidelines with further information
about the subrecipient agreement.
j. Timeframe: The proposed program start date is immediately after HUD’s approval of this
4. Small Rental Program
The Small Rental Program aims to rebuild the affordable rental housing stock by rehabilitating
small rental properties (1 – 7 units) and to create new housing stock, through infill development
of new small rental properties, to meet the increased demand for this type of rental housing in
Houston. This program provides financial assistance, through forgivable loans, to small rental
property owners and developers who serve a low- to moderate-income market. This program
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will assist in expanding the affordable rental housing options, while also stimulating economic
growth by assisting landlords and creating jobs in the housing rehabilitation and construction
sectors.
Program may include assistance to property owners for the following that will meet eligible
CDBG activities:
1. Repair, rehabilitation, or reconstruction of damaged properties
2. Reconstruction or conversion of non-disaster damaged property to meet the needs of
renters impacted by the affordable rental housing shortage exacerbated by Hurricane
Harvey
3. New construction of small rental properties
4. Housing for special populations
5. Resilience measures
Awards for property owners will be based on multiple factors which may include the number
of units, size of property, and overall construction need, as well as the benefits received from
insurance and other sources. Prioritization criteria may include the prioritization of projects
based on length of lien periods, green building and/or energy star rated units, visitability,
American Disabilities Act/Section 504, mitigation measures, and others. The program
guidelines will detail award factors, selection criteria, award calculation/determination
methods, construction standards, quality assurance / quality control functions, appeals and
grievance processes, LMI occupancy requirements, land use restrictions, program compliance,
and monitoring, and other program components.
b. Maximum Award: $3,500,000 per development
c. Eligible Applicants: Property owners acting individually or as participants in LP or LLC:

i. For-profit developers/ borrowers
ii. Public housing authorities
iii. Units of local governments
iv. Not-for-profit developers/ borrowers
d. Eligible Activity: Rehabilitation, Reconstruction, New Construction, and Acquisition

HCDA Section 105 (a)(1), 105(a)(3-4), 105(a)(7-8), 105(a)(11), and 105(a)(14-15). A
waiver eligible under 83 FR 5844 permits new housing construction.
Property owner applicants must
i. Provide proof that
1. Property taxes are current,
2. They have an approved payment plan, or
3. There is an approved property tax exemption in place
ii. Agree to a limited subrogation of any future awards related to Hurricane Harvey
according to duplication of benefits requirements
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iii. Agree to lien period and lien requirements
Property must:
i. Not be in a floodway
ii. Have an environmental clearance
Development:
i. Must meet CDBG-DR eligibility requirements
ii. Must be located within the city limits of Houston, except in certain cases where the
City and County partner on projects that provide housing
iii. At a minimum, 51 percent of the contiguous units rehabilitated or developed may
be reserved for a lien period for LMI households earning 80 percent or less of the
AMFI at affordable rents. Below are the required lien periods, as applicable, which
will maintain affordability for LMI households.
For Rehabilitation:
a) No lien for assistance less than $20,000 per unit*.
b) 5-year lien period for $20,000 to $40,000 of assistance per unit*.
c) 10-year lien period for $40,001 to $80,000 of assistance per unit*.
*Assistance to determine lien period does not include additional site-specific
allocations.
For Reconstruction and New Construction

a. 20-year lien period for new construction and reconstruction requiring above
$80,000 in assistance per unit (excluding site-specific allocations); for
reconstruction requiring $80,000 or less in assistance per unit (excluding site-
specific allocations), the lien period shall be 10 years.
If a single family unit is rehabilitated or developed, it must be reserved for LMI

households. At least two units in a duplex or triplex must be reserved for LMI
households.
iv. Any substantial rehabilitation, as defined by 24 CFR 5.100, or new construction of

a building with more than four rental units will include installation of broadband
infrastructure, as required. Developments may include more than one property,
such as with a scattered site rental development.
v. Property owners receiving disaster assistance that triggers the flood insurance
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vii. Applicable elevation requirements will apply to development and rehabilitation.
f. National Objective: LMI benefit
g. Property Types: Small rental properties of one to seven rental units under common
ownership.
h. Project Selection: Projects will be selected through an application or NOFA/RFP

process. The application or NOFA/RFP will clearly establish the process and acceptance
period, threshold criteria (including applicable building codes), selection criteria, and the
award process. Selected projects must be completed within 18 months of the effective
date of the contract, unless otherwise extended by GLO. Project selection criteria and
process information will be established in the program guidelines. The selection criteria
will likely include, but is not limited to, the following:
a. Housing types
b. Organizational experience
c. Project location information
d. Financial analysis
For new construction, applications or proposals providing housing to certain populations,

including but not limited to permanent supportive housing, Section 811, previously
homeless persons, or extremely low-income households, will be prioritized.
i. Timeframe: The proposed program start date is immediately after HUD’s approval of this
5. Homebuyer Assistance Program
The Homebuyer Assistance Program will provide funds for down payment, closing cost,
principal buydown, and other direct financial assistance to homebuyers to finance the purchase
of a home. This program will help improve homeownership affordability for residents. The
Homebuyer Assistance Program will prioritize households that were impacted by Hurricane
Harvey to facilitate the movement of LMI households into new homes after their homes were
damaged by Hurricane Harvey.
The Homebuyer Assistance Program may provide down payment and closing cost assistance
to eligible households earning up to 120 percent of AMI. Direct homeownership assistance
under 570.201(n) allows the City to pay up to 100 percent of the down payment amount
required by the lender. The City may also utilize other forms of direct homebuyer assistance
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such as subsidizing interest rates and mortgage principal amounts, including making grants to
reduce the effective interest rate on the amount needed by the eligible household to achieve an
affordable mortgage payment level. Primarily, the City will provide direct financial assistance
in the form of forgivable loans. The lien period for homes purchased will have a minimum of
five (5) years. The lien on the property will be removed upon completion with the terms and
conditions of all documents related to the program and completion of the lien period. Should
the Homeowner sell or otherwise convey their ownership interest in the property during the
lien period the remaining prorated amount of assistance will become immediately due and
payable.
b. Maximum Award: $30,000 per unit
c. Eligible Activity: This activity is eligible for CDBG-DR funds as listed in 24 CFR
570.201(n) and HCDA section 105(a)(24); A waiver eligible under 83 FR 5844 permits
Homeownership assistance for households earning up to 120 percent AMI and
downpayment assistance for up to 100 percent of the down payment.
d. Eligible Applicants: The criteria for establishing eligibility of applicants for assistance
through this program are as follows.
The applicant must:
i. Meet income eligibility requirements (up to 120 percent of AMI)
ii. Agree to lien period and/or lien requirements
e. Applicant Selection: Eligible applicants will be households earning 120 percent AMI or
below. Applicants that have been impacted by Hurricane Harvey will receive priority
and the remainder will be prioritized first come, first served.
f. National Objective: LMI benefit; Urgent need
g. Timeframe: The proposed program start date is immediately after HUD’s approval of
this action plan amendment. The proposed end date is 5 years from the program start
date.
6. Buyout Program
Many homes have flooded repeatedly since 2015, highlighting a need for a more permanent
solution for some residents. Through this program, the City or a subrecipient will purchase
residential structures that have flooded and demolish them to create park amenities, open space,
or detention areas. This voluntary program is intended to assist residents to move out of areas
that have been impacted by multiple disasters or are at high risk of flooding from future
disasters. This program is also intended to reduce the impact of future disasters, while
encouraging targeted revitalization efforts and the creation of open space.
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HCDD may work with subrecipients, such as the HCFCD or other City Departments, to
implement this program. If a subrecipient is selected, the City will work with the subrecipient
to choose buyout project locations. Buyouts under this program may be part of a larger City or
County buyout strategy, in accordance with a long-term plan for the property to become future
open space or detention, to avoid removing a viable property from the housing market. It may
include the buyout of impacted single and multifamily housing. Buyout property will be
maintained in perpetuity as greenspace, as applicable to buyouts.
b. Maximum Assistance: Maximum assistance provided to each property will be $250,000

for buyout assistance including incentives/moving and settlement costs and other eligible
project costs. The post-disaster fair market value, less any duplication of benefits, will be
used. The housing supplement will not exceed $31,000 and may include a price differential
payment and incidentals of replacement housing such as loan applications and some
closing costs, and the rental supplement will not exceed $7,200 to include rent differential
higher cost replacement dwellings.
c. Eligible Activities: This activity is eligible for funds as listed in HCDA section
105(a)(1), 105(a)(7-9) 105(a)(24-25), 5305(a)(8), 24 CFR 570.20(b)(4);24 CFR
570.201(g) including but are not limited to:
i. Buyouts
ii. Demolition
iii. Relocation Assistance
iv. Payment of Non-Federal Share
v. Housing incentives
A waiver eligible under 83 FR 5844 permits housing incentives and other requirements
for one-for-one replacement housing, relocation, and real property acquisition
requirements.
iii. Properties that served as second homes at the time of the disaster, or following
the disaster, are not eligible for rehabilitation assistance or housing incentives;
iv. Assistance for the repair, replacement, or restoration of a property to a person who
has failed to meet Section 582 of the National Flood Insurance Reform Act of
1994, as amended, (42 U.S.C. 5154a), which states that no Federal disaster relief
assistance made available in a flood disaster area may be used to make a payment
(including any loan assistance payment) to a person for ‘‘repair, replacement, or
restoration’’ for damage to any personal, residential, or commercial property if
that person at any time has received Federal flood disaster assistance that was
conditional on the person first having obtained flood insurance under applicable
Federal law and the person has subsequently failed to obtain and maintain flood
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e. Eligibility Criteria for Assistance:
Residential Structures
Homeowner Property
i. Owner-occupied at the time of the storm
ii. Served as homeowner’s primary residence
iii. Sustained damage from Hurricane Harvey
iv. Environmentally cleared
v. Located in DRRA or floodplain
Rental Property
i. Renter-occupied at the time of the storm
ii. Sustained damage from Hurricane Harvey
iii. Environmentally cleared
iv. Located in DRRA or floodplain
Homeowner
i. All homeowner applicants and co-applicants must be current on payments for child
support or under an approved payment plan.
ii. Homeowner applicants must furnish evidence that property taxes are current,
under an approved payment plan, or that they have an exemption under current
laws.
iii. Homeowner applicants must agree to a limited subrogation of any future awards
related to Hurricane Harvey, to ensure duplication of benefits compliance.
Rental Property Owner

i. Rental Property owners must furnish evidence that property taxes are current,
they are under an approved payment plan, or that they have an exemption under
current laws.
f. Program guidelines will detail applicant or project eligibility requirements, application

process, compliance with URA regulations, and other information.
g. National Objective: LMI benefit; Urgent need
h. Timeframe: The proposed program start date is immediately after HUD’s approval of
this action plan amendment. The proposed end date is 5 years from the program start
date.
7. Public Services
Houstonians were impacted by Hurricane Harvey in many ways. Physical property was
damaged, homes were flooded, and personal possessions were lost. The lingering effects of
this damage has impacted resident’s physical and mental health. In addition, vulnerable
populations are often less able to recover from disaster impacts, which could directly affect
their job prospects and housing options.
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Public services offered will provide a comprehensive approach to recovery for Houstonians.
These services will support residents to find housing, remedy housing issues, or to become
more resilient in future disasters, whether they be natural, economic, or personal, creating a
stronger more prepared community. Services will be made accessible to individuals with wide-
ranging disabilities through varying outreach strategies, partnerships with organizations
serving people with disabilities, and making accommodations, as needed.
Services may include housing counseling, legal assistance, transportation services, fair housing
services, health/mental health services, employment training, workforce development, and
other services to address the needs of those impacted by Hurricane Harvey. Housing
counseling and legal assistance services will assist in furthering fair housing by addressing
housing barriers and allowing residents greater choice to move to neighborhoods with higher
opportunity. Employment training and workforce development programs, including those that
support housing recovery and housing construction, will address the need for job skills to
support Houston’s recovery. In addition, workforce development will help boost long-term
recovery by supplying residents of impacted communities with the necessary skills and
opportunities to increase household income. To address the needs of those impacted who have
become homeless or are at risk of becoming homeless, services may include case management,
and other services to assist in housing and/or rehousing this population.
The provision of public services is also intended to assist residents in preparing and qualifying
for housing programs. Remedying title or tax issues through legal services and providing
housing counseling for LMI communities may prepare more residents to become eligible for
programs such as HCDD’s Homeowner Assistance and Homebuyer Assistance Programs.
b. Maximum Award: $5,000,000 per contract
c. National Objective: LMI benefit
d. Eligible Activity: Eligible activities include the provision of public services as listed in
HCDA Sec. 105(a)(8)
e. Eligible Applicants: Subrecipients will be determined through an application or

NOFA/RFP process and will include non-profit agencies. Houstonians will receive
assistance directly through the selected subrecipients. These subrecipients will ensure
services are open to all residents, including those with limited English proficiency or other
special needs populations.
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f. Selection Criteria: Projects and subrecipients will be selected through an application or
NOFA/RFP process. The application or NOFA/RFP will clearly establish the process and
acceptance period, threshold criteria, selection criteria, and the award process. Selection
criteria and any prioritization of impacted households will be established in the Public
Services guidelines, NOFA/RFP, or application. Selection criteria will likely include: the
activity and need, cost reasonableness and effectiveness, activity management and
implementation, and experience/past performance.
g. Through the selected subrecipients, public services will be provided to primarily LMI
persons or persons in LMI areas. This may include those that need public services to assist
them in accessing housing programs or becoming eligible for housing programs. Receiving
public services offered is not contingent upon also receiving services through the housing
programs offered.
h. Timeframe: The proposed start date or public services is immediately after HUD’s
approval of this action plan amendment. The proposed end date is 5 years from the
public services start date.
8. Economic Revitalization Program
This Economic Revitalization Program will help create jobs that will improve the economic
viability of areas impacted by Hurricane Harvey. Many small businesses were impacted,
resulting in lost earnings. This has direct implication for a household’s ability to pay for
housing, especially for the 0-30 percent AMI household members who may become homeless
when a household member losses employment.
This program will assist in creating and retaining jobs in the community by providing capital,
credit, and technical assistance to businesses, including microenterprises. Assistance may be
provided through loans or grants, and assistance may be part of a revolving loan fund. It is
intended that this program will support small businesses that include, but is not limited to,
those providing housing construction services, to work with and complement the housing
programs funded with CDBG-DR funds. Economic revitalization activities must contribute to
the long-term recovery and restoration of housing.
b. Maximum Award: $10,000,000 per subrecipient; the maximum assistance is $250,000 per
business
c. National Objective: LMI benefit; Elimination of slum/blight; Urgent Need
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d. Eligible Activity: This activity is eligible for funds as listed in HCDA section 105(a)(17),
105(a)(19), 105(a)(22); a waiver eligible under 83 FR 5844 permits other national objective
documentation and public benefit standards. Cost verification controls must be in place to
assure that construction costs are reasonable and consistent with market costs at the time
and place of construction. Any projects funding for-profit entities must be evaluated and
selected in accordance with guidelines (established in Appendix A to 24 CFR part 570)
developed by HUD and comply with HUD underwriting guidance.
e. Eligible Applicants: Subrecipients will be determined through an application or

NOFA/RFP process and may include nonprofit and for-profit agencies. The application or
NOFA/RFP will clearly establish the process and acceptance period, threshold criteria,
selection criteria, and the award process. Selection criteria will likely include: the need for
program, cost reasonableness and effectiveness, activity management and implementation,
and experience/past performance. Houstonians and businesses will receive assistance
directly through the selected subrecipients. Eligible subrecipients include public or private
nonprofit agencies, authorities, or organizations and for-profit organizations.
f. Timeframe: The proposed program start date is immediately after HUD’s approval of
this Action Plan. The proposed end date is 5 years from the program start date.
9. Planning
Funding will be used for planning activities that will benefit the most impacted and distressed
areas. Vulnerable populations or neighborhoods often struggle to bounce back from disasters.
Planning activities will be focused on various mitigation and resiliency efforts to protect
Houstonians and help them recover from disasters.
Planning activities will include community engagement to inform the City’s recovery plan
development and to support various city-wide housing activities. The City may also use these
funds to study specific topics related to mitigation or resilience or plan for specific projects
that could address impacts of Hurricane Harvey or the recurring nature of disasters in Houston.
The types of studies or plans could include flood control, drainage improvement, resilient
housing solutions, fair housing, homelessness, surge protection, economic development,
infrastructure improvements, or other efforts to further recovery from Hurricane Harvey,
mitigate future damages, and establish plans for comprehensive recovery efforts. The City may
work with other local jurisdictions on various types of planning projects.
Planning activities will strive to promote sound, sustainable long-term recovery planning
informed by a post-disaster evaluation of hazard risk, especially land-use decisions that reflect
responsible flood plain management and take into account future possible extreme weather
events and other natural hazards and long-term risks.
The GLO has limited Houston’s planning costs to 5 percent of its allocation. The City of
Houston will administer these funds as a subrecipient of the GLO. Further amendments may
convert a portion of these planning funds to other eligible expenses to execute specific projects,
which may have been studied or developed through the planning process.
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b. Eligible Activities: The eligible activity is planning, urban environmental design, and
policy-planning-management-capacity building activities as listed in 24 CFR 570.205.
c. Selection Criteria: Projects and/or subrecipients will be selected through an application,

NOFA/RFP, or other competitive process. The application or NOFA/RFP will clearly
establish the process and acceptance period, threshold criteria, selection criteria, and the
award process. Selection criteria will be established in the application, NOFA/RFP or a
competitive process and will likely include planning activity/project description,
organizational experience, cost reasonableness and effectiveness, and management of
activity/project. Priorities for activities include those that deepen the understanding of
housing issues in Houston, evaluate impact of funding, and support the development of
required HUD documents.
d. Timeframe: The proposed program start date is immediately after HUD’s approval of this
10. Administration
The GLO will retain the full 5 percent allocated for administrative costs associated with
CDBG-DR17 for purposes of oversight, management, and reporting. The only exception is for
an allowance for up to 2.5 percent of the City’s program amounts for administrative costs.
Houston plans to budget the full 2.5 percent for administrative costs allowed by the GLO for
program administrative costs as listed in 24 CFR 570.206.
b. Caps: The GLO will allow the City to spend up to 10 percent of program amounts for costs
directly related to implementation of housing activities and 6 percent for non-housing and
infrastructure activities. The GLO has capped engineering and design activities at 15
percent of the total project award, unless special services are necessary, subject to GLO
approval. These activity delivery costs will be defined in the City’s applications to the GLO
for individual programs and projects, as needed.
c. Timeframe: The proposed program start date is immediately after HUD’s approval of this
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6.1. Citizen Participation – State Action Plan
The primary goal of this plan is to provide Texans with definitive opportunities to involve
themselves in the recovery process as it pertains to CDBG-DR funds. The Texas GLO is acutely
aware of the hardships many are faced with in the wake of Hurricane Harvey and strives to provide
an ease of access to vulnerable populations struggling to recover.
The GLO’s Community Development and Revitalization Division (CDR) citizen participation
plan for the Hurricane Harvey allocation was developed based on the requirements outlined in
HUD Federal Register Notice, Vol. 83, No. 28, FridayTuesday, February 9, 2018 and Vol. 83, No.
157, Tuesday, August 14, 2018.
According to the Notice, “To permit a more streamlined process, and ensure disaster recovery
grants are awarded in a timely manner, provisions of 42 U.S.C. 5304(a)(2) and (3), 42 U.S.C.
12707, 24 CFR 570.486, 24 CFR 1003.604, and 24 CFR 91.115(b) and (c), with respect to citizen
participation requirements, are waived and replaced by the requirements below. The streamlined
requirements do not mandate public hearings but do require the grantee to provide a reasonable
opportunity (at least 30 days) for citizen comment and ongoing citizen access to information about
the use of grant funds.”
The most current version of the Texas GLO’s Citizen Participation Plan for Hurricane Harvey will
be placed on the website at recovery.texas.gov.
The State of Texas Action Plan for Hurricane Harvey, and any following amendments
outline the major damages from Hurricane Harvey and unmet needs within the recovery
process. The Action Plan outlines the eligible use of CDBG-DR funds, and specific programs
that will be allowable by the GLO.
A. Publication
Before the GLO adopts the Action Plan for this grant or any substantial amendment to this
grant, the GLO will publish the proposed plan or amendment on
http://recovery.texas.gov/individuals/state-action-plans/hurricane-harvey/index.html or
http://recovery.texas.gov/local-government/hud-requirements-reports/hurricane-
harvey/index.html, the GLO’s recovery websites and will cross-reference with additional
agency websites:
The GLO and/or subrecipients will notify affected citizens through electronic mailings, press
releases, statements by public officials, media advertisements, public service
announcements, newsletters, contacts with neighborhood organizations, and/or through
social media.
The GLO will ensure that all citizens have equal access to information about the programs,
including persons with disabilities and limited English proficiency (LEP). The GLO will
ensure that program information is available in the appropriate languages for the geographic
area served by the jurisdiction. For assistance, in ensuring that this information is available
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to LEP populations, recipients should consult the Final Guidance to Federal Financial
Assistance Recipients Regarding Title VI, Prohibition Against National Origin Discrimination
Affecting Limited English Proficient Persons, published on January 22, 2007, in the Federal
Register (72 FR 2732).
The Action Plan in its entirety will be translated to Spanish, Vietnamese, Chinese, Urdu, and
Arabic. The languages selected were selected based on the entire eligible area of the CDBG-DR
funds and a natural break in the numbers of Limited English Proficiency individuals. Recognizing
there may be a need for individuals to have access to the document in additional languages the
GLO will be contracting with a translation service to provide personalized translations of the
Action Plan upon request. Any public places that work directly in programs available to private
individuals will carry signage detailing this service in applicable languages. The GLO website
will include similar notations.
Subsequent to publication of the action plan or substantial amendment, the GLO will provide a
reasonable opportunity of at least 30 days and have a method(s) for receiving comments. Citizens
with disabilities or those who need technical assistance can contact the GLO office for assistance,
either via: TDD 512-463-5330 or TX Relay Service 7-1-1.
The GLO will take comments via USPS mail, fax, email, or through the GLO’s website:
Texas General Land Office

Community Development and Revitalization
P.O. Box 12873
Austin, TX 78711-2873
Fax: 512-475-5150
Email: cdr@recovery.texas.gov
In the Action Plan, the GLO will specify criteria for determining what changes in the GLO's
plan constitute a substantial amendment to the plan. At a minimum, the following
modifications will constitute a substantial amendment: a change in program benefit or
eligibility criteria, the addition or deletion of an activity, or the allocation or reallocation of a
monetary threshold specified by the GLO in the action plan.
B. Consideration of Public Comments
The GLO will consider all written comments regarding the Action Plan or any substantial
amendment. A summary of the comments and the GLO's response to each located in the
Appendix section will be submitted to HUD with the Action Plan or substantial amendment.
C. Citizen Complaints
The GLO will provide a timely written response to every citizen complaint. The response will be
provided within fifteen (15) working days of the receipt of the complaint, when practicable.
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D. Substantial Amendment
As additional information and funding becomes available through the grant administration process,
amendments to this Action Plan are expected. Prior to adopting any substantial amendment to this
Action Plan, the GLO will publish the proposed plan or amendment on the GLO’s recovery website
and will afford citizens, affected local governments, and other interested parties a reasonable
opportunity to examine the plan or amendment’s contents. At a minimum, the following
modifications will constitute a substantial amendment:
 A change in program benefit or eligibility criteria;

 The allocation or reallocation of more than $5 million; or
 The addition or deletion of an activity.
E. Non-substantial Amendment
The GLO will notify HUD when it makes any plan amendment that is not substantial. HUD will
be notified at least five (5) business days before the amendment becomes effective. HUD will
acknowledge receipt of the notification of non-substantial amendments via email within five (5)
business days.
F. Community Consultation
Before Hurricane Harvey made impact on the Texas Coast, the GLO took measures to email local
officials potentially in the path of disaster, reminding them of the steps that they could take to help
insure an effective recovery, if needed. Since then, the GLO has continued its efforts to elicit
feedback from local officials and interested parties through meetings, conference calls and frequent
trips to impacted communities. These trips have included public forums and meetings with elected
officials, including local, state and federal partners.
Since mid-November, the GLO has held weekly conference calls with local elected officials to
provide updates on recovery efforts following Hurricane Harvey. Calls included time for
participants to ask critical questions pertaining to the overall recovery and their community.
Beginning in February the GLO transitioned to bi-monthly calls, but may increase the frequency
if requested by local officials.
In partnership with HUD, the GLO has been conducting “Strike Team Meetings” to allow local
officials the opportunity to ask specific questions and bring potential projects to state and federal
agencies in an effort to find the best coordinated recovery for individual communities. The intent
is to conduct a strike team meeting with every county in the impacted region.
The GLO has participated in meetings with the Governor’s Commission to Rebuild Texas, Strike
Team Meetings, and other requested meetings. A cumulative list of community consultation is in
Appendix 11.1.
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G. Public Website
The GLO will maintain a public website that provides information accounting for how all grant
funds are used and managed/administered, including: links to all Action Plans; Action Plan
amendments; CDBG–DR program policies and procedures; performance reports; citizen
participation requirements; and activity/program information for activities described in its Action
Plan, including details of all contracts and ongoing procurement policies.
The GLO will make the following items available on recovery.texas.gov: (1) the Action Plan
(including all amendments); each Quarterly Performance Report (QPR) as created using the
DRGR system; (2) procurement, policies and procedures; (3) executed CDBG-DR contracts; and
(4) status of services or goods currently being procured by the GLO (e.g., phase of the
procurement, requirements for proposals, etc.).
In addition to the specific items listed above, the GLO will maintain a comprehensive website
regarding all disaster recovery activities assisted with these funds. This includes reporting
information on the GLO’s recovery website, recovery.texas.gov, and additional in-depth program
information on a separate site dedicated specifically to disaster recovery. The website will be
updated in a timely manner to reflect the most up-to-date information about the use of these funds
and any changes in policies and procedures, as necessary. At a minimum, updates will be made on
a monthly basis.
1. City of Houston and Harris County Websites
 City of Houston: www.houstontx.gov/housing

 Harris County: http://harriscountycommunitycorner.org/
2. COG Websites
 Alamo Area Council of Governments (AACOG): www.aacog.com

 Brazos Valley Council of Governments (BVCOG): www.bvcog.org
 Capital Area Council of Governments (CAPCOG): www.capcog.org
 Coastal Bend Council of Governments (CBCOG): www.cbcog98.org
 Central Texas Council of Governments (CTCOG): www.ctcog.org
 Deep East Texas Council of Governments (DETCOG): www.detcog.org
 Golden Crescent Regional Planning Commission (GCRPC): www.gcrpc.org
 Houston-Galveston Area Council (H-GAC): www.h-gac.com
 South East Texas Regional Planning Commission (SETRPC): www.setrpc.org
H. Waivers
The Appropriations Act authorizes the Secretary of HUD to waive or specify alternative
requirements for any provision of any statute or regulation that the Secretary administers in
connection with the obligation by the Secretary, or use by the recipient, of these funds and
guarantees, except for requirements related to fair housing, nondiscrimination, labor standards,
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and the environment (including requirements concerning lead-based paint), upon: (1) A request by
the grantee explaining why such a waiver is required to facilitate the use of such funds or
guarantees; and (2) a finding by the Secretary that such a waiver would not be inconsistent with
the overall purpose of HCDA. Regulatory waiver authority is also provided by 24 CFR 5.110,
91.600, and 570.5.
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6.2. Citizen Participation – Harris County Local Action Plan
The primary goal of this plan is to provide Harris County residents with definitive opportunities to
involve themselves in the recovery process as it pertains to CDBG-DR funds. Harris County is
acutely aware of the hardships many are faced within the wake of Hurricane Harvey and strives to
provide an ease of access to vulnerable populations struggling to recover.
On April 16, 2018, Harris County officially kicked off is community engagement activities. The
county met with local advocates to discuss the need for residential buyout, other homeowner
incentives, future citizen participation for recovery from Hurricane Harvey and CDBG-DR, and
AFFH, especially during and after a disaster. The county’s goals for community engagement is to
solicit input on needs and unmet needs in the county, provide resource navigation to existing
services for immediate and future needs, educate on the CDBG-DR program, and identify and to
the best extent possible provide access to remedy any discriminatory practices suffered by county
residents as they recover. The county will seek to engage the public, especially vulnerable
populations such as low-income and persons with a disability; housing and civil rights advocates;
local community leaders; non-profits; business owners; and other area stakeholders. Harris County
is providing several methods of engagement:
1. Stakeholder and Focus Group meetings-small group discussions around a specific

topic of recovery and unmet needs
2. Community meetings in an Open House style welcoming all the public
3. Community Survey-provided in English and Spanish
4. Community meeting in a Box-allows grassroot community engagement with local
moderators leading small groups of neighbors through a series of questions regarding
their household’s and community’s recovery and CDBG-DR.
5. The Project Recovery website offers residents of Harris County, community leaders,
businesses, and other interested parties up-to-date information on disaster recovery
programs and links to resources. The website address is http://harrisrecovery.org.
From May to July 2018, Harris County Community Services Department has conducted a series
of community meetings along with our community partners, such as the Texas Organizing Project
and BakerRipley (see a list of meetings in the Appendix). These meetings were held throughout
the county and included some of the county’s small cities. Meeting flyers in English, Spanish and
Vietnamese were distributed via local schools, utility districts, local non-profits, social media,
direct email to residents, door to door canvasing, phone calls to residents, text messaging, posting
in community buildings, and news media release (radio, print and television). Meetings have
averaged 55 persons, with two meetings with attendance over 100 persons. Meetings had language
and sign language interpreters available. Discussions by citizens have ranged from the need for a
buyout program and need for drainage improvements to individuals expressing personal needs for
recovery like home repair options and need for affordable housing. At the meetings, Harris County
has hosted groups like Lone Star Legal, HC Housing Resource Center, FEMA and the local county
precincts to operate information booths for meeting attendees.
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Harris County has conducted two meetings with advocates and subject experts. Attendees included
housing providers, Fair Housing advocates, non-profits, housing authorities, universities,
environmentalist, engineers, financial providers, builders, faith-based leaders, legal service
providers, buyout services providers, and organizations serving disabled populations.
Policies Regarding the Project Recovery Website
Harris County Community Services Department, the County’s lead administrator for CDBG-DR,
has developed The Project Recovery website that offers Harris County residents, community
leaders, businesses, and other interested parties up-to-date information on disaster recovery
programs and links to resources. The County will maintain this public website that provides
information accounting for how all grant funds are used and managed/administered, including:
links to Action Plans and amendments; CDBG-DR program guidelines, policies, and procedures;
performance reports; citizen participation; and activity/program information for activities
described in the County’s section of the State of Texas Action Plan, including details of contracts
and ongoing procurement policies.
The Harris County Project Recovery website address is http://harrisrecovery.org/.
This comprehensive website at a minimum will be regularly reviewed and updated on a monthly
basis.
Partnership with Harris County Flood Control District
The HCFCD is a special-purpose district created by the Texas Legislature in 1937 after community
leaders petitioned for assistance in response to devastating floods in 1929 and 1935. The HCFCD
was originally given the responsibility of overseeing rivers, streams, tributaries, and flood waters
in Harris County "for domestic, municipal, flood control, irrigation and other useful purposes."
Additionally, the HCFCD was responsible for the reclamation and drainage of the overflow land
of Harris County, the conservation of forests, and keeping navigable waters "navigable" by
regulating the stormwater that flowed into them.
HCFCD has operated the Harris County Residential Buyout Program since 1985 and has acquired
and removed approximately 3,000 houses located hopelessly deep in the floodplain where flood
damage reduction projects, like channel improvements or storm water detention basins, are not
cost-effective and/or beneficial. Once bought out, these parcels are returned to their beneficial
function, aiding in the storage of floodwaters. Those homeowners who are bought out receive
assistance to move to an area with reduced flood risk.
As the County is the administrator of the CDBG-DR funding and as Hurricane Harvey was a
devastating flood in the County, it is a natural partnership for Harris County to work with HCFCD.
Harris County, through its Community Services Department (HCCSD) and Engineering Office,
meet regularly with HCFCD to develop future programs to improve drainage in the county and
expand the buyout program, particularly to LMI households. An inter-local agreement will be
executed between HCCSD and HCFCD regarding CDBG-DR funding and programs. The team
also coordinates outreach efforts to residents regarding: 1) the buyout program and 2) future
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drainage improvement. Thoughout May to August 2018, both groups held over 35 community
meetings educating the public regarding recovery resources, and gathering public input on unmet
needs and comments on future possible projects.
Grievances and Appeals
Harris County is responsible for responding to complaints and appeals in a timely and professional
manner. A grievance and appeals procedure will be afforded to applicants to provide a quick and
efficient system for resolution of concerns or disputes that applicants may have with the procedures
followed and services provided by Harris County. The appeals procedure will include both an
informal and a written grievance process which may include but not be limited to informal
hearings, third-party review, and director approval. Harris County will keep a record of each
complaint or appeal that it receives to include all communications and their resolutions.
Complaints alleging violation of fair housing laws will be directed to HUD for immediate review
(see Grievance and Appeals policy). Complaints regarding fraud, waste, or abuse of government
funds will be forwarded to the HUD OIG Fraud Hotline (phone: 1–800–347–3735 or email:
hotline@hudoig.gov). If an applicant disagrees with the County’s decision, he or she can appeal
to the Texas GLO.
When a complaint or appeal is received, a representative will respond to the complainant or

appellant within fifteen (15) business days where practicable. For expediency, Harris County shall
utilize telephone communication as the primary method of contact; however, email and
postmarked letters will be used as necessary.
Harris County will identify staff within their program tasked with handling all applicant and
participant inquiries. These staff will be responsible for: (1) determining whether or not complaints
and appeals relate to the business or authority of Harris County, (2) ensuring that a response to all
complaints and appeals are within the appropriate time frame (a response must be provided within
15 working days of the receipt of the complaint), and (3) ushering all complaints and appeals
through to a resolution. Harris County has a Grievance and Appeals policy that addresses handling
incoming complaints, including a complaint escalation process in order to ensure that complaints
are handled at the earliest stage in the process. The entire appeals and or complaint process will be
concluded within a 45 business day period with final written determination sent to the complaintant
within this timeframe.
Documentation for each complaint or appeal must be maintained. Each file must include the
following:
• Contact information for the complainant;
• Initial complaint;
• Address and Harris County assigned project number (if applicable);
• Any communications to and from complainant or appellant;
• Results of the investigation, together with any notes, letters, or other investigative
documentation;
• The date the complaint or appeal was closed; and
• Any other action taken.
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6.3. Citizen Participation – City of Houston Local Action Plan
The primary goal of this plan is to provide Houstonians with opportunities to involve themselves
in the Hurricane Harvey recovery process as it pertains to CDBG-DR funds.
A. Community Consultation
Beginning in April 2018, the City’s HCDD convened a small working group of community
stakeholders and organizations to discuss best practices and a path forward for community
engagement to ensure that Houstonians have significant input in how the City utilizes Hurricane
Harvey CDBG-DR funding. HCDD’s approach throughout its engagement process is two-fold -
informing the community about the fundamentals of CDBG-DR funding and gathering input at
the neighborhood level to better understand unmet disaster-related needs. In consultation with
community stakeholders, HCDD has adopted the following principles in reaching out to disaster-
affected communities:
 Be transparent with the community about data and programs to address outstanding disaster
related issues
 Inform residents about the CDBG-DR funding process including the Action Plan process,
regulation requirements, eligible and ineligible activities, and interim resources available
 Seek representative input from different areas in the city
 Provide multiple avenues for residents to give feedback
 Link community input to decisions about disaster recovery funding
 Leverage meetings already scheduled with external partners, in addition to scheduling
City-hosted meetings
Throughout May and June 2018, HCDD worked with community groups, groups representing
protected classes, Super Neighborhood Councils, civic groups, and City Council Members to host
public meetings around the city to inform the City’s Action Plan. Additionally, HCDD engaged
community partners, such as [bc] Workshop, University of Houston - College of Architecture
Community Design Resource Center, and University of Texas School of Health, to provide
meeting facilitation and record-keeping assistance. The format of these meetings includes a
presentation on CDBG-DR funding followed by facilitated table discussions on key disaster
recovery challenges and priorities. Table discussions have focused on neighborhoods, with
residents discussing their post-disaster concerns around neighborhood-specific topics. Considering
the targeted audience, meetings have been conducted in English and Spanish, with interpretation
services available, as needed.
In addition, HCDD convened and participated in several disaster recovery community engagement
events with expert groups of developers and housing advocates. To elicit feedback on disaster
recovery needs on a city-wide scale, HCDD launched a Hurricane Harvey public survey in English
and in Spanish on May 14, 2018. As of June 24, 2018, HCDD received 746 responses.
B. Complaints
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HCDD will provide a timely written response to every written complaint received related to
CDBG-DR programs. The response will be provided in writing, or other effective communication,
within fifteen (15) working days of the receipt of the complaint, when practicable.
C. Public Website
HCDD will maintain a public website that provides information for how HCDD’s CDBG-DR
funds related to Hurrican Harvey are used and managed. The Recovery webpage will be
www.recovery.houstontx.gov. HCDD will have a procedure to ensure documents and information
are updated on this website.
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7.1. Appendix A: CDBG-DR Eligible and Most Impacted Counties
and ZIP Codes
Aransas (MI) Grimes Newton (MI) 77335

Austin Guadalupe Nueces (MI) 77351
Bastrop Hardin (MI) Orange (MI) 77414
Bee Harris (MI) Polk 77423
Brazoria (MI) Jackson Refugio (MI) 77482
Burleson Jasper (MI) Sabine 77493
Caldwell Jefferson (MI) San Augustine 77979
Calhoun Jim Wells San Jacinto (MI) 78934
Chambers (MI) Karnes San Patricio (MI)
Colorado Kleberg Tyler MI = HUD
Comal Lavaca Victoria (MI) Identified Most-
DeWitt Lee Walker Impacted
Fayette (MI) Liberty (MI) Waller
Fort Bend (MI) Madison Washington
Galveston (MI) Matagorda Wharton (MI)
Goliad Milam 75979
Gonzales Montgomery (MI) 77320
Page 240 of 420

CDBG-DR Counties by Councils of Governments
CDBG-DR Eligible CDBG-DR Eligible
Counties COG Counties COG
Comal AACOG Calhoun GCRPC
Guadalupe AACOG DeWitt GCRPC
Karnes AACOG Goliad GCRPC
Burleson BVCOG Gonzales GCRPC
Grimes BVCOG Jackson GCRPC
Madison BVCOG Lavaca GCRPC
Washington BVCOG Victoria GCRPC
Bastrop CAPCOG Austin H-GAC
Caldwell CAPCOG Brazoria H-GAC
Fayette CAPCOG Chambers H-GAC
Lee CAPCOG Colorado H-GAC
Aransas CBCOG Fort Bend H-GAC
Bee CBCOG Galveston H-GAC
Jim Wells CBCOG Harris H-GAC
Kleberg CBCOG Liberty H-GAC
Nueces CBCOG Matagorda H-GAC
Refugio CBCOG Montgomery H-GAC
San Patricio CBCOG Walker H-GAC
Milam CTCOG Waller H-GAC
Jasper DETCOG Wharton H-GAC
Newton DETCOG Hardin SETRPC
Polk DETCOG Jefferson SETRPC
Sabine DETCOG Orange SETRPC
San Augustine DETCOG
San Jacinto DETCOG
Tyler DETCOG
Page 241 of 420

8.1. Appendix B: Certifications – State of Texas
24 CFR 91.225 and 91.325 are waived. Each grantee receiving a direct allocation under this notice
must make the following certifications with its action plan:
a. The grantee certifies that it has in effect and is following a residential anti‐displacement and
relocation assistance plan in connection with any activity assisted with funding under the CDBG
program.
b. The grantee certifies its compliance with restrictions on lobbying required by 24 CFR part 87,
together with disclosure forms, if required by part 87.
c. The grantee certifies that the action plan for disaster recovery is authorized under State and local
law (as applicable) and that the grantee, and any entity or entities designated by the grantee, and
any contractor, subrecipient, or designated public agency carrying out an activity with CDBG‐DR
funds, possess(es) the legal authority to carry out the program for which it is seeking funding, in
accordance with applicable HUD regulations and this notice. The grantee certifies that activities
to be undertaken with funds under this notice are consistent with its action plan.
d. The grantee certifies that it will comply with the acquisition and relocation requirements of the
URA, as amended, and implementing regulations at 49 CFR part 24, except where waivers or
alternative requirements are provided for in this notice.
e. The grantee certifies that it will comply with section 3 of the Housing and Urban Development
Act of 1968 (12 U.S.C. 1701u), and implementing regulations at 24 CFR part 135.
f. The grantee certifies that it is following a detailed citizen participation plan that satisfies the
requirements of 24 CFR 91.115 or 91.105 (except as provided for in notices providing waivers and
alternative requirements for this grant). Also, each local government receiving assistance from a
State grantee must follow a detailed citizen participation plan that satisfies the requirements of 24
CFR 570.486 (except as provided for in notices providing waivers and alternative requirements
for this grant).
g. State grantee certifies that it has consulted with affected local governments in counties
designated in covered major disaster declarations in the non‐entitlement, entitlement, and tribal
areas of the State in determining the uses of funds, including the of funding, or activities carried
out directly by the State.
h. The grantee certifies that it is complying with each of the following criteria:
1. Funds will be used solely for necessary expenses related to disaster relief, long‐ term
recovery, restoration of infrastructure and housing and economic revitalization in the most
impacted and distressed areas for which the President declared a major disaster in 2016
pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1974
(42 U.S.C. 5121 et seq.).
Page 242 of 420

2. With respect to activities expected to be assisted with CDBG‐DR funds, the action plan
has been developed so as to give the maximum feasible priority to activities that will benefit
low‐ and moderate‐income families.
3. The aggregate use of CDBG‐DR funds shall principally benefit low‐ and moderate‐
income families in a manner that ensures that at least 70 percent (or another percentage
permitted by HUD in a waiver published in an applicable Federal Register notice) of the
grant amount is expended for activities that benefit such persons.
4. The grantee will not attempt to recover any capital costs of public improvements assisted
with CDBG‐DR grant funds, by assessing any amount against properties owned and
occupied by persons of low‐ and moderate‐income, including any fee charged or
assessment made as a condition of obtaining access to such public improvements, unless:
(a) Disaster recovery grant funds are used to pay the proportion of such fee or
assessment that relates to the capital costs of such public improvements that are
financed from revenue sources other than under this title; or
(b) For purposes of assessing any amount against properties owned and occupied
by persons of moderate income, the grantee certifies to the Secretary that it lacks
sufficient CDBG funds (in any form) to comply with the requirements of clause (a).
i. The grantee certifies that the grant will be conducted and administered in conformity with title
VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d), the Fair Housing Act (42 U.S.C. 3601–
3619), and implementing regulations, and that it will affirmatively further fair housing.
j. The grantee certifies that it has adopted and is enforcing the following policies, and, in addition,
must certify that they will require local governments that receive grant funds to certify that they
have adopted and are enforcing:
1. A policy prohibiting the use of excessive force by law enforcement agencies within its
jurisdiction against any individuals engaged in nonviolent civil rights demonstrations; and
2. A policy of enforcing applicable State and local laws against physically barring entrance
to or exit from a facility or location that is the subject of such nonviolent civil rights
demonstrations within its jurisdiction.
k. The grantee certifies that it (and any subrecipient or administering entity) currently has or will
develop and maintain the capacity to carry out disaster recovery activities in a timely manner and
that the grantee has reviewed the requirements of this notice. The grantee certifies to the accuracy
of its Public Law 115-56 Financial Management and Grant Compliance certification checklist, or
other recent certification submission, if approved by HUD, and related supporting documentation
referenced at A.1.a. under section VI and its Implementation Plan and Capacity Assessment and
related submissions to HUD referenced at A.1.b. under section VI.
Page 243 of 420

l. The grantee certifies that it will not use CDBG‐DR funds for any activity in an area identified as
flood prone for land use or hazard mitigation planning purposes by the State, local, or tribal
government or delineated as a Special Flood Hazard Area (or 100-year floodplain) in FEMA’s
most current flood advisory maps, unless it also ensures that the action is designed or modified to
minimize harm to or within the floodplain, in accordance with Executive Order 11988 and 24 CFR
part 55. The relevant data source for this provision is the State, local, and tribal government land
use regulations and hazard mitigation plans and the latest issued FEMA data or guidance, which
includes advisory data (such as Advisory Base Flood Elevations) or preliminary and final Flood
Insurance Rate Maps.
m. The grantee certifies that its activities concerning lead‐based paint will comply with the
requirements of 24 CFR part 35, subparts A, B, J, K, and R.
n. The grantee certifies that it will comply with environmental requirements at 24 CFR part 58.
o. The grantee certifies that it will comply with applicable laws.
Warning: Any person who knowingly makes a false claim or statement to HUD may be subject to
civil or criminal penalties under 18 U.S.C. 287, 1001 and 31 U.S.C. 3729.
_____________________________________
Heather Lagrone
Page 244 of 420

9.1. Appendix C: Program Execution Timelines – State Action Plan
While a number of factors may contribute to the timeline and execution of recovery programs,
the following is an estimated timeline for housing and infrastructure programs.
Page 245 of 420

A. Housing Program Timeline
B. Infrastructure Program Timeline
Page 246 of 420

10.1. Appendix D: Projected Expenditures and Outcomes – State
Action Plan
Program Allocation 2018
Program Q1 Q2 Q3 Q4
Homeowner Assistance Program $ 1,334,222,225 $ - $ - $ - $ 8,505,883
Local Buyout/Acquisition Program $ 275,620,892 $ - $ - $ - -
Homeowner Reimbursement Program $ 100,000,000 $ - $ - $ - $ 40,000,000
Affordable Rental Program $ 487,675,000 $ - $ - $ - $ -
PREPS Program $ 35,000,000 $ - $ - $ - $ 35,000,000
Local Infrastructure Program $ 413,431,338 $ - $ - $ - $ -
Economic Revitalization Program $ 100,000,000 $ - $ - $ - $ -
State Project Delivery $ 59,480,349 $ - $ -
State Planning $ 137,685,446 $ - $ - $ 200,000 $ 150,000
State Administration $ 222,583,119 $ - $ - $ 664,531 $ 2,215,103
Grand Total $ 3,165,698,369 $ - $ - $ 864,531 $ 85,870,986
Funds Remaining $ 3,165,698,369 $ 3,165,698,369 $ 3,164,833,838 $ 3,078,962,852

Program Q1 Q2 Q3 Q4
Homeowner Assistance Program $ 1,334,222,225 $ 20,657,144 $ 31,593,279 $ 42,529,414 $ 74,122,693
Local Buyout/Acquisition Program $ 275,620,892 $ 1,000,000 $ 3,000,000 $ 5,000,000 $ 7,000,000
Homeowner Reimbursement Program $ 100,000,000 $ 45,000,000 $ 12,000,000 $ 3,000,000 $ -
Affordable Rental Program $ 487,675,000 $ 29,260,500 $ 48,767,500 $ 78,028,000 $ 97,535,000
PREPS Program $ 35,000,000 $ - $ - $ - $ -
Local Infrastructure Program $ 413,431,338 $ - $ 3,000,000 $ 8,000,000 $ 15,000,000
Economic Revitalization Program $ 100,000,000 $ 28,000,000 $ 43,000,000 $ 15,000,000 $ 7,000,000
State Project Delivery $ 59,480,349 $ 2,355,966 $ 4,004,762 $ 4,179,430 $ 3,440,126
State Planning $ 137,685,446 $ 150,000 $ 1,000,000 $ 1,500,000 $ 2,000,000
State Administration $ 222,583,119 $ 4,430,207 $ 7,974,372 $ 10,632,497 $ 12,404,579
Grand Total $ 3,165,698,369 $ 130,853,817 $ 154,339,914 $ 167,869,340 $ 218,502,398
Funds Remaining $ 2,948,109,035 $ 2,793,769,121 $ 2,625,899,781 $ 2,407,397,382

Program Q1 Q2 Q3 Q4
Homeowner Reimbursement Program $ 100,000,000 $ - $ - $ - $ -
Affordable Rental Program $ 487,675,000 $ 107,288,500 $ 58,521,000 $ 39,014,000 $ 19,507,000
PREPS Program $ 35,000,000 $ - $ - $ - $ -
Local Infrastructure Program $ 413,431,338 $ 20,000,000 $ 25,000,000 $ 30,000,000 $ 35,000,000
Economic Revitalization Program $ 100,000,000 $ 4,000,000 $ 2,000,000 $ 1,000,000 $ -
State Planning $ 137,685,446 $ 2,500,000 $ 2,500,000 $ 2,500,000 $ 2,500,000
Grand Total $ 3,165,698,369 $ 262,497,143 $ 289,195,837 $ 281,473,871 $ 209,070,602
Funds Remaining $ 2,144,900,239 $ 1,855,704,402 $ 1,574,230,531 $ 1,365,159,929
Page 247 of 420

Program Q1 Q2 Q3 Q4
Affordable Rental Program $ 487,675,000 $ 9,753,500 $ - $ - $ -
PREPS Program $ 35,000,000 $ - $ - $ - $ -
State Planning $ 137,685,446 $ 2,500,000 $ 3,000,000 $ 12,000,000 $ 15,000,000
Grand Total $ 3,165,698,369 $ 188,992,565 $ 163,981,514 $ 157,578,996 $ 143,159,508
Funds Remaining $ 1,176,167,364 $ 1,012,185,850 $ 854,606,854 $ 711,447,346

Program Q1 Q2 Q3 Q4
PREPS Program $ 35,000,000 $ - $ - $ - $ -
State Planning $ 137,685,446 $ 15,000,000 $ 15,000,000 $ 12,000,000 $ 12,000,000
Grand Total $ 3,165,698,369 $ 136,120,346 $ 122,776,489 $ 103,533,124 $ 96,376,658
Funds Remaining $ 575,327,000 $ 452,550,511 $ 349,017,387 $ 252,640,729

Program Q1 Q2 Q3 Q4
PREPS Program $ 35,000,000 $ - $ - $ - $ -
State Project Delivery $ 59,480,349 $ 1,359,083 $ 1,113,209 $ 803,622 $ 557,748
State Planning $ 137,685,446 $ 10,000,000 $ 8,000,000 $ 5,000,000 $ 4,000,000
Grand Total $ 3,165,698,369 $ 67,825,567 $ 55,504,062 $ 40,232,803 $ 27,481,046
Funds Remaining $ 184,815,162 $ 129,311,099 $ 89,078,296 $ 61,597,250
Page 248 of 420

Program Q1 Q2 Q3 Q4
Local Buyout/Acquisition Program $ 275,620,892 $ 1,000,000 $ 500,000 $ 120,892 $ -
PREPS Program $ 35,000,000 $ - $ - $ - $ -
Local Infrastructure Program $ 413,431,338 $ 3,000,000 $ 2,000,000 $ 1,000,000 $ 431,338
State Project Delivery $ 59,480,349 $ 404,626 $ 337,570 $ 273,215 $ 227,926
State Planning $ 137,685,446 $ 3,000,000 $ 2,500,000 $ 2,000,000 $ 1,685,446
Grand Total $ 3,165,698,369 $ 20,011,631 $ 16,729,449 $ 13,570,860 $ 11,285,309
Funds Remaining $ 41,585,618 $ 24,856,169 $ 11,285,309 $ -
Page 249 of 420

State Programs Projected Expenditures
$180,000,000
$160,000,000
$140,000,000
$120,000,000
$100,000,000
$80,000,000
$60,000,000
$40,000,000
$20,000,000
$-
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
2018 2019 2020 2021 2022 2023 2024
Local Buyout/Acquisition Program Homeowner Assistance Program

Homeowner Reimbursement Program Affordable Rental Program
Local Infrastructure Program Economic Revitalization Program
State Planning State Administration
State Project Delivery PREPS Program
Page 250 of 420

10.2. Appendix D: Projected Expenditures and Outcomes – Harris
County Local Action Plan
Page 251 of 420

Page 252 of 420
10.3. Appendix D: Projected Expenditures and Outcomes – City of Houston Local Action Plan
Expenditure Summary
Page 253 of 420

Quarterly Expenditures by Year
Page 254 of 420

Page 255 of 420
Page 256 of 420
11.1. Appendix E: Consultations – State of Texas
DATE MEETING PARTIES REPRESENTED /
PURPOSE
8/29/2017 Cities of Port Lavaca, Robstown, Assessed damage
Corpus Christi
8/30/2017 City of Port Aransas Toured damaged areas with elected
officials
8/31/2017 City of Corpus Christi Met with the City to discuss recovery
needs
9/1/2017 Brad Gair, Witt O'Brien's Discussed use of FEMA short term
housing with CDBG-DR long term
housing
9/2/2017 Shelter at Home - Louisiana Discussed use of FEMA short term
housing with CDBG-DR long term
housing
9/7/2017 House Urban Affairs Committee Texas Department of Housing and
Hearing - Austin Community Affairs
9/8/2017 Texas Appleseed Discussed Hurricane Harvey Recovery
9/12/2017 Rebuild Texas & Governor's Harris County, City of Houston

Hurricane Harvey
9/12/2017 State Delegation - Houston Listening session and CDBG-DR program
brief
9/12/2017 City of Houston Damage Brief
9/13/2017 Texas Water Infrastructure Discussed CDBG-DR funds for potential

Coordination Committee Harvey allocation; TCEQ, TWDB, other
federal and state partners
9/13/2017 Congressman Pete Olson Various neighborhoods impacted by
Townhall - City of Houston flooding
9/13/2017 Call with Congressman Discussed recovery needs of the district,
Culberson's Office FEMA and CDBG-DR programs, and
eligibility
9/13/2017 Call with Senator Cornyn's Office Discussed recovery needs of the district,
FEMA and CDBG-DR programs, and
eligibility
9/14/2017 Nueces and San Patricio Counties Discussed housing needs
9/15/2017 Call with State Representative Discussed Hurricane Harvey Recovery

James White
9/18/2017 Rebuild Texas & Governor's Jefferson County, City of Port Arthur,
Hurricane Harvey Orange County, City of Orange discussed
NFIP ratings, match needs for FEMA
Programs, and faster housing programs
Page 257 of 420
PURPOSE
9/18/2017 Texas Delegation Call Discuss Hurricane Harvey Recovery
9/22/2017 South East Texas with HUD Discussed mold in flooded units,
Secretary Carson mitigation, need for equitable distribution
of funds
9/22/2017 Texas Association of Regional Discussed 2015 & 2016, update on
Councils Board of Directors Harvey recovery
9/26/2017 Texas Delegation Call Discussed Hurricane Harvey Recovery
related to buyouts and elevation
9/27/2017 Congressman Pete Olson Discussed Hurricane Harvey Recovery
Townhall - north Houston related to repetitive flood prone areas in
north Houston
9/28/2017 Rebuild Texas & Governor's Liberty County, City of Liberty, City of
Hurricane Harvey Sour Lake, and Hardin County discussed
need for fewer rules to expedite recovery,
allow churches to be reimbursed for
expenses and damage, and more details on
the websites
10/2/2017 House Appropriations Committee Harris County, Houston, Fort Bend
Hearing - City of Houston
10/3/2017 Lieutenant Governors Townhall - Discussed Hurricane Harvey Recovery
West Houston
10/4/2017 Lieutenant Governor's Townhall - Discussed Hurricane Harvey Recovery
Clear Lake (Harris/Galveston
Counties)
10/4/2017 City of Baytown Discussed Hurricane Harvey Recovery
related to buyouts, housing, and flood
mitigation
10/6/2017 Public Utilities Commission Reviewed needs for recovery
10/9/2017 Galveston County Toured the Gulf Intercoastal Waterway
10/9/2017 Rebuild Texas & Governor's City of Rockport, Aransas County, City of
Hurricane Harvey Aransas Pass, City of Refugio, City of
Port Lavaca, and City of Victoria
discussed debris, 600 apartments lost,
mold, insurance issues, and need for alert
systems
10/10/2017 Rebuild Texas & Governor's City of Wharton, Matagorda County,
Hurricane Harvey Brazoria County, City of Sugarland, Bay
City, City of Angleton, and City of
Dickinson discussed FEMA denials, need
for match, procurement requirements, non
LMI homeowners impacted too, and fund
distribution
Page 258 of 420
PURPOSE
10/11/2017 Bureau of Economic Geography Discussed Hurricane Harvey data and
effects
10/11/2017 Rebuild Texas & Governor's Cities of Kountze, Liberty, Anahuac, Port
Hurricane Harvey Arthur, Orange discussed debris,
infrastructure, Hwy 87, funds for all cities
and counties, and drainage
10/13/2017 DETCOG Hurricane Harvey Discussed needs for the region and short-
Kickoff term housing
10/16/2017 Congressional Staff at the Joint Program briefs for both FEMA and
Field Office CDBG-DR programs
10/16/2017 Christus Health Discussed housing and health needs of
Port Arthur & Beaumont area
10/18/2017 HGAC Hurricane Harvey Kickoff Discussed needs for the region and short-
term housing
10/20/2017 SETRPC Hurricane Harvey Discussed needs for the region and short-
10/20/2017 CBCOG Hurricane Harvey Discussed needs for the region and short-
10/23/2017 Direct Housing Playbook & Short Long term recovery
& Long-Term housing
opportunities
10/24/2017 Senate Finance Committee Texas Military Department, State Health
Hearing - Austin, TX Services, Texas Education Agency
10/25/2017 Texas Association of Builders Discussed sources, availability, and
shortages
10/25/2017 State Representative Todd Hunter Discussed Hurricane Harvey Recovery
10/26/2017 CAPCOG Hurricane Harvey Discussed needs for the region, and short-
10/27/2017 Joint Housing Task Force Discussed Hurricane Harvey Recovery
11/2/2017 Texas Homelessness Network and Discussed homeless needs and solutions
True Casa Consulting
11/3/2017 American Planning Association of Discussed Hurricane Harvey Recovery
Texas
11/3/2017 City of Dickinson Discussed Hurricane Harvey Recovery
and Dickinson Bayou
11/6/2017 Texas Apartment Association Discussed inventory and potential
programs
Page 259 of 420

PURPOSE
11/8/2017 House Appropriations Hearing - City of Port Aransas, City of Corpus
Corpus Christi, TX Christi, Aransas County, Christus Health
System, Refugio ISD, City of Fulton, Taft
ISD, Wharton County Junior College,
TEA, Nueces County, and San Patricio
County
11/9/2017 City of Houston Discussed Hurricane Harvey Recovery,
and Houston data on damaged units
11/10/2017 Harris County Discussed Hurricane Harvey Recovery
11/16/2017 Victoria County Discussed Hurricane Harvey Recovery
11/16/2017 GCRPC Meeting Disaster Recovery planning and staffing

needs
11/17/2017 FEMA Floodplain Management & Discussed uses of CDBG-DR funds and
Insurance leverage needs
11/21/2017 Chambers County Discussed Hurricane Harvey Recovery
11/21/2017 Newton County Discussed Hurricane Harvey recovery

related to housing and road repairs
11/28/2017 City of Richmond Round Table Discussed city needs related to Harvey
Recovery
11/28/2017 Fort Bend County Discussed Hurricane Harvey Recovery
11/29/2017 GCRPC Kickoff Discussed needs for the region and short-
term housing
11/29/2017 Habitat for Humanity Discussed available programs
11/30/2017 Congressman Randy Weber Updated on Recovery efforts and needs
12/4/2017 House Urban Affairs Committee Corpus Christi Public Housing Authority,
Hearing - Corpus Christi, TX City of Port Aransas, City of Aransas
Pass, City of Fulton, City of Ingleside,
City of Corpus Christi, Aransas County,
and City of Rockport
12/6/2017 City of Aransas Pass Delegation Discussed recovery needs and education
12/7/2017 Housing Strike Team - Aransas Aransas County, City of Fulton, and City
County of Rockport discussed county needs,
permitting issues, housing needs, debris
operations, and equity in funding
allocations
12/7/2017 City of Houston Discussed Houston's needs and planned
programs
Page 260 of 420
PURPOSE
12/12/2017 State Fair Housing Workgroup Holistic approach to AFFH by State
Agencies
12/13/2017 House Urban Affairs Committee City of Galveston, City of Beaumont,
Hearing - Beaumont Jefferson County, Orange County, Hardin
County, HGAC, City of Sour Lake, City
of Anahuac, City of Orange, and City of
Vidor
12/14/2017 Texas Association of Builders Discussed coming program needs and
potential inventory
12/15/2017 State Hurricane Harvey Crisis Consider needs of both victims and
Counseling Program program staff
12/18/2017 Texas Department of Housing & Discussed homelessness initiatives
Community Affairs
12/18/2017 State Representative James White Discussed needs of the district,
preagreement and other eligibility
12/18/2017 City of Houston Discussed multifamily needs
12/19/2017 Nueces County Nueces County Commissioner's Court

Testimony
12/20/2017 House Land & Resource Nueces County, Port Aransas, San
Management Committee Hearing Patricio County, City of Aransas Pass,
- Corpus Christi, TX City of Fulton, City of Corpus Christi, and
City of Rockport
12/22/2017 Texas Low Income Housing Discussed Program and Subrecipient
Information Services needs
1/3/2018 Nueces County Discussed Hurricane Harvey Recovery
discussed time table for funds, mitigation,
housing needs, and tourism
1/4/2018 City of Houston Discussed Hurricane Harvey Recovery,
direct allocation, MOD at the GLO,
buyouts, and duplication of benefit
1/4/2017 Cities of Beaumont and Orange Visited damaged 80 unit multifamily site
and other areas
1/5/2018 Meeting with Quicken Loans Discussed needs of mortgagees and
insurance issues
1/8/2017 SETRPC Discussed long term recovery and needed
preparation
1/9/2018 City of Galveston Discussed Hurricane Harvey Recovery
1/11/2018 Texas State Agency’s Business Brief the concept and state of the housing
Administrators’ Association program to other state agencies
(TSABAA) conference -
Kerrville, TX
Page 261 of 420

PURPOSE
1/12/2018 Aransas County and Texas Discussed the recovery needs of the
Appleseed County and AFFH
1/12/2018 House Appropriations Committee City of Beaumont, Jefferson County,
Hearing - Beaumont, TX Orange County, Memorial Hermann
Health System, Hardin County, Baptist
Hospital, Orange, Chambers County, and
City of Vidor
1/17/2018 HOPE NOW Alliance Discussed foreclosure prevention
1/18/2018 House Urban Affairs Committee City of Houston, City of Galveston, Harris
Hearing - Houston, TX County, HGAC, Houston Habitat for
Humanity, and Texas Housers
1/18/2018 House General Investigations & Houston, Galveston, Harris County,
Ethics Committee Hearing - Catholic Charities
Houston, TX
1/19/2018 University Systems Chancellors Discussed planning needs
1/23/2018 Housing Strike Team - San San Patricio County, City of Ingleside on
Patricio County the Bay, San Patricio County PHA, City
of Sinton, City of Portland, San Patricio
EDC, Aransas Pass Chamber of
Commerce, and Ingleside Chamber of
Commerce discussed local capacity
issues, public housing needs, fund
distribution, low income housing, and
mitigation
1/26/2018 Congressman Blake Farenthold Discussed Hurricane Harvey Recovery
Q&A Session - Corpus Christi,
TX
1/30/2018 Senate Finance Committee Texas Comptroller and Legislative Budget
Hearing - Austin, TX Board discussed Hurricane Harvey
Recovery
1/30/2018 Hardin County Discussed housing needs for both short
term and long term
2/1/2018 Texas Association of Regional Hurricane Harvey Brief and Q&A
Councils Board of Directors
2/2/2018 Texas Low Income Housing Discussed hurricane survivor recovery
Information Services rights, principles, and initiatives
2/5/2017 Housing Strike Team - Montgomery County, Patton Village, City
Montgomery County of Roman Forest, Woodlands Township,
and United Way discussed drainage
needs, need for speed in recovery,
housing, ensuring everyone can
participate equitably, need for match from
CDBG, and buyouts
Page 262 of 420
PURPOSE
2/6/2018 Audubon Discussed potential projects
2/7/2018 Housing Strike Team - Galveston Galveston County, City of Friendswood,

County League City, City of Dickinson, City of
La Marque, City of Kemah, City of
Galveston, City of Clear Lake Shores,
City of Texas City, City of Santa Fe, and
H-GAC discussed need for speed in
recovery efforts, drainage issues in
repetitively flooded bayous, leveraging of
other federal resources
2/9/2018 Texas Association of Businesses Outlined programs for Hurricane Harvey
Annual Conference Recovery
2/12/2018 HUD Community Planning & Discussed program requirements
Development
2/13/2018 Housing Strike Team - Jefferson, Hardin County, Jefferson County, Orange
Hardin, & Orange Counties County, City of Beaumont, and Tri-
County Disaster Recovery discussed need
to recover as quickly as possible,
communities’ inability to meet FEMA PA
cost share, and overall and regional
housing needs
2/13/2018 Alvin Chamber of Commerce Discussed Brazos River flooding in areas
never flooded before
2/14/2018 Town Hall for Newton County Q&A related to programs
and City of Lumberton
2/14/2018 Housing Strike Team - Port City of Port Arthur, Port Arthur EDC,
Arthur, TX Port Arthur Housing Authority discussed
housing needs, consideration for overall
community recovery, pending foreclosure
issues, 80 percent of homes impacted, and
distribution of funds
2/15/2018 Housing Strike Team - Newton & Newton County, Jasper County, and
Jasper Counties DETCOG discussed repetitive impact
areas, housing, and transpiration needs
2/16/2018 State Senator Jane Nelson Staff Discussed eligible uses of CDBG-DR
Meeting funds
2/20/2018 Senate Finance Committee Updated on recovery efforts and needs
Hearing - Austin, TX
2/20/2018 Villages Round Table Discussed Action Plan programs, future
allocations, repetitive flooding and non
LMI needs.
2/20/2018 Affordable Rental Housing Discussed affordable rental housing needs
Presentation - Aransas County and programs
Page 263 of 420

PURPOSE
2/23/2018 Aransas County Discussed recovery needs
2/23/2018 City of the Woodlands Discussed drainage planning study in

Spring Creek
2/26/2018 Round Table Discussion, Houston FEMA and City of Houston officials.
Harvey Recovery, 6 months later Answered Student and Moderator
at UHD Questions KTRK Houston
2/27/2018 Regional Interagency Steering Discussed opportunities utilize various
Committee funding sources toward recovery
3/1/2018 Housing Strike Team - Wharton Discussed need for apartments, repetitive
County flooding areas, business needs
3/2/2018 City of Houston Discussed the Action Plan and programs
3/6/2018 Texas State Transportation Harvey CDBG-DR program presentation

Innovation Council
3/6/2018 Harris County Discussed the Action Plan and programs
3/7/2018 Harris County Discussed the Action Plan and programs,

capacity of the County, and direct
allocations
3/8/2018 House Land & Resource Harris County, Chambers County,
Management - Houston, TX Houston, and City of Dickinson
3/9/2018 City of Houston Discussed Action Plan, needs assessment,
and programs
3/14/2018 City of Houston, Harris County, City of Houston, Harris County, and HUD
and HUD - Washington, D.C. discussed unmet needs and recovery
programs
3/22/2018 Harris County Met with county officials
4/17/2018 Brazoria County - San Bernard County officials, observed impact that
River rushing water had on misdirecting
flooding during Hurricane Harvey and for
future rain events
5/2/2018 Coastal Bend Hurricane Addressed statewide attended event of
Conference - Corpus Christi emergency management personnel
5/2/2018 Port Arthur County and local elected officials,
discussed Hurricane Harvey recovery
5/2/2018 Port Arthur City officials, discussed Hurricane Harvey
recovery funding
5/24/2018 Lufkin DETCOG, updated on Hurricane Harvey
Recovery
6/28/2018 Harris County County official, discussed CDBG-DR
funding process
Page 264 of 420

PURPOSE
6/28/2018 City of Houston Met with city officials
6/28/2018 City of Houston City officials, discussed Hurricane Harvey

recovery
7/6/2018 Rockport Coastal Bend local elected officials
7/6/2018 South East Texas SETRPC, discussed Harvey Recovery and

funding processes for rebuilding
7/25/2018 City of Houston CDBG-DR funding, speech
7/25/2018 City of Clear Lake Clear Lake Chamber of Commerce,

speech
9/24/18 Aransas Pass Corpus Christi & Aransas Pass public
housing authorities discussed unmet needs
9/25/18 Livingston Livingston and Newton public housing
authorities discussed unmet needs
9/27/18 La Grange La Grange Public Housing Authority
discussed unmet needs
10/02/18 Beaumont Beaumont, Port Arthur and Orange public
housing authorities discussed unmet needs
Page 265 of 420

11.2. Appendix E: Consultations – Harris County
Date Location Parties Represented
Monday, April 16, 2018 Harris County Community Focus Group Meeting on Residential
Services Department Buyout Program
LISC, HC Flood Control District,
Texas Southern University, Kinder
Institute/Rice University, Greater
Houston Fair Housing Center, Lone
Star Legal, Texas Low Income
Housing Information (Texas
Housers)
Thursday, May 24, 2018 Harris County Community Organizational Stakeholder Meeting
Services Department on Supplement Amendment to
State’s Action Plan process and
community engagement.
Sierra Club, LISC, TOP, HC Flood
Control District, SEER, Kinder
Institute/Rice University, Greater
Houston Fair Housing Center, Lone
Star Legal, Texas Low Income
Housing Information (Texas
Housers)
Wednesday May 30th Crosby Community Center Community Meeting
4:30pm to 7:30pm 409 Hare Rd; Crosby, TX Pct 2-Sheldon, Barrett Station,
77532 Crosby, Channelview, Huffman
Thursday May 31st Northeast Community Center Community Meeting
4:30pm to 7:30pm (James Driver Park) Pct 2 & 1-Aldine, Airline, El
10918 Bentley St.; Houston, Dorado, Northington-Kentwood,
TX 77093 Sherwood Place
Tuesday, June 5th BakerRipley - Cleveland Community Meeting
8:30am to 11:00am Campus Pct 2-Pasadena, South Houston,
720 Fairmont Pkwy; Galena Park
Pasadena, TX 77504
Wednesday, June 6th Weekly Community Center Community Meeting
4:30pm to 7:30pm 8440 Greenhouse Rd; Pct 3 & 4-Bear Creek, Copperfield,
Cypress, TX 77433 Katy, Cypress
Thursday, June 7th Leon Z Grayson/Baldree Community Meeting
4:30pm to 7:30pm Community Center Pct 2 & 1-Galena Park, Jacinto City,
13828 Corpus Christi St; South Houston, Cloverleaf, Sheldon,
Houston, TX 77015 Channelview
Thursday, June 7th TOP Partner Meeting Community Meeting
7:00pm to 8:00pm HD Center Cloverleaf, Normandy Crossing,
13701 Victoria St. Texas Organizing Project (TOP)
Houston, TX 77015
Tuesday, June 12th El Franco Lee Community Community Meeting
4:30pm to 7:30pm Center Pct 1-Pearland, Friendswood,
Webster, Seabrook
Page 266 of 420
Date Location Parties Represented
9500 Hall Rd; Houston, TX
77089
Wednesday, June 13th Phillip Cezeaux Recreation Community Meeting
4:30pm to 7:30pm Bldg Pct 4- Humble, Mercer,
100 N. Houston Ave; Bordersville, North Belt
Humble, TX 77338
Thursday, June 14th Baytown Community Center Community Meeting
4:30pm to 7:30pm 2407 Market Street; Baytown, Pct 2-Baytown, McNair, Linus,
TX 77520 Channelview, Jacinto City,
Cloverleaf
Wednesday, June 20th Houston Center for Focus Group meeting with CIL
1pm to 2pm Independent Living (CIL)
Thursday, June 21st Sweet Home MBC Community Meeting
7:00pm to 8:00pm 2503 16th St Galena Park, Jacinto City, Texas
Galena Park, TX 77547 Organizing Project (TOP)
Friday. June 22nd Greater New Grove Worship Community Meeting
7:00pm to 8:00pm Center Texas Organizing Project (TOP)
7518 East Mt Houston Rd
Houston, TX 77050
Saturday, June 23rd The Rock International Community Meeting
7:00pm to 8:00pm Ministries Texas Organizing Project (TOP)
14814 Lee Road, Humble TX
77396
Page 267 of 420

11.3. Appendix E: Consultations – City of Houston
The City received rich feedback from all public meetings, through surveys, written notes, and map-
based observations at the neighborhood level. The following are initial observations and a listing of
meetings:
 Some people have been able to rebuild, but others are stuck in unsafe homes: All
Houstonians prioritize the rebuilding of their homes. But there are differences in how quickly
different communities have been able to recover based on their access to the resources needed
for rebuilding. In areas where residents have repeatedly flooded or where poverty rates are
high, some residents described still living in homes that have not been fully gutted, or with
persistent mold that is causing health problems almost a year after the storm. Many people
are worried that their homes aren’t high enough to avoid future damage. And some residents
who have undertaken repairs reported incurring personal debt to meet these costs.
 Housing and drainage are deeply connected: While our meetings were primarily about
housing recovery, most people also identified drainage as a major concern. Outdated drainage
infrastructure, lack of drainage maintenance, the need for varied stormwater management
solutions, and enforcement of stormwater standards for new development were issues that
residents identified in our meetings across the city.
 In areas that didn’t flood, longtime residents want protection from displacement:
Especially in close-in areas with short transit times to downtown, residents are concerned
about being displaced. They fear that long-standing communities will break up in the face of
real estate speculation, gentrification, rising rents, and increasing property taxes after Harvey.
 In areas that flooded severely, a rise in vacant homes is threatening the fabric of
communities: Residents in areas with repeated flooding identified checkerboarded buyouts
and a rise in damaged homes that have been abandoned as eroding the cohesiveness of their
communities and the value of their homes.
 Vulnerable Houstonians need special attention: In every meeting, people expressed

concern for neighbors who they saw as especially vulnerable: seniors, those with disabilities,
mental health challenges, and others. They also shared their struggles to navigate multiple
case management systems and the lack of reliable information about recovery resources.
 Harvey heightened housing challenges for renters: Many renters described moving,
sometimes multiple times, since Harvey. They reported struggling to find decent affordable
rental units that are safe from flooding. Renters also reported unscrupulous behavior by
landlords, such as withholding security deposits or making only cosmetic repairs that left
issues like mold unresolved. Many renters had not received FEMA assistance and were
unaware of benefits that might have been available to them.
 People want clear communication from trusted sources: Especially with the start of
hurricane season, residents want clear, easily accessible information from official sources.
Information can’t be limited to the internet and social media and needs to be available in print
and through traditional media like newspapers, radio, and TV, in multiple languages.
Page 268 of 420

 People don’t know what to do about contractor fraud: Many residents reported losing
money to contractors who collected payment without completing necessary repairs. There is
a lack of awareness of what to do about contractor fraud, and few residents were aware of the
State Attorney General’s fraud reporting site at https://texasattorneygeneral.gov/cpd/home-
remodeling-and-repair.
 The loss of small business and community amenities are threatening hard-hit
communities: Communities with high poverty and widespread flooding reported losing small
businesses, post offices, libraries, and community centers to the hurricane. People identified
these community amenities as essential for providing opportunities for young people and
keeping communities vibrant.
 Delays and confusion in inspection and permitting processes are slowing down
rebuilding: For those with the resources to start rebuilding, frustrations are running high
about the complexity and speed of permitting processes. Some who began doing repairs
themselves or who have been helped by volunteer groups are receiving fines for not being up
to current code. Renters expressed concern about the lack of inspectors for multi-family
properties to enforce health and safety regulations
 People don’t understand the disaster recovery process: Many residents are confused by
the different federal, state, local, and non-profit recovery programs, and almost all
participants are frustrated with the pace of long-term recovery. Clear communication about
the national disaster recovery framework is needed to help manage expectations and receive
meaningful feedback from the community.

PURPOSE
4/25/2018 Small group meeting with potential Discussed best practices for community
community engagement partners engagement and identified potential
community partners
5/2/2018 Small group meeting with potential Discussed format and schedule for
community engagement partners community engagement events
5/3/2018 Community engagement coordination Consulted with other City Departments
meeting with other City Agencies to coordinate community engagement
5/9/2018 Small group meeting with potential Discussed format and schedule for
community engagement partners community engagement events
5/16/2018 Small group meeting at 601 Sawyer St. Discuss format and schedule for
with potential community engagement community engagement events
partners
5/19/2018 Community Meeting - Partnered with Gathered need and priority information
Texas Organizing Project at Harris from community residents, focused on
County AFL-CIO the Eastside
5/20/2018 Presented at the Metropolitan Shared information and answered
Organization Harvey recovery event at questions about long-term recovery
Memorial Drive United Methodist
Church
Page 269 of 420

PURPOSE
5/23/2018 Community Meeting - Partnered with Gathered unmet need and priority
Texas Organizing Project at Denver information from community residents,
Harbor Multi-Service Center focused on neighborhoods near Denver
Harbor
5/24/2018 For Profit Housing Developer Focus Gathered information from for-profit
Group – Hosted at HCDD office developers to assess disaster recovery
capacity and best practices for
implementing upcoming affordable
housing programs
5/25/2018 Non-Profit Housing Developer Focus Gathered information from non-profit
Group – Partnered with LISC at developers specific to expanding
LISC’s offices capacity for disaster recovery and best
practices for implementing upcoming
affordable housing programs
5/26/2018 Community Meeting – Partnered with Gathered unmet need and priority
FIEL Houston at FIEL Houston information from community residents,
focused on neighborhoods in Southwest
Houston
Texas Organizing Project at Acres information from community residents,
Homes Multi-Service Center focused on neighborhoods around Acres
Homes
Texas Organizing Project at Greater St. information from community residents,
Matthew Baptist Church focused on neighborhoods in Sunnyside
and Southpark
6/2/2018 Community Meeting – Partnered with Gather unmet need and priority
Texas Organizing Project at the information from community residents,
Northeast Multi-Service Center focused on neighborhoods in the
Northeast
6/2/2018 Participated in the Extreme Weather Distributed surveys to residents
Ready Expo at the George R. Brown interested in disaster preparedness
Convention Center
6/6/2018 Teletownhall – Partnered with AARP Dial-in format to reach seniors and
(English) answer questions about recovery
6/7/2018 Teletownhall – Partnered with AARP Dial-in format to reach seniors and
and Univision (Spanish) answer questions about recovery
6/7/2018 Community Meeting – Partnering with Gather unmet need and priority
Texas Organizing Project at the SW information from community residents,
Multi-Service Center focused on neighborhoods in the
Southwest
6/11/2018 Presented at the Super Neighborhood Share information with neighborhood
Alliance meeting at City Hall Annex leadership
Page 270 of 420

PURPOSE
6/12/2018 Presented at the Kashmere Gardens Share information with affected
Super Neighborhood Council meeting residents about long-term recovery
at the Kashmere Multiservice Center
6/13/2018 Presented on the Disability Community Share information with disability rights
Harvey Recovery Call hosted by the advocates
Mayor’s Office of People with
Disabilities
6/13/2018 Community Meeting – Partnered with Gather need and priority information
Council Members Gallegos and Davis, from community residents, focused on
and Super Neighborhoods 57 and 59 at neighborhoods in the Pleasantville and
the Judson Robinson, Sr. Community Clinton Park neighborhoods
Center
6/14/2018 Presented at the Houston Housing Share information with housing
Collaborative at the Montrose Center advocates
Council Member Boykins at San from community residents, focused on
Jacinto Community College District D
6/16/2018 Presented at the TOP annual meeting at Report back on disaster recovery
TOP’s office community meetings co-hosted with
TOP
6/18/2018 Community Meeting – Partnered with Gather need and priority information for
the Emancipation Economic community residents, focused on Third
Development Council at Blackshear Ward
Elementary School
6/19/2018 Community Meeting – Partnered with Gather need and priority information for
Council Member Martin at the St. community residents, focused on
Stephen Presbyterian Church Southeast Houston
Council Member Castex-Tatum from community residents, focused on
neighborhoods in District K
the East Houston Civic Association at from community residents, focused on
the East Houston Civic Association neighborhoods in East Houston
Council Member Travis at the from community residents, focused on
Tallowood Baptist Church neighborhoods in District G
Page 271 of 420

12.1. Appendix F: Regional Methods of Distribution
A. State Housing Program Allocations
Hurricane Harvey Housing Allocation Analyses

Professors Patrick Brockett, Rajiv Garg, Linda Golden, James Nolen and Alisa Walch
University of Texas at Austin, March 27, 2018
Updated by GLO-CDR staff as part of Amendment 2 to reflect changes identified by HUD to Texas
CDBG-DR grantees regarding methodology for funding allocation under Public Law 115-123 dated
April 10, 2018, and most recent available data. These changes were applied to allocate the additional
funds distributed to the State Homeowner Assistance Program. No updates were made to the Local
Buyout and Acquisition Program because no additional funds were allocated to it.
State Homeowner Assistance Program and Local Buyout/Acquisition Program Allocations
Allocation of State Homeowner Assistance Program Funds Designated in Initial Action Plan
The list of counties and ZIP codes that are to receive at least 80% of the HUD funding allocation,
and the remaining counties designated to receive 20% of the HUD funding are specified in the Federal
Register (Federal Register/Vol. 83, No. 28 / Friday, February 9, 2018 / Notices). The sub-grouping
of counties and ZIP codes are incorporated into the numerical allocation process of the results in the
State Homeowner Assistance Program and Local Buyout/Acquisition Program spreadsheets.
Altogether there were 16 counties and 11 ZIP codes listed as “most impacted and distressed”. These
represent the HUD 80% allocation group. Since Harris County and the city of Houston are getting
separate allocations, their data (and allocations) are not included in the analyses described below.
80% State Homeowner Assistance Program and Local Buyout/Acquisition Program Allocation
Group Required by HUD in the Federal Register of February 9, 2018
County populations were obtained from the U.S. Census 2016 Update 54. Specific ZIP code
populations cross classified by county were obtained from the U.S. Census Bureau 2010 Decennial
Census using total population for county or part within a Texas 5 digit ZIP code tabulation area
(ZCTA)55.
Median housing values for homeowners was obtained from the U.S. Census Bureau State and County
Housing Unit Estimates56. Housing value for renters was based on construction cost for an 861 square
feet rental unit with a footprint of 24'×35'. These construction costs have a nationwide range of
54
https://www.census.gov/search-results.html?page=1&stateGeo=&searchtype=web&cssp =&q=texas
+counties+population&search.x=0&search.y=0&search=submit
55
https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t. For each zip code, this then
proceeded as follows: 1) Click on “all geographic types”, 2) “Select a Geographic Type” – Select “County (or part) –
880”, 3) Select “Texas”, 4) Select a 5-digit zip code tabulation area. Select Multiple (Hold “Ctrl” and click on ZIP and
County. Can add multiple ZIPs), 5) Click on “Add to Your Selection”, 6) Click on “Topics” – “People” – “Basic
Count/Estimate” – “Population Total”, 7) Click on ID “PI” check box., 8) Click on “View Table”, 9) Click
“Download” to download data table.
56
https://www.census.gov/quickfacts/fact/table/US/PST045216 for State and County and http://www.city-data.com/
for zip codes.
Page 272 of 420

$64,575 to $86,100 per unit57. The midpoint of $75,337.50 is used in the renters’ unmet needs
calculation. The most reasonable data available was used for calculation.
FEMA verified counts of unmet need (both for homeowners and renters) were supplied by FEMA
Individual Assistance (IA) registrant data as of February 2, 2018. The categorization of damage
severity level thresholds used by FEMA for cross-classifying these unmet needs data (Major-Low
Damage Severity, Major-High Damage Severity, and Severe Damage) utilized segments of HUD’s
“most impacted method” procedure and related the FEMA Verified Loss (FVL) dollar amounts for
each registrant to the HUD severity categories.
The spreadsheet column that calculated the unmet need dollar amount for each geography (county or
ZIP code) derived its value using the HUD damage severity level categories and the FEMA supplied
data on the count of the number of housing units experiencing damage in each of the three HUD
designated severity levels, cross classified by county and by renter versus homeowner. The HUD
method provided a monetary multiplier value for the unmet need to homeowners in each of the three
severity categories, with $58,956 being the unmet need multiplier associated with the Major-Low
Damage Severity category, $72,961 being the unmet need multiplier associated with the Major-High
Damage Severity category, and $102,046 being the unmet need multiplier associated with the Severe
Damage category. Assuming “Severe” damage corresponded to approximately 100% damage, this
allowed translation of the unmet need multipliers in each severity category into a percentage damage
estimate for the residential unit corresponding to each category. Such a translation was necessary
since median home values differ significantly across impacted counties.
Accordingly, unmet need was assessed on the basis of percentage damage times the median home
price in the county or ZIP code. For the Major-Low Damage Severity category this percentage of the
housing unit value that is unmet need is $58,956/$102,046 = 57.8% of the value of the structure. For
the Major-High Damage Severity category, the percentage of damaged home value that is unmet
need is $72,961/$102,046 =71.5%. For the Severe Damage category the result is 100% of the value
of the house or construction value of the apartment. These percentages were applied to the median
price of housing in each county or ZIP code, and then multiplied by the count of damaged homeowner
occupied properties in each damage severity category to obtain a category level dollar estimate of
unmet needs for the homeowners in each county and ZIP code. These are then summed to arrive at
estimated total dollars of unmet needs for homeowners in the county or ZIP code.
For renters a similar procedure is used. The HUD method provides damage category thresholds for
renters based on the renter’s FVL, with FVL for renters being based on personal property loss. The
HUD method does not, however, specify a multiplier for the damage severity categories for renters.
Accordingly, the same percentage damage to structure value estimate used for homeowners was also
applied to renter damage severity categories (57.8% for the Major-Low Damage Severity category,
71.5% for the Major-High Damage Severity category, and 100% for the Severe Damage category).
For renters, instead of the median value of the damaged home being the basis of the calculation as it
was for homeowners, the basis for renters was the construction cost of providing an 861 square feet
rental unit with a footprint of 24'×35'. This construction cost has a nationwide range of $64,575 to
$86,100 per unit as mentioned previously. Again, the midpoint of $75,337.50 was used for valuation
total loss for a rental unit, and for renters the percentage in each severity category was applied to this
basic value. The percentage times the rental unit construction cost values were multiplied by the
count of renters in the severity category to obtain an unmet need value for renters in each of the
57
https://www.fixr.com/costs/build-apartment
Page 273 of 420
severity categories. Summing over severity categories yielded an estimate of unmet need to renters
in the county or ZIP code. The unmet needs for homeowners and renters were added together to
calculate the total unmet need value for the county or ZIP code.
A 15% resiliency factor on unmet needs was added to all counties and ZIP codes entries. The
resiliency factor represents the enhancements, improvements, or other components integrated into a
structure to increase its capacity to respond to, or recover from, a disaster more quickly than if these
components had not been integrated.
For counties in the 80% allocation group that had both the county and a ZIP code with parts
overlapping with the county designated as highly impacted in the Federal Register, the ZIP code level
data were split into ZIP code-county pairs and the unmet need plus resiliency for the county
(excluding any overlap with the City of Houston counts) was combined with the ZIP code county
pair data for that county to obtain a single combined entity for the county. ZIP code county pair data
that involved the same county were also combined into a single entity. For example, Fort Bend
(excluding City of Houston and the Fort Bend part of ZIP code 77423) was combined with the Fort
Bend part of ZIP code 77423 to obtain a single Fort Bend total entry for the analysis of Fort Bend
County allocation. Likewise, when there were multiple ZIP code county pairs involving the same
county, these were combined to obtain a single ZIP code county entry for analysis.
The raw SoVI indices for the 49 impacted counties were obtained from Dr. Christopher Emrich at
the University of Central Florida, a leading expert in the development of the Social Vulnerability
Index (SoVI). The Social Vulnerability Index (SoVI), was created by Cutter et al. (Cutter, S. L.,
Boruff, B. J., & Shirley, W. L. (2003). “Social vulnerability to environmental hazards,” Social
Science Quarterly, 84(2), 242–261). The index was created at the University of South Carolina. The
idea behind social vulnerability, and its relevance in the context of the work presented here, is that
social vulnerability arises from certain geographically identifiable population groups have limited
access to political power and resources, have certain physical limitations, or are bound by customs,
social capital, beliefs, and characteristics of the built environment (such as density and infrastructure
type, building age and stock, etc.). The idea of social vulnerability is that it makes the socially
vulnerable people (here, counties) more susceptible to and less resilient to a catastrophic event. More
vulnerable groups are less likely to be able to respond and recover from such catastrophic events on
their own should they occur. The index is useful to quantify, describe and understand the social
burdens of a risk, such as a catastrophe.
The mathematical development of the original SoVI started by identifying those social characteristics
consistently seen in the literature as contributing to social vulnerability. A literature review process
was used by the inventors of SoVI to distill the universe of possible vulnerability measures down to
a subset of variables including, wealth, proportion of elderly residents in a county, race, social status
variables, Hispanic ethnicity, percent of residents without health insurance, persons with special
needs, service industry employment, Native American population, and gender, etc.. These variables
are entered into a statistical principal component factor analysis resulting in 11 components that
explains 76.4% of the variance in social vulnerability relative to the original data set. The resultant
SoVI index for a county is a linear combination of the factors derived. The latest SoVI index now
uses 29 variables and synthesizes socioeconomic variables obtained from data sources primarily from
the United States Census Bureau. A more extensive discussion and presentation of SoVI is given at
http://artsandsciences.sc.edu/geog/hvri/sovi%C2%AE-0.
Page 274 of 420

For purposes of these analyses, a SoVI scale was needed to compare social vulnerability across
affected Hurricane Harvey declared disaster areas (49 Counties). For the analysis in this allocation
process the SoVI analysis utilized 48 impacted counties since Harris County was identified for
individual funding separately from these analyses.
Again, Dr. Christopher Emrich completed the SoVI computations and supplied the SoVI scores for
all of the 49 declared disaster counties. Dr. Emrich is the Boardman Endowed Associate Professor
of Environmental Science and Public Administration and a member of the National Center for
Integrated Coastal Research at the University of Central Florida.
For the purpose of utilizing the SoVI score as a part of the allocation process, an adjustment of the
raw SoVI was needed to make it positive. This was accomplished for each county by subtracting the
minimum raw SoVI value among all counties from the particular county SoVI value, and then adding
one to the result. This makes all values greater than or equal to one.
Another factor used for the allocation decision was the ability of a county (or ZIP code) population
to sustain and/or recover from the disaster by raising or utilizing their own funds. For this purpose
the unmet need per capita was calculated. This method also accounts for the differences in population
between rural and urban areas. For each county or ZIP code the unmet need per capita was calculated
by dividing the unmet need amount (plus resiliency factor) developed by severity level by the
population size.
The allocation of funds by county and ZIP code involved a weighted combination of the unmet needs
per county (or ZIP code), the positive SoVI and the per capita unmet need for each county (or ZIP
code). To facilitate this, a separate distribution percentage was determined for each of these three
factors providing the distribution percentages that would be applicable were this factor the only factor
in consideration. These factor distributions in turn were subsequently combined to present a single
percentage allocation distribution across all counties (and ZIP codes when relevant).
The distributions for the 80% allocation and the 20% allocations were determined separately with
the 80% group and the 20% group delineated by the Federal Register, minus Harris County and the
City of Houston. Thus, for the 80% allocation group the distribution percentage based on unmet need
plus resiliency was calculated for each county and ZIP code by taking the county or ZIP code’s unmet
need plus resiliency score and dividing it by the sum of the unmet need plus resiliency scores over
all county and ZIP codes in the 80% allocation group.
Similarly, for the SoVI based distribution percentage of 1+(Raw SoVI - Min(Raw SoVI)), the
1+(Raw SoVI - Min(Raw SoVI)) value for the county was divided by the sum of the 1+(Raw SoVI
- Min(Raw SoVI)) scores over all counties in the 80% allocation group which gives the distribution
percentage for the positive SoVI scores. Likewise, for the distribution percentage based on unmet
needs per capita, the county or ZIP code per capita unmet need plus resiliency for a county or ZIP
code was divided by the sum of the unmet need per capita value across all counties and ZIP codes in
the 80% allocation group. An analogous process was used for the 20% allocation group of counties
only. This methodology determines the percent allocation to each county (or ZIP code) that would
ensue were that factor to be the only factor in consideration. That is, the first unmet need factor,
determines the percentage allocation distribution that would apply if unmet need were the only factor.
The SoVI factor presents the percentage allocation distribution that would apply if social
vulnerability of the distressed population were the only factor, etc.
Page 275 of 420

These factor considerations are not viewed in isolation as the three need to be combined to produce
a single number. Combining the unmet needs plus resiliency distribution, and the positive SoVI
distribution, and the unmet need plus resiliency per capita distribution was achieved by using a 50-
40-10 model that takes a weighted combination of the three distributions with 50% weight given to
the unmet needs plus resiliency percentage distribution, 40% weight to the positive SoVI distribution,
and 10% weight to the per capita unmet need plus resiliency distribution. This 50-40-10 weighting
determines a funding allocation percentage for each county by using the Unmet need for the county,
the SoVI index for the county, and the per capita unmet need for the county. A weighting of the three
components: Unmet need, SoVI, and Per capita unmet need via the final percentage contribution
weighting for each factor of 50%-40%-10% was used in previous disaster relief efforts. The dollar
allocation amounts obtained using the 50-40-10 model without imposing any constraints on the
amount of funding were calculated using the percentage distribution values for the county or ZIP
code to the total dollar amount to be allocated (80% of the available funds in the 80% group and 20%
of the funds in the 20% group).
The shortfall column displays the unmet need plus resiliency factor for a county or ZIP code versus
the amount they would receive using the unconstrained 50-40-10 model dollar allocation. This
column presents how much under or over their unmet need the county or ZIP codes is by using the
unconstrained 50-40-10 weighting allocation process.
Practicality dictates that there be a minimum allocation amount for counties since it is costly to apply
for funding and to create the policies, administrative procedures, and personnel to implement the
processing and distribution of the HUD funds. This minimum allocation amount was set at
$2,000,000 and applied to all allocation decisions in the State Homeowner Assistance Program
spreadsheet and the 80% allocation group in the Local Buyout/Acquisition Program spreadsheet.
Over-allocating funds to a county far beyond their unmet needs is not reasonable, especially if other
counties have not yet received their unmet need. Accordingly, a maximum allocation amount
constraint is imposed with a cap being set at 200% of the unmet needs plus resiliency amount for the
funding of counties. These two numbers (cap and floor) provide constraints on the funding a county
or ZIP code can receive in a given allocation. If a county or ZIP code reached its maximum allocation,
then any funds ascribed to them by the 50-40-10 rule above and beyond their maximum were
available for reallocation and distribution to other counties or ZIP codes not having reached their
maximum.
This reallocation process was performed in a sequential process of traunch allocations. In the 80%
funding group there was enough funding for two traunches before all monies were fully allocated.
As the spreadsheet shows, the majority of areas in the 80% allocation category did not reach their
maximum in the first traunch allocation.
Regarding the second traunch process, as was done for the first traunch, an allocative percentage
distribution had to be developed to apply to the amount available for distribution in order to direct
the fund allocation. Here, however, zero percent additional allocation was given to those entities
(counties or ZIP codes) that had already obtained their maximum allocation according to the formula
To achieve this second traunch allocation, the original 50-40-10 distribution probabilities for the
counties that had not yet reached their maximum were renormalized to create a an allocative
percentage distribution for second traunch funding. This was done by dividing the original
percentages by the sum of the percentages of the areas remaining below their cap, with the goal of
Page 276 of 420

allocating 100% of unmet need in the second traunch if possible. That was accomplished for the 80%
group as described above.
Because funding was allocated to both counties and ZIP codes in the 80% allocation subgroup, and
because all ZIP codes overlap with either an 80% allocation county or a 20% allocation county, care
had to be taken to avoid the structural issue of double allocation (double counting) due to this overlap.
The overlap had to be subtracted out from the county to avoid over counting.
This process involved using the actual damage data by ZIP code and breaking the data into ZIP code
county pairs. The population count total for the county was also adjusted to remove population of the
county that had already been counted in the ZIP code population. This process eliminated double
counting when there was overlap in county and ZIP data. This process was used for all overlaps. The
same process was used to remove the effect of overlap of ZIP code allocation and county allocation
in the 20% not most heavily impacted allocation subgroup.
Since the city of Houston will receive a separate allocation, it was necessary to delete the overlaps of
the city of Houston counts from any counties or ZIP codes with which it overlaps. Using detailed
FEMA verified loss data from the FEMA data set of counts of damage severity levels by homeowners
and renters, it was possible to identify and extract the totals for the city of Houston homeowners and
renters for all three severity levels. These numbers were then used to exclude city of Houston data
from being counted in any other entity being allocated funds, just as previously described for
overlapping counties and ZIP codes. Population counts and unmet need amounts already
corresponding to Houston residences were removed from the Fort Bend data set.
20% State Homeowner Assistance Program and Local Buyout/Acquisition Program Allocation
Group Required by HUD in the Federal Register of February 9, 2018
The process for the 20% State Homeowner Assistance Program and Local Buyout/Acquisition
Program allocation counties was the same as described for the 80% allocation counties for both the
State Homeowner Assistance Program and Local Buyout/Acquisition Program 80% groups. Namely
a minimum allocation amount was determined and after that, residual funds were allocated in
traunches with maximum allocations imposed at each traunch.
The minimum allocation amount for the 20% Local Buyout/Acquisition required a reasonable
determination for that group separately as there was not enough money available to give all 33
counties a minimum of $2,000,000. This was accomplished by using a buildup approach that
incorporated necessary administration costs for a buyout, unmet needs for the most impacted county,
and the likely buyout percentage of houses in the most impacted county for the 20% Local
Buyout/Acquisition group.
Known administrative costs are that program (2%) and project (10%) administrative costs equal 12%
of the money in a buyout grant award (total grant award). The county with the largest unmet need in
this group is Waller County with $19,548,797 of unmet need. Waller County also has the largest
number of damaged residences (177 total) and the largest total number of properties in the Major-
High and Severe Damage categories (105 total). Properties in the Major-High and Severe Damage
categories are the most likely to be bought out, with 105/177 =59% of damaged houses in the most
damaged county (Waller) being likely to be bought out. These data served as a reasonable and
equitable methodology to calculate the minimum allocation dollars. Multiplying 12% administrative
costs by this unmet need results in .12 x .59 x $19,548,797 = $1,384,055 minimum for each county.
Page 277 of 420
There were eight counties in the State Homeowner Assistance Program and Local
Buyout/Acquisition Program 20% allocation groups that received the minimum distribution in the
first traunch. These were counties that did not receive a FEMA IA county declaration and did not
meet the minimum threshold. However, these counties received a FEMA PA declaration making
them eligible for CDBG-DR funds.
Thus, for the 20% Local Buyout/Acquisition Program group, the first traunch allocated the minimum
to the 33 counties, and this sum ($45,673,815) was subtracted from the amount available for
allocation in the 20% group buyout funding process. This residual amount after minimally funding
all counties was then fully allocated using two more traunches after imposing a maximum allocation
constraint of 200% of unmet need plus resiliency to all counties. When monies ran out with the
second traunch, four counties had reached their 200% of unmet need maximum.
Allocation of State Homeowner Assistance Program Funds Designated in Action Plan Amendment
2
No changes to the initial allocation of State Homeowner Assistance Program funds to regional COGs
was made for the purpose of Amendment 2. However, due to the change in designation of several
geographic areas from State Most Impacted and Distressed to HUD Most Impacted and Distressed
discussed in the HUD memorandum regarding methodology for funding allocation under Public Law
115-123 dated April 10, 2018, the initial allocation to areas re-classified as HUD Most Impacted and
Distressed was moved to the appropriate funding category. The total dollar allocation to those
specific areas did not change and thus the amount allocated to the COGs did not change.
In order to allocate the $236,210,909 in additional State Homeowner Assistance funds designated in
Amendment 2 of the State Action Plan, the following updates were mad to the HAP allocation model:
 Re-classified four counties and four zip codes as HUD Most Impacted and Distressed rather
than State Most Impacted and Distressed in accordance with Federal Register/Vol. 83 No.
157 / Tuesday, August 14, 2018 / Notices;
 Updated need multipliers in accordance and associated percentage adjustments with HUD’s
updated values provided in memorandum dated April 10, 2018 regarding “Methodology for
Funding Allocation Under Public Law 115-123” (resulting in percentage adjustment of 55.6%
for the Major-Low Damage Severity category, 74.4% for the Major-High Damage Severity
category, and 100% for the Severe Damage category);
 Updated Federal Emergency Management Agency (FEMA) Individual Assistance (IA) data
(from February 2, 2018 to June 25, 2018);
 Updated U.S. Census data, including population and median housing value estimates (from
July 1, 2016 to July 1, 2017);
 Applied the maximum allocation constraint to counties and zip codes of two times their unmet
need calculation based on the total allocation from the initial allocation of $1,048,011,316 in
funds and $236,210,909 in additional funds. Therefore, many State Most Impacted and
Distressed counties and zip codes did not receive additional funds in Amendment 2.
Funds that could not be distributed to State Most Impacted and Distressed areas due to the maximum
allocation being reached by all entities were reallocated and distributed to HUD Most Impacted and
Distressed areas, resulting in greater than 80 percent of total program funds going to HUD Most
Impacted and Distressed areas.
B. Local Infrastructure Program Allocation
Page 278 of 420

Hurricane Harvey Infrastructure Allocation Analyses
Professors Patrick Brockett, Rajiv Garg, Linda Golden, James Nolen and Alisa Walch
University of Texas at Austin, March 27, 2018
1) The list of the HUD Most Impacted Counties and ZIP Codes comes from the Federal Register,
Federal Register / Vol. 83, No. 28 / Friday, February 9, 2018 / Notices, Table 1.
2) Data on 2016 population by county population comes County populations were obtained from
the U.S. Census 2016 American Community Survey and other updated information 58.
3) The data set for the projected PA cost was supplied by FEMA Public Assistance (PA) Cost as
of 2/1/2018.
4) The split of 80% to HUD identified most impacted and distresses counties and 20% to
remaining impacted and distressed counties including most impacted ZIP codes is specified in
Federal Register / Vol. 83, No. 28 / Friday, February 9, 2018 / Notices.
5) Harris County has been omitted from the allocation as it will receive funds directly from the
State. Harris County PA Infrastructure claims represented over 93% of the total claims for all
49 counties. The amount of HUD funds to be distributed to the 48 remaining counties is
$413,431,338 with 80% going to HUD determined most impacted and distresses counties
($330,745,070.40) and 20% to the impacted counties and most impacted ZIP codes
($82,686,267.60).
6) Unmet need was calculated using a 10% county matching requirement on total project costs.
7) A resiliency factor was calculated as 15% of total project costs. The resiliency factor represents
the enhancements, improvements, or other components integrated into a structure to increase
its capacity to respond to, or recover from, a disaster more quickly that if these components
had not been integrated.
8) The component [1+ Raw SoVI - Min Raw SoVI]: was calculated based on raw Social
Vulnerability Index (SoVI) scores at the county level. The raw SoVI is made positive by adding
one (1) to each county's raw SoVI minus the minimum raw SoVI score of each of the 49
counties. The raw SoVI scores for the 49 counties were provided by Dr. Christopher Emrich of
the University of Central Florida, National Center for Integrated Coastal Research, and
communicated on February 19, 2018. The raw SoVI indices for the 49 impacted counties were
obtained from Dr. Christopher Emrich at the University of Central Florida, an expert in the
Social Vulnerability Index (SoVI) development. The Social Vulnerability Index (SoVI), was
created by Cutter et al.(Cutter, S. L.,Boruff, B. J., & Shirley, W. L. (2003).”Social vulnerability
to environmental hazards,” Social Science Quarterly, 84(2), 242–261). The index was created
at the University of South Carolina. The idea behind social vulnerability, and its relevance in
the context of the work presented here, is that social vulnerability arises from certain
geographically identifiable population groups having limited access to political power and
resources, having certain physical limitations, or being bound by customs, social capital, beliefs,
and characteristics of the built environment (such as density and infrastructure type, building
age and stock, etc.).
58
https://www.census.gov/search-
results.html?page=1&stateGeo=&searchtype=web&cssp=&q=texas+counties+population&search.x=0&search.y=0&se
arch=submit
Page 279 of 420
The idea of social vulnerability is that it makes the socially vulnerable people more susceptible
to, and less resilient to a catastrophic event. More vulnerable groups are less likely to be able to
respond and recover from such catastrophic events on their own should they occur. The index
is useful to quantify, describe, and understand the social burdens of a risk, such as a catastrophe.
The mathematical development of SoVI starts by identifying those social characteristics

consistently seen in the literature as contributing to social vulnerability. A literature review
process was used by the inventors of SoVI to distill the universe of possible vulnerability
measures down to 27 variables. These 27 variables (including, wealth; proportion of elderly
residents in a county, race, social status variables, Hispanic ethnicity, percent of residents
without health insurance, persons with special needs, service industry employment, Native
American population, and gender, etc.) are entered into a statistical principal component factor
analysis resulting in 11 components that explain 76.4% of the variance in social vulnerability
relative to the original data set. The resultant SoVI index for a county is a linear combination
of the factors derived. The SoVI index and its synthesized socioeconomic variables are obtained
from data sources primarily from the United States Census Bureau. A more extensive discussion
and presentation of SoVI is given at: http://artsandsciences.sc.edu/geog/hvri/sovi%C2%AE-0.
For purposes of this analysis, a SoVI scale was needed to compare social vulnerability across
affected Hurricane Harvey declared disaster areas (49 Counties). Dr. Christopher Emrich was
recommended by Dr. Susan Cutter, one of the originators of this vulnerability index. Dr. Emrich
is the Boardman Endowed Associate Professor of Environmental Science and Public
Administration and a member of the National Center for Integrated Coastal Research at the
University of Central Florida. Dr. Emrich completed the computations and supplied the SoVI
scores for all of the 49 declared disaster counties. Since Harris County is receiving separate
funding from the State, it has been excluded from the PA Infrastructure Allocation table but the
SoVI scores for the other 48 counties would remain unchanged. According to Dr. Emrich, the
SoVI model requires 100 input minimums and were run against the 49 declared disaster
counties. Removing Harris county would not change the SoVI scores in the other remaining
counties.
9) Another factor used for the allocation decision was the ability of a county population to sustain
and/or recover from the disaster by raising or utilizing their own funds. For this purpose, the
unmet need per capita was calculated. This method also accounts for the differences in
population between rural and urban areas. For each county the unmet need per capita was
calculated by dividing the unmet need amount by the population size.
10) The allocation of funds involved a weighted combination of the unmet needs per county, the
positive SoVI and the per capita unmet need for each county. To facilitate this a separate
distribution percentage was determined for each of these three factors which were subsequently
combined for a single distribution across all counties. The distributions for the 80% allocation
(HUD Most Impacted Counties) and the 20% allocations (Impacted Counties and Most
Impacted ZIP Codes were determined through the guidance provided by the Federal Register.
Thus, for the 80% allocation group the distribution percentage based on unmet need plus
resiliency was calculated for each county by taking the county unmet need plus resiliency and
dividing it by the sum of the unmet need plus resiliency over all county in the 80% allocation
group. Similarly, for the SoVI based distribution percentage of 1+(Raw SoVI - Min(Raw
SoVI)), the 1+(Raw SoVI - Min(Raw SoVI)) value for the county was divided by the sum of
the 1+(Raw SoVI - Min(Raw SoVI)) values over all counties in the 80% allocation group which
Page 280 of 420
gives the distribution percentage for the positive SoVI scores. Likewise, for the distribution
percentage based on unmet needs per capita, the county per capita unmet need plus resiliency
for a county was divided by the sum of the unmet need per capita value across all counties in
the 80% allocation group (HUD Most Impacted Counties). An analogous process was used for
the 20% allocation group (Impacted Counties and Most Impacted ZIP Codes).
Concatenation of the unmet needs plus resiliency distribution, and the positive SoVI
distribution, and the unmet need plus resiliency per capita distribution was achieved by using a
50-40-10 model that takes a weighted combination of the three distributions with 50% weight
given to the unmet needs plus resiliency percentage distribution, 40% weight to the positive
SoVI distribution, and 10% weight to the per capita unmet need plus resiliency distribution.
This 50-40-10 weighting determines a funding allocation percentage for each county by using:
Unmet need plus resiliency in the county, the SoVI index for the county, and the unmet used
per capita for the county.
11) The dollar allocation amounts using the 50-40-10 model without imposing any constraints on
the amount of HUD funding were obtained by applying the percentage distribution values to
the county to the total dollar amount to be allocated (80% of the available funds in the 80%
group (HUD Most Impacted Counties) and 20% of the funds in the 20% group (Impacted
Counties and Most Impacted ZIP Codes).
The shortfall (or surplus) displays the unmet needs plus resiliency versus the amount they would
receive using the unconstrained 50-40-10 model dollar allocation. This presents how much
under or over their unmet need the county are by using an unconstrained 50-40-10 weighting
allocation process, as described previously.
Practicality dictates that there be a minimum allocation amount for counties since it is costly to
apply for funding and to create the policies, procedures, and personnel to implement the
processing and distribution of the HUD funds. This minimum allocation amount was set at
$510,000 and applied to all allocation decisions. Likewise, over-allocating funds to a county far
beyond their unmet needs is not reasonable, especially if other counties have not yet received
even their unmet need. Accordingly, if all counties in the group have not yet received their
unmet need allocation amount, then a maximum allocation amount constraint is imposed with
a cap being set at 200% of the unmet needs plus resiliency amount for the funding of counties.
These two numbers (cap and floor) provide constraints on the funding a county can receive in
a given allocation. If a county reached the higher of the minimum distribution or the maximum
allocation, then any funds ascribed to them by the 50-40-10 rule above and beyond their
maximum were available for reallocation and distribution to other counties. This reallocation
process was performed in a sequential process of traunch allocations. In the 80% funding group
of most impacted counties, all counties had unmet needs above the minimum. However, there
were only enough funds for two traunches before all monies were fully allocated and with some
counties not receiving their maximum allocation before funds were exhausted. As the
spreadsheet shows, only 4 counties of the 15 counties in the 80% allocation category reached
their maximum 200% of unmet need and 3 counties did not receive 100% of their unmet need
before funds ran out in the second traunch. In the 20% group of impacted counties and most
impacted ZIP codes, all counties received at least the maximum distribution of 200% of unmet
need plus resiliency. To fully disburse all of the funds allocated by HUD to this 20% group, the
minimum allocation was set at $510,000. Some of the counties receiving the minimum
distribution exceed 200% of their unmet need and are generally the counties with lower unmet
Page 281 of 420
needs but high social vulnerability. Due to rounding, $208.17 of excess funds after the second
traunch was allocated to the highest unmet need in the 20% group and was the last county to
reach the maximum distribution at the end of the second traunch.
Regarding the second and third traunch processes, the percentage distribution had to be
developed for the fund allocation, as was done for the first traunch. To do this, the original 50-
40-10 distribution percentages for the counties that had not yet reached their maximum were
renormalized to create a percentage distribution for second and third traunch fundings. This was
done by dividing the original percentages by the sum of the percentages of the areas remaining
below their cap with the goal of allocating 100% of unmet need in the second traunch if possible
and distributing up to the maximum allocation or the remainder of the funds by the third traunch.
For the 80% group, all allocated funds were disbursed by the second truanch. For the 20%
group, all funds were disbursed by the third traunch.
Page 282 of 420

13.1. Appendix G: City of Houston and Harris County Allocations –
Initial Action Plan
City of Houston Harris County State of Texas
HUD Unmet Need $1,240,915,000 $1,242,557,000 $2,598,543,000
Amount
Less Public Law 115-31 $0 ($43,465,600) ($14,334,400)
Allocation ($57.8 Million)
Public Law 115-56 $1,240,915,000 $1,199,091,400 $ 2,584,208,600
Allocation ($5.024
Billion)
Public Law 115-123 $94,357,700 $94,009,847 $463,807,453
Allocation ($652,175,000)
Less Economic ($25,000,000) ($25,000,000) $50,000,000
Revitalization Program
Allocation Adjustment to $1,310,272,700 $1,268,101,247 $3,098,016,053
Account for Economic
Revitalization
Less Administration (5%) ($65,513,635) ($63,405,062) ($154,900,803)
Allocated Program
Amounts $1,244,759,065 $1,204,696,185 $2,943,115,250
Add State Administration
&, Harris County & City
of Houston
Administration (2.5%)* $31,118,976 $30,117,405 $222,583,119
Allocation Amount $1,275,878,041 $1,234,813,590 $3,165,698,369
*Administration amounts have been adjusted for City of Houston, Harris County, and the State based
on City and County Programs. The City of Houston and Harris County received 2.5 percent of their
total program amounts for associated administrative costs. The 2.5 percent administration amounts
for the City and County Programs were taken from the State’s 5 percent previously budgeted for total
Administration.
Page 283 of 420

14.1. Appendix H: Public Comment – State of Texas
State of Texas Plan for Disaster Recovery: Amendment 3
Amendment 3 to the State of Texas Plan for Disaster Recovery: Hurricane Harvey — Round 1 (the
Amendment) was released on March 22, 2019, commencing the required 30-day public comment
period. The Amendment was posted on the GLO websites. The public comment period for the
document ran to April 20, 2019. The GLO distributed a statewide press release announcing the
availability of the Amendment on the GLO website. Additionally, the GLO sent out an email to over
1,100 recipients across the 49 eligible counties targeting local emergency management coordinators,
county and local government officials, public housing authorities, and other interested parties.
List of those that submitted comments:
Name Individual, County, City or

Last First Organization
Bocox Mary Ann Private Individual
Smith Jerry D. Private Individual
James Carolyn Private Individual
Rener Amy Private Individual
Tindall Mamie City of Houston
Zummo Rachel Texas Rio Grande Legal Aid
Parsons David City of Port Aransas
Odon Chad Private Individual
Smith Nancy Private Individual
Shelton Jimmy Private Individual
Lyssy Vern Private Individual
Sandy Kaddie Private Individual
Ward Jim Private Individual
Smith Konner Private Individual
Chaka Lola Private Individual
Harriss Melodie Private Individual
Guinn Gail Private Individual
Lurker Lance Private Individual
Sloan Maddie Texas Appleseed
The following is a summary of the comments received as well as the response.
Page 284 of 420

Comment Received: Regarding Section 5.1, State Administered Disaster Recovery Program,
the usage of declined or deobligated buyout and acquisition funds to produce additional
affordable rental properties is appropriate. However, the reallocation of infrastructure funds
should take place through a MOD Amendment with a public comment process. The SETRPC
MOD itself was not based on the required unmet need criteria and all funds should initially go
to underfunded areas and address actual unment need.
Staff Response: The Texas General Land Office appreciates this comment and shall give it adequate
consideration moving forward.
Comment Received: [Regarding Section 5.2, Harris County Administered Disaster Recovery
Program] It is not clear whether the recapture amount for the single-family new construction
period is prorated. Based on the language, we assume that the amount recaptured from the
homeowner will be down payment assistance only, and will be pro-rated over the 10-year
affordability period, but the specifics of resale and recapture need to be described in the Action
Plan per 83 FR 40314.
Response from Harris County: Harris County has per 83 FR 40314 established a recapture policy
for the Single-family New Construction program. The recapture policy is detailed in Harris County’s
the Single-family New Construction program Guidelines, which can be found at Harris County
recovery website at https://harrisrecovery.org/guidelines/.
The homebuyer must occupy the home as his/her principal residence throughout the affordability
period. Recapture, under the CDBG-DR guidelines, Federal Register 82 FR 61320, Vol. 82, No. 247,
83 FR 5844, Vol. 83, No. 28, and per HOME Final Program Rule 24 CFR 92, is triggered by any
transfer of ownership, either voluntary or involuntary, during the established CDBG-DR period of
affordability. These requirements are outlined in a written agreement between the homebuyer and
Harris County and enforced via lien on the property. The County recaptures the full amount of the
direct CDBG-DR subsidy to the homebuyer when there is a voluntary or involuntary transfer of the
property before the period of affordability is complete, provided that the net proceeds are greater than
or equal to the full amount of the direct CDBG-DR subsidy to the homebuyer.
 If the net proceeds from the sale of the home are not sufficient to recapture the full CDBG-
DR subsidy loan amount, Harris County will collect only what is available from net proceeds.
The amount recaptured will never exceed the net proceeds.
 To ensure awareness of the recapture requirements involved in receiving a CDBG-DR

subsidy loan through the CDBG-DR New Single-Family New Construction Program and
CDBG-DR Downpayment Assistance Program, Harris County staff will meet with all
applicants and discuss the recapture provision, written agreement, Deed of Trust, and Loan
Note.
Page 285 of 420

Comment Received: [Regarding Section 5.3 City of Houston Administered Disaster Recovery
Program] Because the City has chosen much longer lien periods than required by the FR notice,
we recommend the inclusion of an alternative option for homeowners, for example an
agreement to resell to another LMI homeowner at an affordable price, or the option for heirs
to take over the lien, as is provided in the Single Family Development Program. Such
alternative would prevent the loss of affordability and preserve and build wealth in low-income
families and communities.
Response from the City of Houston: HUD requires that the City of Houston select either the resale
or recapture method when setting up programs. The selected method must be used across the board
with all programs and cannot distinguish between Urgent Need and Low and Moderate Income (LMI)
homeowners. While the City has opted to use the recapture method, we are allowing for heirs to
continue to live in the property and transfer the lien.
Comment Received: The City has already included an option for the heirs to take over the lien
and compliance periods if the homeowner dies during the compliance period in the Single
Family Development Program, it should also include an option such as conveying the property
to another LMI homeowner at an affordable price to preserve affordability in the
neighborhood.
Response from the City of Houston: Please see the above response.
Comment Received: We remind the City that the location of lots for Single Family
Development Program must comply with fair housing requirements.
Response from the City of Houston: The City is aware of fair housing requirements and will be
taking this into consideration as we begin acquiring property.
Comment Received: A 20-year minimum lien period for reconstruction for the Multifamily
Rental Program is appropriate, and the City should incentivize longer affordability periods.
Response from the City of Houston: The City has incentivized a 40 year affordability period within
its recent NOFA for multifamily properties.
Comment Received: There is not a clear explanation of why the City has chosen to use the Low-
Income Housing Credit rent limits, 26 U.S. Code§ 42 (g)(2)(a), instead of High HOME rents in
the Multifamily Rental Program. This explanation should be included in order to enable the
public to provide responsive comments.
Response from the City of Houston: The High HOME rents target affordability for households to
65% of AMI, but does not for Extremely Low Income and Very Low Income households that include
those below 30% of AMI and 30% -50% AMI. HCDD used the Section 42 rent index to clearly
identify targeting to these households which developers and housing providers were already familiar
with.
Page 286 of 420

Comment Received: The Small Rental Program should include income proportionality
requirements. Landlords will be receiving assistance on income-producing property on the
same terms as homeowners; they should be providing affordability on the same terms in order
for the program to avoid replacing affordable housing with less affordable housing.
Response from the City of Houston: Landlords receiving assistance through the Small Rental
Program will all have affordability requirements. The City will monitor compliance to ensure the
continued affordability of housing assisted with disaster recovery funding.
Comment Received: A buyout program that provides additional assistance to LMI

homeowners in order to ensure that they can move to safer areas is critical, and we appreciate
that the City of Houston's buyout program include these kinds of incentives and assistance.
However, the language of the Action Plan appears to say that such assistance is capped at
$31,000 over the post-disaster fair market value of the home, which would leave homeowners
in the areas most in need of buyouts -including areas where repeat flooding and proximity to
environmental hazards have depressed property values -with the least amount of assistance
that may be inadequate to enable them to move. These homeowners should be eligible for the
maximum amount of assistance.
Response from the City of Houston: At this time, HCDD is in development of its buyout guidelines
that will be released later this year. HCDD is currently developing a multifamily buyout strategy to
offer post-storm value to existing property owners. The program would also include relocation
assistance to relocate eligible households out of the floodplain and floodway.
Comment Received: It is unclear how the addition of two national objectives will affect the
Economic Revitalization Program. Any job training and job creation incentives must be
directed towards LMI residents of disaster-affected neighborhoods. This also aligns with the
City's required Section 3 compliance.
Response from the City of Houston: The City will target funding for LMI communities
(specifically the Complete Communities). We will also focus on programs and service that support
small businesses that employ or will hire LMI employees. Programs currently under development
are: Access to Capital- lending; Facade Improvements- grants; and Business Innovation - lending
and grants.
Comment Received: This City's commitment to planning activities that "will promote sound,
sustainable long-term recovery planning informed by a post-disaster evaluation of hazard risk,
especially land-use decisions that reflect responsible flood plain management and take into
account future possible extreme weather events and other natural hazards and long-term
risks" is correct. We particularly appreciate both the City's commitment to community
engagement in planning, and to using a post-disaster evaluation of hazard risks.
Response from the City of Houston: Thank you for your comment.
Comment Received: Citizen Participation Houston Local Action Plan: There were no
identifiable changed from the language of Amendment Two to the Action Plan to the language
of Amendment Three of the Action Plan. Please identify which changes have been made, if any.
Page 287 of 420

Response from the City of Houston: The City removed language about the Local Action Plan
amendment process as the amendment process for Houston's sections is now incorporated into the
State's Action Plan process.
Comment Received: My home has been mortgage free for more than fifty years prior to
Harvey. Because of the damage sustained, I am now thousands of dollars in debt related to
financing repairs. I propose $136.5 million be made available for homeowner reimbursement
of repairs with any remaining funds allocated to Harris County and Houston for social
programs.
Staff Response: The Texas General Land Office recognizes the unique issues presented to Texans
in the face of recovering from a disaster. It remains the goal of the agency to ensure that all Texans
have access to an effective and efficient disaster recovery through a diverse group of recovery
programs and policies.
Response from the City of Houston: Thank you for your thoughtful input regarding the Harvey
State Action Plan's Third Amendment. The City of Houston Housing and Community Development
Department (HCDD) appreciates your input and has given consideration to your comments. As
currently structured in the proposed Amendment, over 88% of all funding is set aside for housing
programs to assist those affected by Hurricane Harvey. The Homeowner Assistance Program is
funded at a level of $427,900,063 and includes a Reimbursement Program that provides assistance
to homeowners that have incurred expenses to repair their homes.
Comment Received: It is requested that a portion of the $37.6 million dollars reallocated to the
Multi-Family Affordable Housing projects be allocated to projects that were erroneously
issued a conditional letter of award in Fall of 2018.
Staff Response: The Texas General Land Office shall give this comment adequate consideration as
it moves forward with utilizing the reallocated funding.
Comment Received: Obtaining disaster recovery assistance has been complex and I am unsure
of whether or not I am approved to receive grant funding.
Staff Response: The Texas General Land Office remains committed to ensuring all Texans have
access to the resources they need to achieve an effective and efficient recovery process. Any citizens
who may be having difficulties in navigating programs are strongly encouraged to reach out to the
GLO directly for support in resolving those issues.
Comment Received: It is time to get people back into their homes, let's get the ball rolling.
Comment made in full support of Amendment 3.
Staff Response: The Texas General Land Office appreciates the support of this comment and shall
continue to work to provide the most comprehensive disaster recovery process possible.
Comment Received: The Commissioners Court of Harris County, Texas approves and
supports the amended State of Texas Action Plan for Hurricane Harvey Round 1 CDBG-DR
funding Amendment #3 by the Texas General Land Office.
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Staff Response: The Texas General Land Office appreciates the support of this comment and shall
continue to work to provide the most comprehensive disaster recovery process possible.
Comment Received: The changes made in Amendment 3 do not meet the needs of impacted
renter households. The FEMA Verified Loss threshold to determined unmet need for renters
does not properly address the unique challenges faced by renters. As a result, the vast majority
of renters (which reflect 50% of FEMA applicant households) are not qualified to receive the
assistance necessary to recover.
Staff Response: The Texas General Land Office recognizes the unique issues faced by impacted
renter households and has worked to utilize other data, like the Social Vulnerability Index, to provide
the most wholistic view of need possible. The GLO remains committed to exploring other means of
analysis to address issues like those brought up in this comment.
Comment Received: The City of Port of Aransas is requesting an amended to the State Action
Plan that would permit the city to keep funding that has been awarded specifically for Local
Buyouts, Acquisitions, and Infrastructure and apply those funds to the Affordable Housing
Program.
Staff Response: The Texas General Land Office shall, in the manner deemed best for fostering an
efficient and effective recovery process, consider the reallocation of funds as circumstance allow.
This comment will be given adequate consideration as the GLO moves forward with the disaster
recovery process.
Comment Received: The way in which the GLO has allocated the Round 2 $200 million in
funding has completely neglected the HUD designated most impacted and distressed areas.
Why did HGAC-West have a 13% drop in funding from Round 1?
Staff Response: The Texas General Land Office, in determining a method of distribution among the
HUD designated most impacted and distressed areas, considers the most up-to-date relevant data.
The result of these considerations are detailed and explained in the Action Plan.
Comment Received: Relying on FEMA data by county to assess Renter Unmet Needs does not
accurately account for the impact on The City of Wharton.
Comment Received: By not considering the proportion of total housing stock effected in a given
area, the distribution of funding is inequitable and disadvantageous to smaller communities.
The Round 2 MOD should be reassessed and the Round 3 MOD should be updated.
Staff Response: A central part of funding distribution for the Affordable Rental Program is the
GLO's methodology for determining remaining unmet need. This methodology must take into
consideration specific damage for pre-storm housing stock to ensure current MODs are working to
address remaining unmet needs for housing replacement. By using this formula, the GLO is helping
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communities address housing needs proportionate to their overall housing inventory damaged during
Hurricane Harvey.
Comment Received: The GLO should publish the detailed data and methodology used in
creating summary charts to inform their MODs in the Action Plan.
Staff Response: The formula and method of distribution were fully disclosed in the State Action
Plan Amendment 2 that was published and underwent a full public comment period. This
methodology can be found on page 61 of the Action Plan and viewed online at recovery.texas.gov.
Comment Received: The GLO has changed policy in requiring all scattered site projects to be
100% LMI and this impacts communities in that it excludes anyone who isn't LMI from
qualifying to live in rental units in their communities.
Staff Response: The Texas General Land Office remains committed to ensuring all disaster recovery
programs are administered in a manner that is compliant with all applicable federal law. In this
instance, 24 CFR §570.208(a)(3) controls and requires that 51% of any given housing structure be
reserved for LMI usage.
Comment Received: $200 million in federal funds have been inequitably distributed in the last
month, dramatically impairing housing recovery in Port Lavaca.
Hurricane Harvey. All information regarding MOD calculations can be found at recovery.texas.gov
and on page 61 of the Action Plan.
Comment Received: Round 2 Method of Distribution allocated 90% of total funds to only 9
counties and 2 COGs.
Staff Response: The formula for and final method of distribution were fully disclosed in the State
Action Plan Amendment 2 that was published and underwent a full public comment period. This
methodology can be found on page 61 of the Action Plan and viewed online at recovery.texas.gov.
Comment Received: The GLO should go beyond data analysis in forming the Affordable
Rental Program Round 3 MOD. This should include consultations with stakeholders, citizens,
and local governments.
Staff Response: All CDBG-DR Programs require, per federal law, a robust citizen participation
process to ensure all relevant stakeholders are consulted throughout the disaster recovery process.
This requirement is satisfied through the solicitation of public comments, consultation with local
governments and citizens, and other outreach programs.
Comment Received: We request that $37.6 million be moved to the Affordable Rental Housing
fund to help the housing shortage in Calhoun County and Port Lavaca.
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Staff Response: The Texas General Land Office shall, in the manner deemed best for fostering an
efficient and effective recovery process, consider the reallocation of funds as circumstance allow.
This comment will be given adequate consideration as the GLO moves forward with the disaster
recovery process.
Comment Received: The GLO should confirm that it did not accept applications during each
of the 3 priority funding times that did not meet the GLO-provided description of Rehab,
Recon, or New Construction. The GLO should also affirm that applications where no existing
unrepaired Harvey damage was document were rejected under the first 2 rounds of funding.
Staff Response: The Texas General Land Office, in processing applications for its programs, adheres
to all established policies and procedures. This compliance is inclusive of any and all Multifamily
Programs.
Comment Received: The Renter Unmet Need formula is based on a standard number
methodology that doesn't take into consideration proportionate impact and, as a result, skews
the true impact of losses.
Comment Received: Can we get clarification as to why the Yoakum project was accepted by
the GLO when it had very little damage from the storm? We ask that the GLO affirm that
applications with no existing Harvey damage were properly rejected under the first two rounds
of funding and only approved under the New Construction application submission period. We
ask that the GLO rescind all conditional letters of award issued in Round 2 and that didn't
follow Round 1 criteria and fund all three Port Lavaca projects.
Staff Response: The Texas General Land Office, in processing applications for its programs, adheres
to all established policies and procedures. This compliance is inclusive of any and all Multifamily
Programs.
Comment Received: The GLO allocated 90% of Round 2 funds to 9 counties and 2 COGs. The
GLO should include more than summary charts in providing reasoning for this allocation and
should post a link to supporting data, calculation, and methodologies.
Hurricane Harvey. All information regarding MOD calculations can be found at recovery.texas.gov
and on page 61 of the Action Plan.
Comment Received: The Action Plan only contains summary charts, tables, and maps and fails
to provide background data and calculations. The GLO should 'show its work'.
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Comment Received: Port Lavaca is in dire need of affordable housing! (Multiple respondents
provided this feedback.)
Comment Received: There is an absolute need for rental properties in Port Lavaca as much of
the labor force in the city has to live elsehere because housing is not currently available.
Comment Received: Port Lavaca is in dire need of affordable housing! All of our young people
have jobs locally, but no place to live. Please help our declining little town keep our young kids
local.
Comment Received: Port Lavaca is in need of housing. I have been looking for an affordable
place to live and there is nothing available.
Comment Received: The GLO has changed policy in requiring all scattered site projects to be
100% LMI and this impacts communities in that it excludes anyone who isn't LMI from
qualifying to live in rental units in their communities.
programs are administered in a manner that is compliant with all applicable federal law. In this
instance, 24 CFR §570.208(a)(3) controls and requires that 51% of any given housing structure be
reserved for LMI usage.
Page 292 of 420

Amendment) was released on November 19, 2018, commencing the required 30-day public comment
document ran to December 19, 2018. The GLO distributed a statewide press release announcing the
List of those who submitted comments:

Sloan Madison
Texas Appleseed
Sangueza Tony
Turner The Honorable Mayor
City of Houston
Sylvester
Zummo Rachel
Texas RioGrande Legal Aid, Inc.
Nathan Alexi
Comment Received: Amendment 2 should not reduce the affordability period for rehabilitated
and reconstructed multifamily properties from twenty to fifteen years.
Staff Response: The Texas General Land Office, in its commitment to implementing disaster
recovery programs within the bounds of federal law, designs programs and policies that comply with
the most currently issued guidance. In this case, the Federal Register notice associated with
Amendment 2 presents the following acceptable modifications to housing affordability periods:
a) For the rehabilitation or reconstruction of multi-family rental projects with eight or more
units, the minimum affordability period shall be fifteen (15) years.
b) For the new construction of multi-family rental projects with five or more units, the minimum
affordability period shall be twenty (20) years.
The Texas General Land Office has, as permitted under federal law, modified its housing
affordability periods to be in line with the most recently updated federal requirements.
Comment Received: Amendment 2 should provide metrics or guidelines to ensure that the
Local Infrastructure Program, the Homeowner Assistance Program, and Planning activities
meet the additional requirements established by the Federal Register.
Staff Response: The Texas General Land Office is in the process of developing specific policies and
procedures to comply with the additional requirements presented under the Federal Register
published August 14, 2018. This includes developing policies and procedures to assess cost-
effectiveness of assisted housing rehabilitation and reconstruction projects and ensuring Local
Infrastructure Programs and Planning Activities align with all presented criteria
Page 293 of 420
Comment Received: The State should continue using the most recent information available to
inform its disaster recovery programs.
Staff Response: The Texas General Land Office remains committed to utilizing the most up-to-date
data in the formation and implementation of all disaster recovery programs to ensure the best use of
limited recovery dollars.
Comment Received: The Affordable Rental Program is still inadequate to meet the unmet
needs of displaced renters.
Staff Response: The Texas General Land Office recognizes the potential for analytical gaps that
may exists when utilizing one data set over another in determining unmet need. To combat this, the
GLO has also utilized the Social Vulnerability Index to supplement the unmet needs analysis of
disaster areas.
It also deserves noting that each property in the Affordable Rental Program must, as a condition of
program participation, reserve a percentage of the units for usage by the LMI population in the area.
Each development must also participate in an Affirmative Marketing Plan that function to specifically
target vulnerable populations in the area to ensure affordable units are marketed to those least likely
to apply for those units. As the GLO completes necessary underwriting of applications it may become
possible to fund additional units.
It should be noted that although these housing developments and their corresponding marketing plans
do not specifically target Harvey survivors, they do present a increase in the overall availability and
quality of affordable housing stock in the area.
Comment Received: The State should conduct more consultation with citizens, in addition to
their consultation with stakeholders and local governments, to determine updates to local needs
assessments.
Staff Response: The Texas General Land Office has prioritized citizen participation throughout the
Hurricane Harvey recovery process. This consultation process has included ongoing and consistent
dialogues with affected citizens, stakeholders, local governments, long term recovery groups, and
public housing authorities to ensure that the disaster recovery process is specifically tailored to the
individualized needs of each community.
Although the GLO collaborates with local officials in guiding the formation and implementation of
disaster recovery programs, many projects are also statutorily required to undergo public comment
throughout the life of the project. The GLO remains committed to ensuring citizens remain a viable
part of the disaster recovery process.
Comment Received: We would like to reiterate our previous comments that the State, and not
regional or local governments, should be responsible for long-term planning.
Staff Response: The State recognizes this feedback and is committed to ensuring that all public
comments, previously submitted or otherwise, are given adequate consideration as Hurricane Harvey
recovery continues. Communities may choose to utilize portions of their infrastructure and buyout
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and acquisition funds for local planning needs but the planning allocation set aside in the Action Plan
will be administered directly by the GLO.
Comment Received: We continue to express concerns regarding the distribution methodology

utilized in the State’s Action Plan. Particularly, we remain concerned that the FEMA data
utilized systematically undercounts the unmet needs of renters and low-income families.
Staff Response: The Texas General Land Office remains committed to utilizing the most current
data available in assessing damage and unmet need in disaster areas. To date, the GLO has
incorporated historically utilized FEMA data into these calculations and, in addition to these data
sets, has utilized the Social Vulnerability Index in an effort to develop the most wholistic view of
need following Hurricane Harvey.
The GLO recognizes the issues that may be associated with analyzing one collection of data over
another and remains open to exploring processes and policies that incorporate reliable and accurate
data sets to develop the most effective recovery process possible.
Comment Received: We would also like to note that using FEMA damage severity categories
almost certainly underestimated unmet need in low- and moderate-income areas. It should be
noted that these homeowners likely did not have resources to make immediate repairs to their
homes a year ago (when the damage assessments were performed). The delay in repairs is likely
translate into many of these homes needing to be reconstructed (as opposed to repaired) as
damage has compounded over time.
Staff Response: The Texas General Land Office recognizes the validity of the content of this
comment and shall give it adequate consideration as programs progress. It should be noted that the
GLO remains committed to utilizing lessons learned from prior grant administration to ensure all
programs and policies continually evolve in a manner that presents the most benefit to disaster
victims.
Additionally, applicants are not limited in their application to programs if they have less damage
utilizing the FEMA damage assessment methodology. Eligibility must include a remaining unmet
need with consideration for any other sources of funds and repairs already completed. The program
is also committed to bringing any homes repaired or reconstructed up to housing quality standards
and local code and zoning.
Comment Received: We would like to applaud the State on the following: a. The State is
correctly using construction costs for a new unit of rental housing rather than FEMA’s
estimated personal property loss to estimate unmet need for affordable rental housing, and b.
The State’s use of the Social Vulnerability Index (SoVI) to evaluate unmeet need; however, the
State must ensure that funding based on SoVI actually reach the socially vulnerable areas.
Staff Response: The Texas General Land Office agrees that the damage-based data sets HUD must
use to compare states to one another is limited in its strength to allocate funds to regional and local
needs. By utilizing both per capita damage and the SoVI the formula as well as FEMA and SBA
damage estimates the GLO can consider a community and private applicants’ ability to recover from
other resources.
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Comment Received: We appreciate that there will be policies and processes for assessing cost-
effectiveness and we look forward to seeing these develop.
The Texas General Land Office remains committed to implementing disaster recovery programs in
a manner that satisfies all requirements under federal law. This commitment includes ensuring there
are policies and procedures in place that accurately access a cost-effectiveness analysis for projects
utilizing CDBG-DR funds.
Comment Received: We fully agree that consultation with ‘affected citizens’ is critical to the
development of needs assessments.
The Texas General Land Office remains committed to developing disaster recovery policies and
procedures which accurately address the individualized needs of each impacted community. In order
to achieve this goal, consultation with impacted local governments, officials, and citizens is required.
Comment Received: We would like to continue to emphasize the importance of consideration

future possible extreme weather events and other natural hazards in long-term planning.
All CDBG-DR funded programs and projects administered by the GLO work to ensure an effective
disaster recovery that fosters more resilient communities. This principle is inclusive of cognizant
planning that gives adequate consideration to the potential for the future impact of extreme weather
events or other natural hazards. All projects constructed are built to green and more resilient standards
which has shown from previous recovery to affect the projects ability to withstand future events.
Comment Received: We agree that planning activities must promote sound, sustainable, long-
term recovery planning and would like to emphasize that land-use decisions must take non-
natural hazards and long-term risks into account as well.
The GLO recognizes the validity of this comment and shall give it adequate consideration as
programs involving land-use decisions develop. As a part of federally required environmental
clearances the GLO considers the built environment and any known hazards as a part of program
eligibility and design.
Comment Received: We agree that the use of eminent domain powers must not benefit private
parties, but must be utilized in a manner that results in public use that reduces disaster risk.
The GLO will be allowing local communities to utilize eminent domain authorities as they see fit in
their recovery.
Comment Received: The State should not reduce the affordability period for rehabilitation and
reconstruction in the Affordable Multifamily Program. The Federal Register does establish
minimum affordability periods, but does not prevent the State from extending those period.
The Texas General Land Office remains committed to ensuring that all disaster recovery programs
are implemented in compliance with all applicable federal law. To date, applicable federal law
establishes a minimum affordability period of fifteen (15) years and it is the commitment of the GLO
to enforcing that provision
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Comment Received: We agree with the language specifying the requirements for Local
Infrastructure Program projects.
Comment Received: We agree with the requirement language presented for Planning Activities
and believe that jurisdictions that conduct or participate in a comprehensive Assessment of
Fair Housing will be best positioned to conduct effective planning.
Comment Received: The Method of Distribution completed by The South East Texas Regional
Planning Commission (SETRPC) does not comply with the State’s Action Plan, MOD
Guidelines, Federal Register Notice, or required civil rights certifications: a. SETRPC based
its suballocation of funds solely on an undefined distribution factor it called ‘storm impact’.
Although certain data sources were listed, it was not explained how these sources were used to
arrive at any particular breakdown of ‘impact’ by local jurisdiction, b. After further
information was provided to Texas Housers, it was determined that ‘storm impact’ was
determined by the development of a regional representation of water heights using inundation
maps created by FEMA after Harvey. This confirms that SETRPC allocated funds based solely
on level of inundation and total population in the inundated area without considering unmet
need, ability to recover, or the relative population of the impacted area, and c. SETRPC’s
method of distribution fails to include the required plan to facilitate meeting the 70% low- and
moderate-income requirement.
Staff Response: The GLO will review this Method of Distribution again to ensure all requirements
were met in its development. It should be mentioned that any allocations made from the MOD still
must comply with the requirement for 70% of the projects funds being spent on LMI eligible
activities, that the project have a direct tie back to Hurricane Harvey and a remaining unmet need.
Comment Received: We appreciate the GLO’s work and ongoing commitment to efficient and
equitable disaster recovery.
Comment Received: The City of Houston believes that the GLO, in keeping with the intent of
the Federal Register to ensure consistency across allocations for the same qualifying disasters,
should utilize the same methods for estimating unmet need for this allocation as it did for the
prior allocation. In using this formula, The City of Houston should receive a fourth of the total
funds under this amendment (about $162.5 million) to provide the most effective use of funds
in addressing the extensive unmet need that exists in Houston.
Staff Response: Please remember that the GLO is responsible for the allocation of funds to the entire
impact area and must consider datasets that are representative of that whole area. The Texas General
Land Office recognizes the incredibly devastating impact that Hurricane Harvey had on the City of
Houston and its citizens and, as a result, remains committed to fostering the most effective and
efficient recovery possible from the very limited funds provided to the State. The content of this
comment and the reasoning behind it shall be given adequate consideration as the GLO moves
forward with the implementation of disaster recovery programs.
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Amendment) was released on September 7, 2018, commencing the required 30-day public comment
document ran to October 6, 2018. The GLO distributed a statewide press release announcing the
List of those that submitted comments:

Cutts Dana Private Individual
Gallo Sandy PEG, LLC.
Gary Aaron Tempo Partners
Gonzalez Jose Carlos Gonzalez & Associated Homeland
Security Resource Allocation
Consulting
Luzier Michael Home Innovation Research Labs
Nathan Alexi Texas Rio Grande Legal Aid
Rainey Kate
Richards Jennifer
Zummo Rachel
Muñoz Ned Texas Association of Builders
Reinhardt Chris Private Individual
Shiyou-Woodard Julie Smart Home America

Sitter Paula Private Individual
Toole Jaclyn National Association of Home Builders
Comment Received: 1. Will any of these funds be allocated for the repair of yard damage
including landscaping, trees, fencing, etc.?; 2. Will rental costs paid while waiting for homes to
be made livable again be an eligible use of funds?; and 3. Will any of these funds be allocated
to cover the costs associated with living in FEMA approved hotels, cost of restaurant meals,
and other living expenses?
Staff Response: Community Development Block Grant for Disaster Recovery funds must be utilized
in a manner that complies with all applicable federal laws and regulations. Activities deemed eligible
for funding may be located first in federal law and second in individual program rules and regulations.
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Comment Received: 1. The National Association of Home Builders applauds the GLO’s
inclusive of industry-recognized green building standards in the Action Plan; and 2. The
National Association of Home Builders supports policy for voluntary green building programs
as it provides flexibility to builders and developers without compromising rigor.
Staff Response: The Texas General Land Office remains committed to ensuring Texas recovery
efforts align with the most effective and efficient building standards currently accepted within a given
industry. The inclusion of multiple green building programs in the State Action Plan Amendment 1
is intended to provide flexibility for funds while maintaining the highest standards.
Comment Received: Home Innovation Research Labs supports the Texas General Land
Office’s proposed amendment to the Texas State Action Plan which recognizes ICC/ASHRAE-
700 National Green Building Standard (NGBS) as a compliance method for the HUD
requirement that buildings seeking funding comply with green building standards.
Comment Received: PEG and Home Innovation Research Labs support the Texas General
Land Office’s proposed amendment to the Texas State Action Plan recognizing ICC/ASHRAE-
700 National Green Building Standard (NGBS) as a compliance method for the HUD
requirement that buildings seeking funding comply with green building standards.
industry. The inclusion of multiple green building programs works in the State Action Plan
Amendment 1 is intended to provide flexibility for funds while maintaining the highest standards.
Comment Received: I am in support of the revisions to the State Action Plan that change the
Quality Construction Standards to recognize multiple certification programs such as ENERGY
STAR, Enterprise Green Communities, LEED, and ICC-700 National Green Building
Standard. The initial language contained within the State Action Plan restricted recognition to
ENERGY STAR and was not competitive.
Comment Received: 1. Resiliency in Texas generally, and Houston in particular, could be aided
tremendously by the expansion of Medicaid; 2. AMI should be increased to 95%; 3.
Disbursement of CDBG-DR funds should not be allowed for those seeking settlement from
lawsuits against the Army Corps; and 4. Increase focus on citizen participation from the areas
with the largest unmet needs.
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Staff Response: The Texas General Land Office (GLO) is the primarily agency charged with the
administration of Community Development Block Grant for Disaster Recovery Funds. Our agency
has no authority over nor do we participate in any processes that may influence the expansion of
Medicaid in the State of Texas.
The GLO remains committed to administering CDBG-DR funds in a manner that complies with all
current federal law and regulation. Absent a HUD directive or federal law to the contrary, the GLO
does not retain the authority to adjust AMI percentages nor do we retain authority to make CDBG-
DR eligibility standards beyond what is in accordance with current law.
The GLO has and will continue to conduct robust citizen participation processes in accordance with
HUD requirements for all programs and areas associated with CDBG-DR funds.
Comment Received: 1. The Texas Association of Builders (TAB) commends the GLO for
including all of the green building program options listed by the U.S. Department of Housing
and Urban Development in the Amendment I of the State Action Plan for Community
Development Block Grant for Disaster Recovery funds; and 2. TAB respectfully requests that
the GLO also add Houston’s green building program, Green Built Gulf Coast, to the list of
industry-recognized standards listed in Addendum 1. The inclusion of this standard is logical
and adds a greater level of flexibility for builders in our region without compromising rigor.
The GLO shall give the suggestion of adding Houston’s green building program, Green Built Gulf
Coast, to the list of industry-recognized standards adequate consideration.
Comment Received: No money should go to those properties that were rental properties or to
properties owned by some entity other than a homeowner at the time of the flood event.
Staff Response: The disposition of Community Development Block Grant funds allocated for
Disaster Recovery purposes is governed by the rules and regulations set by the U.S. Department of
Housing and Urban Development through the publication of the Federal Register notice. The GLO
remains committed to ensuring that all CDBG-DR funds are administered in a manner that is
consistent with all Federal Register guidelines and applicable federal law.
Comment Received: 1. Smart Home America commends the GLO on its inclusion of the IBHS
Fortified Home resilient construction standards in the Hurricane Harvey Housing Design
Guidelines; 2. Smart Home America would also recommend the GLO consider inclusion of the
IBHS Fortified Home resilient construction standards directly in the State of Texas Plan for
Disaster Recovery as a quality construction standard; and 3. The addition of FORTIFIED
Home guidelines to the Action Plan should include the following language: ‘A Certificate of
Compliance issued as a part of the chosen standard’s compliance process will be required to be
submitted as proof of compliance’.
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Comment Received: I am 65 years old and disabled. When Harvey hit, the apartment complex
in which I was living, operated by The Houston Housing Authority, gave residents five days to
vacate the premises. These evictions were put on hold by Mayor Turner and Houston Housing
Authority was able to provide moving help in the form of man power and supplies. Many of
the disabled residents of my residence that was damaged by Harvey were moved into non-ADA
units and now, because the owner of these units is unwilling to renovate to meet our ADA needs,
are being moved again. Bottomline: I want to ensure that there is adequate oversight and
accountability for the processing of all the funds allocated to Houston. Please make sure that
ADA requirements are actually met in seeing that all complexes built are up to current ADA
code and regulation, including walk-in or roll-in showers for any senior living facilities.
Staff Response: All funds allocated as Community Development Block Grants for Disaster
Recovery in relation to Hurricane Harvey must, in accordance with federal law, meet specific
accessibility and fair housing standards. The Texas General Land Office remains committed to
ensuring that all funds are utilized in a manner consistent with federal law.
Comment Received: The City of Houston and Harris County allowed more robust public
engagement than did the State, raising equity issues.
Staff Response: The Texas General Land Office is committed to ensuring all disaster recovery
programs are administered in a manner that balances active engagement with impacted communities
with the expediency required for disaster recovery response. Given the severity and widespread
immediate aftermath of Hurricane Harvey, the U.S. Department of Housing and Urban Development
saw it fit to permit streamlined requirements for public comment that did not mandate public
hearings, but did mandate a minimum public comment period of not less than thirty days. The GLO
utilized this streamlined requirement as it was deemed reasonable under federal law.
Comment Received: By prioritizing transparency through a centralized and searchable

database, the GLO will prevent its limited resources from being spent on answering duplicative
public information requests.
Staff Response: The Texas General Land Office shall, in compliance with all federal requirements,
maintain a public facing website that accounts for how all grant funds are being used and
administered. This website shall include links to all action plans, action plan amendments, CDBG-
DR program policies and procedures, performance reports, citizen participation requirements, and
any other information deemed relevant and necessary under the law.
Comment Received: Action Plan Amendment 1 does not adequately tie its needs assessment to
its program allocation decisions.
Staff Response: The Action Plan Amendment 1 utilizes the most current data available to make all
allocation decisions. The GLO remains committed to ensuring the needs of communities are
adequately assessed and addressed to promote a comprehensive recovery for all impacted Texans.
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Comment Received: The Needs Assessment undervalues unmet needs among renters and LMI
households. The GLO has an obligation to use the CDBG-DR funds in a manner that will best
serve the impacted population by developing a methodology that properly accounts for the
needs of LMI households.
Staff Response: The Texas General Land Office has utilized the most current available data to
formulate unmet needs values across all impacted regions. This unmet needs analysis, combined with
a commitment to adhering to the requirement that 70% of the aggregate amount of funds be utilized
to benefit the LMI population, work to ensure that CDBG-DR funds are allocated in a manner that
will best serve all impacted households. Additionally, the GLO utilized the Social Vulnerability
Index (SVI) in calculating unmet need in an effort to account for some of the issues addressed in this
comment.
Comment Received: The GLO must address the inadequate allocation of funds to renter, who
are more likely to be African-American and Hispanic, to avoid any potential for a disparate
impact on these protected groups.
Staff Response: The Texas General Land Office is committed to administering CDBG-DR funds in
a manner that complies with all applicable federal law, including Title VI of the Civil Rights Act of
1964. Those efforts include an analysis that is cognizant of how pure empirical data must be
supplemented with data like that contained in the Social Vulnerability Index to reach a more wholistic
view of needs.
Comment Received: We have concerns about the Affordable Rental Program, including its
limited funding, program participation, and the past difficulties the GLO has faces in finding
suitable sites.
Staff Response: The Affordable Rental Program allows for the rehabilitation, reconstruction, and
new construction of units. The current program guidelines were designed in an effort to ensure that
the multifamily housing needs of those in the impact area are addressed as quickly and efficiently as
possible. The GLO shall give adequate consideration to the idea of permitting single-family home
rental properties under future Affordable Rental Programs.
Comment Received: The GLO should reallocate the $72.7 million for the Partial Repair and
Essential Power for Sheltering (‘PREPS’) match to the Affordable Rental Program by relying
on the rainy day fund or existing funds to cover this expense. Additionally, the GLO should
encourage local jurisdictions to focus on housing instead of covering cost shares for mitigation
and public assistance that can be done with future allocations.
Staff Response: The State of Texas, in an effort to ensure that impacted Texans were able to quickly
get back into their homes following Hurricane Harvey, made the decision to allocate $72.7 million
for the Partial Repair and Essential Power for Sheltering to cover the required funding match in order
for the program to move forward. The PREPS program has allowed for thousands of impacted Texans
to shelter in their homes while necessary repairs are being made and promotes a faster and less
financially burdensome recovery process for eligible applicants.
The GLO and all jurisdictions utilizing CDBG-DR funds are required, as presented in the federal
register, to primarily consider housing throughout the recovery process.
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Comment Received: We commend the GLO for not seeking a waiver to lower the requirement
that 70% of CDBG-DR funds be used to benefit LMI populations. We also applaud the GLO’s
recognition that needs assessments “should set goals within the income brackets similar to the
damage units within the impacted areas”.
Staff Response: The GLO recognizes the support provided in this comment.
Comment Received: It is not only a waste of time to develop program guidelines by regional
areas, but an administrative burden on regional entities, the GLO, and advocates.
Staff Response: The Texas General Land Office is committed to ensuring that all disaster recovery
programs and projects are tailored to the specific needs of each community. This dedication to local
control includes the allowance of program guidelines that are specific to the needs and environment
of each locality. It should be noted that although there is a certain degree of local control, the GLO
maintains oversight of all CDBG-DR programs and ensures compliance under federal law.
Comment Received: The GLO has failed to set out a plan to ensure timely completion of
projects or to minimize opportunities for fraud, waste, mismanagement, and abuse.
Staff Response: All disaster recovery funding and projects are subject to the following timeline as
outlined in the Federal Register notice. The GLO and HUD maintain responsibility for the auditing
and compliance monitoring of all programs. These routine and robust audits work to minimize the
opportunity for fraud, waste, mismanagement, and abuse of CDBG-DR funds.
Comment Received: The GLO should require standard benefit levels across jurisdictions to
ensure housing assistance programs are offered across all parts of the disaster affected regions.
Staff Response: The Texas General Land Office shall give adequate consideration to the feedback
provided in this comment.
Comment Received: We support funding the Local, Regional, and State Planning Program;
however, the GLO needs to be more inclusive of nonprofits during the planning process.
Staff Response: The Texas General Land Office remains open to partnering with nonprofit entities
to ensure disaster recovery planning is effective and efficient. The feedback provided in this comment
will be given adequate consideration.
Comment Received: The Local Buyout and Acquisition Program described in Action Plan
Amendment 1 is too vague to ensure equitable buyout administration.
Staff Response: The formation and administration of buyout programs associated with Amendment
1 to the State Action Plan shall be outlined in the program specific policies and procedures as they
are developed by the entity administering the funding. The Texas General Land Office, however,
shall maintain ultimate oversight of these programs and will ensure that all programs are administered
in accordance with federal law.
Comment Received: Action Plan Amendment 1’s references to infrastructure spending are
too vague to ensure that the funds will be spent on projects that will mitigate future disaster
impacts for LMI communities.
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programs work to rebuild in resiliency and mitigate the potential impact of future disasters. All
infrastructure projects are subject to the rules and regulations outlined in both the Federal Register
associated with the funding and all applicable federal law. Additionally, infrastructure activities are
a factor in calculating whether 70% of the aggregate amount of grant funds have been utilized to
benefit the LMI population in a given impact area. Combined, these facts afford protections to ensure
that funds will be spend on projects that will mitigate future disaster impacts for LMI communities.
Comment Received: The GLO should increase funding to affordable housing initiatives and
expand programs like mobility counseling, the provision of relocation expenses, and the
provision of incentive payments to fulfill its obligation to affirmatively further fair housing.
Staff Response: The Texas General Land Office remains committed to ensuring all programs
administered with CDBG-DR funds are done in accordance with current federal law, including the
obligation to affirmatively further fair housing. The GLO will give adequate consideration to the
feedback provided in this comment as it strives to foster a recovery for Texans in a manner that
furthers the objects presented under its obligation to Affirmatively Further Fair Housing.
Comment Received: The Homeowner Assistance Program will not adequately allow
homeowners to relocate unless it incorporates additional protections.
Response from Harris County: The County’s Homeowner Assistance Program (HAP) provides
assistance to homeowners who are in need of temporary relocation while their home is being repaired
or reconstructed. Within the relocation assistance and for those homeowners who required additional
storage of personal property, storage assistance is available. Additional information on HAP
assistance will be provided in the HAP guidelines, which are available for review at
https://csd.harriscountytx.gov/Pages/DisasterRecovery.aspx.
Response from the City of Houston: Relocation assistance in the City of Houston’s Homeowner
Assistance Program will be provided to displaced homeowners in compliance with federal, state and
local regulations. The City of Houston will include information on relocation assistance in the
program guidelines for the Homeowner Assistance Program.
Comment Received: The Homeowner Reimbursement Program is unlikely to meet the 70%
LMI threshold, considering LMI households are unlikely to have the means to pay for out of
pocket repairs.
Staff Response: The Texas General Land Office shall administer CDBG-DR programs in a manner
that adheres to the HUD requirement that 70% of the aggregate amount of funding are utilized to
benefit the LMI population within the impact area.
Comment Received: The GLO must allocate more money to the rehabilitation and construction
of multifamily units with CDBG-DR funds and use CDBG-DR funds to address the
shortcomings in FEMA’s programs.
Staff Response: The Texas General Land Office shall continue to utilize the most current data
available to assess need and design programs to address those needs. To date, the GLO has designed
the Affordable Rental Program to address the need to rehabilitate, reconstruct, or construct multi-
family housing throughout the impact area. The GLO shall take the feedback provided and give it
adequate consideration.
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Comment Received: Action Plan Amendment 1 fails to identify the extent of displacement or
address the significant obstacles displaced residents face in returning to their communities.
Staff Response: The Texas General Land Office remains committed to working towards a recovery
process that utilizes the most current data to recognize and address the needs of disaster victims. The
feedback provided in this comment shall be given adequate consideration as GLO programs work to
address obstacles displaced disaster victims face when attempting to return to their homes.
Comment Received: Action Plan 1 does not address vulnerable populations or shelters.
Staff Response: The Texas General Land Office is committed to addressing the needs of all disaster
victims, including vulnerable populations including the homeless and the elderly. The feedback and
insight provided in this comment will be given adequate consideration as programs progress.
Comment Received: The GLO should commit to using any means necessary to prevent
homelessness and seek guidance from nonprofit experts in gauging the need for supportive
services.
Staff Response: The Texas General Land Office is committed to engaging with subject matter
experts to develop innovative and effective programs that foster a wholistic disaster recovery. The
GLO is open to engaging with nonprofit experts to assess and address issues related to homelessness
prevention and will give the feedback provided in this comment adequate consideration.
Comment Received: The Economic Revitalization Program should be limited to no more than
$25 million and available only to microenterprises.
Staff Response: The Texas General Land Office shall utilize the Economic Revitalization Program
to provide interim assistance to small businesses impacted by Hurricane Harvey by offering
deferred forgivable loans in exchange for job creation or retention for low-to moderate-income
employees. As currently constructed, the Economic Revitalization Program is available to small
businesses in CDBG-DR eligible counties to foster an expansive recovery for the impact area. The
suggestions provided in this comment shall, however, be given adequate consideration.
Comment Received: Action Plan Amendment 1 does not appropriately account for other
sources of funds.
Staff Response: Other sources of funds, beyond those provided through CDBG-DR programs, will
vary by program and impact area. In the instance of Amendment 1, Harris County and the City of
Houston would need to address how their specific programs and impact area present distinct
opportunities for other sources of funding.
Response from Harris County: The County is continuously working to writing grants for additional
non-HUD funding, such as FEMA Hazard Mitigation funding for such activities as residential buyout
and drainage improvements. The County is also participating in the FEMA Public Assistance
program to repair affected systems and a countywide bond program for drainage improvements. To
date, the majority of these funds have not been awarded to the County. When awarded, Harris County,
as required by HUD, will account for any leveraging/matching funding to a CDBG-DR funded
project in a duplication of benefit review. For those homeowners, who received FEMA/SBA or other
Page 305 of 420

charitable funds to repair their home, a duplication of benefit review will also be conducted during
the program’s applicant eligibility review.
Response from the City of Houston: The City of Houston will leverage public and private sources
of funding as necessary to carry out activities related to disaster recovery. These sources may include
the Tax Increment Reinvestment Zones (TIRZ) affordable housing set-aside funds, Affordable
Housing Bond funds, the Tax Abatement Ordinance, federal and state tax incentives, federal
entitlement grant funds, state funded bond programs, and private sources.
Page 306 of 420

State of Texas Plan for Disaster Recovery: Hurricane Harvey – Round 1
The State of Texas Plan for Disaster Recovery was released on April 10, 2018. The Action Plan was
posted on the GLO website. The public comment period for the document ran to April 10, 2018 to
May 1, 2018. The GLO distributed a Statewide press release announcing the availability of the Plan
on the GLO website. Additionally, the GLO sent out an email to over 1,100 recipients across the 49
eligible counties targeting local emergency management coordinators, county and local government
officials, public housing authorities and other interested parties.
List of Those that Submitted Comment:

Migues Phill Private Individual
Reyna Robert Beaumont Housing Authority
Branick The Honorable Judge Jeff Jefferson County
Boone Christopher City of Beaumont
Jobe Ken Private Individual
Herbert The Honorable Fort Bend County
Judge Robert
Steele Jack Houston-Galveston Area Council
Sylvia The Honorable Chambers County
Judge Jimmy
Choudhury Shamim Private Individual
Choudhury Tajin Private Individual
Clark Commissioner Ken Galveston County
Omidi Rouga Private Individual
Scoggin Gary Private Individual
Johnson Eric Private Individual
Tuttle Wren Private Individual
Blaschke Stephanie Private Individual
Wiginton Cindy Private Individual
general public_1 unknown Private Individual
Grimes Summer Private Individual
Moore Michelle Private Individual
Ashworth Krisen Private Individual
Heiligbrodt Blair Private Individual
Murphy State Representative Jim Texas House of Representatives
Conly Shandy and James Private Individual

Balasubramanian Bala Private Individual
Paul State Representative Texas House of Representatives
Dennis
Ardoin Joel Orange County Environmental Health
and Code Compliance
Holloway Susan Pearland Independent School District
Jaramillo Geronimo Private Individual
Babb Margaret Private Individual
Page 307 of 420
LePore Deborah Private Individual
Stalarow Staci Houston-Galveston Area Council
Grimuado Carla Private Individual
Stocks Mikayla Private Individual
Ermis Terry Private Individual
Pendleton DJ Texas Manufactured Housing
Association
Rodriguez Angie Private Individual
Sebesta Honorable Judge Matt Brazoria County
Strong Catherine West Houston Citizens
Record Sara Disability Rights Texas
Cerrone Sarah Chambers County
Meyers Commissioner W.A. Fort Bend County
"Andy"
Lunde Emily Private Individual
Briseno Charmaine Private Individual
Gregorcyk Tracey Private Individual
Tomas Alun City Secretary, City of Dickinson
Asghari Fatemeh Private Individual
Murphy The Honorable Judge Polk County
Sydney
Mills Ronald Port Mansfield
Dailey Balis Mayor, City of Grapeland
Ledbetter Parham Amy Habitat for Humanity
Cockram Mark Private Individual
Haines Donna Private Individual
Pennington Bobby Assistant City Manager, City of
Cleveland
Owen Robert Private Individual
McGuill Joyce Private Individual
Turkel David Harris County
Miller Cheryl Private Individual
Miller Kimberly Private Individual
Duhon The Honorable Judge Waller County
Carbett
Nelson Commissioner Gary Chambers County
Melton Daryl Sabine County
Stewart Bill City of Huntington
Jones Deborah Private Individual
Reed Cyrus Sierra Club Lone Star Chapter
Samuels Eric Texas Homeless Network
Page 308 of 420

Murphy State Representative Jim Texas House of Representatives
Mills, Jr The Honorable Judge Aransas County

C.H.
No Name Private Individual
Henry The Honorable Mark Galveston County
Charles Miller Private Individual
Lee Krystal Private Individual
Fiederlein Robert Avenue
Shields Vincent Private Individual
Adra Hallford City of Texarkana
Rasch Steven Private Individual
Denson John Private Individual
Schick Maria Private Individual
Schick Doug Private Individual
Ferguson Blair Private Individual
Clements Janet Private Individual
Cobb Jennifer Private Individual
Cowan Nicole Private Individual
Whiles Richard Private Individual
Lackenby Karen Private Individual
Ward Johnathan Private Individual
Andel Joan Private Individual
Ferguson Blair Private Individual
Polk County, Texas Office of
Comstock Courtney Emergency Management
Blair-Cockrum Jennifer Private Individual
Hunt Lonnie DETCOG
Ashworth Krisen Private Individual
Mcknight Jennifer Private Individual
Robert Smith Mayor, City of Hudson
Lovell The Honorable Jim Houston County
Rainey Kate Texas Rio Grande Legal Aid, INC
Jennifer Blair-Cockrum Private Individual
Kelley Denise City Manager, City of Jasper
Craig Sally Private Individual
Defilippo John Private Individual
Stone Lorita Private Individual
Tenczar Bob Private Individual
Stehle DeLaine Private Individual
Salinas Marianne Private Individual
Nogaret Leslie Private Individual
Inaba Jonathan Private Individual
Rasch Dawn Private Individual
Page 309 of 420

Salinas Joe Private Individual
DallePezze Stacey Private Individual
Clark Ken Commissioner, Galveston County
Houston Housing and Community
McCasland Tom Development Department
George Frank Mayor, City of Kirbyville
Saavedra Griselda Private Individual
Congresswoman Sheila Congress of the United States House of
Lee Jackson Representatives
Jobe Ken Tyler County Emergency Management
Podvorec Candice Private Individual
Masters Julie Mayor, City of Dickinson
Holland Kevin Mayor, City of Friendswood
Hallisey Pat Mayor, City of League City
Elliott Libby Texas Department of Insurance
Menefee Janet Private Individual
Lane Kathy Private Individual
Heiligbrodt Hagan Private Individual
Chavez Lisa Private Individual
Shook Lora Private Individual
Costal Bend Center for Independent
Stover Linda Living
Nesting Jill Private Individual
Chavez Javier Private Individual
Pearce Helen Private Individual
Kubena Linda Private Individual
Woodrome C.D. City Secretary, City of Ivanhoe
Price Honorable Judge Paul Newton County
McLawhon Kyle Private Individual
Higgins Michele Private Individual
Chris J Private Individual
San Patricio Emergency Management
Williams Sara Coordinator
Spenrath The Honorable Phillip S. Wharton County
Aycoth Andrew Private Individual
Taft Ray Private Individual
Gonzales Cheryl Private Individual
Palmer Kathy Private Individual
Wolff Liz Houston Organizing Movement for
Equity
Collins Amy Rio Texas Conference United
Methodist Church
Friedberg Andrew City of Bellaire
Cruse Rebecca Private Individual
Page 310 of 420

Oviedo Marcie Lower Rio Grande Valley Development
Council
Kube Kaycee Private Individual
Rainey Kate Texas Rio Grande Legal Aid
Duncan Charlie Texas Housers
Green Graham Smart Home America
Beardsley Elizabeth U.S. Green Building Council
Hess Darren Private Individual
Laywell Kayla Coalition of the Homeless
Sloan Maddie Texas Appleseed
Comment Received: The Fort Bend Community is in peril of another flood without assistance
to correct the current retention problem. Please include Katy and Fort Bend (Canyon Gate
area) in the funding distribution.
Staff Response: The Texas General Land Office remains committed to ensuring the efficient and
effective distribution of the disaster recovery funds allocated to our state in response to Hurricane
Harvey. Although the current draft of the Action Plan does carve out specific allocations for Harris
County and the City of Houston, Fort Bend County and several zip codes in the area have also been
designated as potential beneficiaries of these funds. All project selections will be determined by the
local communities so you should ensure both your County and City are aware of any specific project
needs. As this process progresses, the GLO shall maintain a close working relationship with
community leaders in all impacted communities to ensure that specific needs are adequately
addressed.
Comment Received: Some housing authorities have public housing units that were severely
impacted and need reconstruction; however, requiring Affirmatively Furthering Fair Housing
reviews could determined many of those sites ineligible for use. The most cost efficient use of
these funds would be to permit those housing authorities to rebuild some of those units directly
on the same land where the current damaged units exist.
Staff Response: The Texas General Land Office, as the primary steward of Community
Development Block Grant funds for Disaster Recovery purposes, is committed to ensuring that all
funding is allocated in a manner that is effective, efficient, and in compliance with all applicable
laws. At the date that this response as drafted, the underlying policies and procedures of the
Affirmatively Furthering Fair Housing doctrine control and the GLO shall conduct evaluations and
reviews as directed under federal law unless otherwise instructed by the U.S. Department of Housing
and Urban Development.
The GLO will, however, continue to coordinate with the U.S. Department of Housing and Urban
Development in exploring all available options in order to execute the most efficient and effective
disaster recovery possible.
Page 311 of 420

Comment Received: It is extremely strange that the other 15 most impacted counties
(notwithstanding the City of Houston and Harris County) are being put under a state-wide
disaster funding administration plan without the GLO being able to leverage the talent and
experience of the COGs.
Staff Response: The Texas General Land Office remains committed to ensuring that disaster
recovery funding is administered in a manner that best serves the needs of local communities. At the
direction of the U.S. Department of Housing and Urban Development, the City of Houston and Harris
County have been given a direct allocation of funding to execute their disaster recovery measures. It
has also been under the direction of the U.S. Department of Housing and Urban Development that
the GLO has been directed to oversee the remaining programs for the rest of the impacted counties.
Although the GLO shall be administering a state-wide disaster recovery program, it should be noted
that Local needs and input will be considered in programs that allocate funding to specific geographic
areas.
Comment Received: The downtown area of the City of Beaumont has, a result of damage
caused by Hurricane Harvey, has suffered economic damages after the closing of Chicago
Bridge and Iron. Commenter is asking that Beaumont be considered as a recipient of local
planning funds to develop a Downtown Revitalization Plan. Commenter also requests planning
funds to undertake a Downtown Housing Planning Study utilizing the non-profit group
ArtSpace to develop downtown housing and attract new residents to the area. Finally,
Beaumont recognizes that Hurricane Harvey had a significant impact on the homeless
population in the area and is requesting planning funds to develop a comprehensive homeless
strategy.
Staff Response: The Texas General Land Office, in an effort to ensure the recovery process has
successful long-term impact on each community served, has designated a set amount of CDBG-DR
funds for planning purposes. The GLO will leverage Texas universities and/or vendors to conduct
such studies and each community will be given the opportunity to submit potential study ideas for
consideration. The GLO recognizes how long-term planning can impact the overall economic well-
being of impacted communities and remains dedicated to ensuring that each community has a
substantial opportunity to be considered for planning funds. These study requests have been noted.
Comment Received: Would it be allowable for local jurisdictions to have more freedom to use
funds for infrastructure instead of housing? Example: could a locality use 60% of funds for
housing needs and 40% for infrastructure based on local need?
funding is allocated in a manner that is consistent with the rules and regulations provided for in the
Federal Register. In this instance, the Federal Register has mandated that each grantee primarily
consider and address its unmet housing recovery needs. All funding distribution must remain in
compliance with Federal Register guidelines unless otherwise permitted by the U.S. Department of
Housing and Urban Development.
Comment Received: Fort Bend County is requesting that the Texas General Land Office
request a waiver from the U.S. Department of Housing and Urban Development to expand the
proposed State-administered housing recovery program to include opportunities for regional
and locally-administered housing recovery programs.
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Staff Response: The Texas General Land Office, as the primary administrator of CDBG-DR funds
for the State of Texas, is committed to ensuring each impacted community retains the most local
control feasible in determining the most effective use of disaster recovery funds while complying
with the U.S. Department of Housing and Urban Development preferences for program
implementation. The GLO shall continue to work with each impacted community, regardless of
which entity is considered the primary administrator of the program, to ensure an efficient and
effective recovery.
Comment Received: Houston-Galveston Area Council (H-GAC) is requesting that the Texas
General Land Office request a waiver from the U.S. Department of Housing and Urban
Development to expand the proposed State-administered housing recovery program to include
opportunities for regional and locally-administered housing recovery programs.
Staff Response: The Texas General Land Office seeks to administer CDBG-DR funds in the most
effective and efficient manner possible while complying with the U.S. Department of Housing and
Urban Development preferences for program implementation. The GLO shall, however, administer
these programs in close coordination with localities to ensure each program is tailored to the needs
of that impacted region.
Comment Received: H-GAC is requesting that the GLO seek a waiver to the requirement that
70% of the aggregate amount of funds be utilized in a manner that benefits the LMI population
in the impacted area.
Staff Response: The U.S. Department of Housing and Urban Development has established the
requirement that 70% of the aggregate of CDBG-DR funds be utilized for the benefit of the low- and
moderate-income population in the impacted area. the U.S. Department of Housing and Urban
Development has indicated they will only consider a waiver to this requirement if it can be adequately
demonstrated that the needs of the low- or moderate-income population within the impacted area
have had their needs sufficiently addressed or potentially if the impact is less than 70% low- or
moderate-income persons. If, during the recovery process, the GLO determines that this burden has
been met in a manner that warrants a waiver request from HUD, it will pursue that option.
Comment Received: H-GAC requests the GLO seek a waiver to lower the LMI area benefit
requirement as it pertains to potential infrastructure projects.
moderate-income population in the impacted area. The U.S. Department of Housing and Urban
Development has indicated they will only consider a waiver to this requirement if it can be adequately
demonstrated that the needs of the low- or moderate-income population within the impacted area
have had their needs sufficiently addressed or potentially if the impact is less than 70% low- or
moderate-income. If, during the recovery process, the GLO determines that this burden has been met
in a manner that warrants a waiver request from the U.S. Department of Housing and Urban
Development, it will pursue that option.
Comment Received: What is the justification for allocating Harris County and Houston 45%
of the total funds?
Page 313 of 420

Staff Response: The Texas General Land Office is committed to ensuring all Community
Development Block Grant funds allocated in response to Hurricane Harvey are implemented in a
compliance with all rules and regulations outlined by federal law. To date, it has been determined by
the U.S. Department of Housing and Urban Development that the $5 Billion allocation of CDBG-
DR funds shall be allocated in the manner presented in the Action Plan. The GLO is obliged to follow
these guidelines. Allocation amounts to Harris County and the City of Houston were determined by
the U.S. Department of Housing and Urban Development.
Comment Received: Does the GLO considered these funds to be locally controlled? If so,
explain local control when only 8.2% of the total allocation is for 'locally controlled'
infrastructure programs and all remaining funds are going to 'state administered' housing and
planning activities.
projects, whether it be housing, infrastructure, or economic development, are developed and
implemented in constant communication with local officials to ensure the needs of each community
are being addressed. It should be noted that the words 'state administered' do not in any way reduce
the level of local participation in selecting and executing recovery projects. Program implementation
is being performed as per the U.S. Department of Housing and Urban Development direction.
Comment Received: How will communities and/or projects that do not have a high LMI
percentage, but do need address local and regional storm related impacts, access these funds?
Staff Response: CDBG-DR funds must be administered in a manner that is consistent with federal
law, which includes the usage of 70% of the funds for the benefit of low- and moderate income
populations which allows the remaining 30% of the funds to be spent on projects that do not meet
the low to moderate income national objective.
Comment Received: What will be the process to determine which planning studies are
pursued? Will their be priority given to regional projects? Will studies for Cities and Counties
be eligible?
Staff Response: The Texas General Land Office is working in coordination with research institutions
within the state to present ample resources to conduct planning activities funded by the Hurricane
Harvey recovery funds. Each community will have to opportunity to present their specific planning
needs and studies for cities and counties will be eligible. Outside of the restrictions placed on funds
by federal law, the GLO does not have a prioritization method currently in place for these studies.
Additional details will be made available in the planning guidelines.
Comment Received: Does the GLO have an itemized budget for the Administration of funds in
the amount of $251,210,750 as well as Project Delivery in the amount of $27,537,089 for
infrastructure and $27,537,089 for housing?
Staff Response: The Texas General Land Office shall, as it has with prior grants, will remain within
the prescribed caps for Administrative and Project Delivery. And as has previously occurred any
funds not utilized for those purposes will be converted to additional project dollars.
Page 314 of 420

Comment Received: Will local control be maintained for procurement of Administration,
Acquisition Services, Engineering, and Environmental Service Providers? What is the cap on
fees?
Staff Response: The Texas General Land Office will only procure vendors for their own use.
Subrecipients will be responsible for the procurements of all support services necessary to implement
the CDBG-DR funded projects. Caps associated with project delivery, administration, and
engineering are detailed in the Action Plan and vary by program type.
Comment Received: Why is so much of the funding being allocated towards housing projects?
Staff Response: The Federal Register notice associated with this CDBG-DR allocation established
the rules and regulations by which these funds are to be allocated. In particular, the federal register
notice requires a substantial amount of funds from this allocation be used towards housing projects.
The GLO is committed to ensuring all CDBG-DR funds are implemented in a manner that is
consistent with these rules.
Comment Received: What is the remaining balance in the Hurricane Ike Housing Program?
Does the GLO expect to expend 36% of the total allocation on housing projects alone?
Staff Response: The Hurricane Ike Housing Program and any remaining funds currently have no
bearing on the allocation for which this Action Plan was published. Any further information
regarding those grants should be through inquiries submitted outside of this public comment forum.
Comment Received: How does the GLO expect the Homeowner Assistance Program, the Local
Buyout and Acquisition Program, and the Affordable Rental Program to be complete in three
years?
Staff Response: The Texas General Land Office recognizes that the CDBG-DR allocation associated
with this Action Plan has specific timelines associated with both the obligation of and expenditure of
funds. These timelines have been set by the Federal Register notice and the GLO is committed to
working with communities to meet these deadlines. If needed, the GLO will request additional time
as is outlined in the Federal Register.
Comment Received: Please remember that when it comes to counties and cities, one size doesn't
fit all.
Staff Response: The Texas General Land Office recognizes that every community is experiencing
different recovery needs and is committed to working with each community to ensure those specific
needs are addressed to foster the most effective and efficient recovery possible. Where possible, local
prioritization will apply.
Comment Received: Residents, like myself, living in Canyon Gate are currently unable to fund
repairs to common areas that have suffered significant damage as this area is insured for wind
and peril, but not for floods. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office remains committed to ensuring that the needs of
communities are adequately addressed through disaster recovery programs funded by the allocation
discussed in this Action Plan. It should be noted, however, that the City of Houston and Harris County
Page 315 of 420
shall be largely responsible for a portion of recovery programs within their respective jurisdictions.
Comments and concerns like this one, should also be voiced to these authorities as well as programs
are formed and executed.
Comment Received: Galveston County is requesting The Texas General Land Office pursue
maximum flexibility in the use of CDBG-DR funds allocated under this Action Plan by
requesting a waiver that would expand state-run housing programs to include locally and
regionally controlled housing programs. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office seeks to administer CDBG-DR funds in the most
effective and efficient manner possible while complying with the U.S. Department of Housing and
Urban Development preferences for program implementation. The GLO shall, however, administer
these programs in close coordination with localities to ensure each program is tailored to the needs
of that impacted region.
The GLO is committed to working alongside communities, like Galveston County, produce the most
effective and efficient recovery possible.
Comment Received: Why is HUD discriminating between Hurricane Harvey victims by

providing direct financial assistance when homeowners who were flooded still need financial
help?
Staff Response: The Texas General Land Office is committed to working with impacted
communities to ensure recovery needs are adequately addressed from available funds; however, that
work must be conducted in a manner that is consistent with federal laws and regulations. The GLO
remains dedicated to advocating for all Texans throughout the recovery process.
Comment Received: There should be no 70% LMI requirement associated with these funds.
Staff Response: The federal requirements associated with the CDBG-DR allocation discussed in this
Action Plan are outlined in the Federal Registered. An aggregate of 70% of all CDBG-DR funds
must be used to benefit the low- or moderate-income population in the impacted area unless a waiver
is granted by the proper authority. The GLO remains committed to ensuring that all CDBG-DR funds
are used in a manner consistent with federal law. Without a waiver or change by the U.S. Department
of Housing and Urban Development the 70% low- or moderate-income aggregate requirement must
be maintained. Federal Register
Comment Received: The home for this community member was flooded from the reservoir and
is not located in an area where natural disaster flooding typically occur, why should they have
to elevate their home?
Staff Response: Flood plain requirements are locally administered and elevation requirements for
homes in the flood plain seeking to utilize CDBG-DR assistance are outlined in the Federal Register
associated with this allocation and cannot be waived by The Texas General Land Office. Despite
this, your concerns are valid and the GLO will continue to advocate for all Texans impacted by
Hurricane Harvey as the recovery process continues.
Comment Received: The 14 Day comment period set forth by the GLO is too short for effective
analysis of the plan. The Galveston County Long Term Recovery Group is requesting the GLO
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take input gathered during the 14 day comment period and adjust/republish the Action Plan
with an additional 30 day comment period to include public meetings.
Staff Response: The Texas General Land Office, in full compliance with the rules and regulations
set forth in the Federal Register associated with this Action Plan, published this Draft Action Plan
for more than the 14 days required by the Federal Register to ensure an effective and efficient
recovery process. The GLO considers this publication period adequate.
The Federal Register requires the Action Plan be submitted within 90 days of February 9, 2018 which
will not allow for any further extensions of the Action Plan public comment period.
Comment Received: The Galveston County LTRG is requesting that all calculations utilized in
determining fund distribution be made public and that appropriate time be given for the
recovery community to analyze and comment.
Staff Response: The current Action Plan presents the data analysis that outlines the distribution of
funds starting at the highest level and working its way down to localities. Direct allocations to the
City of Houston and Harris County were determined and calculated by the U.S. Department of
Housing and Urban Development and all other calculations done by the GLO are presented within
the Action Plan for review.
Comment Received: The Galveston County LTRG is requesting that a criterion under the
required 70% aggregate LMI benefit be set. If the GLO is not authorized to do this, then a
waiver should be requested from HUD.
Staff Response: The requirement that 70% of the aggregate of CDBG-DR funds be utilized for the
benefit of the low- or moderate-income population within a disaster impacted area is established in
the Federal Register.
Comment Received: The Galveston County LTRG suggests that local input processes
associated with planning studies be expanded to include input from local experts,
organizations, and governments.
Staff Response: The Texas General Land Office remains committed to ensuring robust public
participation at all stages of the disaster recovery process. This commitment includes ensuring local
experts, organizations, and governments are able to productively consult with research institutions to
formulate planning studies. The GLO has every intention of conducting the planning study process
in a manner that is open and transparent.
Comment Received: The PREPs and DAHLR Programs are not good templates for the much
larger CDBG-DR Program and the GLO should work to understand why these programs were
unsuccessful or select a different contracting strategy
Staff Response: The PREPs and DAHLR Programs originated with FEMA and were administered
as Temporary Housing Programs directly following Hurricane Harvey in compliance with FEMA
requirements. The Texas General Land Office intends to leverage these programs by allowing for
qualified applicants who participated in either PREPs or DAHLR to still receive assistance under the
CDBG-DR grants to complete repairs. The GLO is fully cognizant of the important differences
between implementing a temporary housing program and long-term recovery efforts and has already
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taken review steps to review and refine programs like PREPs and DAHLR are more efficient
responses for future disasters.
Comment Received: The City of Houston and it's allocation of $1.55 Billion dollars must be
given thorough oversight throughout this process to ensure funds are not misappropriated.
Staff Response: The Texas General Land Office, is responsible for maintaining oversight of all uses
of federal dollars allocated in connection with Hurricane Harvey to include funds provided to the
City of Houston. This responsibility includes ensuring that all funds are spent in a manner that is
consistent with federal law. The City of Houston will also be subjected to audit and compliance
functions performed by federal authorities at different stages of the recovery program to ensure
compliance like all subrecipients funded under the CDBG-DR funds.
Comment Received: Please include Refugio County in the method of distribution for this
Action Plan
Staff Response: Refugio County is eligible as a county with a federal disaster declaration from
Hurricane Harvey. The Texas General Land Office has worked diligently to ensure that all
communities impacted by Hurricane Harvey are given consideration during the method of
distribution process. All feedback pertaining to the MOD will be given ample consideration as the
GLO wants to ensure that Texans impacted by Hurricane Harvey are given adequate opportunity to
recover.
Comment Received: Please consider adding Refugio County to the list as Austwell, Tivoli,
Woodsboro, and Bayside were directly hit by Hurricane Harvey.
recover.
Comment Received: Please include the County of Refugio in this Action Plan's method of
distribution.
recover.
Comment Received: Please include Bayside and Refugio County in areas that need help after
the hurricane.
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recover.
Comment Received: Please do not overlook the town of Bayside, TX in the method of
distribution for this allocation.
recover.
Comment Received: As a resident of the 77079 zip code, I believe that all disaster victims who
flooded should be eligible for grant assistance.
Staff Response: The Texas General Land Office has worked diligently to ensure that all communities
impacted by Hurricane Harvey are given consideration during the method of distribution process. All
feedback pertaining to the MOD will be given ample consideration as the GLO wants to ensure that
all Texans impacted by Hurricane Harvey are given adequate opportunity to recover
Comment Received: The City of Houston and the Mayor are not equipped to distribute these
funds.
Staff Response: It has been determined by the U.S. Department of Housing and Urban Development
that the City of Houston shall receive a direct allocation of CDBG-DR grant funds. The Texas
General Land Office remains committed to ensuring, through adequate oversight procedures, that all
CDBG-DR funds are administered in a manner that is in compliance with federal law.
Comment Received: The requirement for 70% of the funding to go to the LMI population does
not address hard hit areas with families that have been excluded or deemed ineligible for
FEMA assistance. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office is dedicated to ensuring that, subject to federal
regulations, the needs of impacted communities are adequately addressed; however, the
administration of CDBG-DR funds must be done in accordance with federal law. The requirement
that 70% of the aggregate of funding be used to aid the Low- and moderate-income population in the
impacted area has been established in the Federal Register in which this allocation was published and
must be followed.
Comment Received: All of those who were impacted by Hurricane Harvey should be eligible
to receive grant aid regardless of zip code, SBA loan status, or income level.
Staff Response: The Texas General Land Office is committed to ensuring all CDBG-DR funds are
distributed, to the greatest extent allowable under the law, to as many disaster victims as possible.
The GLO is, however, bound by the rules and regulations set by the U.S. Department of Housing and
Urban Development and those rules include the restrictions on zip codes, income levels, and flood
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insurance. Despite this, the GLO is dedicated to advocating for the needs of impacted Texans and
will continue to work diligently to ensure an effective and efficient recovery process.
Comment Received: The City of Houston and the Mayor are not equipped to distribute these
funds.
Staff Response: It has been determined by the U.S. Department of Housing and Urban Development
that the City of Houston shall receive a direct allocation of CDBG-DR grant funds. The Texas
General Land Office remains committed to ensuring, through adequate oversight procedures, that all
CDBG-DR funds are administered in a manner that is in compliance with federal law.
Comment Received: Allow all who were flooded to receive direct CDBG-DR grants, regardless
of zip code, income level, flood insurance, or not. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office is committed to ensuring all CDBG-DR funds are
distributed, to the greatest extent allowable under the law, to as many disaster victims as possible.
The GLO is, however, bound by the rules and regulations set by the U.S. Department of Housing and
Urban Development and those rules include the restrictions on income levels and flood insurance.
Despite this, the GLO is dedicated to advocating for the needs of impacted Texans and will continue
to work diligently to ensure an effective and efficient recovery process.
Comment Received: The City of Houston, Mayor Turner, and Harris County are not equipped
to distribute these funds and it will delay aid to those who need it. Please allow the GLO to
administer these funds. (Multiple respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Development has deemed the City of
Houston as eligible to receive a direct allocation of the CDBG-DR funds associated with this Action
Plan. The City of Houston shall be responsible for administering this direct allocation; however, the
Texas General Land Office remains committed to ensure proper oversight is conducted at every stage
of the recovery process.
Comment Received: Funds need to be available and distributed to assist families with the
increased cost of compliance in Houston. (Multiple respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Development has, through established
federal law, determined eligibility criteria for applicants seeking aid under CDBG-DR grants. The
Texas General Land Office has been made aware of this new issue through this public comment
period and will work to advocate on behalf of impacted Texans to find a viable solution.
Comment Received: All of the CDBG-DR funding needs to be available to all households and
the requirement that 70% of total funds be used for LMI populations excludes impacted
families. (Multiple respondents provided this feedback)
Staff Response: The requirement that 70% of the aggregate amount of CDBG-DR funds be used for
the benefit of Low- and Moderate-Income populations in the impacted area has been set by the U.S.
Department of Housing and Urban Development. Absent an approved waiver, the Texas General
Land Office shall work to ensure that all CDBG-DR funds are administered in a manner that is
consistent with federal law.
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Comment Received: Allocation of Funds for Buffalo Bayou Flood Mitigation Efforts. Much of
the damaged sustained by citizens in my district was caused by an overflow of flood waters
from Buffalo Bayou. Investment of resources into prevention and mitigation of future flooding
will reduce future costs of recovery.
Staff Response: The Texas General Land Office is committed conducting an in-depth analysis of
every proposal for disaster recovery to ensure an effective recovery and mitigation and prevention of
damage from future disasters. Local communities will prioritize the use of CDBG-DR funds through
project selection for all infrastructure allocations. The GLO, in its evaluation of Houston's draft
Action Plan, will utilize this feedback and give it thoughtful consideration.
Comment Received: The requirement that 70% of the aggregate amount of funds be utilized
solely for the benefit of the LMI impacted population fails to direct an adequate amount of
funds to non-LMI households.
Staff Response: The requirement that 70% of the aggregate amount of funds be utilized to benefit
the Low- and Moderate-Income households that were impacted by the storm has been set by the U.S.
Department of Housing and Urban Development through the publication of the Federal Register
associated with this allocation of grant funds. Despite this current designation, the GLO is committed
to advocating for all impacted Texans and is willing, with justification, to seek a waiver to this
requirement as the recovery process develops.
Comment Received: Clarification of the maximum assistance waiver criteria and process as it
is permitted to be developed by sub-recipients of CDBG-DR dollars.
Staff Response: The Texas General Land Office will, as programs and policies are developed,
coordinate with communities to ensure they are adequately aware of all policies associated with
programs. This will include the amount of maximum assistance allowable under each program.
Comment Received: The Action Plan should specifically address the 77079 zip code within
Harris County as this area was flooded due to releases from the reservoirs following Hurricane
Harvey.
Staff Response: Harris County and the City of Houston will make all funding and program decisions
within their jurisdictions. Harris County and the City of Houston will be submitting their proposed
programs and use of funds to the GLO in the coming months. The programs after approval by the
GLO will be incorporated in an Action Plan Amendment and will be subject to a public comment
period similar to that of the Draft Action Plan.
Comment Received: An SBA loan should not be considered in a duplication of benefits analysis
as it is a loan that has to be paid back and homeowners are seeking to repair their homes
immediately.
Staff Response: The Texas General Land Office must, in its administration of CDBG-DR funds,
ensure that all funding is distributed to eligible applicants in accordance with federal law. All
duplication of benefit analysis performed on incoming applications for assistance are mandated by
federal law and the GLO is required to follow those processes. Unless directed differently by the U.S.
Department of Housing and Urban Development, the GLO shall maintain the current procedures
required under the law.
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Comment Received: Please do not distribute these funds through The City of Houston and
make the funds available to all of those impacted by Hurricane Harvey
Houston eligible to receive a direct allocation of CDBG-DR funds to aid its citizens in the recovery
process following Hurricane Harvey. Although the City of Houston shall be the primary
administrator of these funds, the Texas General Land Office will maintain an active role in oversight
to ensure that programs are being conducted in an effective and efficient manner. The administration
of CDBG-DR funds is governed by federal rules and regulations outlined by the U.S. Department of
Housing and Urban Development. The GLO remains committed, absent a separate directive from the
U.S. Department of Housing and Urban Development, to ensuring that every aspect of federal law is
followed in administering these funds.
Comment Received: On behalf of the citizens of House District 129 and our coastal-bay
communities, I respectfully request the State of Texas request an exemption to the 70% LMI
requirement.
Staff Response: The Texas General Land Office, as a designated administrative body for CDBG-
DR funds, is obliged to implement all disaster recovery programs in compliance with current federal
laws and guidelines.
Comment Received: If the 20% of total funds allocated to the most impacted areas are not
completed utilized for Homelessness Prevention, Affordable Rental, and Local Infrastructure
are not fully expended, how will those funds be reallocated?
Staff Response: The Texas General Land Office shall, to the best of its ability, ensure that all funds
are expended in the manner in which they have been designated under federal guidelines. If and only
if, at the end of all programs, there is a surplus of funding then the GLO will re-evaluate the needs
of that community and make a decision as to how those funds may be utilized.
Comment Received: Please clarify the balance of 2% that is available to local communities for
Project Delivery?
Staff Response: Project delivery funds in the Draft Action Plan budget are for the GLO to utilize
when Subrecipients need support to implement their programs.
Comment Received: Please elaborate on how programs directly implemented by the GLO will
be structured and the role of local communities within that structure?
Staff Response: All programs directly administered by the Texas General Land Office will be
structured in a manner that emphasizes local participation at every step. Programs will likely include
a Grant Administrator who works directly with local officials and GLO personnel to ensure that
programs both meet local needs and are administered in a manner that is consistent with federal law.
Comment Received: Woodsboro and Bayside should be considered for funding as they need
help to rebuild after Hurricane Harvey.
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GLO wants to ensure that all Texans impacted by Hurricane Harvey are given adequate opportunity
to recover.
Comment Received: How will local communities pay for administering, delivering, and
working with state vendors on these endeavors?
Staff Response: The Texas General Land Office shall, in accordance with the law, remit payment
for any allowable costs associated with the administration of these programs. The delineation of costs
and responsibilities for each program will be refined as these programs develop.
Comment Received: Where, if any, is there local control?
Staff Response: The Texas General Land Office remains committed to ensuring each impacted
community is given the maximum allowable control over the disaster recovery process within its
jurisdiction. The GLO will foster this local control through robust cooperative efforts with
community leaders at every stage of the process.
Comment Received: How will the application process for housing programs administered by
the GLO be structured?
Staff Response: The structure of the application process for housing programs administered by the
GLO is currently under development and will be published to the communities as soon as possible.
The GLO will dedicate ample resources during the application period to ensure public outreach to all
potential eligible applicants is effectively conducted.
Comment Received: Are drainage districts and other non-governmental entities with eminent
domain authority eligible applicants for acquisition?
Staff Response: Cities, counties, and other entities with eminent domain authority are eligible to
receive allocations from the regional methods of distribution for the buyout and acquisition
program.
Comment Received: Does the infrastructure program include drainage districts and other non-
governmental entities with eminent domain authority as eligible applicants for the buyout
program?
Staff Response: Only cities and counties will be eligible to receive allocations from the regional
methods of distribution for the infrastructure program.
Comment Received: Is the GLO going to provide or reimburse planning funds to local
governments to assist in planning processes? Will the GLO allow for the reimbursement for
funds already expended on these activities?
Staff Response: To date, the Texas General Land Office will be leveraging the expertise of research
institutions within the state to aid impacted communities in conducted meaningful planning studies
to aid in their long-term recovery. Any funds expended by a local community must be considered
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allowable under the current planning study program design to be eligible for reimbursement. The
details of this structure will be released for public consumption as soon as possible.
Comment Received: Will there be a pre-award of planning funds?
Staff Response: To date, the Texas General Land Office has not permitted a pre-award for the
purpose of planning studies.
Comment Received: When will the GLO make needs assessment data available to local
communities?
Staff Response: All needs assessment data utilized in the analysis conducted in the current Action
Plan is located within the Action Plan document in Section II of the Needs Assessment. Data not
contained within the Action Plan may be requested from FEMA by the locality.
Comment Received: How will housing elevations apply if local codes require more than the
two-foot limit imposed by the Action Plan? Will allowable cost adjustments be made?
Staff Response: If the situation arises where local code is more stringent than the elevation
requirements established by the Action Plan, then the local code controls. Any increases in expense
related to more stringent local zoning and code would be eligible expenses to the CDBG-DR
program.
Comment Received: Is the GLO going to make administrative and planning funds available to
Orange County to support the state administered housing and planning activities?
Staff Response: It is not envisioned that the County will need to participate in the actual
implementation of the housing or planning programs. If at a later date that changes, the GLO will
consider such an arrangement.
Comment Received: Who will conduct the public outreach for State administered programs?
If localities conduct this, will funds be made available to cover those costs?
Staff Response: As currently designed, the Texas General Land Office will remain responsible for
public outreach as an integral part of its duties to administer CDBG-DR programs. The GLO will
only permit the reimbursement of allowable costs defined within each individual program.
Comment Received: Economic development projects should be done at the local level.
Staff Response: The Texas General Land Office is steadfast in its commitment to ensuring that all
recovery programs are specifically tailored to meet the needs of each impacted community. This level
of commitment includes the exercise of open and engaging cooperation between the GLO, local
governments, community leaders, and disaster victims.
Comment Received: Local communities and vendors are better positions to efficiently conduct
studies that will yield effective results.
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Staff Response: The Texas General Land Office recognizes the value in utilizing local communities
and their vendors to achieve effective program results and this feedback shall be given adequate
consideration as programs are designed.
Comment Received: The use of local vendors, contractors, and suppliers would enhance
recovery efforts within regions by increasing spending within the region.
Staff Response: The Texas General Land Office shall make every effort to conduct programs that
present a comprehensive disaster recovery strategy, including utilizing methods that not only rebuild,
but foster local economies by spending money locally when feasible.
Comment Received: Will the GLO allow access to planning funds to local communities for the
planning efforts the program will require them to undertake?
Staff Response: Communities will be granted access to funding for costs deemed allowable for each
specific program.
Comment Received: Which flood maps will be utilized to determine the Base Flood Elevation?
Staff Response: The Texas General Land Office will utilize the most up –to-date available flood
maps to determined base flood elevation for projects within program areas.
Comment Received: The current allocation does not offer funding for addressing long-term
solutions to reduce disaster-related homelessness. The Coordinator of Student Outreach and
Intervention Services for the Pearland Independent School District suggests the following: 1.
Funding should be increased to aid the homeless population as the Annual Point-in-Time Count
reveals thousands of Texans are still experiencing homelessness or housing instability because
of Hurricane Harvey; 2. Funding should be increased to at least $50 million for Homelessness
Prevention Programs to include short-term mortgage assistance, utility assistance, and rental
assistance for households still recovering from Hurricane Harvey; and 3. The plan should
designate funding amounts to certain school districts impacted by Hurricane Harvey to be used
for land improvement as well as directly for student and family needs for the Homelessness
Prevention Program.
Staff Response: The Texas General Land Office recognizes the homelessness and housing instability
issues either directly or indirectly caused by Hurricane Harvey. As a result, the GLO has worked to
include a portion of CDBG-DR funding for programs that would have a meaningful and positive
impact on those affected. All comments that present a suggested change to the current distribution
calculations will be given adequate consideration as the GLO works to ensure an effective and
efficient recovery process. It is the intent of the GLO to procure a vendor(s) to implement this
program. The GLO encourages all entities that are capable of administering this program to
participate in the procurement.
Comment Received: Woodsboro and Bayside should be considered for funding as they need
help to rebuild after Hurricane Harvey.
impacted by Hurricane Harvey are given consideration during the method of distribution process. All
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all Texans impacted by Hurricane Harvey are given adequate opportunity to recover.
Comment Received: Bayside and its zip code, 78340, were nearly wiped off the map and neither
are included in this Action Plan. Why?
to recover.
Comment Received: Please reconsider the method of distribution and include the county of
Refugio as a whole.
to recover.
Comment Received: HGAC requests an extension of the public comment period for an
additional 15 days for the State of Texas Plan for Disaster Recovery: Hurricane Harvey –
Round 1.
Staff Response: The Texas General Land Office has, in accordance with the guidelines established
by the Federal Register associated with this allocation, conducted the required public comment period
to meet the public participation requirement under the law. Additionally, the GLO extended that
period and accepted public comment up and until May 1, 2018 at 5:00 pm. Extending the public
comment period any longer would prevent the GLO from meeting the due date for submission of the
Action Plan to the U.S. Department of Housing and Urban Development.
Comment Received: Please include Bayside and all of Refugio County in the method of
distribution for this action plan.
to recover.
Comment Received: Hurricane Harvey has exacerbated the homelessness issues in Houston
and the GLO should consider revision the allocation of funds to ensure homelessness
prevention is adequately funded.
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Staff Response: The Texas General Land Office is dedicated to ensuring that all of those impacted
by Hurricane Harvey have a stable path to recovery, including those who were either homeless at the
time of landfall and those who were made homeless as a result of the storm. The City of Houston is
receiving a direct allocation of CDBG-DR funds from the GLO. The City of Houston will determine
the homelessness programs and funding they will offer.
Comment Received: Please consider canal cleanup as a part of the recovery efforts as they are
currently very littered and a hazard to boaters and swimmers in and around Rockport, Fulton,
Lamar, Holiday Beach, and Copano Ridge areas.
Staff Response: Local communities will prioritize the use of CDBG-DR funds allocated to them for
infrastructure projects. The Texas General Land Office remains committed to ensuring all CDBG-
DR funds associated with this Action Plan are administered in a manner that is both in compliance
with federal law and fosters an effective and efficient long-term recovery for each community. The
GLO will work continue throughout the recovery process to work with local communities to ensure
that their most pressing needs are met and addressed to the greatest extent allowable under the law
and subject to limited funding.
Comment Received: The TMHA applauds the Texas General Land Office for including
manufactured home replacement as an eligible activity within the Action Plan. TMHA support
providing homeowners facing 'Major-High' and 'Severe' damage to their manufactured homes
with the choice to replace their homes with a new manufactured home.
Staff Response: The Texas General Land Office is committed to pursuing all available aspects of
disaster recovery to ensure impacted Texans have access to the most efficient recovery programs.
Comment Received: THMA requests that the GLO include manufacture homes as an option
for replacement and new construction choices throughout recovery programs. This suggestion
includes utilizing manufactured housing not only as replacements for damaged or destroyed
manufactured housing units, but also for replacement of damaged or destroyed site-built
homes.
Staff Response: The Texas General Land Office shall consider the feedback provided in this
comment as it moves forward with the development of housing programs encompassed in this Action
Plan.
Comment Received: Modern manufactured homes can be built to look indistinguishable from
site-built counterparts and this should be considered as the GLO works to implement these
programs an eliminate the stigma often associated with manufactured home.
Staff Response: The Texas General Land Office is committed to ensuring impacted Texans have
access to the most efficient means of disaster recovery available. As programs develop, the GLO
shall dedicate necessary resources to ensure public outreach that addresses issues like these is
conducted.
Comment Received: The manufactured housing industry in the State of Texas is adequately
regulated via the HUD code and TDHCA regulations. These regulations present a highly
regulated industry that proves to be efficient.
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Staff Response: The Texas General Land Office will give this comment adequate consideration as
it moves forward with housing programs.
Comment Received: Manufactured homes are often more suited for increased elevation
requirements compared to other single-family housing options.
Staff Response: The Texas General Land Office will give this comment adequate consideration as
it moves forward with housing programs.
Comment Received: While TMHA believes that local control is necessary to tailor programs to
the needs of a community, it would like to advocate against jurisdictions making blanket
prohibitions against the use of manufactured housing units.
Staff Response: The Texas General Land Office recognizes that there must be a balance between
the exercise of local control and the satisfying of the needs of impacted citizens within a community.
That being said, the GLO shall continue to coordinate with local officials to ensure that this balance
remains intact as the recovery process progresses.
Comment Received: Woodsboro is a small town with limited resources that was heavily
damaged by Hurricane Harvey. The City of Woodsboro and the zip code 78393 should be
added to the Action Plan to receive funds under this allocation.
to recover.
Comment Received: All households that sustained damage from Hurricane Harvey should be
eligible for all funding allocated under this Action Plan. Additionally, Mayor Turner and the
City of Houston have been hostile in their response to citizen's questions during a meeting held
at Tallowood Church and West Houston does not trust him to manage the program.
Staff Response: The U.S. Department of Housing and Urban Development has determined that the
City of Houston shall receive a direct allocation of CDBG-DR funds to aid its citizens in recovery.
The Texas General Land Office, however, will retain oversight and audit functions to ensure allocated
funds are distributed in a manner that is in compliance with federal law.
Comment Received: Round 1 fails to assess the needs of individuals with disabilities impacted
by the disaster. We offer the following specific comments to this second plan, the GLO did not
outreach to any disability organization to access the needs of individuals with disabilities.
(Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office has, as required by the Federal Register, conducted
a robust public participation process throughout the Action Plan process. This public participation
process has included hundreds of phone calls and in-person meetings with leaders from the majority
of impacted communities in an effort to address the specific needs of their impacted population.
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Comment Received: The draft plan does not account for children under 5 with disabilities or
those over 65 with disabilities. (Multiple respondents provided this feedback)
Staff Response: The GLO has utilized the most up-to-date data available to its office in conducting
all analysis associated with forming a needs assessment for the CDBG-DR funding allocated under
this plan. As recovery progresses, a more detailed look into the needs of the population of persons
with disabilities in each impacted area will be assessed and the GLO will continue to work to create
innovative solutions to meet those needs.
Comment Received: The draft plan does not include efforts to increase accessibility and assure
compliance with state and federal laws and regulations relating to new construction, substantial
rehabilitation, and infrastructure projects.
Staff Response: All CDBG-DR funds are, at every program level, subject to the rules and regulations
presented under federal law as they pertain to protecting and providing services to aid persons with
disabilities within the impacted population. Additional detail will be provided in each programs’
guidelines. Any programmatic decisions regarding establishing policies and procedures that exceed
the minimum established services and protections provided under federal law will be given adequate
Comment Received: Each grantee should be required to remain in compliance with the
Americans with Disabilities Act of 1990 (42 USC §§12101 et seq.) and the Rehabilitation Act of
1973 (29 USC §§701 et seq.) by provided certifications of support. (Multiple respondents
provided this feedback)
Staff Response: The Texas General Land Office is dedicated to ensuring the needs of impacted
Texans are adequately assessed and addressed through the administration of the CDBG-DR funds
associated with this Action Plan. The feedback presented in this comment will be thoughtfully
considered as program guidelines are developed.
Comment Received: Cities and Counties should be given the choice to manage their own
housing programs. Why are Harris County and the City of Houston being treated differently?
These direct allocations were not outlined in the Federal Register, so where did this originate?
City of Houston and Harris County shall receive direct allocations from the money allocated within
this Action Plan. Although not outlined in the Federal Register, this decision was made at the senior
level of the U.S. Department of Housing and Urban Development and The Texas General Land
Office is obliged to ensure that all funds are administered in accordance with federal guidelines and
law.
Comment Received: Chambers County feels that local administration of housing programs
would create a more robust program that would serve homeowners better.
City of Houston and Harris County shall receive direct allocations from the money allocated within
this Action Plan. Although not outlined in the Federal Register, this decision was made at the senior
level of HUD and The Texas General Land Office is obliged to ensure that all funds are administered
in accordance with federal guidelines and law.
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Comment Received: It is the understanding of Chambers County that HUD mandated the
Individual Housing Program, but that requirement is not published in the Federal Register.
Where did this requirement originate?
Staff Response: The U.S. Department of Housing and Urban Development has determined that an
Individual Housing Program be conducted utilizing the money allocated within this Action Plan.
Although not outlined in the Federal Register, this decision was made at the senior level of HUD and
The Texas General Land Office is obliged to ensure that all funds are administered in accordance
with federal guidelines and law.
Comment Received: Will the GLO adjust its administration amount in light of the direct
allocations given to the City of Houston and Harris County?
Staff Response: The Texas General Land Office shall remain the primary administrator of programs
developed under this Action Plan. The majority of tasks performed by either the City of Houston or
Harris County personnel will be Project Delivery in nature. As those entities define the programs
being implemented adjustments in administrative funds may become necessary.
Comment Received: I believe that any engineering studies should be conducted by private
engineering firms that have requisite experience, adequate knowledge, and existing data of
pertinent information to complete studies in a timely manner instead of using the engineering
departments of Texas research institutions.
Staff Response: The Texas General Land Office has determined that leveraging research institutions
and/or vendors within the state is a productive and beneficial use of CDBG-DR funds in developing
relevant studies relating to disaster recovery programs. The GLO recognizes the value of
coordinating with local experts to ensure this process is effective and efficient and remains open to
fostering beneficial working relationships between research institutions and agencies like those
addressed in this comment.
Comment Received: There is much damage in Refugio County, can it be included in the
allocation of funds? (Multiple respondents provided this feedback)
distribution process; however, certain eligibility criteria have been established by HUD and the GLO
is committed to ensuring that all CDBG-DR funds are administered in compliance with that law.
Despite this, the GLO will continue to advocate for all impacted Texans as the recovery process
continues.
Comment Received: The City of Dickinson would like to express, through the five submitted
letters and one resolution, its strong opposition to unequal treatment afforded to it in relation
to the City of Houston and Harris County. Whereas both of these entities are proposed to be
afforded the ability to control their programs locally, the City of Dickinson is not. The City of
Dickinson requests the same opportunity to oversee its own programs.
Staff Response: The U.S. Department of Housing and Urban Development has, through the Action
Plan and the issuance of other opinions, designated the City of Houston and Harris County as
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qualified to receive a direct allocation of CDBG-DR funds. The GLO, as the primary agency
providing oversight for all CDBG-DR funds expended in the state, is obliged to ensure that all funds
are administered in a manner that is consistent with the U.S. Department of Housing and Urban
Development policy and federal law. Despite this, the GLO remains dedicated to advocating for all
impacted Texans and shall, through state wide program administration, work closely with
communities to ensure recovery programs are tailored to the individual and unique needs of the
community. Communities will have authority within the CDBG-DR regulations to determine
prioritization of the buyout and acquisition and infrastructure funds allocated to them through the
regional methods of distribution.
Comment Received: My husband, who is retired, and myself, soon-to-be-retired, were flooded
during Hurricane Harvey. The first floor of our home was destroyed and we have had to utilize
an SBA loan and credit cards to pay for repairs. We are very concerned that we will be unable
to pay off all of the debt that we are accruing trying to recover. Please let us know if we are
able to get any grant funds.
Staff Response: The Texas General Land Office has presented, through this Action Plan, several
ways in which homeowners may qualify for grant assistance. Depending on where you live, potential
grants may be administered by the GLO, Harris County, or the City of Houston. Once recovery
programs are started each of these entities will make every effort to ensure that impacted citizens are
aware of their recovery options. The GLO remains committed to ensuring impacted Texans are, to
the greatest extent allowable under the law, given every opportunity to utilize grant funds to foster
an effective and efficient recovery process.
Comment Received: Review and change the LMI criteria as residents in Polk County who
would qualify as LMI in other counties do not qualify as LMI as Polk County has lower income
levels as a whole.
Staff Response: The calculation for low- or moderate-income is defined by the U.S. Department of
Housing and Urban Development and the GLO does not have the authority to utilize another
methodology. This may however be developed into an argument for a waiver specific to certain areas
or the entire state.
Comment Received: Reduce the 70% LMI objective to 50%.
the low- or moderate-income population within the disaster impacted area is a requirement set by the
U.S. Department of Housing and Urban Development. The GLO, as an administrator of CDBG-DR
funds, is obliged to implement disaster recovery programs in a manner consistent with current federal
law.
Comment Received: Review and reduce the LMI objective for infrastructure projects.
Staff Response: The requirement that 70% of infrastructure funds be utilized to benefit the low- or
moderate-income population within the disaster impacted area is a requirement set by the U.S.
Department of Housing and Urban Development. The GLO, as an administrator of CDBG-DR funds,
is obliged to implement disaster recovery programs in a manner consistent with current federal law.
Any waiver requests to change federal requirements will be conducted at the sole discretion of the
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GLO. It should be noted that the granting of any requests remains at the sole discretion of the U.S.
Department of Housing and Urban Development.
Comment Received: The storm surge brought in by Hurricane Harvey had a devastating
impact on the harbor entrance at Port Mansfield and on the navigational fairway at Mansfield
Cut. The exclusion of these areas from the allocation will have a permanent negative impact on
the local economy of the State's poorest county and on the local marine life.
Staff Response: The Texas General Land Office remains committed to accurately assessing the
needs of impacted communities as recovery programs are designed and implemented. The GLO,
through the public comment process, has been made aware of local issues that would otherwise not
be highlighted and it will take this feedback and work to address these concerns in the most effective
manner possible. Local communities will prioritize the use of CDBG-DR infrastructure funds
allocated to them through the regional methods of distribution subject the all federal regulations.
Comment Received: The City of Grapeland requests, in order to maximize the effectiveness of
recovery funds that are allocated to our region, the following: 1. The criteria used to determine
a person's low- and moderate-low (MI) status discriminates against the lo-income residents of
our region and an alternative should be used; 2. The 70% LMI objective should be reduced to
a more reasonable 50%; and 3. The LMI National Objective for Infrastructure Projects should
be relaxed.
Staff Response: The Texas General Land Office, as the primary administrator of the CDBG-DR
funds associated with this Action Plan, is committed to the utilization of all funds in a manner that is
consistent with established federal law and guidelines. To that end, the U.S. Department of Housing
and Urban Development has established all regulations relating to low- and moderate-low income
calculations, the 70% of the aggregate requirement, and the meeting of the low- or moderate-income
National Objective.
Comment Received: The focus on housing restoration with an emphasis on low- and moderate-
income Texans is crucial to long-term economic recovery for all impacted areas. Nonprofit
Owner-Builder Housing Providers (NOHPs) are uniquely capable of providing unmet needs
for Harvey affected communities. Habitat for Humanity requests the GLO to administer state-
run programs in partnership with NOHPs.
Staff Response: The Texas General Land Office is committed to leveraging experience and expertise
of varying organizations to produce the most efficient and effective disaster recovery process
possible. The feedback provided in this comment will be given thoughtful consideration and the GLO
encourages organizations like Habitat for Humanity to remain vigilant in responding to procurement
opportunities posted by the GLO.
Comment Received: Please consider distribution of funds to have them go to all Harvey/COE
flood victims regardless of income level. Please reconsider the fund distribution to make it
available to all impacted.
Staff Response: The Texas General Land Office is dedicated to ensuring that, subject to federal
regulations, the needs of impacted communities are adequately addressed. The requirement that 70%
of the aggregate of funding be used to aid the Low- and moderate-income population in the impacted
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area has been established in the Federal Register in which this allocation was published and must be
followed.
Comment Received: The City of Cleveland was unable to download the Action Plan, but would
like to provide the following: What is the justification for allowing Harris County and the City
of Houston 45% of the total funds?
Staff Response: The U.S. Department of Housing and Urban Development has, through its issuance
of guidance regarding the Action Plan, determined that the City of Houston and Harris County will
receive direct allocations under this grant. The Texas General Land Office, as the primary oversight
agency for these funds, is obliged to implement this grant in accordance with that guidance and
federal law.
Comment Received: What will the process be to determine which planning studies are pursued
and will priority be given to regional projects? Will studies for cities also be eligible?
Staff Response: The Texas General Land Office is currently designing the planning studies process
and will present further in-depth program guidelines as soon as they become available. It can be
relayed, however, that each proposed planning study will be given adequate consideration as both
regional and local studies are eligible for funding. As of the date this response was drafted, there is
no prioritization of proposals and each proposal will be evaluated on its own merit before a decision
is made.
Comment Received: Will local buyouts and acquisition programs be run at the local or state
level? If administered at the local level, will that locality receive an allocation subject to the
COG MOD?
Staff Response: Local buyout and acquisition programs will be allocated through regional methods
of distribution to cities, counties and entities with eminent domain authority for local implementation.
Comment Received: CDBG-DR funds should be distributed based on loss and not income as
defined by the 70% LMI rule.
Staff Response: The Texas General Land Office is dedicated to ensuring that, to the greatest extent
possible, the needs of impacted communities are addressed; however, the administration of CDBG-
DR funds must be done in accordance with federal law. The requirement that 70% of the aggregate
of funding be used to aid the Low- and moderate-income population in the impacted area has been
established in the Federal Register in which this allocation was published and must be followed.
Comment Received: Refugio County has been largely left out of the plans for assistance. Our
community will NEVER recover without state/federal assistance.
impacted by Hurricane Harvey are given consideration during the method of distribution process
subject to the U.S. Department of Housing and Urban Development’s most impacted definitions. All
Texans impacted by Hurricane Harvey are given adequate opportunity to recover.
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Comment Received: My home, after living in it for 23 years, was flooded when local authorities
decided to release water from a reservoir in West Houston. My home was flooded because of
the decision of a government agency. To add insult to injury, another government agency has
decided that the zip code in which my home is located is not worthy of assistance and, on top
of that, I would not qualify for aid under this grant because of my income. I am a single mother
who raised four children in this home and now I struggle to pay the mortgage, pay rent on an
apartment to live in, and am slowly draining my savings. Please do not permit The City of
Houston and Mayor Turner to handle these funds as they have clearly disregarded citizens like
myself from the start. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office is committed to administering CDBG-DR funds in
a manner that is in compliance with federal law. To date, HUD has solidified a determination that
certain areas (counties and zip codes) are eligible to participate in programs under this grant. Despite
this, the GLO remains an advocate for citizens like yourself as we seek to ensure all impacted Texans
are presented with an avenue for meaningful disaster recover. The feedback presented in this
comment will be given adequate consideration moving forward.
Comment Received: My sister-in-law's home was flooded during Hurricane Harvey when
water was released from a reservoir in West Houston sending 4 ½ feet of polluted water into
her home for 12 days. Her zip code (77079) is not listed as eligible to receive funding under the
current Action Plan. This program should be open to all who flooded, regardless of zip code or
means testing. The City of Houston should not be permitted to administer their own program
either.
Staff Response: Anyone living in Harris County will be eligible for assistance under this program
subject to the federal regulations governing the funds. Harris County and the City of Houston will be
designing programs to support the recovery needs within their jurisdictions.
Comment Received: Waller County is requesting the State of Texas General Land Office
exercise maximum flexibility in administering the CDBG-DR funds associated with this Action
Plan in requesting a waiver of the 70% LMI overall benefit requirement. Waller County would
like to propose, in addition to this waiver, a replacement distribution ratio of 50% for the
benefit of LMI households and 50% for the benefit of non-LMI households.
Staff Response: The requirement that 70% of the aggregate amount of funding associated with this
Action Plan be utilized in a manner that benefits the Low- and Moderate-Income population within
the impacted area is established by the U.S. Department of Housing and Urban Development via the
Federal Register. The Texas General Land Office, as an administrative body for these funds, is
obliged to implement programs in compliance with all federal. The GLO shall, however, continue to
advocate for all impacted Texans and will seek every option for effective recovery if there is
compelling evidence that the requested option is both warranted and necessary.
Comment Received: Chambers County is requesting the State of Texas General Land Office
exercise maximum flexibility in administering the CDBG-DR funds associated with this Action
Plan in requesting a waiver of the 70% LMI overall benefit requirement. Chambers County
would like to propose, in addition to this waiver, a replacement distribution ratio of 50% for
the benefit of LMI households and 50% for the benefit of non-LMI households.
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Staff Response: The requirement that 70% of the aggregate amount of funding associated with this
Action Plan be utilized in a manner that benefits the low- and moderate-income population within
the impacted area is established by the U.S. Department of Housing and Urban Development via the
Federal Register. The Texas General Land Office, as an administrative body for these funds, is
obliged to implement programs in compliance with all federal. The GLO shall, however, continue to
advocate for all impacted Texans and will seek every option for effective recovery if there is
compelling evidence that the requested option is both warranted and necessary.
Comment Received: As a survivor of Hurricanes Carla, Katrina, Ike, and Harvey, I disagree
with the disproportionate distribution of the CDBG-DR allocation that gives Houston
significantly more money than smaller, poorer, and more devastated communities like
Galveston, Brazoria, Wharton, etc. Please correct this unfair, discriminating, and inhumane
decision by reallocating these dollars immediately.
City of Houston and Harris County will each be direct recipients of the amount of funds discussed in
this Action Plan using the U.S. Department of Housing and Urban Development allocation formula
for states. The Texas General Land Office, as the primary administrator of these funds, is dedicated
to ensuring all funds are utilized in accordance with the regulations and guidelines established by
U.S. Department of Housing and Urban Development, but will continue to advocate for all Texans
who were impacted by Harvey. The GLO is committed to rebuilding every community and working
to ensuring that Texans are more prepared for the next disaster within the funds provided.
Comment Received: It is recognized that the GLO did a better job at meeting it local
government partners and some non-profit organizations, but we believe future plans would
also benefit from more public participation. We hope the GLO will encourage The City of
Houston and Harris County to hold their own public meetings regarding their funding.
Staff Response: The Texas General Land Office will work in coordination with the City of Houston
and Harris County to ensure that their programs are implemented in a manner that satisfies the federal
public participation requirements at both the local and state level.
Comment Received: The GLO and The State of Texas need to formally recognize the impacts
of climate change in designing recovery programs.
Staff Response: The GLO will take this comment into consideration moving forward with disaster
recovery.
Comment Received: We urge the GLO not to be more detailed in its development of an
infrastructure plan as the Action Plan merely lists potential projects. We would also suggest
the GLO prioritize all funding to housing and related infrastructure in response to the actual
hurricane, versus spending money on infrastructure projects designed to mitigate damage from
future storms.
Staff Response: The Texas General Land Office shall work in coordination with impacted
communities to ensure that any infrastructure projects proposed are specifically tailored to the needs
of that community. These needs include rebuilding what was lost as well as strengthening for
resiliency to ensure damages from the next major storm are mitigated.
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Comment Received: The GLO should conduct a cost benefit analysis on every proposed
infrastructure project.
Staff Response: The Texas General Land Office or, in the case of the direct allocations, The City of
Houston or Harris County shall evaluate each proposed project on its merits before approval within
CDBG-DR regulations.
Comment Received: We suggest that the purchasing of land to be used as a flood control
measure be added as an eligible activity.
Staff Response: As presented under the Action Plan, buyouts programs are eligible activities for
communities under this grant. In utilizing a buyout program, the purchased land may not be built on
and must be used as either green space or for some other method of flood mitigation.
Comment Received: Prioritizing the needs of LMI households and communities.
Staff Response: The Federal Register associated with this Action Plan specifically designates 70%
of the aggregate of funds be utilized for the benefit of the low- or moderate-income population within
the impacted areas.
Comment Received: Incorporating principles relating to environmental justice in every

program.
Staff Response: The GLO will meet all environmental compliance required by the CDBG-DR
program and give the feedback contained within this comment thoughtful consideration moving
forward.
Comment Received: Prioritizing the rebuilding of affordable rental housing.
Staff Response: As stated in the Action Plan, the primary focus of this allocation is housing with
70% of the aggregate directed towards the low- or moderate-income population. The GLO has set
aside $250 million for this purpose and plans to prioritize its implementation.
Comment Received: Prioritizing construction and reconstruction that leads to more resilient
buildings
Staff Response: All construction and reconstruction of structures shall be done in a manner that
promotes more resilient buildings in accordance with local code and zoning and construction
guidelines to be issued at the program level. The Action Plan also calls out specific improvements
for reconstructed and new construction.
Comment Received: Address hazard mitigation to eliminate the impact from future pollution
from future events.
Staff Response: The GLO will take this feedback into consideration as it moves forward with the
disaster recovery process.
Comment Received: Ensure buyout programs provide families with the funding to relocate.
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Staff Response: All buyout programs must be conducted in a manner that complies with federal
relocation laws. These laws include provisions that provide for relocation assistance and guidance.
Comment Received: Assuring that the majority of funding for buyouts is focused on LMI
families.
Staff Response: As stated in the Action Plan, 70% of the aggregate amount of funding must be
utilized for the benefit of the low- or moderate-income population in the impacted area.
Comment Received: Incorporate equity into programs as a best practice.
Staff Response: The GLO, in implementing all CDBG-DR programs, remains committed equitable
treatment of all applicants in all of its programs. This includes adherence to all federal laws
prohibiting discrimination based on protected class status.
Comment Received: Emphasize mitigation and resilience.
Staff Response: Mitigation and building in resilience continue to be eligible uses in the
administration of all CDBG-DR funds.
Comment Received: Provide training on civil rights requirements for local grantees.
Staff Response: All local grantees shall be made aware of their legal obligations under federal law
when implementing grant funds.
Comment Received: Reaffirm the State's commitment to ensuring all impacted Texans benefit
equally from these funds.
Staff Response: The GLO remains committed to ensuring impacted Texans benefit equally, as
allowed under the law, from the limited funds associated with this Action Plan.
Comment Received: The GLO should match local elevation standards within its programs.
Staff Response: The GLO shall utilize the elevation standards presented in the Federal Register and
shall only adjust this standard if and when it can be demonstrated that local standards do not inhibit
project development.
Comment Received: Buy-Outs should prioritize LMI families and include storm water controls
to mitigate future flooding hazards.
Staff Response: All buyout programs shall be conducted in accordance with federal law and in
compliance with the guidelines set forth in the Federal Register.
Comment Received: Sierra Club requests that buyouts serve LMI families 2:1 compared to
their non-LMI counterparts
Staff Response: All buyout programs shall be conducted in accordance with federal law and in
compliance with the guidelines set forth in the Federal Register.
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Comment Received: We suggest that 25% of the total amount of funding be moved from
infrastructure and economic revitalization and be transferred to public housing and multi-
family housing.
Staff Response: The GLO has set aside affordable rental housing funds that public housing
authorities impacted by Hurricane Harvey may participate in. As future funds are made available and
the GLO continues to get additional data to support more funding that will also be considered.
Comment Received: New homes should be required to meet both local and federal energy and
water efficiency standards.
Staff Response: New construction, as outlined in the Federal Register associated with this Action
Plan, is required to meet specified energy and water efficiency standards.
Comment Received: The GLO should consider a revolving loan fund for rehabilitations.
Staff Response: This feedback will be given thoughtful consideration moving forward.
Comment Received: The GLO should prioritize community engagement throughout the
disaster recovery process.
Staff Response: The GLO is dedicated to working with local communities to ensure meaningful
input is received from community members regarding the use of CDBG-DR funds. All community
input is carefully considered as disaster recovery must be tailored to specific communities to be
successful.
Comment Received: The disaster recovery money (and the programs it funds) will create jobs
that will present an overall benefit to Houston as a whole.
Staff Response: The GLO agrees with this assessment.
Comment Received: Contractors should be screened for prior violations of labor laws and
monitored to prevent such violations during program implementation.
Staff Response: Contractors who seek to be utilized for work under this grant allocation do face a
screening process as required by federal and state procurement law that excludes certain contractors
for varying types of violations.
Comment Received: Grant funds should be leveraged towards workforce development by

requiring contractors to participate in apprenticeship programs.
Staff Response: The GLO will take this feedback into consideration as disaster recovery programs
develop. The GLO will ensure all Subrecipients comply with all Section 3 goals as applicable.
Comment Received: The use of all funds should include an air quality aspect to ensure residents
near projects are protected
Staff Response: All CDBG-DR projects are subjected to federally outlined environmental reviews.
For further detail on these environment reviews, please see 24 CFR Part 58.
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Comment Received: The state should create a plan addressing relocation assistance for citizens
living in communities that border polluting industries.
Staff Response: This feedback will be taken into consideration as disaster recovery projects develop.
However, the GLO may not use these funds except in response to Hurricane Harvey impacts.
Comment Received: Continuums of Care (CoCs) are the regional authorities best suited to
broker homelessness-related disaster recovery – both planning and funding—between state
agencies and local service providers. Any effort to address disaster-related homelessness cannot
be done solely at the state level.
Staff Response: The Texas General Land Office appreciates the willingness of the THN to offer
support services and expertise as the Homelessness Prevention Program move forward. The GLO is
committed to utilizing every resource available to form processes and procedures that foster an
effective and efficient disaster recovery. The GLO would encourage all CoCs to respond to
procurements related to implementation of this program.
Comment Received: The THN recommends that the three CoCs that contain CDBG-DR
eligible counties be given a more central role in homelessness-related disaster recovery
planning and program implementation.
Staff Response: The Texas General Land Office appreciates the willingness of the THN to offer
support services and expertise as the Homelessness Prevention Program move forward. The GLO is
committed to utilizing every resource available to form processes and procedures that foster an
effective and efficient disaster recovery. The GLO would encourage all CoCs to respond to
procurements related to implementation of this program.
Comment Received: The proposed Homelessness Prevention Program falls short in its total
funding allocation, its limited geographic scope, and its lack of plan to stabilize the large
number of households still in Transitional Shelter Assistance.
Staff Response: The U.S. Department of Housing and Urban Development has, through its issuance
of the Federal Register notice pertaining to this specific allocation, designated particular counties and
zip codes as eligible for funding. The GLO, as the primary administrator of these CDBG-DR funds,
must adhere to those regulations and administer funds in accordance with federal law.
Comment Received: This Action Plan omits Bexar, Dallas, Tarrant, and Travis Counties as
eligible counties for funding. The THN recommends that the homelessness prevention program
be expanded to encompass the burdens faced by inland counties and municipalities.
Staff Response: The GLO may not use the CDBG-DR funds for received for Hurricane Harvey on
any other purpose except response to this event.
Comment Received: This allocation does not specifically address the timely housing needs of
the thousands of Texans who remain in TSA.
Staff Response: This feedback is considered valuable by the Texas General Land Office and will be
given adequate consideration as the disaster recovery process develops.
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Comment Received: There is a need for a formalized and coordinate disaster response plan to
ensure that agencies, departments, municipalities, and service providers are working as
efficiently as possible when the next disaster strikes. The THN recommends a nominal amount
of funding be set aside for the development of a Texas Disaster Housing Action Plan.
Staff Response: The Texas General Land Office recognizes the need to reform and improve the
disaster response and recovery process at every level. The GLO is committed to working with
partners across the state to identify and rectify areas of concern. The GLO is more than willing and
ready to work with partners toward this effort.
Comment Received: The THN recommends the development of an intermediate step in the
planning studies process presented in the Action Plan in which municipalities, agencies, and
CoCs develop community action plans based off the findings in the CDBG-DR funded studies.
Staff Response: The Texas General Land Office, though not specifically spelled out in the Action
Plan, has every intention of utilizing planning studies conducted by the listed research institutions to
develop recovery plans of action for each community.
Comment Received: The THN recommends that the proposed database system that will
potentially house all of the planning data gathered as a result of planning studies conducted
under this Action Plan include robust information on disaster-related homelessness.
Staff Response: The Texas General Land Office appreciates this feedback and will give it adequate
consideration as it explores every option that has the potential to improve the disaster response and
recovery processes.
Comment Received: The THN recommends that the State develop a more comprehensive data
warehouse that would allow state agencies and other contributors to better understand
disaster-related needs of at-risk populations.
recovery processes.
Comment Received: The THN recommends that any data warehouse created also have a public
facing portal through which Texas residents and other interested parties can view long-term
data on natural and man-made disasters.
recovery processes.
Comment Received: The THN recommends that any data warehouse created have
corresponding computer and mobile-based applications for easier and more standardized
collection of data.
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recovery processes.
Comment Received: The THN recommends that, in line with HUD's National Mitigation
Investment Strategy, technology be given a more explicit role in infrastructure funding,
particularly in the development of a data warehouse.
recovery processes.
Comment Received: The THN recommends that the GLO be more explicit in its commitment
to attending to the housing needs of people with disabilities affected by Harvey.
Staff Response: The Texas General Land Office is committed to administering all CDBG-DR funds
in a manner that adheres to all federal laws. These laws include stringent protections that are in place
to address to the housing needs of the population of impacted persons with disabilities.
Comment Received: The THN recommends that the GLO explicitly commit to addressing the
unmet needs of ELI households in a manner at least proportionate with all LMI households'
unmet needs.
Staff Response: The Texas General Land Office remains committed to helping Texans recover from
Hurricane Harvey and this comment presents a unique perspective that will be given adequate
Comments Received: Allocation of Funds for Buffalo Bayou Flood Mitigation Efforts. Much of
the damaged sustained by citizens in my district was caused by an overflow of flood waters
from Buffalo Bayou. Investment of resources into prevention and mitigation of future flooding
will reduce future costs of recovery.
Staff Response: The Texas General Land Office does not select projects but rather relies on local
knowledge of need to prioritize these limited funds subject to the CDBG-DR regulations. The GLO,
in its evaluation of Houston's draft action plan, will utilize this feedback and give it thoughtful
consideration.
Comment Received: The requirement that 70% of the aggregate amount of funds be utilized
solely for the benefit of the LMI impacted population fails to direct an adequate amount of
funds to non-LMI households.
the Low- and Moderate-Income households that were impacted by the storm has been set by the U.S.
Department of Housing and Urban Development through the publication of the Federal Register
associated with this allocation of grant funds. Despite this current designation, the GLO is committed
to advocating for all impacted Texans and is willing, if deemed necessary and justified, to seek a
waiver to this requirement as the recovery process develops.
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Comment Received: Clarification of the maximum assistance waiver criteria and process as it
is permitted to be developed by sub-recipients of CDBG-DR dollars.
Staff Response: The Texas General Land Office will, as programs and policies are developed,
coordinate with communities to ensure they are aware of all policies associated with programs. This
will include the amount of maximum assistance allowable under each program.
Comment Received: Aransas County believes that it is in a better position to implement a

housing plan locally and is willing to develop a formal delegation of authority in the form of an
MOU if necessary.
Staff Response: The U.S. Department of Housing and Urban Development has, through the Action
Plan and the issuance of other opinions, designated the City of Houston and Harris County as
qualified to receive a direct allocation of CDBG-DR funds. The GLO, as the primary agency
providing oversight for all CDBG-DR funds expended in the state, is obliged to ensure that all funds
are administered in a manner that is consistent with the U.S. Department of Housing and Urban
Development policy and federal law. Despite this, the GLO remains dedicated to advocating for all
impacted Texans and shall, through state wide program administration, work closely with
communities to ensure recovery programs are tailored to the individual and unique needs of the
community. No other communities will be directly implementing their housing programs.
Comment Received: How can the GLO and Aransas County work to keep recovery efforts
better aligned? Is the GLO willing to partner with Aransas County to establish an active MOU
to achieve this?
Staff Response: The GLO will execute Subrecipient Agreements with communities allocated funds
for both buyout and acquisition and infrastructure funds. The GLO is committed to working closely
with impacted communities to ensure their recovery needs are adequately met in the most efficient
and effective manner possible.
Comment Received: Will local governments be given the chance to choose from a pre-vetted
list of administrators derived from the GLO's RFQ No. X0014574-AW?
Staff Response: All vendor procurement necessary for project implementation must be locally
procured by Subrecipients. The GLO is only procuring vendors for its own use.
Comment Received: Infrastructure funding is a major concern as a lack of current adequate

infrastructure presents a significant barrier for construction of workforce housing. The
funding of infrastructure would also allow a 'buy done' to meet workforce housing goals.
Staff Response: Communities will prioritize the use of infrastructure funds allocated to them subject
to the CDBG-DR regulations. The Texas General Land Office shall give ample consideration to all
feedback provided by communities that address their individualized needs for recovery. The
information provided in this comment will be utilized moving forward as programs develop.
Comment Received: Please consider funding infrastructure improvements to address infill and
redeveloped housing.
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Staff Response: Communities will prioritize the use of infrastructure funds allocated to them subject
to the CDBG-DR regulations. The Texas General Land Office shall give ample consideration to all
feedback provided by communities that address their individualized needs for recovery. The
information provided in this comment will be utilized moving forward and programs develop.
Comment Received: Please clarify 'local government'. Will the County/Cities be working
directly with the State?
Staff Response: The Texas General Land Office will contract directly with cities and counties for
hurricane recovery efforts. This effort includes coordination with cities and counties to ensure the
needs of every disaster impacted Texan are addressed.
Comment Received: Please consider expanding the rehab and reconstruction program beyond
those victims who received Individual Assistance.
Staff Response: An applicant does not have to be a FEMA Individual Assistance participant to be
eligible for housing assistance from the CDBG-DR funds.
Comment Received: Has down payment assistance been considered for survivors that are not
under the buyout program? If so, what is the criteria?
Staff Response: Individual Subrecipients operating buyout and acquisition programs may include
down payment assistance from the CDBG-DR funds.
Comment Received: How will the regional method of distribution be addressed in the Coastal
Bend Council of Governments? What is that formula?
Staff Response: The CBCOG will be responsible for developing the regional method of distribution
through a public process that is currently beginning.
Comment Received: For those programs that are 'in partnerships with COGs', how will
feedback for community needs be handled by CBCOG?
Staff Response: The CBCOG will be responsible for developing the regional method of distribution
through a public process that is currently beginning.
Comment Received: Can repair and replacement of manufacture housing units include
relocation to non-floodplain sites? Could funding be used to establish a manufactured home
park with adequate public sewage and mitigation improvements?
Staff Response: This type of program could potentially be funded from infrastructure funds allocated
to Subrecipients from the regional methods of distribution.
Comment Received: If the GLO intends to administer a state level housing program, will local
governments get the opportunity to develop housing standards that are relevant to the areas
long term goals?
Staff Response: The Texas General Land Office is committed to working with impacted
communities to ensure all recovery efforts are tailored to the specific needs of their citizens. This
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joint effort will include the development of programmatic processes and procedures that will be
determined at a later date
Comment Received: Aransas County highly supports the portion of the economic development
program that offers deferred forgivable loans.
Staff Response: The Texas General Land Office appreciates this feedback.
Comment Received: Can we include Bayside, TX and Refugio County in this allocation?
to recover.
Comment Received: Please distribute the individual needs assessments for each county, city,
or community. What will the housing recovery plan under the GLO look like for Galveston
County? What are the dollars v. projected home builds?
Staff Response: The Texas General Land Office will work in close coordination with impacted
regions to ensure that housing recovery programs are designed to meet the needs of that region. These
policies and processes will be developed in a collaborative effort and work to ensure an ongoing
relationship that fosters an effective and efficient disaster recovery.
Comment Received: How will the imposition of the 70% overall benefit rule for the LMI
population help all of the impacted areas?
Staff Response: The 70% aggregate requirement has been established by the U.S. Department of
Housing and Urban Development and the GLO, as an administrator of these grant funds, is obliged
to implement programs that are in compliance with this requirement as it is the law. If and when the
U.S. Department of Housing and Urban Development, within its sole discretion, were to grant a
waiver altering these percentages, then the GLO would ensure all communities are made aware and
all programs would reflect those changes.
Comment Received: For those areas not participating in a buyout and/or acquisition program,
can those funds be redirect for other programs?
Staff Response: The GLO plans for the funding levels for each program to remain constant until that
particular needs is met for the entire region.
Comment Received: What information will be utilized in determining community shares for
HGAC communities?
Staff Response: HGAC will be responsible for the development of the regional method of
distribution through a public process that is currently beginning.
Comment Received: What are the socioeconomic factors the GLO speaks of and how will those
impact funding to the most impacted areas?
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Staff Response: HGAC will be responsible for the development of the regional method of
distribution through a public process that is currently beginning
Comment Received: Why would a state run program be administered instead of one run by
local governments?
effective recovery.
Comment Received: What is available through the Action Plan to help Galveston recover its
loss of revenue caused by the impact on tourism in the area?
Staff Response: The GLO does not have a program specifically designed to meet this need. The
County could perhaps explore using any infrastructure funds to consider this need with adequate
documentation.
Comment Received: Can a county, city, or government request a waiver to run its own housing
program?
Staff Response: To date, the Texas General Land Office is not accepting waivers for counties, cities,
or local governments to run their own housing recovery program.
Comment Received: Was the option to locally run a housing program, like Houston and Harris
County, presented to other areas?
Staff Response: The City of Houston and Harris County have been designated by the U.S.
Department of Housing and Urban Development as eligible to be direct recipients and administrators
of grant funds for disaster recovery. The Texas General Land Office has made no such presentation
to any potential subrecipient and the decision to directly allocate funds was made at the federal
government level. This does not, however, imply that the GLO will not be actively involved in
monitoring these Harris County and the City of Houston funds to ensure that they are administered
in a manner that complies will all aspects of federal law.
Comment Received: Local governments should be fully satisfied with state run programs
before the state should be permitted to implement programs with a potential third round of
grant money.
Staff Response: The Texas General Land Office, in its administration of CDBG-DR funds, will be
periodically subjected to several types of reviews and audits by the U.S. Department of Housing and
Urban Development aimed at gauging compliance with the federal law. The GLO, only through the
approval and performance ratings from the U.S. Department of Housing and Urban Development,
shall retain its duty to administer CDBG-DR funds. The GLO shall, however, remain open to all
feedback from communities as refining processes and policies in a manner that fosters a better
recovery for impacted Texans is one of our highest priorities.
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Comment Received: Can a waiver to section 582 be considered for building in a floodplain?
Staff Response: The GLO will need more information regarding section 582 before a waiver may
be considered.
Comment Received: Will CDBG funds be available if programs move families out of the area
and alter the tax base and tax revenue?
Staff Response: The GLO does not have a program specifically designed to meet this need. The
County could perhaps explore using any infrastructure funds to consider this need with adequate
documentation.
Comment Received: Will the GLO seek approval and input from local governments when
developing Affordable Housing Programs?
Staff Response: The Texas General Land Office will absolutely seek input from local communities
and citizens when developing Affordable Housing Programs. As a part of a robust citizen
participation process, the GLO shall make every effort to allow a community present its comments
and concerns so each housing program may be tailored specifically for the needs of that area.
Comment Received: Why will waivers not be accepted concerning the exclusion from funding
of buildings generally used to conduct government business?
Staff Response: the U.S. Department of Housing and Urban Development has not provided for this
waiver as they have in the past. If a community has a specific need they to present evidence to the
GLO for consideration to submit to the U.S. Department of Housing and Urban Development.
Comment Received: Please define the GLO's administrative funding amount and release an
administrative budget.
Staff Response: The Texas General Land Office shall, as it has with prior grants, will remain within
the prescribed caps for Administrative, Project Delivery, and Housing presented under federal law.
Any funds not utilized for those purposes will be converted to additional project dollars.
Comment Received: Please share any information pertaining to the administrative funding
currently projected to be used by the City of Houston and Harris County.
Staff Response: The Harris County and the City of Houston programs have not been defined so their
needs of administrative funds have not been determined.
Comment Received: Will the GLO hold public meetings in the impacted communities?
Staff Response: The Texas General Land Office is committed to ensuring local communities are
given ample opportunity to understand each aspect of the recovery process. The GLO has a plan for
various meetings to present and discuss the Action Plan programs to communities.
Comment Received: Will the GLO request a waiver of the 70% LMI benefit requirement?
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Staff Response: The Texas General Land Office, along with any other subrecipient of CDBG-DR
grant funding, is required to administer those funds in accordance with current federal law. Absent
compelling evidence that the current requirements present a significant impediment to the disaster
recovery process. Despite this, the GLO shall continue to advocate for impacted Texans and is willing
to revisit this subject if and when the circumstances discussed present themselves.
Comment Received: Will the comment period be extended from 14 days to a full 30 days?
Staff Response: The Texas General Land Office has, in accordance with the guidelines established
by the Federal Register associated with this allocation, conducted the required public comment period
presented as sufficient to meet the public participation requirement under the law. Additionally, the
GLO extended that period and accepted public comment up and until May 1, 2018 at 5:00 pm.
Comment Received: Hello, I am an immigrant from Vietnam who came to the USA in 1981 and
moved to Houston with my husband in 1997. We purchased a home in the Memorial Bend
subdivision, which is located in the 500-year floodplain, but it had never flooded before.
Hurricane Harvey rains combined with multiple reservoir released caused our home to flood.
Our home flooded and we lost everything: our home, all the contents, memorable pictures, and
our cars. My family is still displaced and we are stressed emotionally, physically, and
financially. My husband and I are good citizens. We work hard, pay our taxes, and haven't had
to ask for handouts. We are asking to be fairly compensated for our losses from the CDBG-DR
funds.
Staff Response: The Texas General Land Office remains dedicated to ensuring families like yours
are given ample opportunity, to the extent allowed under the law, to recover from the effects of
Hurricane Harvey. The GLO will continue to work with your local community leaders to build
recovery programs that foster the most efficient and effective recovery possible.
Comment Received: All levels of government should be involved in the recovery process and
public input should at every stage of the recovery process.
Staff Response: The Texas General Land Office is committed to developing ongoing relationships
with impacted communities to ensure all recovery programs are administered in a manner that is most
beneficial to each specific community. This includes cooperation and coordination during the
assessment, planning, construction, and post-construction monitoring stages.
Comment Received: To the greatest extent practicable, control and direction of programs
should be devolved to the lowest level of government possible.
Staff Response: The Texas General Land Office is willing to work with all communities and provide
the necessary technical assistance when required. The GLO recognizes that capacity levels differ
among communities and will maintain oversight of all programs to ensure proper administration
under federal law.
Comment Received: Funds should be allocated and spent at the fastest rate possible.
Staff Response: The Texas General Land Office remains committed to the efficient and effective
administration of CDBG-DR funds within the bounds of federal law.
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Comment Received: Programs should be developed with an eye towards local capacity,
particularly the use of non-profits.
Staff Response: The Texas General Land Office is committed to leveraging local expertise and
resources in a manner that fosters the most efficient and effective recovery process possible. This
will include consulting with local businesses, non-profits, and other organizations to develop the
most wholistic recovery possible.
Comment Received: Reference points should be added to avoid confusion as to which parts of
the Action Plan will be managed by the GLO.
Staff Response: The Texas General Land Office will be primarily responsible for the administration
of programs that fall outside of the boundaries of Harris County. Harris County and the City of
Houston have received a direct allocation and will be the primary administrators of CDBG-DR funds
for their respective jurisdictions.
Comment Received: There should be clarification as to when and how citizens may provide
input into the Harris County and City of Houston Action Plans.
Staff Response: Citizen participation plans shall be developed separately by both Harris County and
the City of Houston and will be published as Amendment 1 for a state wide public comment period
over the coming months.
Comment Received: What is the basis for the general requirement making homeowners who
make over 120% of the area median income not eligible for assistance?
Staff Response: All requirements set forth in the Action Plan are either required under federal law
or have been implemented in an effort to create a more equitable recovery. This requirement was set
directly by the U.S. Department of Housing and Urban Development.
Comment Received: What is the specific dollar amount of 120% of median income?
Staff Response: The specific dollar amount inquired about in this comment will vary depending on
the area in which the homeowner resides.
Comment Received: 1. I would like to see more Homelessness Prevention funds and Rapid
Rehousing funds be made available. 2. The Continuum of Care and Texas Homeless Network
have the most desirable background and should be included in interagency cooperative
planning and implementation efforts.
Staff Response: The Texas General Land Office has received the comment presented and will give
them thoughtful consideration as the disaster recovery process moves forward. The GLO is dedicated
to fostering an effective and efficient disaster recovery through a collaborative effort and appreciates
the points made in this submission.
Comment Received: Language that results in ineligibility due to income level, flood plain
location, and lack of insurance should be removed. (Multiple respondents provided this feedback)
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Staff Response: All requirements presented in the language addressed in this comment have been
established on the federal level by the U.S. Department of Housing and Urban Development. The
GLO is obliged to administer the CDBG-DR funds associated with this grant in a manner that is
consistent with all current federal rules.
Comment Received: Many in Houston suffered flooding due to decisions made by the Army
Corps of Engineers and Harris County Flood Control District and are engaging in legal action
against these agencies and other culpable parties. Any potential award that may result from
these legal actions should be specifically from the category of 'future award' and exempt under
the subrogation agreement. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office recognizes the points made in this comment and
will give them thoughtful consideration in consultation with the U.S. Department of Housing and
Urban Development related to duplication of benefit regulations.
Comment Received: The LMI distribution should be changed from 70% of total funds to 50%
of total funds. (Multiple respondents provided this feedback)
Staff Response: The requirement that 70% of the aggregate amount of CDBG-DR funds be utilized
to aid the low- or moderate-income population in an impacted area has been established in the Federal
Register and the GLO is obliged to follow that guidance.
Comment Received: Remove language that includes an SBA loan application as a

benefit/duplication of benefits. (Multiple respondents provided this feedback)
Staff Response: All rules and regulations relating to SBA loans and duplication of benefits are
federally established and the GLO, as the primary administrator of CDBG-DR funds, is obliged to
follow those rules unless otherwise indicated by the U.S. Department of Housing and Urban
Development.
Comment Received: As a flooded resident of the Fleetwood subdivision (zip code 77079) caused
by the release of Barkers and Addicks dam waters, I believe that the funds should be
distributed more equitably and that 70% to LMI folks is unfair.
Staff Response: The Texas General Land Office must, in accordance with the federal regulations
outlined in the Federal Register notice associated with this CDBG-DR allocation, administer disaster
funds consistent with the 70% low- or moderate-income requirement. This requirement is established
by the U.S. Department of Housing and Urban Development and the GLO and/or any recipient of
funds is obliged to administer these funds in line with that regulation.
Comment Received: Will the GLO assure local governments that it will establish a mechanism
whereby CDBG-DR funds will be available to meet the 25% local share of HMGP elevation
programs? Would the GLO consider making these awards directly to local governments to
coordinate elevation programs?
Staff Response: The CDBG-DR funds are permitted to be used as the match for HMGP local cost
share as long as the project is CDBG-DR eligible. Applying to use these funds for a match will be
program specific, but there will be clear and concise instructions presented by the administrator of
the program, TDEM.
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Subrecipients allocated funds under the buyout and acquisition and infrastructure programs may
choose to prioritize their funds toward match.
Comment Received: In regards to the State Action Plan for Hurricane Harvey Recovery, I ask
for consideration for the following: 1. Review/change the current LMI criteria, 2.
Review/change the 70% overall LMI benefit requirement, 3. Review/change the LMI national
objective for infrastructure projects.
Staff Response: The U.S. Department of Housing and Urban Development has, through the
publication of the Federal Register notice, established the low- or moderate-income determination
criteria and the 70% overall low- or moderate-income benefit requirement for all projects, including
infrastructure. The Texas General Land Office and any direct subrecipient must administer all
CDBG-DR funds in compliance with current federal law.
Comment Received: On behalf of our member governments and citizens who are suffering
from the impact of Hurricane Harvey, we offer the follow comments to the State Action Plan
for Hurricane Harvey Round 1 Disaster Recovery: 1. The criteria used to determine a person's
LMI status actually discriminates against the low-income residents of our region because they
are looped in with the more affluent areas; 2. The 70% LMI national objective should be
reduced to a more reasonable 50% to ensure flexibility needed to assist more citizens in need;
3. The LMI national objective for infrastructure projects should be relaxed to allow maximum
flexibility, which in turn will benefit more LMI persons. (Multiple respondents provided this
feedback)
publication of the Federal Register notice associated with this grant, established and defined the
impact area and the 70% overall low- or moderate-income benefit requirement. The U.S. Department
of Housing and Urban Development defines the methodology that must be used to calculate low- or
moderate-income.
The GLO shall, however, remain steadfast in its commitment to advocate for all Texans throughout
the disaster recovery process and is open to reevaluating its current stance on this issue as recovery
programs develop.
Comment Received: The Mayor of Houston and his staff are not competent enough to
sufficiently and swiftly administer this size of a program. (Multiple respondents provided this
feedback)
Staff Response: The U.S. Department of Housing and Urban Development has determined that The
City of Houston shall receive a direct allocation of funding under this grant. Unless otherwise directed
by the U.S. Department of Housing and Urban Development, the GLO will work to ensure that these
funds, though administered by Houston, are given ample oversight to ensure complete compliance
with federal law.
Comment Received: So far, the Mayor has diverted funds from certain zip codes and we don't
want this type of bias. (Multiple respondents provided this feedback)
City of Houston shall receive a direct allocation of funding under this grant. Unless otherwise directed
by the U.S. Department of Housing and Urban Development, the GLO will work to ensure that these
Page 350 of 420
funds, though administered by Houston, are given ample oversight to ensure complete compliance
with federal law. The GLO is obliged to ensure lawful administration of these funds as currently
defined under federal law.
Comment Received: The 70%/30% split of funds should be waived to at least 50%/50% to
ensure all folks, not just LMI, can recover. (Multiple respondents provided this feedback)
Staff Response: The requirement that 70% of the aggregate of funds be utilized to benefit the low-
and moderate-income population in an impacted area is established in the Federal Register by the
U.S. Department of Housing and Urban Development.
Comment Received: The maximum allowed amount of $50,000.00 for the Homeowner
Reimbursement Program is not high enough. (Multiple respondents provided this feedback)
Staff Response: The GLO remains committed to ensuring all impacted Texans have access to
resources that foster a meaningful recovery and this comment will be given thoughtful consideration
moving forward.
Comment Received: SBA loans should not be considered a duplication of benefits as there is
an obligation to pay that debt back. (Multiple respondents provided this feedback)
Staff Response: All duplication of benefits rules and regulations are established under federal law
and any changes to those rules are outside of the scope of the Texas General Land Office. Your
concerns are, however, important and the GLO will continue to advocate for impacted Texans on
issues like this one.
Comment Received: The GLO should increase funding for affordable housing initiatives and
expand programs that support those initiatives: a. We urge the GLO to accomplish this partly
by reallocating the $75 million from PREPs to the Affordable Rental Program; b. Additionally,
we ask the GLO to make changes to its proposed programs to better the needs of homeowners
and renters. These changes could include requirement to use funding to make relocation a
viable option or allow multi-family landlords to recoup repair costs in the Homeowner
Reimbursement Program.
Staff Response: The Texas General Land Office, in an attempt to meet the primary housing focus
emphasized in the Federal Register and administer other necessary programs required for recovery
efforts, has determined that the current proposed programs do that.
The GLO is committed to funding affordable housing initiatives and is working to refine the policies,
processes, and procedures that support those programs. The feedback provided in this comment will
be given thoughtful consideration as the programs resulting from this grant allocation progress.
Comment Received: The Action Plan falls short of Affirmatively Furthering Fair Housing.
Staff Response: The Texas General Land Office is fully committed to ensuring all CDBG-DR funds
are administered to impacted communities in a manner that is consistent with federal law. As stated
in the Action Plan, all programs and projects will be undergo an individual review for AFFH
compliance. The GLO has gone further than required by federal law in coordinating a portion of these
review efforts with an outside housing advocacy group to be as thorough as possible.
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Beyond the AFFH requirements, the GLO is fully committed to administering programs that comply
with Title VI of the Civil Rights Act of 1964. The GLO firmly believes that disaster recovery efforts
should be undertaken in an equitable manner absent of discrimination of any kind.
Comment Received: The City of Houston and Harris County have had disproportionate access
to the Proposed Action Plan which raises concerns about the GLO's transparency.
Staff Response: The Texas General Land Office has complied with all requirement presented under
the Federal Register regarding the development of a robust citizen participation process. Not only
has the public been given the 14-day requirement comment period, but the GLO extended that
deadline.
The U.S. Department of Housing and Urban Development has determined, at its own discretion, that
Harris County and the City of Houston are eligible to receive and directly administer funds under
this allocation as such the GLO provided the Action Plan to Harris County and the City of Houston.
Despite this, the GLO remains the primary agency for conducting oversight and monitoring of these
programs and will work diligently with these entities to ensure compliance under federal law. Finally,
the GLO is dedicated to the continual advocacy of all impacted Texans and is working tirelessly to
ensure all communities, regardless of their size, are given an adequate chance to access funds to allow
for an effective recovery within the U.S. Department of Housing and Urban Development program
requirements and program implementation preferences
Comment Received: The GLO has no legitimate reason for not holding at least one public
hearing on the Proposed Action Plan.
Staff Response: The Texas General Land Office and its staff has made every effort to conduct a
robust citizen participation process in accordance with the Federal Register. In fact, this process
began as soon as Hurricane Harvey made landfall when members of the GLO team conducted nearly
300 community visits and weekly conference calls with local officials to begin accessing the impact
of the storm and the needs of disaster victims. The GLO has worked in constant tandem with local
elected officials to gauge the needs of their constituency and those efforts have played directly into
the formation of this Action Plan.
Comment Received: We commend and applaud the GLO for not seeking a waiver to lower the
requirement that 70% of CDBG-DR funds be used to benefit LMI populations. The GLO
cannot relinquish control of recovery funds to jurisdictions that do not recognize the
importance of this requirement, especially Galveston County.
Staff Response: The Texas General Land Office has noted the feedback presented in this comment.
Comment Received: The Acton Plan does not appropriately account for other sources of funds.
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Staff Response: The Texas General Land Office shall, in coordination with funding provided by
other federal, state, local, private, and nonprofit sources, leverage CDBG-DR funds in a manner that
allows for the most efficient recovery possible. This process would include identifying those funding
sources and potentially using CDBG-DR funds to fill gaps and finish projects were other sources of
funding were inadequate to do so.
Comment Received: The Needs Assessment undervalues unmet need among renters and LMI
households.
Staff Response: The Texas General Land Office is committed to identifying and assessing the needs
of all Texans impacted by Hurricane Harvey and recognizes that every method of evaluation and
analysis presents certain shortcomings. Because of this, the GLO has dedicated resources to think
beyond the means of evaluation and using resources like the Social Vulnerability Index to gain a
more wholistic view of impact and recovery needs. The feedback in this comment shall be given
thoughtful consideration as the disaster recovery process progresses.
Comment Received: The Action Plan does not tie its Needs Assessment to its funding allocation
decisions.
Staff Response: The Texas General Land Office, through the analysis presented in the Action Plan,
has provided all data up on which funding allocation decisions have been made outside of the direct
allocations presented to Harris County and the City of Houston. The programs identified allow for
the most efficient and effective recovery possible by allowing recovery to begin in several capacities
from these very limited funds.
Comment Received: The GLO must allocate more money to the rehab and reconstruction of
multi-family units with CDBG-DR funds as there were zero participants in the Multi-Family
Lease and Repair Program funded by Section 408 of the Stafford Act.
Staff Response: The Multi-Family Lease and Repair Program was a FEMA funded program
administered separate from any anticipation of CDBG-DR grant funds. The lack of participation in
one program does not directly correlate with the decisions for funding distribution within this Action
Plan.
Comment Received: The GLO should reallocate the $72.7 million for the PREPS match to the
Affordable Rental Program and rely on the Rainy Day funds or existing funds to cover this
expense. Additionally, the GLO should encourage local jurisdictions to focus on housing
instead of covering cost shares for mitigation and public assistance that can be done with future
allocations.
Staff Response: The PREPS program is a FEMA program administered separate from any
anticipation of CDBG-DR funds within our state. Additionally, the State of Texas has worked to
utilize funding in the interim period between Harvey landfall and CDBG-DR funding to ensure all
Texans are given the most efficient route to recovery. The GLO does not have jurisdiction over any
other State funds that could be used for this purpose.
Comment Received: It is a waste of time and an administrative burden to develop program

guidelines by regional area.
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Staff Response: The Texas General Land Office shall, on a high level, develop programmatic
guidelines to ensure efficiency and uniformity in administration of CDBG-DR funds. However, the
GLO is committed to coordinating with localities and regions to ensure that programs are allowed
flexibility to be tailored to best serve the needs of those localities and regions.
Comment Received: The Homeowner Assistance Program does not adequately allow
homeowners to relocate.
Staff Response: The Texas General Land Office recognizes that all programs proposed under this
Action Plan must be carried out in a manner consistent with current federal law inclusive of adherence
to the Uniform Relocation Assistance Act and all of its supporting provisions.
Comment Received: The Local Buyout and Acquisition Program is too vague to ensure
equitable buyout administration.
Staff Response: The Texas General Land Office is committed to aiding communities in designing
programs under the framework presented in this Action Plan. The GLO, as an oversight entity, shall
work closely with communities to ensure that all programs created and carried out are done so in
accordance with federal law. The GLO is dedicated to serving all impacted Texans to ensure an
equitable recovery process.
Comment Received: There are concerns that the Homeowner Reimbursement Program does
not serve LMI homeowners as they do not have the means necessary to render repairs in the
first place. We encourage the GLO to open this program up for landlords who have made
qualifying repairs on multi-family units.
Staff Response: The Texas General Land Office appreciated the feedback provided in this comment
and will give it thoughtful consideration moving forward.
Comment Received: The Homelessness Prevention Program should be expanded to using any
means necessary to prevent homelessness.
Staff Response: The GLO will consider every avenue available and allowable under CDBG-DR
grant administration to provide for homelessness prevent. The feedback provided in this comment
shall be given thoughtful consideration moving forward.
Comment Received: We have serious concerns that the Affordable Rental Program will be a
less likely recovery alternative for many landlord as time passes.
Staff Response: The GLO recognizes how the typical timeline associated with the allocation of
CDBG-DR funds can present unique obstacles to the recovery process. In light of this, the GLO is
willing and open to utilizing the feedback presented in this comment to work to conquer those
obstacles in a manner that fosters an effective recovery process.
Comment Received: The infrastructure spending references are too vague to ensure that funds
will be spend to benefit the LMI community.
Staff Response: The U.S. Department of Housing and Urban Development has presented, in the
Federal Register notice, the requirement that 70% of the aggregate amount of funding from this
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CDBG-DR grant be utilized to benefit the low- or moderate-income population in the impact area.
All programs, including infrastructure, are included in this calculation.
Comment Received: The economic revitalization program should be limited to no more than
$25 million and available only to microenterprises given the GLO's recognition that the unmet
housing need for the LMI population is $4.45 billion.
Staff Response: The Texas General Land Office appreciates the feedback provided in this comment
and will give it thoughtful consideration as the Economic Revitalization Program specifics are
developed.
Comment Received: The State needs to be more inclusive of nonprofits in identifying and
participating in studies for executing projects developed during the planning process.
Staff Response: The Texas General Land Office is committing to utilizing expertise and knowledge
from all sources to ensure Texans impacted by Hurricane Harvey are given the most wholistic
recovery process possible. This commitment includes consultation with local citizens, governments,
and relevant nonprofits.
Comment Received: The GLO has failed to set out a plan that ensures completion of projects
in a timely manner, or to minimize opportunities for waste, mismanagement, fraud, and abuse.
Staff Response: The GLO must, in compliance with the requirements presented in the Federal
Register, expend all obligated funds within two years of their obligation unless an extension is
granted by the U.S. Department of Housing and Urban Development. Additionally, the GLO remains
subject to regular audit proceedings to ensure all programs are implemented in a manner that
minimizes the risk of waste, mismanagement, fraud, and abuse.
Comment Received: The GLO should present a centralized and searchable database to prevent
wasting resources on answering duplicative public information requests.
Staff Response: The GLO has received the feedback presented in this comment and will give it
thoughtful consideration as the recovery process continues.
Comment Received: The proposed Action Plan does not address vulnerable populations or
shelters.
Staff Response: The GLO, through its programs to prevent and mitigate homelessness, shall look to
address issues faced by vulnerable populations and in shelters. As these programs develop and
progress, those details will be made available to the public to present the opportunity for collaborative
problem solving.
Comment Received: The Action Plan fails to address the extent of displacement or the obstacles
displaced residents face in returning to their communities.
Staff Response: The GLO has received the feedback in this comment and will give it thoughtful
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Comment Received: The GLO should require standard benefit levels across jurisdictions to
ensure housing assistance programs are offered across all parts of the disaster affected area.
Staff Response: The GLO is committed to ensuring that localities have the ability to develop
programs in a manner that best serves their impacted population. This includes permitting
jurisdictions to set certain programmatic guidelines. Despite this, the GLO shall maintain oversight
of these programmatic details and ensure that all programs are designed in a manner that is consistent
with federal law.
Comment Received: The LMI distribution should be changed from 70% of total funds to 50%
of total funds.
Staff Response: The requirement that 70% of the aggregate amount of CDBG-DR funds be utilized
to aid the low- or moderate-income population in an impacted area has been established in the Federal
Register and the GLO is obliged to follow that guidance. Any changes to this guidance must be
explicitly issued by the U.S. Department of Housing and Urban Development.
Comment Received: By the Texas General Land Office and NOT the City of Houston. We have
not been treated fairly by current city and county administrators and this must change. We
have confidence in the GLO and request that your office be in charge of the distribution of
current and any future CDBG-DR funds related to Hurricane Harvey.
City of Houston will receive a direct allocation of CDBG-DR funds under this Action Plan for
Hurricane Harvey disaster recovery. The GLO shall, however, remain committed to ensuring that
these funds are administered in a manner that remains in compliance with federal law through
oversight and audit type functions. The GLO also remains committed to advocating for all impacted
Texans as the recovery process continues.
Comment Received: In a 50/50 split between LMI households and non-LMI households as the
flooding caused by Harvey did not maintain a 70/30 split in who it impacted.
Staff Response: The requirement that 70% of the aggregate amount of funding be utilized for the
benefit of low- or moderate-income households is a regulation that has been established by the U.S.
Department of Housing and Urban Development through the publication of the Federal Register. The
GLO, in an effort to administer funds in accordance with the law, shall maintain this division unless
otherwise directed from the U.S. Department of Housing and Urban Development. Any change in
this requirement is the sole discretion of HUD, but the GLO recognizes this concern and will continue
to advocate on behalf of impacted Texans.
Comment Received: Please do not limit the reimbursement program to $50,000 per household.
Staff Response: The designation of caps for programs have been determined during the initial design
of each assistance program to ensure each program has necessary available funds to help as many
impacted Texans as possible. The Texas General Land Office is committed to considering this
feedback and will utilize this to reevaluate currently set caps in all programs. It should be noted,
however, that the adjustments of any caps are at the sole discretion and determination of the program
administrators.
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Comment Received: There is a concern that the City of Houston is not capable of managing an
amount of money in excess of $1 billion dollars. How can an organization the size of a city staff
up appropriately and competently enough to efficiently and swiftly administer this size of a
program?
City of Houston and Harris County are eligible to both directly receive funding under this Action
Plan and administer those funds through varies recovery programs. Despite this, the Texas General
Land Office shall maintain oversight and audit functions, offer technical assistance when necessary,
and continue to advocate on behalf of all Texans impacted by Hurricane Harvey.
Comment Received: Grant an extension of the public comment period to total thirty days.
Staff Response: The Texas General Land Office has, as outlined in the requirements presented in
the Federal Register, conducted a robust citizen participation process by publishing this Action Plan
for public comment for the required period. Additionally, the GLO extended that period and accepted
public comment up and until May 1, 2018 at 5:00 pm.
Comment Received: Galveston County formally objects to the direct allocations being given to
the City of Houston and Harris County and requests that the State of Texas modify the Action
Plan to include these two entities in an allocation process consistent with the other impacted
communities across Texas. (Multiple respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Developed has deemed the City of
Houston and Harris County as eligible to receive direct allocations of funding under this grant. The
Texas General Land Office, however, shall maintain a certain level of oversight duties and work with
each of these entities to ensure that all federal funding is administered in a manner consistent with
federal law.
Comment Received: Galveston County requests the State seek a waiver to the 70% LMI overall
benefit requirement and replace it with a 50% LMI overall benefit requirement. (Multiple
respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Development has established the 70%
low- or moderate-income overall benefit requirement through the publication of the Federal Register.
All subrecipients, including the Texas General Land Office, are obliged to administer all grant money
in accordance with current federal law. Otherwise, it should be noted that all requirements presented
in the Federal Register are considered established law and may only be waived at the discretion of
Comment Received: Galveston County requests the State seek a waiver to the LMI area benefit
requirement. (Multiple respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Development has established the low-
or moderate-income area benefit requirement through the publication of the Federal Register notice.
All subrecipients, including the Texas General Land Office, are obliged to administer all grant money
in accordance with current federal law. Otherwise, it should be noted that all requirements presented
in the Federal Register are considered established law and may only be waived at the discretion of
Page 357 of 420
Comment Received: Galveston County requests the State revise the Action Plan to clearly
indicate which types of studies will be conducted by vendors and which will be intended for
research institutions. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office has determined that the usage of research
institutions within the state to conduct planning studies related to Hurricane Harvey recovery would
be the most effective and efficient.
Comment Received: The City requests to be allowed to retain and utilize program income to
allow the City to quickly cycle funding back into the community.
Staff Response: The GLO will consider on a case by case basis allowing Subrecipients to maintain
program income.
Comment Received: The City requests the GLO allow flexibility in the caps set for
administrative and project delivery costs.
Staff Response: The Texas General Land Office has, in utilizing its experience with CDBG-DR
grant fund administration, set certain cost caps associated with administrative and project delivery
activities. These caps have been determined as reasonable and will only be adjusted if, at the sole
discretion of the GLO, it is determined that such an adjustment is warranted and necessary.
Comment Received: The City requests the following waivers: Provide a scalable affordability
requirement to improve the feasibility to fund both large and small scale projects.
Staff Response: The Texas General Land Office recognizes the reasoning behind this comment and
will take this feedback into consideration as programs progress.
Comment Received: The City requests the following waivers: Extend the timeframe each
grantee has to expend all obligated funds from two years to six years.
Staff Response: All expenditure deadlines have been established by the Department of Housing and
Urban Development and the GLO shall only seek waivers of these deadlines if and when it can be
shown that such an extension is warranted and necessary.
Comment Received: The current program implementation of small business grants does not
align with historical legislative efforts as it does not target 'Mom and Pop' business. a. The
following are recommendations related to this point: i. Grant amounts should be capped at
$100k to support assistance being provided to a greater number of applicants; ii. No applicant
should receive total funds in excess of the $100k cap, inclusive of any other compensation for
loss received from any other governmental agency, and iii. Work retention or new hires under
this program should target areas hardest hit by Harvey.
Staff Response: The Texas General Land Office is committed to developing recovery programs that
are both efficient in practice and effective in outcome. The feedback provided in this comment will
be taken into consideration as the policies and procedures related to the pilot Small Business Loan
Grant Program are developed.
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Comment Received: I applaud and support the direct allocation of the Houston and Harris
County disaster recovery planning process. The GLO should work closely with The City of
Houston and Harris County to ensure a seamless process. The following are recommendations
related to this point: i. The focus on the most vulnerable areas for recovery is important and
for this reason the level of scrutiny should include zip codes and carrier routes to better
understand poverty within counties. ii. The GLO should include an assessment of persons who
are at risk of homelessness. iii. The goal should be to sustain, not degrade, the number of
multifamily LMI housing options. iv. Native American communities should be engaged in the
housing recovery process.
Staff Response: The U.S. Department of Housing and Urban Development has deemed Harris
County and the City of Houston eligible to be direct recipients of grant money allocated in association
with this Action Plan. The Texas General Land Office shall, however, build and maintain a close
working relationship with both of these entities to ensure all grant funding is administered in a manner
that is consistent with federal law.
The GLO shall record all aspects of this comment and present them for consideration by the Harris
County and The City of Houston as these entities remain a higher level of autonomy when designing
their recovery programs.
Comment Received: Multi-Family Lease and Repair needs refining. a. The following are
recommendations related to this point: i. The affordability period is too short given the length
of time recovery is expected to take. ii. Residents in the 500 or 1000 year floodplains should be
consulted with to ensure resilience and sustainable designs are a part of the repairs provided.
iii. A census of neighborhoods should be conducted to determine scope and severity of damage.
iv. A construction training program should be established in coordination with local programs
and schools to fuel the workforce need. v. Focus efforts for new hires for construction jobs on
those residing in the hardest hit areas.
Staff Response: The Multi-Family Lease and Repair Program, a FEMA funded program
administered by the GLO is not a part of this Draft Action Plan.
Comment Received: Oversight of home repairs as it relates to the PREPs Program. a. The
following are recommendations related to this point: i. The GLO should establish an audit
process whereby audits of the work performed under these programs can be performed and
assessed. ii. The State should establish an ombudsman and a complaint line for consumers to
report problems and provide an effective means to have legitimate complaints addressed.
Staff Response: The PREPs Program, a FEMA funded program administered by the GLO is not a
part of this Draft Action Plan.
Comment Received: The GLO should collaborate with local jurisdictions to include a census
of homeless persons in the impacted areas.
Staff Response: The Texas General Land Office has, through the outlining of programs in the Action
Plan, set aside a portion of grant funds specifically to address prevention of homelessness within the
impacted area. It is the full intention of the GLO to collaborate with local communities to identify
the specific needs of each population and work to create programs that foster the greatest ability to
meet those needs.
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Comment Received: The GLO should commit to hiring locally in the hardest hit areas.
Staff Response: The Texas General Land Office recognizes the value of hiring locally in the areas
hardest hit by Hurricane Harvey and will consider instituting policies and practices that prioritize this
practice.
Comment Received: How can City of Houston staff manage a grant this large? The Mayor has
already diverted funds from my zip code and we don't want this type of bias associated with
these grant funds.
Houston eligible to receive a direct allocation of these grant funds to be administered for disaster
recovery purposes. The Texas General Land Office shall remain available to all grantees to offer
technical assistance to ensure all funding is administered in accordance with federal law.
Comment Received: The Homeowner Reimbursement Program should not cap funds at $50k
per household. (Multiple respondents provided this feedback)
Staff Response: The Texas General Land Office has worked to establish program caps that permit
the grant funds allocated in associated with this Action Plan to reach as many impacted Texans as
possible. It is the ongoing goal of the GLO to design programs, policies, and processes that have the
most widespread impact as the recovery process progresses.
Comment Received: Extend the comment period beyond April 25, 2018. (Multiple respondents
Staff Response: The Texas General Land Office has, in compliance with the citizen participation
requirements presented in the Federal Register, has conducted the mandatory fourteen-day public
comment period. Additionally, the GLO extended this comment period up and until May 1, 2018 at
5:00 pm.
Comment Received: Request a waiver from HUD or by State Administrative Plan, if sufficient
authority exists, to seek a reduction in the 70% overall benefit requirement. (Multiple
respondents provided this feedback)
Staff Response: The U.S. Department of Housing and Urban Development has established, through
the publication of the Federal Register, that 70% of the aggregate amount of CDBG-DR funding
associated with this Action Plan must be utilized for the benefit of low- or moderate-income
households. Absent compelling evidence that this requirement presents a serious impediment to the
disaster recovery process, it is the decision of the GLO not to seek such a waiver at this time. It should
be noted that all waiver decisions are solely within the discretion of the U.S. Department of Housing
and Urban Development.
Comment Received: The Texas Department of Insurance would like to present the following:
1. As future submissions of Hurricane Harvey data are reviewed and finalized, these reports
will be published via www.TDI.Texas.gov under the Reports and Publications section. 2. TDI
also provides a residential property statistical plan that may also be found via our website. 3.
TDI has provided the GLO with the Quarterly Residential Property Policy and Exposure
report.
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Staff Response: The Texas General Land Office has received all relevant information and
documentation associated with this comment and will give it ample consideration as the disaster
recovery process progresses.
Comment Received: Needs Assessment. It appears to me that the needs assessment presented
has been conducted without actually visiting the impacted areas and visiting with citizens.
Staff Response: The Texas General Land Office has, and continues, to meet with impacted
communities to assess their specific needs. The GLO began weekly conference calls along with in
person meetings as soon as Harvey made landfall and has remained in constant contact with local
officials to adequate assess need and determine the programs needed to foster an effective recovery
for each specific community. To date GLO staff have participated in in excess of 300 meetings,
hearings, and discussions related to response and recovery for Hurricane Harvey.
Comment Received: The median value of impacted homes is listed at $105,800, but this requires
more money to be allotted to homes that require less money to be repaired. Why is needs not
based on the difference between income and home value?
Staff Response: This value was set to be representative of an average home cost to calculate damage
and unmet need. The actual need and cost of a repair per home will determine the cost spent per
home.
Comment Received: The previous system used to determine need after Hurricane Harvey is
flawed in that it doesn't account for the discrepancy between insurance monies and the actual
cost to fix a home, it doesn't account for the discrepancy between income and home valuation,
and does not account for the lack of construction workers and the high cost of basic supplies.
Staff Response: The Texas General Land Office utilizes up-to-date data and long-standing
methodology to determine unmet need within disaster impacted communities. This value was set to
be representative of an average home cost to calculate damage and unmet need. The actual need and
cost of a repair per home will determine the cost spent per home.
Comment Received: It is with a heavy heart that I am pleading that this grant be administered
by the Texas General Land Office and not City of Houston. I urge you to please look at cases
for assistance individually and not make a general analysis as there are residents in the 77079
zip code who are struggling. I have lost faith in the City of Houston. (Multiple respondents
Staff response: The U.S. Department of Housing and Urban Development has deemed the City of
Houston eligible to directly receive and administer grant funds under this Action Plan. The Texas
General Land Office, as an oversight entity, is obliged to ensure that all funds are administered in the
manner laid out by federal law. Despite this, the GLO remains committed to advocating for all
impacted Texans. The feedback provided in this comment is valuable and our agency will give this
ample consideration as we continue our advocacy efforts.
Comment Received: Please ensure that grant funds are available to all impacted citizens,
regardless of income or whether or not they had flood insurance.
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Staff Response: Eligibility criteria, including income levels and flood insurance status, are all
determined at the federal level by the U.S. Department of Housing and Urban Development. The
Texas General Land Office, as the primary administrator of CDBG-DR grant funds, is obliged to
ensure that all grant funds are utilized in a manner consistent and in compliance with current federal
law. Despite this, the GLO remains an advocate for impacted Texans and will utilized every available
option to ensure as many citizens are given access to recovery resources as possible.
Comment Received: Redefined 'Future Award Related to Harvey' to exclude any future legal
award that results from pending suits.
Staff Response: All rules and regulations relating to duplication of benefits are federally established
and the GLO, as the primary administrator of CDBG-DR funds, is obliged to follow those rules unless
otherwise indicated by the U.S. Department of Housing and Urban Development.
Comment Received: We had a lot of damage in Bayside ,Texas which is in Refugio County,
from hurricane Harvey.
Staff Response: The Texas General Land Office is dedicated to working with disaster impacted
communities to assess their recovery needs. The GLO recognizes the needs presented in Refugio
County and will utilize this feedback as recovery programs and processes develop.
Comment Received: We have been carefully reviewing the Action Plan presented for Public
Comment and overall, we feel that developing a state run method of distribution if fair and
justifiable. We would like to emphasize that the Coastal Bend Council of Governments is
experienced in grant administration, but would need funds for addition staff to administer a
grant of this magnitude. Because of the scale of Hurricane Harvey's impact and the relatively
small populations of communities within our County, we will need much assistance in both the
dissemination of information and in aiding citizens with grant applications.
Staff Response: The Texas General Land Office is prepared to offer technical assistance at all levels
to ensure local communities have the tools and people they need to successfully implement disaster
recovery programs.
Comment Received: Hurricane Harvey also had a major negative impact on the LMI
apartment housing in the area which has translated into impacts on the economy as families
have been forced to relocate to find housing.
Staff Response: The Texas General Land Office recognizes the need for the rebuilding of multi-
family housing for both the low- or moderate-income and non-low- or moderate-income population
in impact areas and if working to specifically develop programs for each area. It is the goal of the
GLO to ensure impacted Texans are able to remain within their communities and/or return to their
communities as the recovery process progresses.
Comment Received: Information from the Texas Education Agency should be considered
during the needs assessment. Of the six school districts within the county, only one of them has
a percentage of economically disadvantaged students that is less than the state average. The
families of these students have been hit the hardest financially by the storm.
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Staff Response: The information presented in these statistics is valuable and will be given thoughtful
consideration as recovery programs, policies, and procedures are designed and implemented.
Comment Received: Our county also has an aging infrastructure system that would greatly
benefit from CDBG-DR funds. Our region lacks readily available engineering services and will
have to contract out for these services. This unique need should be considered during the
formulation of the Method of Distribution for this region.
Staff Response: Infrastructure projects impacted by Hurricane Harvey are likely eligible activities
under CDBG-DR grants and the Texas General Land Office will work with local officials to ensure
that the most effective recovery projects are selected and implemented in accordance with the law.
The GLO recognizes the specific concern addressed in this comment and will consider the lack of
engineering services in the formation program designs.
Comment Received: Wharton County respectfully requests the Texas General Land Office
modify the State Action Plan to clearly indicate which types of planning studies will be
conducted by vendors and which will be conducted by research institutions. Wharton County
believes that allowing vendors with experience with projects within the community would
ensure a timely, robust, and lasting recovery.
Staff Response: The Texas General Land Office has determined it would be beneficial to leverage
the knowledge, expertise, and resources available through state universities and vendors to conduct
planning studies for the benefit of disaster impact communities. Although these research institutions
will be spearheading these efforts, they will work closely to coordinate with all local resources to
ensure studies are conducted in the most efficient and effect manner possible.
Comment Received: The 70/30 rule should be lowered to include more of the areas that flooded
within Galveston County. As it stands, Galveston County had more homes sustain more
damage than Harris County and will see little benefit from the grant funding in terms of
infrastructure projects.
Staff Response: The U.S. Department of Housing and Urban Development has mandated, through
the publication of the Federal Register, that 70% of the aggregate amount of funding under this grant
be utilized in a manner that provides a benefit to low- or moderate-income households in the impact
area. The GLO will continue to advocate for the needs of all impacted Texans as the disaster recovery
process continues. It should be noted, however, that the U.S. Department of Housing and Urban
Development maintains sole discretion in granting or denying these waivers.
Comment Received: Several Galveston County Mayors along with Galveston County
Commissioners Court are asking the state to pursue a waiver to the federal requirement that
70% of CDBG-DR funds be used to benefit LMI households in the impacted area. If this waiver
is pursued and granted, citizens living in unincorporated areas will not be allocated the
resources necessary to recover. This rule should remain unchanged and the state should keep
control of the funds.
Staff Response: The U.S. Department of Housing and Urban Development has mandated, through
the publication of the Federal Register, that 70% of the aggregate amount of funds allocated under
this grant be utilized in a manner that directly benefits low- or moderate-income households. The
GLO, as the primary administrator of these funds, is obliged to administer programs in a manner
consistent with current federal law. As of the date this response was drafted, the GLO is not actively
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pursuing a waiver to this requirement absent the presentation of compelling evidence that suggests a
change to this rule is necessary to produce an effective recovery.
Comment Received: Should Kemah look to build a new water treatment plant in advance of
the next hurricane as the current plant is not adequate for the tourism brought to the area
every year?
Staff Response: The Texas General Land Office remains committed to identifying and analyzing all
proposed disaster recovery projects. The information provided in this comment will be given
thoughtful consideration as the recovery process progresses.
Comment Received: Please do not limit who can get financial help from Harvey funds. We own
our home and have a rental home that flooded and was a total loss. Our rental home is not
eligible for funds because it was ' a rental'. Well, somebody in our community was living there
and they are now out of a home. We should not be ignored or refused because we have worked
hard not to have to ask for help or be dependent on others our entire lives.
Staff Response: The GLO remains committed to ensuring all CDBG-DR funds are allocated in a
manner that is consistent with federal law. The GLO shall remain an advocate for impacted citizens
like yourself as the recovery process progresses.
Comment Received: The Action Plan must prioritize Low- and Moderate-Income
Communities to ensure an equitable recovery.
Staff Response: The GLO shall administer all CDBG-DR recovery funds in compliance with current
federal law, including the 70% overall low- or moderate-income benefit requirement established in
the Federal Register.
Comment Received: HOME believes the GLO should follow the principles listed below in
meeting the housing needs of Texas residents: a. Recovery funds should be spent on housing
and not infrastructure; b. We believe that the 70% overall benefit requirement is too low; c.
The money should prioritize Black, Brown, and low-income Asian Pacific Islander
neighborhoods which need more investment to make up for historic underinvestment; d.
Money should be set aside by income levels according to who sustained damage (regardless of
whether or not the qualified for FEMA assistance).
Staff Response: The GLO shall, as stated above, ensures that the administration of all CDBG-DR
funds is in compliance with all currently applicable federal law. The GLO remains committed to
working with all impacted communities to ensure the needs of their citizens are adequately addressed.
Comment Received: Buyouts should be executed in an equitable manner. This includes

compensation for buyouts that would provide homeowners with the amount needed to buy
another house with the same level of indebtedness in a neighborhood of opportunity.
Staff Response: Per federal guidelines, compensation for Buyouts may include the pre-disaster fair
market value. Outside of this requirement, the GLO is open to considering the feedback presented in
this comment to foster a more equitable execution of buyout programs.
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Comment Received: Money should be allocated for renters who were denied FEMA assistance.
Staff Response: The GLO has received the feedback presented in this comment and will give it
thoughtful consideration as programs progress.
Comment Received: PREPS work was subpar and should not reduce the overall amount of
CDBG-DR assistance an applicant is able to receive.
Staff Response: The PREPS Program, a FEMA program administered by the GLO, was designed as
a 'shelter in your home' program to allow impact citizens the ability to remain in their homes while
the rebuilding process continued. It is the intention of the GLO to leverage work done under this
program with CDBG-DR funds to expedite the rebuilding process for eligible applicants.
Comment Received: The GLO should prioritize community engagement.
Staff Response: The GLO shall, in compliance with the Federal Register notice, conduct a robust
public participation process at all levels of CDBG-DR grant administration in order to ensure disaster
recovery programs are specifically tailored to the needs of each community.
Comment Received: Recovery monies in the Action Plan should create a platform which can
create good safe jobs that benefit local workers.
Staff Response: The GLO has received this feedback and will give it adequate and thoughtful
consideration as the recovery process continues.
Comment Received: The State should ensure all work crews have OSHA-10 training and
proper PPE.
Staff Response: The GLO is committed to ensuring all rehabilitation and construction work
conducted as a part of CDBG-DR programs is done in compliance with all federal wage and safety
laws.
Comment Received: All contractors should be screened for prior wage and/or labor law
violations before being utilized by CDBG-DR grant funded programs.
Staff Response: As required by federal law, all potential contractors must undergo a vetting process
to check for prior violations of wage and labor law before being permitted to contract for work funded
by CDBG-DR grants.
Comment Received: Recovery dollars should be leveraged towards training and career
development by requiring contractors to participate in DOL apprenticeship programs.
Staff Response: The GLO intends to utilize every aspect of the disaster recovery process to benefit
impacted communities and the feedback provided in this comment will be given thoughtful
Comment Received: The GLO should hire independent monitors to ensure Department of
Labor law compliance.
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Staff Response: The GLO shall conduct or cause to conduct all monitoring procedures related to
state administered CDBG-DR grant funds. These monitoring duties include compliance checks for
U.S. Department of Labor laws throughout the recovery process.
Comment Received: Any repairs or reconstruction should meet modern water and energy
efficiency standards to build for a more sustainable future.
Staff Response: As presented in the Federal Register, water and energy efficiency standards for
reconstruction projects must be met when using CDBG-DR grant funds. The GLO is committed to
ensuring these standards are implemented in compliance with federal law.
Comment Received: I would like to know how organizations can utilize this grant? More
specifically, what is the process for applying for funding or who is responsible for disbursing
the funds?
Staff Response: The Texas General Land Office shall be the primary administrator of CDBG-DR
grant funds for any regional outside of Harris County and the City of Houston. As recovery programs
progress, the GLO shall make program eligibility and application processes known to all impacted
citizens through a robust citizen participation process.
Comment Received: The City of Bellaire, Texas hereby requests that the State of Texas pursue
maximum flexibility in the use of HUD CDBG-DR funds by requesting a waiver to seek a
reduction in the 70% overall LMI benefit rule.
publication of the Federal Register, established the requirement that 70% of the aggregate amount of
CDBG-DR funds associated with this Action Plan must be utilized in a manner that benefits the low-
or moderate-income population in the impacted area. The Texas General Land Office, along with
any other subrecipient of CDBG-DR funds, is obliged to administer these funds in consistent with
all standing federal law.
Comment Received: I would like to strongly encourage housing projects developed as a part of
the Affordable Rental Program outlined in the Action Plan be done in line with an initiative
known as Equitable Transit-Oriented Development (eTOD).
Staff Response: The Texas General Land Office remains committed to evaluating and analyzing
innovative initiatives, like eTOD, as programs are developed under the Action Plan. The feedback
provided in this comment is valuable and will be given thoughtful consideration as the disaster
Comment Received: The GLO's reliance on the methodology used by HUD in Appendix A
prevents it from including an accurate estimate of unmet need in the Proposed Action Plan.
Staff Response: The Texas General Land Office has utilized the most up-to-date data in the analysis
presented in this draft Action Plan. The GLO remains committed to looking for innovative ways to
make the assessment of needs process more accurate and will consider the feedback provided in this
comment.
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Comment Received: We strongly urge the GLO to consult with the Governor's Office to use
the Economic Stabilization Fund instead of CDBG-DR funds to pay the local cost shares for
FEMA Hazard Mitigation Grants.
Staff Response: The Texas General Land Office remains in constant contact to coordinate disaster
recovery efforts associated with this allocation. However, the use of the Economic Stabilization Fund
is entirety within the discretion of the Office of the Governor.
Comment Received: The GLO already fails to meet the requirement to use 70% of the CDBG-
DR funding for LMI populations.
Staff Response: The Texas General Land Office is committed to meeting the requirement that 70%
of the aggregate amount of funds provided under this allocation be utilized in a manner that benefits
the low- or moderate-income population within the impacted area. The GLO shall continually
monitor programs and projects as they develop to ensure this national objective is met.
Comment Received: The GLO must ask HUD for additional time before submitting the
Proposed Action Plan as the current timeline is insufficient to allow the GLO to respond to
comments and, more importantly, incorporate the comments into the proposed Action Plan.
Staff Response: The Federal Register notice requires the Action Plan be submitted within 90 days
of February 9, 2018 which will not allow for any further extensions of the Action Plan public
comment period.
Comment Received: The GLO has refused requests to grant reasonable access to data the
agency relied on to produce the draft Action Plan.
Staff Response: The Texas General Land Office has been responsive to all requests for data utilized
in this draft Action Plan to the extent allowable under current law.
Comment Received: The methodology for determining unmet needs underestimate those for
LMI households, and especially for extremely low income households. We recommend the
following actions: a. The GLO should used the methodology proposed so that it appropriately
prioritizes the needs of LMI households and proportionally funds regions as required; b. The
GLO should re-allocate Local Infrastructure Program funding and Economic Revitalization
funding in order to cover the additional LMI unmet needs that exist as revealed through the
proposed methodology.
Staff Response: The Texas General Land Office has utilized the most up-to-date data in analyzing
the unmet need for low- or moderate-income households as presented in the draft Action Plan.
However, the GLO remains open to exploring innovative ways of accurately assessing disaster
impact and will consider the feedback provided in this comment.
Comment Received: The draft Action Plan fails to adequately provide for affordable housing,
which will result in the failure to appropriately serve renter households and increase the
existing severe affordable shortage. We recommend the following actions: a. The GLO should
make explicit in its Action Plan clear rental affordability targets for each subrecipient for the
Affordable Rental Program; b. The GLO should create an outreach plan for making affordable
rental housing funded under CDBG-DR primarily available to LMI disaster victims who were
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renters before the disaster; c. The GLO should impose agreements on rental housing providers
that will maximize the long-term affordability of rental housing units to ensure a minimum of
40-years of affordability and the mandator acceptance of Housing Choice Vouchers.
Staff Response: The Texas General Land Office has worked diligently to construct a series of
recovery programs that provide the most need for the greatest amount of people within the impact
area. The GLO remains open, however, to tailoring these programs in a manner that best suites the
needs of each individual community and will give this feedback thoughtful consideration as the
Comment Received: The Action Plan provides no funding or programs to assist households
with clearing title, property tax, or other issues the prevent households from accessing
assistance from the programs described in the draft Action Plan. We recommend the following:
a. The GLO should re-allocate Economic Development and/or Local Infrastructure Program
funding for the purposes of funding a program that assists LMI disaster victims in overcoming
title, property tax. And other issues that are a barrier to accessing the benefits of disaster
recovery programs.
Staff Response: The Texas General Land Office remains dedicated to developing efficient and
effective recovery programs that foster an effective and efficient recovery process. The GLO
appreciates comments that work to address specific issues that may arise as a program is implemented
and will take the feedback provided in this comment and adequately consider it as programs develop.
Comment Received: The draft Action Plan fails to provide an option for CDBG-DR eligible
households to choose to move out of high-risk and/or racially-concentrated areas of poverty.
We recommend the GLO include funding for the Homeowner Opportunity Program.
Staff Response: The Texas General Land Office maintains its stance that the currently presented
programs are necessary for disaster recovery and will remain the primary focus of this Action Plan
allocation. The Draft Action Plan offers a buyout and acquisition program that will allow
homeowners to relocate.
Comment Received: The Action Plan lacks details and clarity that are needed in the duplication
of benefits review. We recommend the following: a. The GLO put in place a clear policy that
established Duplication of Benefits protocol for PREPS homes to ensure these homeowners are
not unjustly barred from received funds under this allocation; b. The GLO should work with
HUD and FEMA to establish DHAP and make it immediately available to disaster survivors.
Staff Response: All duplication of benefit reviews will be governed by federal duplication of
benefits law. The GLO shall conduct all reviews in accordance with the current federal law.
Comment Received: The draft Action Plan excessively and unjustifiably applies the resiliency
multiplier to recovery activities, which is inappropriate for CDBG-DR funds. We recommend
a review of resiliency multiplier protocol.
Staff Response: The Texas General Land Office shall take the feedback in this comment and
consider a review of the resiliency multiplier protocol as suggested.
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Comment Received: There is no meaningful analysis of LMI by any geographic measure that
justifies allocations among the City of Houston, Harris County, and COG regions.
Houston and Harris County as eligible to direct receive and administer CDBG-DR funds under this
allocation. The GLO, however, shall maintain oversight duties of these funds and is committed to
ensuring all CDBG-DR funds are administered in a manner that is consistent with federal law.
Comment Received: The methodology described on pages 117-127 is overly complicated, nearly
unintelligible to the public, does not provide a clear methodological process that the local
government can reasonably be expected to interpret and follow, and fails to adequately explain
how it is being applied to the administration of CDBG-DR governed by this draft Action Plan.
Staff Response: The Texas General Land Office has utilized the most up-to-date data to form a
logical chain of analysis that presents a basis for funding decisions within the Action Plan. The GLO
recognizes the complexity of administering federal funds and shall remain a constant source of
technical assistance for local governments as they navigate the disaster recovery process.
Comment Received: The five "Interim Housing Programs" are listed, but there is no analysis
of any of these programs and excessive funding appears to be allocated to the PREPS program.
Staff Response: The five forms of Temporary Direct Housing Assistance are separate from this
CDBG-DR allocation in that they are FEMA funded programs administered by the GLO. Although
the GLO has proposed using some of the CDBG-DR funds as a 'match' for PREPS program
implementation, that is considered an allowable use of CDBG-DR funds and no further analysis of
any other programs is necessary.
Comment Received: The Action Plan fails to establish a method by which it will monitor how
its recovery Affirmatively Furthers Fair Housing.
Staff Response: The Texas General Land Office is committed to administering all CDBG-DR funds
in a manner that is consistent with federal law, including the AFFH rule. As stated in the Action Plan,
the GLO is partnering with an advocacy group to conduct an AFFH compliance review for each
program and project conducted under this allocation. The compilation of these reviews will serve as
a comprehensive way in which the GLO will be able to monitor how the overall recovery process is
adhering to AFFH guidelines.
Comment Received: The infrastructure project guidelines lack needed specificity.
Staff Response: The GLO shall, as the infrastructure program develops, refined guidelines to a
certain level of specificity as they pertain to individual communities and projects. The GLO is
committed to coordinating with impacted localities to ensure these guidelines foster an effective and
efficient disaster recovery process.
Comment Received: There is no specific mention of mold remediation under the Protection of
People and Property on page 67. We recommend mold inspections and remediation be
performed on all homes and that clear guidelines are established to govern this.
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Staff Response: The feedback presented in this comment has been received and the GLO will give
it adequate consideration as the recovery process progresses.
Comment Received: The draft Action Plan defers too many programmatic discretion to local
governments which poses administrative and compliance challenges. We recommend that the
GLO prescribe both the needs assessment and housing guidelines using the FEMA data to
which the GLO has unique access.
Staff Response: The GLO is committed to administering CDBG-DR funds in a manner that is both
consistent with federal law and tailored to the specific needs of each impacted community due to the
varying impacts across the vast impact area. In order to achieve these goals, the GLO has determined
that a certain level of programmatic discretion, while still subject to GLO oversight, must be allowed
in order for local governments to truly address the needs of their community.
Comment Received: The draft Action Plan does not provide enough guidance in its proposed
Buyout Program. We recommend specific guidelines for all buyout program participants to
follow. We also recommend the use of housing incentives that allow LMI homeowners a more
viable opportunity to purchase a replacement home outside of high risk and inside higher
opportunity areas.
Staff Response: The GLO is dedicated to forming programs and guidelines that provide the most
effective and efficient recovery process possible. This will include the development of more specific
guidelines as they pertain to a Buyout Program, all of which will be done in close coordination with
impact communities through a public process.
Comment Received: The Homeowner Reimbursement Program lacks sufficient guidelines for
how the GLO will administer the program in a way that prioritizes LMI households. We
recommend the GLO establish guidelines and criteria that ensure the Homeowner
Reimbursement Program primarily benefits LMI households.
Staff Response: The GLO is dedicated to forming programs and guidelines that provide the most
effective and efficient recovery process possible. This will include the development of more specific
guidelines as they pertain to the Homeowner Reimbursement Program, all of which will be done in
close coordination with impact communities through a public process.
Comment Received: The Affordable Rental Program fails to target housing for very and
extremely low income households. We recommend the GLO provide targets for each
subrecipient for unmet rental housing need and establish criteria and other guidelines that
promote developments which substantially contribute towards meeting those affordability
targets.
Staff Response: The feedback provided in this comment will be given thoughtful consideration as
the disaster recovery process progresses.
Comment Received: The Local Infrastructure Program proposes to provide inadequate data
for assessing needs an ensuring AFFH compliance. We recommend the GLO provide data at a
smaller geography to subrecipients to allow for adequate demographic analysis.
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Staff Response: The GLO has developed all strategies presented in the Action Plan by utilizing the
most up-to-date data on the most granulated level allowable under current law.
Comment Received: The proposed public website provides insufficient information to the
public.
Staff Response: The Texas General Land Office is committed to fulfilling its duties for a robust
public participation process by maintaining a public facing website that contains all documents
specifically required by the Federal Register. This is an ongoing process and the GLO is dedicated
to ensuring all relevant documents are posted to our website in a timely fashion.
Comment Received: We would like to recommend incorporating 1. FEMA's P-804, Wind

Retrofit Guide for Residential Buildings as a method to address hazard mitigation and tie local
mitigation efforts directly to federal funding and 2. A FEMA job aid establishes the use of pre-
determined benefits to demonstrate the cost-effectiveness of wind retrofit projects that comply
with FEMA P-804, thus eliminating the requirement for applicants to conduct a separate
benefit-cost analysis for a hurricane wind retrofit project that meets the criteria identified.
Staff Response: The Texas General Land Office remains committed to administering CDBG-DR
funds in a manner that both helps impacted community’s recovery and aids in their ability to rebuild
in resilience. The information presented in this comment is valuable and the GLO will give it
thoughtful consideration as the recovery process develops.
Comment Received: USCBG would like to recommend the following as they relate to the Action
Plan: 1. Leadership in Energy and Environmental Design should be included among options
for green building certification in the final action plan, providing choice to the market and to
project teams; 2. USGBC supports ENERGY STAR as included in the draft action plan among
permitted construction standards for reconstruction and new construction, alongside LEED as
an additional certification option for projects.
Staff Response: The Texas General Land Office remains committed to helping impacted
communities rebuild in a manner that fosters sustainable and resilient communities. The feedback
provided in this comment contributes to that objective and the GLO will give the information
contained herein adequate consideration as the recovery process develops.
Comment Received: I would like to present the following public comments: 1. The GLO should
seek a reduction in the 70% overall LMI benefit requirement; 2. The GLO should seek a
reduction or removal of the LMI requirement for infrastructure projects; 3. The Action Plan
should be amended to allow certain local jurisdictions (based on size) to form and manage their
own programs associated with the Action Plan.
publication of the Federal Register, established the 70% low- or moderate-income overall benefit
rule and the low- or moderate-income requirement for infrastructure projects. The Texas General
Land Office is obliged to administer all CDBG-DR funds in a manner that is consistent with existing
federal law.
The GLO has determined that leveraging previous experience with grant administration with local
expertise would be the most effective and efficient way to administer CDBG-DR funds to impacted
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communities. The City of Houston and Harris County have been determined eligible for a direct
allocation of CDBG-DR funds by the U.S. Department of Housing and Urban Development and all
other impacted areas will complete programs ran and overseen at the state level.
Comment Received: I would like to present the following comments: 1. I am concerned with
the disproportionately low amount of funding provided under this Action Plan for
Homelessness Prevention. 2. The GLO should designate Continuums of Care as a regional
partner in recovery planning.
Staff Response: The Texas General Land Office remains committed to ensuring all impacted Texans
are given adequate resources to recovery from the impacts of Hurricane Harvey in the most effective
and efficient manner possible. The GLO shall continue to advocate for all Texans and will continue
to seek innovative ways to leverage the expertise and knowledge of organizations like Continuums
of Care throughout the disaster recovery process. The feedback provided in this comment will be
given adequate consideration as programs develop under this Action Plan.
Comment Received: The Unmet Needs of LMI Texans are Not Accurately Determined by HUD
and GLO Methodology.
Staff Response: The Texas General Land Office, in its formation of the Action Plan associated with
this allocation, has utilized the most recent available data for analysis. The GLO remains committed
to supporting housing as the most urgent and critical recovery need and will continue to prioritize
safe, resilient, and affordable housing for disaster survivors.
Comment Received: Use of Funds, a. Homeowner Assistance Program: We applaud the State's
commitment to proportional funding for various income categories. The State should include
a homeowner mobility program like the post Ike/Dolly Homeowner Opportunity Program
(HOP), which allows for eligible homeowners to choose to move to a lower-risk higher
opportunity area rather than rebuild in place. Including this program would increase resiliency
and mitigate the impact of future disasters by allowing homeowners to move to sage and less
disaster-vulnerable areas. The Action Plan should also include mobility counseling and legal
assistance for to ensure a more equitable mobility program. These services would help
homeowners present a clear title to their homes and/or present alternative proofs of ownership.
Staff response: The GLO is committed to ensuring the effective and efficient administration of a
Homeowner Assistance Programs. Feedback like that provided in this comment will be given
adequate consideration moving forward as the GLO seeks to leverage as many resources as possible
to make programs under this grant successful.
Comment Received: Local Buyout and Acquisition Program, Program guidelines for this
program must be developed in a transparent process with extensive community input. Without
planning and community buy-in, a voluntary individual buyout program can result in a
patchwork of empty and occupied homes, creating blight in neighborhoods. Local buyout and
acquisition programs must prioritize LMI households in floodways and be constructed in a
manner that provides enough funds that the choice to move is a realistic one. In particular,
using the pre-storm value of a home to determine program benefits often has a discriminatory
impact on LMI households.
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Staff Response: The GLO is committed to conducting a robust citizen participation process at every
stage of disaster recovery program implementation. The GLO recognizes the unique issues that could
arise from a buyout and/or acquisition program that is not conducted with extensive community input
and will work with program administrators on all levels to achieve the highest level of coordination
possible.
Comment Received: Homeowner Reimbursement Program, as a direct housing program, the

reimbursement program must set aside proportional funding to serve each income category.
Staff Response: The feedback presented in this comment has been received and the GLO will give
it thoughtful consideration as the Homeowner Reimbursement Program develops.
Comment Received: Homelessness Prevention Program, the Homelessness Prevention

Program does not allocate enough funds, potentially leaves out families displaced to Bexar,
Dallas, Tarrant, and Travis Counties, and does not include help for households that are
currently homeless as a result of the hurricane.
Staff Response: The Texas General Land Office is committed to adequately addressing and
assessing the needs of all impacted Texans. The feedback provided regarding the Homelessness
Prevention Program is valuable and will be given thoughtful consideration as the details of the
program are developed.
Comment Received: Affordable Rental Recovery Program, the Action Plan should allocate
significantly more funding for rebuilding affordable rental housing. The State should also
increase the set-aside for affordable rental in order to dedicate funds specifically to rebuilding
public housing, assisted and affordable housing, housing for persons with special needs, and
other types of affordable housing listed in the Action Plan. We ask the State increase funding
for rebuilding affordable rental housing be re-allocating the current funds set aside for the
PREPS program alongside the leveraging of money currently held in the Rainey Day Fund.
Staff Response: The Texas General Land Office, in its method of distribution of funding, has worked
diligently to ensure that CDBG-DR funds are administered in a manner that fosters the greatest level
of recovery for the most people possible. The GLO will consider the suggestions made in this
comment.
Comment Received: Local Infrastructure Program and Economic Revitalization Program,

Infrastructure programs must prioritize the needs of LMI households and communities, in
particular, communities with substandard infrastructure as a result of discrimination and
disinvestment. Also key to economic recovery and future resilience is ensuring that jobs
generated by recovery projects are filled by local workers and those who lost jobs due to the
storm. To accomplish this, we strongly urge the state to fully enforce Section 3 of the Housing
and Urban Development Act of 1968 (12 USC 1701u; 24 CFR 135).
Staff Response: The Texas General Land Office shall ensure that all infrastructure projects are
implemented in a manner consistent with the low- or moderate-income benefit requirement presented
in the Federal Register notice. The feedback provided in this comment pertaining to Section 3
enforcement will be given adequate consideration as recovery programs develop.
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Comment Received: Public Participation, Reporting, and Public Access to Disaster Recovery
Information, Meaningful public participation and comment require the direct engagement of
impacted communities and individuals. Jurisdictions must actively seek out and engage
affected communities, particularly, as required by CDBG regulations, those least likely to
participate. We encourage the GLO to post information and data on the public website as
progress of programs and projects is ongoing. We particularly urge the GLO to publish waiver
requests and supporting documentation on its website, and allow public comment before the
waiver request is submitted to HUD to keep the waiver process transparent.
Staff Response: The Texas General Land Office shall, as required by the Federal Register notice,
ensure that certain documents are published to the GLO's disaster recovery website. Additionally,
the GLO is committed to engaging with communities to ensure that all impacted citizens are given
ample opportunity to participate in all levels of the recovery process.
Comment Received: The Houston-Galveston Area Council is requesting that the State of Texas
pursue maximum flexibility in the use of the U.S. Housing and Urban Development Community
Development Block Grant disaster recovery funds by request of waiver from HUD or by State
Administrative action.
Staff Response: The Texas General Land Office remains committed to developing processes and
procedures to foster a comprehensive long-term recovery for all Texans impacted by Hurricane
Harvey. In developing these processes and procedures the GLO shall remain open to pursuing all
options, to the greatest extent allowable under the law, that may contribute to a more effective and
efficient recovery. If, at any time during the administration of CDBG-DR funds associated with this
Action Plan, the GLO determines a waiver request would further these goals, it will pursue that
waiver at that time.
Comment Received: HGAC requests that the State of Texas seek a waiver as it applies to the
requirement that 70% of the aggregate of CDBG-DR funds be used to support activities
benefitting the low to moderate income population within the impacted area.
moderate-income population in the impacted area. This requirement may only be waived if it can be
adequately demonstrated that the needs of the low- or moderate-income population within the
impacted area have had their needs sufficiently addressed and met. If, during the recovery process,
the GLO determines that this burden has been met in a manner that warrants a waiver request from
the U.S. Department of Housing and Urban Development, it will pursue that option.
Comment Received: HGAC requests the Action Plan be expanded to include opportunities for
regional and locally administered housing recovery programs.
effective recovery.
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Comment Received: HGAC requests a reduction or removal of the low to moderate in come
benefit requirement for infrastructure projects.
moderate-income population in the impacted area. This requirement may only be waived if it can be
adequately demonstrated that the needs of the low- or moderate-income population within the
impacted area have had their needs sufficiently addressed and met. If, during the recovery process,
the GLO determines that this burden has been met in a manner that warrants a waiver request from
the U.S. Department of Housing and Urban Development, it will pursue that option.
Comment Received: HGAC requests that the Action Plan be modified in a manner that
removes current limits on recovery efforts to buyout and acquisition.
Staff Response: The Texas General Land Office, in coordination with leaders in impacted
communities, has determined that buyouts and acquisitions be given ample programmatic
consideration in moving forward with the recovery process. If the needs of a particular community
warrant other programmatic decisions, the GLO shall give those proposed changes thoughtful
consideration.
Comment Received: HGAC requests that the Action Plan be revised to clarify which types of
planning studies are eligible for completion by universities in the state and which are eligible
for completion by vendors.
Staff Response: The Texas General Land Office has determined that the most effective process for
conducting planning studies would be through the utilization of established research institutions
within the state. If it is determined that the utilization of certain vendors makes for a more efficient
process, then the GLO will consider the inclusion of those vendors at its discretion. Regardless, the
GLO remains committed to ensuring the execution of planning studies that provide a direct benefit
to the communities in which they are conducted.
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14.2. Appendix H: Public Comments – Harris County
The public comment period was from June 27, 2018 to July 10, 2018. The following comments
were received.
Commenter Name: Eva Thibaudeau
Organization: The Way Home CoC (Coalition for the Homeless)
Date Commented: June 27, 2018
Comment Received via email:
Hello and thank you for accepting our comments regarding the needs of homeless individuals
impacted by Harvey. I am pleased to let you know that I am responding on behalf of the 100+ non-
profits and funding entities that comprise The Greater Houston’s homeless response system
(Continuum of Care – CoC) known locally as The Way Home. My organization, the Coalition for
the Homeless, serves as the Lead Agency for our community and has the authority to respond publicly
on matters impacting homelessness.
We have worked closely with Harris County for many years, but most significantly since 2012, to
solve the problem of homelessness. Each year, our community undertakes a massive count of persons
experiencing homelessness who are both sheltered and unsheltered. In January 2018, the results of
this count show that 18% of unsheltered respondents reported being homeless due to Hurricane
Harvey. This number accounts for more than half of the increase in unsheltered homelessness this
year. We are continuing to collect data regarding persons who are becoming homeless due to the
impact of Hurricane Harvey.
Since 2012, our homeless response system has housed over 14, 500 individuals in permanent housing
and ended their homelessness. This tremendous progress corresponded with a 63% reduction in
overall homelessness. Unfortunately, Hurricane Harvey had a devastating impact on our
community’s most vulnerable citizens – those without a permanent, fixed, nighttime residence. The
homeless response system answered the call and worked with our impacted community leaders to
rapidly re-house nearly 1,000 individuals who were left with no viable exit strategy from the Red
Cross shelters. This work continues today; as does the on-going impact of the storm.
The damaged housing stock in Harris County makes a tight housing market even tighter. On behalf
of The Way Home and its 100+ partners, we would like to recommend consideration of the following
activities in the County’s plan as related to preventing and ending homelessness for our highly
vulnerable citizens:
 Supportive services dollars to pair with rental subsidies to end household homelessness
 Rental subsidies to support a range of assistance (short to medium to long-term)
 Multi-family unit acquisition with units dedicated to permanent housing interventions for
persons experiencing homelessness
 Acquisition of smaller properties (i.e., motels, former treatment centers, nursing homes,
etc…) to accommodate the enhanced needs of persons experiencing homelessness who are
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suffering from substance use disorders, serious mental illness and/or chronic health
conditions that require assistance with activities of daily living
 Funds to bring existing apartments up to habitability standards for rental use by those exiting
homelessness
On behalf of The Way Home CoC, we thank you for accepting these comments. We look forward to
continuing to work together to prevent and end homelessness for the many impacted citizens of Harris
County.
Sincerely,
Eva
Eva Thibaudeau-Graczyk, LCSW

Coalition for the Homeless
Vice President of Programs
The Way Home CoC Lead Agency/HMIS Administrator
713-882-8274 │ homelesshouston.org
2000 Crawford Street, Suite 700, Houston, TX 77002
County Response: We thank the Coalition for its comment. The Harris County Supplemental Action
Plan includes several services for those displaced and made homeless by Hurricane Harvey. While
Homelessness was a priority issue in the county before the storm, post-Harvey homeless numbers
and housing conditions have declined. The county has added homeless programs in the plan to
include short-term mortgage assistance to prevent loss of housing and tenant-based rental assistance
to assist LMI households, particularly those who were those who are homeless. Case management
services will be a part of these programs as the county already has a department that provides case
management services to assist households to find and secure safe, affordable housing and maintain
that housing for the long-term. This existing program is in partnership with the Coalition for the
Homeless/Way Home CoC. The county also expects to work with local housing developers, non-
profits, and housing authorities to acquire/rehabilitate and build new affordable housing with a unit
set aside for homeless populations.
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Commenter Name: June Tyler
Organization: City of Baytown, Texas – Community Development Division
Date Commented: July 10, 2018
 Will the County administer the Housing program County wide? Or will each jurisdiction be
given the opportunity to "self-administer" the housing program? The City of Baytown would
like Harris County to administer it’s housing program within our corporate city limits.
 Will the County allocate Buyout/Acquisition funds by way of a MOD to the local
governments for implementation similar to how H-GAC and other COGs did with their
MOD's? If so, will the local governments be given control for the administration of these
funds? The City of Baytown would like Harris County to administer buyout/acquisition
programs within the city limits with coordination and approval of each project.
 Will jurisdictions be able to participate in the Competitive Application if they are also
included in a local MOD?
 Does the County plan to administer all programs (housing & infrastructure) for the entire
County and each jurisdiction receiving an allocation? Or, will the County allow
jurisdictions to "self-administer" if they are able to show capacity and a proven track
record on similar programs with similar allocations?
 If the City is able self-administer (and we realize it could potentially take months before
funding is finally approved), we would like procure and secure administrative services
immediately.
County Response: We thank the city of Baytown for its comments. The county will administer all
housing programs countywide (outside the city of Houston). As one of its housing program, Harris
County will also administer the buyout program in partnership with the Harris County Flood Control
District and Harris County Engineer. The county requests to work with the small cities to
development housing needs (including for a buyout program) within their jurisdiction and to market
the housing programs to their residents.
If a city is named in the county’s MOD, they cannot also participate in the competitive round RFP.
Currently, the Texas General Land Office informs that the county will administer all CDBG-DR
funding.
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Commenter Name: Julie Robinson
Organization: City of Spring Valley Village, Texas – City Administrator
See next page for letter
Page 379 of 420

July 10, 2018
VIA EMAIL TO plancomments@csd.hctx.net

Harris County Community Services Department
8410 Lantern Point Dr.
Houston, TX 77054
RE: City of Spring Valley Village’s Written Comments Concerning the Draft Harris County Supplemental
Action Plan for Hurricane Harvey Community Development Block Grant Disaster Recovery
Funding (Round One) (“Harvey CDBG-DR Round One”)
Dear Sir or Madame:
The City of Spring Valley Village (“Spring Valley Village”) respectfully submits the following written
comments concerning the above-referenced Draft Harris County Supplemental Action Plan for Harvey
CDBG-DR Round One (“Draft SAP”) that was released on June 26, 2018. These written comments
supplement any verbal comments made on behalf of the City of Spring Valley Village during any public
hearings that will be held on the Draft SAP.
General Comments
• Spring Valley Village understands the expedited schedule within which HCCSD has had to develop
the Draft SAP and greatly appreciates the work of the HCCSD staff in developing the Draft SAP.
• Spring Valley Village does not support the overall distribution of the Harvey CDBG- DR Round One
funds between Housing and Infrastructure. Spring Valley Village is aware that the distribution in the
Draft SAP matches the distribution that was outlined by HUD in Federal Register, Vol. 83, No. 28,
February 9, 2018. However, based on the actual Unmet Needs as reflected in Table 1, Summary of
Unmet Needs in Harris County (outside the City of Houston), on Page 3 of the Draft SAP, the
distribution is inversely disproportionate at its most basic level. Table 1 of the Draft SAP reflects
that the percentage of Unmet Need for Housing is 20% while the percentage of Unmet Need for
Infrastructure is 80%. However, the percentage of the County Program Allocation that has been
designated for Housing is 79%, and the percentage of the County Program Allocation for Infrastructure
is a mere 21%. Spring Valley Village strongly encourages the County to reallocate the distribution of
the Harvey CDBG-DR Round One funds proportionately to match the actual percentage of Unmet Needs
for both Housing and Infrastructure or, in the alternative, to split the County’s allocation equally
between Housing and Infrastructure.
1025 CAMPBELL ROAD • HOUSTON, TEXAS 77055-7495

(713) 465-8308 • FAX (713) 461-7969 • www.springvalleytx.com
Page 380 of 420

• Spring Valley Village does not support the overall requirement that 70% of the County’s
Program Allocation (both Housing and Infrastructure) be used to benefit the low-to-moderate income
(“LMI”) populations. While Spring Valley Village is certainly sympathetic to the impact of Hurricane
Harvey on LMI populations, the flood waters from Hurricane Harvey did not discriminate based on
income. Most assuredly, an enormous amount of the non-LMI populations suffered severe and
catastrophic loss from Hurricane Harvey. Spring Valley Village strongly encourages the County to split
the County’s Program Allocation equally between LMI and non-LMI populations. In the alternative,
since 30% of the County’s Program Allocation is available for providing relief to non-LMI populations,
Spring Valley Village strongly encourages the County to utilize such portion of the allocation to benefit
as much of the non-LMI populations as possible.
• Spring Valley Village requests clarification as to whether the County plans to administer all
programs (Housing & Infrastructure) for the entire County and each jurisdiction receiving an
allocation. Spring Valley Village requests that the County allow each jurisdiction to "self-
administer" if they are able to show capacity and a proven track record on similar programs with
similar allocations.
• Based on the June 29, 2018, Monthly CDBG-DR Grant Financial Report from the U.S.
Department of Housing and Urban Development Disaster Recovery Grant Reporting System, the Texas
General Land Office (“GLO”) has a balance of $432,722,979.00 from the Hurricane Ike CDBG-DR
funding that has yet to be utilized for any housing or infrastructure projects almost 10 years after
Hurricane Ike. Spring Valley Village strongly encourages the County to request the reallocation of
these funds to Harris County to be used to benefit non-LMI housing and infrastructure projects related
to Hurricane Harvey.
Housing Allocation Comments

• Spring Valley Village does not support the overall requirement that 70% of the County’s
Program Housing Allocation be used to benefit the LMI populations. As the Draft SAP is currently
written, there will be little to no relief for the thousands of non- LMI households that suffered and are
still suffering from Hurricane Harvey. There are thousands of non-LMI households that remain
displaced from their homes and/or are living in unrepaired homes because they, just like the LMI
populations, were unable to afford flood insurance and/or their flood claims were denied by the
National Flood Insurance Program (“NFIP”). Spring Valley Village strongly encourages the County
to split the County’s Program Housing Allocation equally between LMI and non-LMI populations. In
the alternative, since 30% of the County’s Program Allocation is available for providing relief to
non-LMI populations, Spring Valley Village strongly encourages the County to utilize such portion
of the allocation to benefit as much of the non-LMI populations as possible.
• With the majority of the Harvey CDBG-DR Round One funding being allocated to
benefiting housing needs of the LMI population, Spring Valley Village has serious
concerns about the County’s ability to actually utilize the entirety of the housing
allocation for this purpose. After Hurricane Ike nearly 10 years ago, there was a similar
amount of funding allocated to housing for LMI populations, and almost immediately
there were issues with LMI individuals not being able to qualify for the housing funds
for a variety of reasons – not the least of which was lack of clear title for their damaged
properties. This problem occurred in almost every community that was impacted by
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Hurricane Ike. Therefore, Spring Valley Village again encourages the County to split
the County’s Program Housing Allocation equally between LMI and non-LMI
populations. In the alternative, since 30% of the County’s Program Allocation is
available for providing relief to non-LMI populations, Spring Valley Village strongly
encourages the County to utilize such portion of the allocation to benefit as much of the
non-LMI populations as possible.
Non-Housing Allocation Comments

• As reflected in the Draft SAP, the repair and enhancement of local infrastructure and
mitigation efforts are crucial components of a comprehensive long-term recovery
program. Spring Valley Village agrees that infrastructure activities are vital not only for
the long-term recovery and restoration of housing but for the long-term recovery,
protection, and viability of communities – regardless of the income levels of their
populations.
• Spring Valley Village understands that a County level Method of Distribution (“Local
MOD”) under the Local Infrastructure Program has yet to be developed by HCCSD. In
order to provide the most information to the public and all eligible cities, Spring Valley
Village strongly encourages HCCSD to post all notices and the draft Local MOD on the
home page of its website. When searching for the Draft SAP on the HCCSD website, it
was difficult to actually locate the document without performing a specific search of the
website. Posting all notices and the draft Local MOD on the home page of the HCCSD
website would provide ease of access as well as transparency that would benefit the
public, eligible cities as well as HCCSD.
• Spring Valley Village does not agree with implementing a damage level threshold of
$1,500,000 in CDBG-DR funds to any local entity receiving funding through the Local
MOD. The impacts of Hurricane Harvey affected every local entity in the entire
Houston-Galveston region. It was obvious that water and flood control projects
regardless of their location can and do have an impact on the surrounding areas - the flood
waters did not observe any jurisdictional boundaries. While Spring Valley Village has no
issue with funding direct damages to city facilities that resulted from Hurricane Harvey,
there are numerous water and flood control projects that are absolutely necessary in cities
that did not necessarily have direct damages that will reduce the flood risk of these cities
and the surrounding areas. Therefore, there should not be a damage level threshold for
the Local MOD in order for a city to be awarded funding under the Local MOD.
• With regard to the Local MOD, the draft SAP includes a plan to meet the 70% LMI
benefit requirement. Spring Valley Village strongly encourages the County to split the
County’s Program Infrastructure Allocation equally between LMI and non-LMI
populations. In the alternative, since 30% of the County’s Program Infrastructure
Allocation is available for providing relief to non-LMI populations, Spring Valley Village
strongly encourages the County to utilize such portion of the allocation to benefit as
much of the non-LMI populations as possible.
• Spring Valley Village requests clarification as to whether cities, either through the
Local MOD or Competitive RFP Program, will have local control with regard to the
program development and implementation of any funds if awarded. Spring
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Valley Villages encourages the County to allow local control by cities for program
development and implementation of any funds awarded. Additionally, Spring Valley
Village asserts that cities should be allowed to allocate a percentage of their allocation
for professional services (i.e. engineering, administration, environmental services, etc.).
• With regard to the Competitive RFP Program, Spring Valley Village requests that the
first paragraph outlining the intent of the RFP Program on Page 44 of the draft SAP be
clarified. While this paragraph specifically states that the intent of the RFP is to provide
funding for local infrastructure improvements, the previous sentence limits those local
infrastructure improvements to repairing and rebuilding infrastructure and facilities
impacted by Hurricane Harvey. While Spring Valley Village has no issue with funding
direct damages to city infrastructure and facilities that resulted from Hurricane Harvey,
there are numerous water and flood control projects that are absolutely necessary in cities
that did not necessarily have direct damages that will dramatically improve public,
residential and commercial concerns by mitigation of flooding, reducing storm water on
roadways and properties, conveying storm water into the appropriate channels, and
providing shelter to displaced residents. Spring Valley Village requests that the
Competitive RFP Program be available for all local infrastructure improvements and not
limited to only repairing damaged infrastructure/facilities.
• It is unclear in the draft SAP whether cities will be able to participate in both the Local
MOD as well as the Competitive RFP Program, or if cities will be limited to participation
in one or the other. Spring Valley Village requests clarification with regard to the ability
of cities to participate in both the Local MOD and the Competitive RFP Program.
• Since the draft SAP reflects a requirement that 70% of Infrastructure projects benefit
LMI populations, Spring Valley Village requests clarification as to how cities and/or
projects that do not have a high LMI percentage, but do address local and regional storm
related impacts, access the Hurricane Harvey CDBG-DR Round One funds.
The City of Spring Valley Village appreciates the opportunity to provide its comments
on the Draft SAP. Should you have any questions or require clarification of any of the
information provided herein, please do not hesitate to contact me by phone at (713) 465-
5306 or by email at jrobinson@springvalleytx.com.
Sincerely,
Julie M. Robinson
City Administrator
c: Honorable Mayor and City Council Members
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County Response: We thank Spring Valley Village for its comments.
 Per the Federal Register and based on GLO guidance in their Action Plan, all
housing unmet needs must be administered before significant progress can be
made on non-housing/infrastructure unmet needs. The Federal Register
proscribes that a minimum of 79 percent of CDBG-DR funding in Round One
will be for housing related programs and to alleviate unmet needs in local
housing affected by Hurricane Harvey. The U.S. Congress has set aside a
greater amount in CDBG-DR funding Round Two continue the assistance on
non-housing/infrastructure unmet needs.
 Per the Federal Register, 70 percent of CDBG-DR funding must be used to
benefit low- to moderate-income households (one of HUD National Objectives),
whether under housing or non-housing/infrastructure CDBG-DR programs.
Once this threshold is met, funding can be used to meet the HUD National
Objective of urgent need.
 The CDBG-DR program requires all projects show that the problem the
proposed project for CDBG-DR funding seeks to alleviate be directly related to
Hurricane Harvey as well as meeting the 70 percent low- to moderate-income
benefit discussed above. The county’s MOD takes into account damage levels,
percentage of low- to moderate-income population, and level of unmet needs of
all jurisdictions.
 Currently, the Texas General Land Office informs that the county will
administer all CDBG-DR funding. The county will work with all cities with
CDBG-DR awarded projects to develop the projects including
engineering/design activities. Environmental Review will be performed by the
county as requirement by the GLO as the responsible entity of CDBG-DR
funding.
 If a city is named in the county’s MOD, they cannot also participate in the
competitive round RFP.
Page 384 of 420

Commenter Name: The Metropolitan Organization (TMO)
Organization: The Metropolitan Organization
The Metropolitan Organization

Gulf Coast Leadership Council
4141 Southwest Freeway Suite # 650,
Houston, Texas 77027
Email: tmo@tmohouston.net
Memo
TO: County Judge Ed
Emmett
Commissioner
Rodney Ellis
Commissioner Jack
Morman
Commissioner Steve
Radack Commissioner
R. Jack Cagle
FROM: The Metropolitan Organization

DATE: July 10, 2018
RE: Action Plan for Hurricane Harvey CDBG Disaster Recovery Funding
Thank you for the opportunity to provide comments on the “Hurricane Harvey CDBG
Disaster Recovery Funding (Round One)” Draft Action Plan. This letter represents the
collective comments of the congregations that are members of The Metropolitan
Organization. TMO has hosted 10 home repair intake sessions in partnership with the
LISC collaborative and there were nearly 300 clients in attendance. Approximately, 80%
of these clients did not have an active case manager working on their case and for some,
these sessions were their first interaction with a case manager or home repair agency. The
need for quality disaster case management is extreme. After reviewing the Draft
Action Plan, we would like to make the following recommendations:
Page 385 of 420

Bestow an equity-based approach to recovery efforts by ensuring low-income
families qualify for mitigation and buyouts as described in the Chapter 19
Floodplain Management Data Analysis.
As an extension of larger community recovery programs, ensuring individual

homeowners can benefit in recovery efforts by benefiting from flood mitigation and
buyout initiatives will help create a more resilient community development plan. Low-
income homeowners will benefit the most from a housing plan that places them in areas
where they will not be subject to chronic flooding, expensive flood insurance, or the cost
of elevating a home. Therefore, it is imperative that funding be allocated directly to these
types of individual homeowners who otherwise would be subject to further weather
implications, impeding their path to recovery.
Quality Case Management is essential to recovery and investment is needed to ensure an

individual’s personal route to full recovery.
Recovery Programs are only as effective as the quality Case Management available to help people
who are recovering from the storm to navigate the complex programs systems for recovery.
Based on our estimates, there are not enough Case Managers to fulfill the needs of people in need
of recovery support. Even with additional Case Managers being made available through federal
contracts and some of the City resources, ensuring that the Case Managers are well-trained and
effectively coordinating with all of the other entities involved in recovery is paramount for
effective recovery. For housing programs to be successful in helping people effectively,
investment in case management and ensuring effective coordination with other service providers
will be key to an individual’s route to full recovery. Case Management and Housing Programs are
interdependent, and the Action Plan as well as subsequent program design should address the
relationship it foresees with case management agencies moving forward into recovery.
Funds should be made available to assist qualifying low income families in resolving title
and tax issues so they can receive housing assistance from CDBGDR funded programs.
We have found that a significant obstacle to some low income households receiving assistance
from FEMA or through CDBGDR funded programs is the fact that they do not have clear title to
the home they have inherited from family members. In low income communities, possession and
ownership of real estate passes informally from family member to family member over many
years. Since many people die without wills, there are numerous heirs with potential interest in
the property. Since it takes the time of experienced lawyers to help resolve these issues, funds
should be allocated to assist families to resolve title issues where that is possible. Likewise,
families have unpaid taxes and other obligations that will block them from accessing housing
program funds. A well crafted program to help homeowners set up reasonable payment plans
could result in more families being able to take advantage of the Housing Assistance Program.
Commit to full transparency and accountability for the benefit of increasing trust in the
recovery process to the homeowner and people recovering from the storm.
There is no doubt that another storm will eventually land on the Gulf Coast and within the
Houston area. The current sentiment we are hearing from households affected by the storm is
confusion and lack of trust because of the difficulty in securing accurate, complete information
Page 386 of 420
on the steps to recovery. We understand that numerous parties play a role in this (federal, state
and local governments as well as the nonprofit sector). A well-designed system that allows for
transparency and accountability in the recovery process can build trust between residents and the
public sector, which will help in times of recovery. The Local Action Plan has the capability to
make amends with residents who feel disenfranchised and give hope that they will not be left
behind in the rebuilding process. Using our recovery resources to build systems that serve us
now in Harvey recovery while also improving our readiness for the next event is welcomed. The
intentions of the Action Plan must take into account those populations who are most vulnerable
and offer a clear pathway in a very difficult situation.
Again, we appreciate the opportunity to provide comments to the Action Plan. We as a collective
are eager to work with Harris County to ensure a successful recovery for our county’s vulnerable
communities. Thank you for your attention and consideration of these recommendations into the
“Hurricane Harvey CDBG Disaster Recovery Funding (Round One)” Action Plan.
County Response: We thank TMO for their comments.
 Per the Federal Register that establishes these CDBG-DR funds, 70 percent of CDBG-DR
funding must be used to benefit low- to moderate-income households (one of HUD
National Objectives), whether under housing or non-housing/infrastructure CDBG-DR
programs. Harris County seeks to ensure that low- to moderate-income households have
access to CDBG-DR funding for home rehabilitation/reconstruction including flood
mitigation, fair buyout of flooded homes and incentives for a replacement home that is
safe and in an area of reduced flood risk and does not cause additional cost burden, and
construction of new affordable renter- and owner-occupied housing.
 Each of these programs will come with quality case management to assist those affected
by Hurricane Harvey navigate the programs. Harris County has also been and will
continue to work with case management groups in the county to educate on the county’s
programs.
 The county is working and will continue to work with non-profit legal services to assist
the public with resolving title issues. The programs under the county’s action plan will
work with individuals to reduce barriers created by title and tax issue to assist them to
successfully navigate our systems.
Page 387 of 420

Commenter Name: Cyrus Reed
Organization: Lone Star Chapter of the Sierra Club
July 9, 2018
The Lone Star Chapter of the Sierra Club is pleased to offer these brief comments on the
Long-term Housing Plan for Harris County. Separately, the Sierra Club through the local
Houston group is also signing onto comments submitted by the HOME coalition, and we
are in full support of those comments as well. Thus, some of our comments here are
repetitive to those comments.
We wanted to reiterate that Harris County will need to not only promote compliance with
modern building codes and standards, but enforce those provisions most likely through
third-party inspectors, since Texas law does not currently allow direct inspections by
county officials. We want to assure that in this plan or future MODs such inspections are
paid for and included, and that third-party inspectors, builders and contractors are aware
of the codes they must meet and properly trained as appropriate.
Thus, we repeat below the comments submitted by the Home Coalition.
Promote environmentally-friendly standards. Any repair or reconstruction should

follow modern and energy-efficient building codes and standards. Reconstruction, repair
and new construction of residential buildings should follow the Energy Star program,
and/or the HUD CPD Green Building Retrofit Checklist for non-substantially damaged
residential buildings. In addition we recommend requiring the following standards:
 Require the 2015 International Energy Conservation Code for all commercial buildings,
including multi-family buildings over three stories
 Require new residential buildings be built solar-ready, thus easily able to incorporate solar
energy in the future by reserving adequate roof space
 Require compliance with modern plumbing codes, such as the 2015 UPC or 2015 IPC,
which will help lower utility and energy bills
 Give priority to new construction or major reconstruction of multi-family buildings that are
designed to meet a more robust standard, such as the ASHRAE 189.1 - 2014 Standard
for the Design of High-Performance Green Buildings, or the recently published ASHRAE
189.1 - 2018 Standard for the Design of High-Performance Green Buildings.
Ensure proper oversight and quality control of construction. The County should
require certified quality and code compliance inspections on all projects. Funding should
also be allocated to train contractors, building code officials and builders on code
compliance. Every project must have at least a midpoint and final inspection completed
by a trained inspector and based on publicly available inspection criteria. Inspection
criteria should be reviewed by community, aid, and constructions groups before finalized.
Page 388 of 420
There also must be a hotline for concerns with construction and contractors, although it
should be assumed most issues will not be reported. Therefore a third party agency
entrusted with quality control should proactively contact every family within one week of
each inspection to detect any issues. Every family must have a copy of the hotline
number, final inspection criteria, their work order, and program details.
Secondly, we want to ensure that Harris County gives special attention to the
communities impacted by both Harvey, repeated flooding and environmental degradation
and pollution, and that the buyout program is fair for families. We would suggest that
Harris County use a small amount of the administrative monies to beef up monitoring and
inspection equipment. Thus, the county could consider using a small amount of the funds
for purchase of actual monitoring equipment such as a Trace Atmospheric Gas Analyzer
(TAGA) or handheld gas leak detection cameras to better protect the community from
future events and assure spills and air emission events are properly catalogued and
monitored.
Make buyouts fair for families. The buyout program should make people whole. In
other words, no family should have to take on additional debt to relocate to a comparable
home in a safer neighborhood. If a family owns a three bedroom home free and clear,
the relocation funds they receive should be enough to purchase a three bedroom home
free and clear in a location suitable to the family’s needs with no threat of flooding. The
County should also establish a minimum buyout per household of no less than $200,000
(including any accompanying “housing incentive”). Failing to fully fund relocation costs
will also exclude the lowest income families from buyout programs, abandoning them in
high-risk neighborhoods.
Neighborhoods or neighbors that were doubly impacted by flood waters polluted with
chemicals, oils, waste, or sewage as indicated with overlays should be prioritized for
buyouts. By doing so, the County of Houston can simultaneously mitigate the risk of
flooding and hazardous toxics. Areas that face environmental and flooding risks should
also be considered for additional funding for clean-up and better monitoring. Properties
that are bought out should not be redeveloped for housing, or major non-green
infrastructure projects.
Consider Pilot Revolving Loan for Housing
Finally, the County could consider implementing a pilot revolving fund --principally for
middle-income families who may not qualify for grants but may not have access to loans
-- for a zero or slight interest rate for fixing up their homes and making them more
resilient, energy-efficient and water-efficient. Such funds -- sometimes called WHEEL
(Warehouse for Energy Efficiency Loans) -- would supplement the other programs
contained in the housing plan. We would suggest a small amount of funds for single-
family home repair be dedicated to such a revolving fund, such as $2 million. This public
money could also attract private money.
Sincerely,
Cyrus Reed, Conservation Director

Lone Star Chapter, Sierra Club
Page 389 of 420
County Response: We thank C. Reed of the Lone Star Chapter Sierra Club for his comments.
Harris County does provide inspection services for all projects under its CDBG-DR program.
Working with the County’s Engineer, the county sets standards for rehabilitation and construction
that incorporates IECC, Energy Star, Green Building and other local building codes for CDBG-
DR projects. The county has paid inspectors on staff and uses third-party inspection services to
augment staff as needed. These inspectors are well trained and have the required certifications to
perform the work.
Harris County has Affordable Housing Standards for construction of housing which include our
criteria. These Standards can be found on our Harris County CSD website at
https://csd.harriscountytx.gov/Pages/rfq.aspx.
Harris County seeks to ensure that low- to moderate-income households have access to CDBG-
DR funding for fair buyout of flooded homes and incentives for a replacement home that is safe
and in an area of reduced flood risk and does not cause additional cost burden. The county has
developed several incentives and homebuyer programs that will provide additional funding to
purchase a replacement home. Case management and navigation services will also be available to
assist buyout participants. Moving cost are also included in the assistance. The Harris County
Residential Buyout Program Guidelines provide a detailed description of the program and
incentives.
The county will research the eligibility of a pilot revolving loan fund for home repair, however
this type of program is currently not an available under the Texas Action Plan, however, the
county will work with the Texas GLO to research its eligibility under CDBG-DR and the State’s
Action Plan.
Page 390 of 420

Commenter Name: HOME Coalition Members
Organization: HOME Coalition
Re: Draft Supplemental Action Plan for 2017 CDBG-DR Funds (Round 1)
To Whom It May Concern:
The Houston Organizing Movement for Equity (HOME) Coalition commends the County’s
recognition that rebuilding a stronger, more resilient community canno happen unless it is also
a more equitable community and its recognition that low- and moderate-income families must
be prioritized for assistance. The draft CDBG-DR Local Action Plan is a good step forward,
which the HOME Coalition believes can b strengthened by incorporating the following
recommendations to the plan itself and program design. We appreciate the County’s ongoing
commitment to listen to community voices as the recovery moves forward and stand ready to
assist you in that work.
We offer the following recommendations for strengthening the County of Houston’s draft Local
Action Plan:
Prioritize low- and moderate-income families. The County should allocate 100% of the
funding to families at 80% AMI and below. For a family of four in Harris County, 80% AMI is
$59,900, almost four times the annual income of one breadwinner earning minimum wage. Not
only are low- and moderate-income families the least likely to have disposable income or other
resources available and the most housing cost-burdened, but unmet needs calculations show
that these families also have overwhelming unmet needs. As the Action Plan acknowledges,
“[t]he scarcity of safe, quality affordable housing in Harris County has caused a severe housing
burden and disproportionate housing needs particularly among African American, Hispanic and
large family (5+ persons) households.”
The prioritization of LMI families in the homeowner repair and rehabilitation program, for
example, is appropriate and commendable.
Allocate funds proportionally by household income. We understand that the Harris County
Needs Assessment will determine the recommended proportions of funding that should be set
aside for LMI and non-LMI populations. We specifically want the County to commit to dividing
all funding sources in each program activity by income categories. The brackets of LMI should
follow the traditional 0-30%, 31-50%, 51-80% of AMI divisions and serve those categories
proportionally based on estimates of households harmed in the storm. These income
categories should be applied to all housing programs, including single family
Page 391 of 420

rehabilitation/rebuild, repair reimbursement, new single family home construction (to the extent
possible), single family
rental, and construction of multifamily housing etc. In any infrastructure improvement projects,
the needs of LMI families and communities should be prioritized.
The local needs assessment must go beyond the analysis of flawed HUD/FEMA demographic
IA data that undercounts the needs of LMI homeowners and renters.. As the County
acknowledges in the Action Plan, “[w}hile LMI households made up over 70 percent of the
FEMA IA applicants in the county only about 20 percent of NFIP resources went to LMI areas.
This indicates that LMI households were likely under-represented in the NFIP claims due to
inability to afford flood insurance and high claims denial rates by NFIP.” LMI households also
received fewer SBA loans.
Within Harris County (outside the city of Houston), SBA Disaster Home Loans to those who
could avail totaled $67,065,960 as of December 2017. The average loan disbursed by
December 2017 was $21,324 and tended to be awarded to those of gross incomes higher
than area median. The gross income of those to whom SBA Disaster Home Loans had
been disbursed averaged $117,192 as of December, 2017. Only 15% of these loans were
written to renters.
LMI families have received the least help and have the largest remaining unmet need.
FEMA data itself indicates that renters were particularly likely to be denied FEMA assistance.
“FEMA Registrants included 171,622 owner-occupied households and 150,221 renter-occupied
households. For Harris County (outside the city of Houston), there are 61,828 applicants with a
FVL of over $0. Of these, 45,634 (73.8 percent) were owners and 16,175 (26.2 percent) were
renters.” Homeowners and renters applied for help in roughly equal numbers, but only 26% of
renters affected by Harvey got help, as opposed to 73% of homeowners.
Harris County’s Action Plan is very clear that it understands the flaws in FEMA data.
It should be noted that the FEMA IA for Harris County (outside the city of Houston) listed only
4,460 total applicants who were age 60 and over with only 958 applicants with a FVL over $0
and who received some FEMA assistance. Harris County has more than
300,000 residents over the age of 60. The county believes based on anecdotalaccounts of
canvassers, case management agencies, and rebuilding organizations that the FEMA
numbers for seniors, who had a FVL over $0 and received some assistance, significantly
underestimate the unmet needs of seniors in Harris County. (emphasis added)
This is the kind of information and data that must be incorporated into the local needs
assessment for other populations to account for flaws in FEMA data.The local needs
assessment must pay particular attention to LMI residents of Harris County, particularly the
lowest income families. HOME strongly supports a proportional allocation, but it must be based
on a more accurate unmet needs assessment that reflects the real levels of unmet need for
Page 392 of 420
low- and moderate-income Houston families. We recommend using Texas Housers alternate
methodology to re-assess unmet needs. (attached)
Program selection and design must also reflect the urgent disaster recovery needs of low- and
moderate-income disaster victims.The County must assess, given the proposed programs in
the Action Plan, how people affected by Harvey in the three income brackets (0-30%, 31-50%,
51-80% AMI) will be proportionally served, as well as whether there will be a discriminatory
impact on disaster victims based on their race or other protected class status.
Create family-sustaining jobs. Rather than embedding job creation into the Economic
Revitalization and Public Services Programs, the County should create a stand alone program
specially for disaster recovery that ties direct deliverables to local hire and earn-and-learn job
training. The County should prioritize creating family-sustaining jobs for local residents by
creating a Disaster Recovery Workforce Development and Training Program. As the County
rebuilds, local residents impacted by the storm should be given priority for jobs created by the
rebuilding process. Such a program would ideally create a pipeline to train and introduce low to
moderate income residents from Harvey impacted neighborhoods to construction career jobs,
by partnering with local pre-apprenticeship programs that will offer direct entry into a DOL-
registered apprenticeship or DOL-certified third party accredited bilingual craft training
program. The Disaster Recovery and Workforce Development Training Program agreement
should also require that disaster related apprentices be placed on eligible new construction,
repair, remodel, or renovation projects, including those designated as Better Builder® sites,
identified in the Disaster Recovery Workforce Development component of the plan. This will
ensure fair wages, workers compensation coverage, health and safety protections, and
independent compliance monitoring intended to help families in impacted areas gain viable
access to career pathway.
The Action Plan indicates that the County will participate in the Economic Revitalization
program, but does not provide any needs assessment numbers demonstrating the need for this
program or any detail about what those specific activities will be. These must be included in the
final action plan.
Ensure public services programs match needs. We recommend that the County prioritize
the following public services that have increased access to disaster recovery programs for
lower income families and communities of color following past disasters:
● Legal Services, particularly to help families clear title so they can access mobility and
buyout programs, as well as philanthropic assistance. The State funded a successful title
clearing project following Hurricane Ike. The issue of heirs’ property disproportionately affects
Black families and communities.
● Comprehensive and effective mobility counseling to ensure that both renters and
homeowners can make informed choices about where to live and have access to less
vulnerable neighborhoods.
● Job training programs that prepare local residents for the jobs associated with disaster
recovery programs, both construction and administrative.
Page 393 of 420

● Navigators/case coordinators that can help families through the process of applying for
benefits and the recovery process, and connect them to other services if necessary.
Extend rental affordability. Any multifamily property funded by CDBG-DR funds must be
subject to a Land Use Restriction Agreement (LURA) requiring a 40 year minimum affordability
period for affordable units. This 40 year period preserves affordability for developments that
otherwise would be converted into market rate units in transitional areas over the course of
time.
In addition to longer-term affordability, the Harris County Affordable Rental Program Notice of
Funding Availability (NOFA)/Request for Proposal should incentivize additional affordability and
accessibilty and rebuilding in safer and higher opportunity areas that mitigates future disaster
vulnerability. We applaud the list of primary selection criteria that Harris County has included in
its Action Plan, particularly the first four criteria.
i. Located in High Opportunity Zones; and areas of revitalization as demonstrated by other

public and/or private investments in such areas.
ii. Targets extremely low-income (30 percent AMFI);
v. Leverages public and private financing; (may request waiver to fully fund certain
developments to expedite project completion)
We note, however, that when locating affordable rental housing in “areas of revitalization”, the
relevant public and/or private investment (the County should require evidence of both) must be
substantive and substantial. The location of affordable housing in historically disinvested,
distressed, and minority-segregated areas, particularly given this long-term siting pattern in
Harris County, is a violation of the County’s obligation to affirmatively further fair housing and
may be discriminatory in and of itself.
Make buyouts fair for families. Local buyout and acquisition programs must prioritize LMI
households in floodways and floodplains, who have the least resources which which to relocate
on their own, leaving them a choice between housing instability and potential homelessness or
continuing to live in homes that may be structurally compromised or present health risks
because of mold. We commend that Harris County is making this program available first to LMI
families.
It is particularly critical for LMI families this buyout program includes assistance not only
acquisition and demolition, but relocation payment and assistance as well. As the Federal
Register Notice states, “a buyout program that merely pays homeowners to leave their existing
homes does not result in a low- and moderate-income household occupying a residential
Page 394 of 420

structure and, thus, cannot meet the requirements of the LMH national objective.” (83 FR 5863)
Local buyout programs should include plans to build housing in safer areas. In other words, no
family should have to take on additional debt to relocate to a comparable home in a safer
neighborhood.
As the Action Plan lays out, “[o]f the 43 buyout interest areas, the county has identified 13
areas that are in low- to moderate-income areas and or in Social Vulnerable areas. Seven of
the 13 areas have an average home market value of under $85,000, the lowest average home
market value was $27,105 in the community of Allen Field. As stated in the above section G.1.
Real Estate Market, median home price in Harris County is $160,000. The low market value of
the homes to be bought out to the higher median home price may place a severe cost burden
on low-income and vulnerable populations to find safe, quality affordable replacement housing.
We appreciate the County’s recognition that “[a]dditional housing incentives, the creation
of new affordable housing, and homebuyer assistance programs will be needed to
alleviate this
burden.”
The buyout program should make people whole. If a family owns a three bedroom home free
and clear, the relocation funds they receive should be enough to purchase a three bedroom
home free and clear in a location suitable to the family’s needs with no threat of flooding. The
County should also establish a minimum buyout per household of no less than $200,000
(including any accompanying “housing incentive”), based on the median home values above.
Failing to fully fund relocation costs will also exclude the lowest income families from buyout
programs, abandoning them in high-risk neighborhoods.
Neighborhoods or neighbors that were doubly impacted by flood waters polluted with
chemicals, oils, waste, or sewage as indicated with overlays should be prioritized for buyouts.
By doing so, the County of Houston can simultaneously mitigate the risk of flooding and
hazardous toxics. Areas that face environmental and flooding risks should also be considered
for additional funding for clean-up and better monitoring. Properties that are bought out should
not be redeveloped for housing, or major non-green infrastructure projects.
We commend Harris County for thinking about preserving neighborhoods and communities as
part of buyout programs.
As a public/private partnership approach, Harris County will build on national community

development & housing finance models that promote quality larger scale neighborhood
development for LMI families that is context sensitive and aims toward implementing mixed-
income/mixed use development styles. LMI families affected by flooding especially those
experiencing repetitive flooding, will enjoy opportunities to relocate with their neighbors
from these flood prone areas, thus preserving community cohesion, sustaining the local
tax base, and local institutions such as schools, and other community assets. (emphasis
added)
Page 395 of 420

The HOME Coalition also applauds the community revitalization aspect of Harris County’s
proposed buyout program:
As a separate initiative under this program, the county will identify LMI target areas in need of
community revitalization and that were highly impacted by Hurricane Harvey and other recent
disaster events. These areas will need a comprehensive approach to improve housing,
infrastructure, and facilities to achieve reduced future flood loss and resilience. It is the
county’s intent as we improve housing through rehabilitation, reconstruction, and new
construction to also improve the neighborhood’s
drainage and other infrastructure that serve those homes in the LMI target area. For if the
drainage and infrastructure are not corrected, any repairs or new construction of housing will
be flooded in the next disaster event just as these homes have been affected by 2016 Floods
and Hurricane Harvey. (emphasis added)
This kind of comprehensive investment strategy in historically disinvested neighborhoods is
one of our priorities.
Prioritize intentional and ongoing community engagement. The County should proactively
seek out partnership opportunities with community-led groups to better understand and
address the needs of low-income people and communities of color. This will be particularly
critical around its buyout programs. Community organizations should also be at the heart of
doing outreach and bringing people into the rehabilitation process. To ensure deep and
rigorous community input, the HOME Coalition would like to meet with County staff and
contractors designing the programs early and often, from the program design and the RFP
stage to program completion. Additionally, we recommend the creation of a community
engagement advisory board made up of community leaders to provide the County with regular
input. We recommend prioritizing community leaders from the zip codes with high unmet needs
as members of the advisory board.
We offer the following recommendations for program design and implementation:
Ensure the system is easily navigable through quality case management and
transparency. One of the most challenging parts of the recovery for residents has been
understanding programs, preparing paperwork, and applying for assistance. Information must
be presented clearly and quality case managers must be available to assist in navigation.
Residents and case managers must be able to easily know their status in recovery programs
and understand eligibility, denials, and ability and the appeal process.
Administer a title clearance program to ensure all otherwise eligible homeowners are
able to receive assistance. Inability to show clear title because of heirs’ property ownership is
a barrier to choosing to move to a safer location, particularly for African-Americanhomeowners
. The State of Texas has successfully addressed this issue in disaster recovery
programs in two ways. First, in 2009, the Texas Legislature passed HB 2450, which allowed
the agency administering CDBG-DR to accept alternative proof of ownership, including an
Affidavit of Heirship, for purposes of disaster recovery programs that repaired or rebuilt homes
in place. Second, following Hurricanes Ike and Dolly, the State funded the Texas Title Project,
Page 396 of 420

which helped LMI households clear title and access, in particular, the State’s homeowner
mobility program, allowing them to choose to move to a safer area rather than rebuild in place.
Include a homeowner mobility program like the post-Ike/Dolly Homeowner Opportunity

Program (HOP). While the eligible activities include “new construction”, which would allow
relocation activities, the County should explicitly include a homeowner mobility program like the
post-Ike/Dolly Homeowner Opportunity Program (HOP), which allows eligible homeowners to
choose to move to lower-risk higher opportunity area rather than rebuild in place, in its
Homeowner Assistance Program. The HOP program, created after Hurricanes Dolly and Ike,
was the first of its kind nationally. As of February 17, 2017, 282 households, or 9% of total
applicants for homeowner assistance had been successfully relocated to safer,
higheropportunity areas.
The HOP program not only provided homeowners with a choice of whether
to move or rebuild in place, but it included services like mobility counseling and real estate
assistance to help ensure that the choice was an informed one, as well as using a formula
determined benefit amount that the choice to relocate a real one for LMI families. The State
and regional Councils of Government have experience running a homeowner mobility program
that is a source of valuable lessons learned on how to improve the program, a resource for
other voluntary and mandatory buyout programs, and will allow this program to be established
quickly following HUD’s approval of the State’s draft Action Plan (as amended to include a
homeowner mobility program.)
Including a homeowner mobility program not only increases resiliency and mitigates the impact
of future disasters by allowing homeowners to move to safer and less disaster-vulnerable
areas, but also ensures that the State can truthfully certify that it is in compliance with civil
rights laws and its obligation to AFFH. Homeowner Assistance Programs that lock homeowners
into rebuilding in place, because of historical segregation imposed by federal, state, and local
government policies, may perpetuate segregation in violation of the Fair Housing Act and/or
result in the use of federal financial assistance in a way that discriminates based on race, color,
and national origin, even if the State lacks any discriminatory intent.
Do not use pre-storm value of a home to determine disaster recovery program

assistance because it often produces a discriminatory impact on the basis of race and
ethnicity. Following Hurricane Katrina, a lawsuit was filed against the State of Louisiana and
the U.S. Department of Housing and Urban Development (HUD) alleging racial discrimination
in the State’s CDBG-DR funded Road Home Program, which provided grants to homeowners
to repair or rebuild their homes. The original grant formula was based on the pre-storm value of
a home, which resulted in African-American homeowners receiving less repair money than
White homeowners, because their homes were located in neighborhoods with lower home
values due to market discrimination and the legacy of segregation.
Many African-American families were

left unable to complete repairs or return home or were left living in uninhabitable houses. As
Louisiana Congressman Cedric Richmond said when the case was settled in 2011,
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“[e]veryone knew that the Road Home formula for calculating grant awards was deeply flawed
and punished folks in neighborhoods where home values were lower. . . After all, if two families
are both rebuilding a three bedroom home then their construction costs will be the same—
regardless of the neighborhood. In that case, each family deserves the same assistance from
their government. Unfortunately, the flawed formula was effectively discriminatory, locking many
[5]
families out of equitable assistance.
”
The lawsuit (which resulted in a change to the Road Home formula) and settlement resulted in
an additional $535 million in repair and rebuilding funds for LMI homeowners in the four most
[6]
impacted parishes in Louisiana .
As the Action Plan acknowledges, the buyout program must be accompanied by additional
funding for LMI families in order to ensure that it is equitable and successful.
Do not include demolition costs in maximum assistance calculations for the homeowner
assistance program.
Including this cost for reconstruction of homes will put reconstruction out of reach for many
households, since the cost of reconstruction included in the guidelines references only a
standardized cost based on household size, not cost of construction plus demolition of a prior
structure.
Provide assistance for those who became homeless as a result of the hurricane. This
includes over 3,800 evacuee households living in hotels through the Transitional Shelter
Assistance (TSA) program.
Some of these households will have a place to return to once
repairs are completed on their housing. Many of these households, however, particularly renter
households who are dependant on whether third parties rebuild, will not have stable housing
after TSA ends and may become homeless.
No mold left behind. Any house that has had any kind of repairs since the storm, particularly
those repaired through PREPS, should be inspected for mold and moisture, and unless the
home is going to be demolished and rebuilt, the mold must be properly treated. The inspection
must require checking for mold behind sheetrock, behind bathtubs, and in sub-flooring, as well
as ensuring that any flooded, porous material has been removed, as this was neglected in the
PREPS program and other rebuilding. Families should be presented the option of gaining a
Certificate of Mold Damage and Remediation. If homes are gutted, they must be properly
remediated and dried in line with the CDC and NIEHS’s guidelines. Assessment for rebuilding
costs must include any necessary gutting and treatment.
Promote environmentally-friendly standards. Any repair or reconstruction should follow

modern and energy-efficient building codes and standards. Reconstruction, repair and new
construction of residential buildings should follow the Energy Star program, and/or the HUD
CPD Green Building Retrofit Checklist for non-substantially damaged residential buildings and
Page 398 of 420

should at a minimum meet the 2015 International Energy Conservation Code (or the equivalent
chapter of the 2015 International Residential Code). In addition we recommend requiring the
following standards:
● Require the 2015 International Energy Conservation Code--as is required by state law--for
all commercial buildings, including multi-family buildings over three stories
● Require new residential buildings be built solar-ready, thus easily able to incorporate solar
energy in the future by reserving adequate roof space
● Require compliance with modern plumbing codes, such as the 2015 UPC or 2015 IPC,
which will help lower utility and energy bills
● Give priority to new construction or major reconstruction of multi-family buildings that are
designed to meet a more robust standard, such as the ASHRAE 189.1 - 2014
Standard for the Design of High-Performance Green Buildings, or the recently published
ASHRAE 189.1 - 2018 Standard for the Design of High-Performance Green Buildings.
Ensure proper oversight and quality control of construction. The County should require
certified quality and code compliance inspections on all projects. Funding should also be
allocated to train contractors, building code officials and builders on code compliance.
Everyproject must have at least a midpoint and final inspection completed by a trained
inspector and based on publicly available inspection criteria. Inspection criteria should be
reviewed by community, aid, and construction groups before finalized. There also must be a
hotline for concerns with construction and contractors, although it should be assumed most
issues will not be reported. Therefore a third party agency entrusted with quality control should
proactively contact every family within one week of each inspection to detect any issues. Every
family must have a copy of the hotline number, final inspection criteria, their work order, and
program details.
Increase Theft of Service Enforcement. Even before Hurricane Harvey, wage theft was an
issue in the Harris County construction industry. The Texas Penal Code Section §31.04,
criminalizes Theft of Service; the intent to avoid payment for services rendered. In 2011, the
Texas Legislature passed SB 1024, the Wage Theft Law, to clarify that the failure of an
employer to pay an employee for work performed may be investigated and prosecuted as Theft
of Service under the Texas Penal Code. The Harris County District Attorney should:
● Convene a meeting with the Houston Police Department and the Harris County Sheriff’s
Office to establish a streamlined and accessible system for workers to make Theft of Service
reports county-wide;
● The Houston Police Department and Harris County Sheriff’s Office should designate a
point of contact in their offices for community organizations who assist workers in making
such complaints, and establish a regular meeting between its office and our
organizations to follow up on enforcement efforts;
● Provide training to Assistant District Attorneys about wage theft, the 2011 amendments to
the Theft of Service Statute, and the proper protocols to follow when investigating and
prosecuting such cases;
Page 399 of 420

● Collaborate with community and labor organizations in theft of service enforcement
efforts, and support community education efforts to advise Harris County workers and
employers that local law enforcement will take theft of service reports seriously.
Offset the burden of insurance. We recommend that Homeowner Assistance Program,

Homebuyer Assistance Program, and Buyout Program funds pay for three years of flood
insurance for recipient families for whom insurance is a significant financial strain (specifically
households at 80% AMI and below).
Approve local infrastructure proposals based on the most urgent needs. An evaluation of
whether “infrastructure activities … contribute to the long-term recovery and restoration of
housing” should include a review for specific and articulable ways the proposal prioritizes the
needs of communities with substandard infrastructure as a result of discrimination and
disinvestment. While we understand that this may feel unequal to individual jurisdictions, it
would be the most effective use of disaster recovery funding. In addition, infrastructure
proposals should be reviewed to ensure that potential flood water is not simply moved from one
community to another. The County’s acknowledgement that “local neighborhood drainage
systems are needed to reduce the flood risk of these areas” supports this recommendation.
Repercussions for source-of-income discrimination. All rental properties receiving

CDBG-DR funding must agree to take Housing Choice Vouchers and not to discriminate based
on source of income. Landlords that are on record as refusing tenants with vouchers or
otherwise discriminating based on source of income should be reported to the appropriate
County agency and be made ineligible for future CDBG or County assistance. The Land Use
Restriction Agreement (LURA) placed on all rental properties receiving disaster recovery funds
must set out income and rent restrictions; the affordability period; and requirements that rental
projects must accept Housing Choice Vouchers for all units, not just the affordable units.
Again, thank you for the opportunity to provide comments to the County’s draft Local Action
Plan. We look forward to continuing to collaborate to bring about an equitable recovery.
Sincerely,
HOME Coalition Members:

Texas Organizing Project
Workers Defense Project
Texas Gulf Coast Area Labor Federation
Texas Appleseed
Texas Environmental Justice Advocacy Services
Service Employees International Union Texas Plumbers Local Union 68
Texas Building and Construction Trades Council
Houston Gulf Coast Building and Construction Trades Council
Laborers International Union of North America, LIUNA Local 350 and the Southwest Laborers
Page 400 of 420

District Council
International Brotherhood of Electrical Workers, Local 716 International Union of Painters and
Allied Trades, District Council 88 West Street Recovery
FIEL Houston
Faith in Texas
Air Alliance
Sierra Club Houston
Coalition of Community Organizations
S.A.F.E.
Diversity Communities
Living Hope Wheelchair Association
Action CDC
County Response: We thank the HOME Coalition for their comments.

 Harris County has prioritized the serving of low- to Moderate-income households and
communities in both its housing and non-housing/infrastructure programs. A minimum of
70 percent of all CDBG-DR funding will be used to benefit this population, this has been
set by the Federal Register for these funds. Currently, the county is expanding the
information in the Harris County Supplemental Action Plan’s Housing Impact and will
include the information in the Harris County Needs Assessment. The county will continue
to expand data for vulnerable populations, including disabled, LMI, and homeless
populations.
 The county will investigate job creation opportunities under the CDBG-DR program and
work with Federal, State and local partners. It is expected that the county will establish a
robust Section 3 program under its CDBG-DR program to ensure jobs are made available
to low-income persons, and Section 3 businesses in construction projects that receive
funding from Harris County’s CDBG-DR allocation.
 It should be noted that the county is participating in the State run Economic Development
program.
 The county agrees and has made the public services mentioned (legal, counseling/case
management and navigation) a part of its plan. We hope to work with area non-profits and
Harris County CSD Social Services program on this effort.
 The Harris County CDBG-DR Residential Buyout program prioritizes LMI communities
for buyout efforts as seen in the Harris County Residential Buyout Guidelines.
 As program guidelines are developed for the housing programs, such as rehabilitation,
reconstruction and new construction, the county welcomes the input of local support
groups. In the case of the recently approved Buyout guidelines, Harris County hosted
meetings with housing providers, advocates, legal service providers, and fair housing
organizations to assist in the development of the guidelines.
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 The county does plan to provide funding suitable under its Buyout program (buyout and
incentives) to ensure each client has the resources they are eligible to receive under the
Federal requirements of CDBG-DR to assist them to find affordable, quality replacement
housing in a reduced flood risk area. Demolition costs will not be calculated in the
homeowners assistance award.
 Housing program clients will have the assistance of quality case workers and housing
navigators to assist them to navigate the CDBG-DR recovery system. We understand that
some populations may need additional help to understanding the programs, preparing
paperwork, and applying for assistance. Programs will have language translation services
available to all who require.
 Harris County has and will accept alternative forms of ownership and will work with local
legal services to assist with title clearance as needed.
 The county will investigate the incorporation of mobility programs with the Texas GLO.
 The county does not plan use pre-storm home value to determine award amount in its
repair program. The award amount is based on the scope of work to repair or reconstruct
the damaged home.
 It is the county intention to provide housing programs in partnership with local homeless
providers and the Coalition for the Homeless to those displaced and made homeless or
those in eminent danger of homelessness due to Hurricane Harvey. As stated in the
county’s action plan, the last Point in Time Count by the Coalition reported an increase in
street homeless due to Harvey.
 Mold inspection will be a part of the county’s housing repair programs.
 The county’s Affordable Housing Standards for construction of housing includes requires
for Energy Star and IECC. The standards also promote LEED standards in housing
construction.
 The county will investigate the “Increase Theft of Services” cited by the HOME
Coalition.
 Currently, the county is allowed to provide one year of insurance coverage, however the
county will investigate with the GLO additional years of coverage.
 The county will review local infrastructure proposals based on several factors including
their impact on community recovery. The county expects to invest planning funding on
planning studies that investigate: substandard infrastructure and solutions, need for
affordable housing and citing and drainage needs.
 The county does and will continue to require funded rental projects under the CDBG-DR
program to agree to take Housing Choice Vouchers and not to discriminate based on
source of income. The county plans to work with local Housing Authorities and non-profit
developers in its rental-housing program.
Page 402 of 420

Commenter Name: Mark Smith
Organization: SBP, Inc USA

Good Afternoon,
Please see the attached comments on the Harris County Harvey CDBG-DR Action Plan Draft. These comments
have been compiled by Mark Smith and Reese May who are employees of SBP, Inc, a national nonprofit disaster
recovery organization that is currently assisting Harris County residents. We would be more than happy to
discuss our thoughts and feedback with Harris County officials at any time.
Please also see the summary of our comments below.
Positive Feedback
1. We applaud Harris County's prioritization of home repairs for Harvey survivors still living in FEMA/GLO
provided temporary housing.
2. We are glad to see reimbursement as a pathway. At a minimum, it ensures that clients are not
punished/denied CDBGDR assistance simply for having begun work themselves.
3. The buyout program is a great way to reduce long-term risk exposure for clients and/or communities who
cannot afford to conduct mitigation activities on their own. Additionally, we applaud that LMI client's whose
homes have repeatedly flooded will have the option to purchase new homes in low-risk areas.
Areas of Concern:
#1: Data sources, and completeness
In any recovery, data drives decisions. As we read the action plan, there are a few concerns about the data
sources and their accuracy. We understand the county is compiling needs assessments for its housing programs
and we want to point out the following concern for consideration. Harris County has found that FEMA IA data
under-represents the needs of seniors citizens. This leads us to believe that other populations may be
underrepresented as well. Can the county work with the insurance industry and/or others to assist with satellite,
flyover, and claims data to get a more current and accurate picture of need?
#2 Housing Program
After a natural disaster, the longer people go without stable and safe housing the more likely they are to reach
their breaking point at which families and lives are irreparably damaged. Given the limited federal resources for
home repairs and reconstruction assistance and that additional funds have been allocated to Texas for
mitigation, which can include infrastructure activities, we ask Harris County to increase the allocation of funds to
the housing programs.
#3: Reimbursement
1. How will reimbursement pathway work for homeowners who have repairs in progress when the Harris County
program launches? Will clients need to halt construction while they complete their application for the program?
Will they have to change to program approved contractors?
2. What is the environmental clearance procedure/threshold that will be accepted/required by the County for
homeowners in the reimbursement pathway?
3. What was the calculation methodology used to determine the max reimbursement award of $50,000?
Page 403 of 420

Clear communication and predictability surrounding reimbursement will be incredibly important to survivors
who would like to begin repairs or who have already begun repairing their homes but may need assistance from
the county to complete their recovery.
We appreciate your time and efforts in developing a plan to expedite the recovery of Harris County and look
forward to working with the county moving forward.
Sincerely,
Mark
Mark Smith
Advisory Services Manager
www.SBPUSA.org
@SBPUSA
County Response: We thank SBP, Inc for their comments.

 Currently, Harris County is expanding the data presented in the Harris County Supplemental
Action Plan’s Housing Impact and will include the information in the Harris County Needs
Assessment.
 The data provided in the action plan shows an unmet need for housing and infrastructure
funding. The county will be prioritizing projects that not only improve drainage to mitigate
future storm events but will also provide funding to assist in the repair of critical infrastructure
in our neighborhoods damaged by Hurricane Harvey.
 Regarding the reimbursement process, the county is awaiting more information and guidance
from the Texas GLO and will be developing program guidelines over the coming months. The
maximum reimbursement amount of $50,000 was determined by the Texas GLO in their State
Action Plan.
Page 404 of 420

Commenter Name: Cortney Morris
Organization: Resident of City of Houston
My Name is Cortney Morris, a homeowner in the Kashmere Gardens area. I have experienced
having to move family members due to a buyout when the first phase started at Hunting Bayou.
Those family members were over the age of eighty (80) and have since passed away. It is sad
that we had to relocate them from a home they had resided in for over fifty (50) years and
nearly ten (10) years later, the improvements to the bayou still have not been completed.
I recently attended an “open House” the County held at the Kashmere Gardens Multi Service
Center in June. My understanding of the bond is to release more funds into the Houston Area
to help with flood improvements. My concern with the bond and other funds that are released
is that they be distributed to areas and citizens with the most need. According to County
Commissioner Rodney Ellis, often money is distributed based on the value of homes and their
replacement cost versus bayou expansion or other infrastructure needs. It seems as though
areas such as Greenspoint, Kashmere Gardens, South Park and others that are often low
income or culturally diverse are used as the face of flooding despair to increase giving and need
based funds. Once funds are made available, more often than not, the homogenous areas such
as Meyerland or Upper Kirby see road and drainage improvements. Even when it comes to
assistance from FEMA, oftentimes needs assessments are based on whether home owners have
flood insurance.
A family friend who lives on our street, Minden, was affected like many of us during H arvey. She
had over four feet of water in her home. She DID NOT have flood insurance because when it
was time to renew she had to choose between medication for her husband or paying the
insurance premium on a fixed income. She chose the former. She just moved back in to her
house at the end of April with help from church members, family, and friends. Her husband died
two weeks later. The stress of flooding, living elsewhere, the cleanup process and draining their
life savings yet again to restore their home has been debilitating. Her husband wanted to hold
on to get back into his house, which he did, but he didn’t get to enjoy it long. Flood insurance in
this area is nearly $3000 a year and must be paid in full at the time of renewal. Homes in
Brazoria County are required to have flood insurance and those premiums run less than
$1000/year. I understand that HUD guidelines have requirements for flood insurance, but
people in my community should not be penalized for not being able to afford insurance. I ask
that home rehabilitation projects include preventive measures like elevation, so in the future, if
a family must choose between high cost medication or flood insurance they will still be
protected.
Please remember the faces that you’ve seen on TV and know that we are still struggling. Many
people still are not back in their homes and recovery is long. Limited incomes greatly restrict
Page 405 of 420
reconstruction efforts. We’ve got to stop expecting nature to conform to our development and
instead start accepting that we must conform to the area itself. We are the BAYOU CITY and
living in a neighborhood that backs up to a bayou should not limit funds availability. No one
should have to be forced out of their home due to city planning that established neighborhoods
in flood plains.
Most Homes in Kashmere Gardens are on pier and beams, not foundations, so providing
assistance in elevating these homes could be more affordable and effective than other repairs. I
plead with you, help those most in need financially, mentally, and physically. Stop using the
face of the needy and their housing circumstances to tug at purse strings just to empty its
contents into more financially viable neighborhoods.
Thank you for taking time to read my comments and please do not forget Kashmere Gardens,
seniors, and people on fixed incomes who can’t always afford insurance, and who are still
rebuilding.
County Response: We thank C. Morris a resident of the city of Houston for their comments.
Although the neighborhoods mentioned in this comment are located in the city of Houston, the
county acknowledges that all communities affected by Hurricane Harvey should equally have
access to recovery resources. Due to cost benefit ratios, some federal funding may be more focus
outside low-income areas. In the case of CDBG-DR funding, 70 percent of funding must benefit
low- to moderate-income households and or communities. CDBG-DR funding requires the county
to perform a duplication of benefits test, collecting information of other repair funding such as
flood insurance, but attempts not penalize poor families who could not afford insurance. Those
assisted with county CDBG-DR funding (rehabilitation/reconstruction program) may be eligible
for flood insurance coverage funding for one year (based on GLO guidance). The County’s home
rehabilitation programs will evaluate or reconstruct homes that are below the based flood
evaluation requirement to reduce future flood risk. Buyout programs under the CDBG-DR
programs have been established for areas that have a severe flood risk for residents and
emergency first responders. Both of these programs have program specialists and case workers to
assist residents to navigate the CDBG-DR system.
Page 406 of 420

Commenter Name: K. Prickett
Organization: Resident in Katy, Texas area
Good Morning!
Our home flooded in both the Tax Day Flood & Harvey
We were given some funding from FEMA, I don’t know if we qualify for any additional funding
through this Harris County Publishes Action Plan for spending 1.1 Billion in HUD Money Slated
for Harvey Recovery?
Please let me know how I would need to proceed if so.
Thank You,
K. Prickett
County Response: Resident referred to county case worker (Housing & Community Resource
Center) for case review and service navigation.
Page 407 of 420

Commenter Name: Jonathan Krantz and Bryan Howard
Organization: U.S. Green Building Council Texas Chapter
See next page for letter.
Page 408 of 420

July 10, 2018
Harris County Community Services Department

8410 Lantern Point Drive
Houston, Texas 77054
Attn: Planning and Development,
Thank you for the opportunity to provide comment on the Draft Supplemental Action Plan for
the 2017 Community Development Block Grant – Disaster Recovery (CDBG-DR) Funds (Round 1).
On behalf of the U.S. Green Building Council (USGBC), our more than 12,500 member companies,
and strong Texas community of members and credential holders, we contact you to recommend
that Harris County include Leadership in Energy and Environmental Design (LEED) green building
certification as an option for meeting quality construction standards requirements for CDBG-DR
funding.
USGBC and LEED in Harris County and Texas 1
USGBC is a nonprofit organization committed to transforming the way all buildings and
communities are designed, built and operated to enable a sustainable, resilient, and prosperous
environment that improves the quality of life for all. Representing the full range of the building
sector, including builders, product manufacturers, professional firms, and real estate, over 450
Texas organizations are USGBC members, and there are nearly 12,000 individuals in Texas
holding a LEED professional credential.
Our flagship green building system, LEED, has been embraced by the Texas market. Indeed,
Harris County has recognized the value of LEED certification by giving preference to projects who
peruse certification in affordable housing standards 2 to achieve high-performing and durable
buildings and homes. In fact, Texas is one of the top states for LEED for Homes with over 18,000
certified units,3 and a 2017 study by the University of Texas Austin found that LEED-certified
homes showed an 8 percent boost in value. 4 LEED also supports the state-wide economy,
contributing an estimated $21.39 billion to the Texas GDP and helping to create or sustain an
estimated 244,000 jobs from 2015-2018. 5 Texans know the value of achieving LEED status for
their projects.
Recommendation for Harris County Action Plan
USGBC applauds the work of the Harris County in outlining a detailed plan for restoration that
identifies resilience – informed by post-disaster risk assessment – as a top priority.
In order to ensure 2018 CDBG-DR funding is used effectively to rebuild in ways that help mitigate
future major weather events, USGBC recommends that LEED certification be included among
1 For more information on USGBC’s work in Texas, see USGBC Texas Chapter.
2 Harris County Affordable Housing Standards: Project Standards, Design Criteria and Underwriting
Guidelines Harris County Community Services Department Revised January 2017, pg 14.
3 See state market briefs for LEED Homes and LEED in Motion: Residential.
4 The study looked at homes sold in the Austin-Round Rock area from 2008-2016.
5 2015 Green Building Economic Impact Study, Booz Allen Hamilton. See State Infographics.
Page 409 of 420

options for green building certification in the local action plan , providing this choice to the
market and to project teams. Including LEED as an option will help the county achieve more
resilient housing that supports residents’ quality of life through improved human health, greater
disposable income, and an overall safer living environment. 6
Inclusion of LEED builds on the General Land Office (GLO) minimum compliance standards for
CDBG-DR. As you know, ENERGY STAR and LEED work together to empower property developers,
owners, and occupants to increase projects’ energy efficiency and reduce power load
requirements, thus enhancing opportunities for resilience. For example, LEED for Homes uses
ENERGY STAR for Homes as a core performance standard, while LEED systems for mid-rise and
high-rise existing residential buildings incorporate ENERGY STAR certification as a compliance
option. While ENERGY STAR is an effective path to improvement in energy performance, LEED
represents a more comprehensive approach to overall sustainability, durability, and resilience.
Additionally, LEED can guide rebuilding projects to optimize community value from quality
affordable housing. For example, incorporating communal green space such as parks, gardens,
corridors, and roofs adds value to both building occupants and the greater public. Moreover, as
our built environment unequivocally impacts human health, green building practices utilize
materials and smart design known to promote wellness and decrease rates of asthma as a
priority in housing developments.7
We stand ready to assist Harris County in implementing its CDBG-DR program regulations, to
help provide high-performing, resilient housing to reduce risks of future destruction and
disruption to Harris County. If you have any questions, please contact us at (214) 293-2996
jonathan@usgbctexas.org or bhoward@usgbc.org (202) 640-2344.
Sincerely,
Jonathan Kraatz Bryan Howard

Executive Director Legislative Director
U.S. Green Building Council Texas Chapter U.S. Green Building Council
6 See USGBC Policy Brief, “Green for All: Healthy and Efficient Affordable Housing. ”
7 For example, a Washington, D.C. study of green certified low income housing renovations (including LEED) identified
significant health benefits to residents. According to the study, self-reported general health in adults significantly
Page 410 of 420

improved from 59% to 67%; allergen dust loadings showed large and statistically significant reductions and were
sustained at one year. The study also reported energy and water cost savings of 16% and 54%, respectively. Jacobs et al,
Health and housing outcomes from green renovation of low-income housing in Washington, D.C., C.J Environ Health.
2014 Mar;76(7):8-16.
County Response: We thank the U.S. Green Building Council for its comment. As noted in the
comment, Harris County values green building, specifically Energy Star and LEED for its
construction projects. Energy Star is a requirement in our HCCSD Housing Standards for
construction. The county will continue to use these approaches and will consult as needed with
green building experts and research to further enhance our recovery projects.
Page 411 of 420

14.3. Appendix H: Public Comment – City of Houston
The City of Houston published its draft local action plan on Thursday, June 7, 2018 and accepted
public comments through Sunday, June 24, 2018. The City published a press release, social
media posts, and a public notice in the Houston Chronicle and several other community
newspapers announcing the availability of the plan online at HCDD’s website and in hard copy
at the Houston Public Library and at HCDD’s office. The following is a list of those that
submitted public comment

Boston-Perez Laura Texas Organizing Project
Brents Tom Garden Villas Community Association
Burroughs Roberta
De Hoyos Janie Individual
De Leon Gina Harvey Partners Network
Egge Rosalinda Individual
Fisher Bill Sonoma Housing Advisors
Gage Brian Houston Housing Authority (HHA)
Henneberger John Texas Housers (Texas Low Income
Housing Information Service)
Houston Housing Collaborative
Hunter Veralisa Individual
J Rick Individual
Jackmon Amira Individual
Khalil Hany Texas Gulf Coast Area Labor
Federation, AFL-CIO
Lawler Mary Avenue
Legette Sasha Houston Organizing Movement for
Equity (HOME)
Miles Borris State Senator
Murphy Jim State Representatives District 133
Sequra Maribel Individual
Shields Vincent Individual
Smith Mark Individual
Vruqqink Matthew Ojala Holding, LLC
Timm Amanda LISC Houston
Thibaudeau Eva Coalition for the Homeless
Zini Christina Individual
The Metropolitan Organization (TMO)
Page 412 of 420

Comment Received: While the Homebuyer Assistance Program benefits families, policies
should ensure that the benefit goes to families and not to subsidize any inflated interest rates
allowing lenders to recapture funds intended to go to build the family’s financial stability.
Staff Response: Your comments will be considered as program guidelines are developed for the
Homebuyer Assistance Program.
Comment Received: The City should incorporate the following into the local action plan: 1)
Texas Houser’s Hurricane Survivor Recovery, Rights Principles and Initiatives, 2) an
updated methodology to determine unmet needs, 3) reallocate funds from the local
infrastructure program and Economic Revitalization Program. 4) clear rental affordability
requirements for each income category that are based on the income group’s proportional
shares of households with unmet needs, 5) adoption of an outreach plan prior to program
implementation, 6) funding for housing assistance activities to remedy title and property tax
issues, 7) the Homeowner Opportunity Program, 8) provision of payment for buyout
activities above current fair market value and use incentive payments, 9) more information
about elevation costs and priorities, 10) review and update resiliency multiplier, 11)
incorporation of data to analyze protected classes, 12) additions about fair housing, 13)
targets for assistance to LMI households for the Buyout Program, 14) prioritization of flood
control in LMI neighborhoods, 15) target rental housing for income categories based on
unmet need to serve extremely low-income renters and prioritize developments in high
opportunity areas, 16) add information about the City’s public website to ensure
transparency.
Staff Response: HCDD followed the methodology provided by the GLO for the unmet needs
assessment including the resiliency multiplier in the local action plan and is in the process of
analyzing additional data for the in-depth needs assessment. The in-depth needs assessment will
supplement information provided in the local action plan and include data about protected classes,
as feasible. This information will be used in the program design. Priorities for affordability will be
included in program guidelines, and your prioritization for extremely low-income and very low-
income rental will be considered in guideline development. Information about the Hurricane Ike
Homeowner Opportunity program and buyout payment specifications will also be considered in
program development. As program guidelines are developed, an outreach plan will be developed
to ensure programs are made available to all eligible applicants. There is no current funding
allocated to a local infrastructure program and infrastructure projects are not prioritized in the local
action plan. The Economic Revitalization Program will help to provide jobs and support small
businesses to complement the housing programs. Funding has been allocated to public service
activities, which may include housing services to assist remedying property title and tax issues.
HCDD will continue to build upon and expand its community engagement efforts in the long-term
disaster recovery process, which will include transparency and accountability to gain public trust.
HCDD’s website, along with other communication mediums, will be utilized to inform the public
about program guidelines, program requirements, application processes, and other information, as
appropriate.
Page 413 of 420

Comment Received: Continue the City’s robust public engagement efforts that have already
begun. Incorporate a comprehensive approach to revitalization of affected neighborhoods,
including updating and strengthening neighborhood preservation and neighborhood
protection policies. Economic revitalization efforts should also include deferred payment
loans to small businesses affected by Harvey and job training for youth. Barriers to
affordable homeownership and renting safe housing should be addressed through best
practices.
Staff Response: The City will continue to partner with community organizations and
neighborhood groups to build on community engagement efforts already underway. As program
guidelines are developed, the City will focus on ways in which CDBG-DR investment can
influence neighborhood revitalization and strengthen neighborhood preservation. The City will
consider recommendations made about the Economic Revitalization Program as the program is
designed and intends to undertake a holistic approach to recovery that leverages public service
activities, such as job training and preparation for homeownership, to help remove barriers to safe
housing and expand homeownership options.
Comment Received: Can the City analyze additional data to get a better picture of need and
accurately depict unmet need? Clarification is needed regarding the reimbursement
program about timing, environmental clearance, and the award calculation method.
Staff Response: The City is in the process of developing an in-depth needs assessment to
supplement data provided in the local action plan. This assessment will include additional data to
better define and expand upon the characteristics of unmet need in Houston. The reimbursement
option of the Homeowner Assistance Program will include homeowners that have completed
partial or full repairs on their homes before applying to the program. The repairs must comply with
program specific environmental review requirements. The maximum award amounts for
reimbursement are set by the Homeowner Assistance Program, unless otherwise specified in the
program guidelines.
Comment Received: A local organization providing financial, strategic and technical

assistance to build inclusive communities made the following recommendations: 1) continue
robust outreach and community engagement efforts, 2) include development of nonprofit
capacity in all recovery programs, 3) commit to full transparency and accountability, 4)
publish results from community engagement, 5) align goals with other affordable housing
and community development initiatives already underway in the city, 6) integrate resiliency
planning and design in the action plan and recovery programs, 7) leverage all resources to
holistically revitalize affected neighborhoods, 8) clarify Section 3 and MBE/WBE
participation, 9) connect job training and workforce development to CDBG-DR funded
construction investments.
Staff Response: HCDD will strive to build upon and expand its community engagement efforts
in the long-term disaster recovery process, which will include transparency and accountability to
gain public trust. HCDD will make a summary of community engagement from May and June
2018 available online. HCDD partners with and depends on nonprofit partners to help achieve its
goals and will work to assist with providing opportunities for capacity building. As program
Page 414 of 420
guidelines are developed, efforts will be made to align programs to other housing and community
development initiatives, as appropriate, to create a holistic neighborhood revitalization approach
to CDBG-DR investments and to integrate resiliency design and construction best practices. As
guidelines for the Economic Development Program are developed and Requests for Proposals are
issued, effort will be made to clarify Section 3 and MBE/WBE requirements. In this program,
HCDD will also strive to link workforce development and job training programs with the
construction and rehabilitation programs, as appropriate.
Comment Received: A collective of people and organizations working to promote affordable

housing made the following recommendations: 1) continue robust outreach and community
engagement efforts, 2) include development of nonprofit capacity in all recovery programs,
3) commit to full transparency and accountability, and 4) align goals with other initiatives
already underway,
Staff Response: HCDD will continue to build upon and expand its community engagement efforts
in the long-term disaster recovery process and will include transparency and accountability in its
community outreach to gain public trust. As program guidelines are developed, efforts will be
made to align programs to other housing and community development initiatives already underway
in the city, as appropriate. HCDD depends on nonprofit partners to help achieve its goals and will
work to assist with providing opportunities for their capacity building.
Comment Received: The commenter made the following recommendations 1) use an equity-
based approach to recovery efforts to ensure low-income families qualify for mitigation and
buyout programs, 2) ensure quality disaster case management for individualized recovery,
3) commit to transparency and accountability in the recovery process, and 4) improve data
and technology to inform solutions.
Staff Response: HCDD will prioritize LMI families and ensure outreach to and funding for
families in all low-income categories. HCDD agrees that case management is a component to help
individuals with personalized assistance and is in the selection process to hire a case management
firm to supplement HCDD’s current staff. HCDD is also building upon and expanding its
community engagement efforts in the long-term disaster recovery process, which will include
transparency and accountability to gain public trust. HCDD will strive to use the best available
data for program design and may consider investing in data systems and technology solutions to
create efficiencies in the recovery process.
Comment Received: A coalition of organizations supporting equity recommended to: 1)

prioritize LMI families, 2) allocate funds proportionally by household income in LMI
categories, 3) create family-sustaining jobs, 4) ensure public service programs match needs,
5) extend rental affordability, 5) make buyouts fair for families, 6) prioritize intentional and
ongoing community engagement, 7) Ensure recovery system is navigable, 8) promote
environmentally-friendly standards, 9) ensure proper oversight and quality control of
construction, 10) offset the burden of insurance, and 11) minimize source of income
discrimination.
Page 415 of 420

Staff Response: HCDD will prioritize LMI families and ensure outreach to and funding for
families in all low-income categories. HCDD looks forward to partnering with other agencies to
provide sustainable jobs and workforce development programs for low-income persons. HCDD
will continue to build upon existing relationships to expand community engagement through the
process of developing guidelines and program implementation. As the guidelines for housing
programs are developed, staff will consider these program specific recommendations.
Comment Received: A group of community development practitioners and groups engaging

in disaster recovery recommended to: 1) continue expanding outreach and community
engagement efforts, 2) align action plan goals with other initiatives underway, 3) use an
equity-based approach to recovery efforts to ensure low-income families qualify for
programs, 4) utilize quality case managements, and 5) commit to transparency and
accountability in the recovery process.
Staff Response: HCDD staff will continue to build upon and expand its community engagement
efforts in the long-term disaster recovery process, which will include transparency and
accountability to gain public trust. As program guidelines are developed, efforts will be made to
align programs to other housing and community development initiatives, as appropriate, and to
provide safe housing for homeowners to prevent future flooding. HCDD agrees that case
management is a component to help individuals with personalized assistance and is currently in
the selection process to hire a case management firm to supplement current staff.
Comment Received: I need assistance repairing my home.
Staff Response: Please contact HCDD staff representing the Home Repair Program. You may call
832.394.6200, send an email to homerepair@houstontx.gov, or learn more information about the
programs online at http://www.houstontx.gov/housing/home_repair_programs.html.
Comment Received: Why is the City not addressing infrastructure issues with FEMA
payout? What community input is needed and when? Is the repair and replace program
being developed? Does Texas Organizing Project have a contract with the City of Houston?
Staff Response: The City has applied for FEMA PA funding for repairs needed to various City
owned infrastructure and will apply for additional FEMA PA as applications are developed. HUD
is expected to announce additional CDBG-DR in Fall 2018 to address infrastructure and mitigation
needs. Additional community input about CDBG-DR funds that address housing needs will be
solicited in July through September 2018 as program guidelines are developed. The Homeowner
Assistance Program, as summarized in the local action plan, has repair and reconstruction
components that will be available to single family homeowners. The City does not have a contract
with the Texas Organizing Project regarding this local action plan.
Comment Received: The City should utilize the affordable housing plan that was developed
by Midtown Redevelopment Authority and the Center for Civic and Public Policy
Improvement that would assist the City to quickly spend the disaster recovery funding on
shovel ready projects.
Page 416 of 420

Staff Response: HCDD looks forward to working with the Midtown Redevelopment Authority to
implement affordable housing strategies.
Comment Received: The commenter made recommendations to strategically advance equity

when utilizing disaster recovery funds in Houston. General recommendations include to: 1)
build intentional and ongoing community involvement into the local action plan, 2) prioritize
low-income families, 3) use FEMA and other data to assess need, 4) utilize sound
methodology to determine loss and unmet needs, 5) include impacted undocumented
Houston families, 6) ensure accessibility to city programs, and 7) invest in future-looking
planning and community response. Recommendations about housing programs included: 1)
calculate buyout assistance based on comparable relocation costs, 2) provide other forms of
assistance to homeowners based on need, 3) make single family homes and multifamily units
greener and affordable, and 4) improve infrastructure to protect neighborhoods in harm’s
way. Recommendations about job creation include: 1) create a Disaster Recovery Workforce
Development Program, 2) create Community Workforce Hiring Program, 3) develop
Disaster Recovery Contractor Policy, and 4) increase theft of service enforcement. Finally,
environmental justice recommendations were made to ensure resiliency and minimize health
consequences.
Staff Response: HCDD will continue to build on relationships with community organizations to
expand the community engagement supporting the long-term disaster recovery process. Programs
will follow regulations and guidelines provided by HUD and the GLO and will prioritize assistance
for LMI persons. HCDD is working to utilize various data sources and create new datasets to assess
need, determine unmet need, and guide programs. The program specific recommendations about
the residential buyout assistance calculation, affordability targets for rental housing, assistance to
homeowners, the Homeowner Opportunity Program, building green housing, mitigating
infrastructure to protect residents from future flooding, creating a workforce development and
hiring program, and ensuring environmental justice will be considered as HCDD develops
recovery program guidelines in the next few months.
Comment Received: The City should recognize the needs of and provide grants to residents
who received Substantial Damage letters and must now rebuild their home at a higher
elevation, as mandated by City code.
Staff Response: HCDD will consider your priority recommendation when developing the
guidelines for the Homeowner Assistance Program.
Comment Received: Will there be a cap on the maximum award for the Multifamily Rental
Program. Is there a target allocation between acquisition, rehab, and new construction? Is
there a funding cap? Is there an affordability term and is the loan forgivable? Is it 18 months
to complete project and is that reasonable period of time for completion?
Staff Response: As stated in the local action plan, the Multifamily Rental Program has a maximum
award amount of $40,000,000 per development with a minimum affordability period of 20 years.
The effective date of the contract is the date the agreement with the borrower is executed and
closed. This is often followed by a 30-day mobilization period until work begins on the project.
Page 417 of 420
Currently under development, the program guidelines will contain specific information regarding
any additional funding caps, targeted amounts for acquisition, rehabilitation, and new construction,
and other priorities.
Comment Received: There is a need for neighborhood preservation and protecting

communities, such as those in the Third and Fourth Ward, against gentrification and blight.
Funds should be used for non-traditionally designed homes that allow the community to
remain interconnected and help preserve neighborhood character.
Staff Response: In the recovery process, HCDD will strive to provide affordable housing that best
fits the community’s need without displacement. HCDD is interested in working with local
organizations and developers to provide various affordable housing options. HCDD will offer a
Small Rental Program to rehabilitate and develop rental housing between 1 and 7 units. In addition,
HCDD continues to promote the creation of a community land trust to ensure long-term
affordability of housing in Houston.
Comment Received: To prevent and end homelessness, use disaster recovery funds for: 1)
supportive services paired with rental subsidies, 2) rental subsidies for short- and long-term
assistance, 3) acquisition of multifamily unit acquisition to dedicate for persons experiencing
homelessness, 4) acquisition of small properties to accommodate homeless persons in need of
additional mental health and health assistance, and 5) rehabilitating existing apartments for
use by persons exiting homelessness.
Staff Response: With disaster recovery funding, HCDD intends to fund public service activities
that stabilize persons and families at risk of homelessness and prepare them for permanent housing
solutions. These activities may include, but are not limited to, homeless prevention services,
housing counseling, legal counseling, job training, and mental and general health services. More
targeted services, such as subsistence payments, rental housing subsidies, security deposits and
other services that assist in the housing and/or rehousing of the homeless or those at risk of
becoming homeless may also be undertaken. The Multifamily Rental Program and Small Rental
Program will help assist families impacted by Harvey, including those exiting homelessness, to
access safe, affordable rental housing. HCDD will consider your input regarding dedicated
multifamily units as permanent housing options for the homeless and creating accommodations
for persons with substance abuse disorders as the guidelines for the housing programs are
developed in the next few months.
Comment Received: The Homeowner Assistance Program should include set-aside funds for
those that receive and accept the substantial damage letters from the City of Houston.
Housing assistance should be provided to non-LMI homeowners. Non-housing programs
should have limited funding.
Staff Response: HCDD will consider your priority recommendation for homeowners who receive
substantial damage letters when developing the guidelines for the Homeowner Assistance
Program. HCDD continues to analyze data and will develop an in-depth needs assessment, which
will help HCDD target programs. The City plans to utilize this CDBG-DR round of funding only
for housing and housing related activities.
Page 418 of 420
Comment Received: The $40 million maximum award amount per development for the
Multifamily Rental Program is too high and should be lowered. CDBG-DR funding should
be leveraged to more than $1 billion in new or rehabilitation of affordable housing
Staff Response: HCDD is committed to preserving and expanding the supply of affordable rental
housing in Houston by leveraging its funding. The maximum award amount allows HCDD
flexibility in project selection. HCDD will strive to leverage this funding to achieve the greatest
housing benefit. HCDD will develop guidelines for housing programs which will contain more
detailed information about requirements and priorities, including leveraging. These comments will
be taken under consideration as HCDD develops these guidelines.
Comment Received: CDBG-DR funds should be used to advance equity in Houston’s labor
market. Recommendations include: 1) hire local residents impacted by Harvey for jobs
created in the rebuilding process, 2) support construction training programs in Harvey
impacted neighborhoods, including pre-apprenticeship programs, 3) contractors should
demonstrate how they will enhance the community by providing safe jobs, fair
compensation, and quality work, and 4) fund a workforce development program consistent
to the scope of the damage to area homes.
Staff Response: As described in the local action plan, public service activities and the Economic
Revitalization Program will include workforce development activities, job training, and assistance
to microenterprises and small businesses, such as those that provide housing construction services.
HCDD looks forward to working with local organizations to advance equity and resilience through
workforce development in the long-term recovery process.
Comment Received: All affected districts in the City should be eligible for and benefit from
CDBG-DR. Rehabilitation and reconstruction activities should be available to all, regardless
of income, especially semi-retired/retired/persons with disabilities living on a fixed income
that may be above LMI caps. Clarification is requested regarding ineligibility of
rehabilitation for those living in the floodplain without insurance. The sites for development
of new single family and multifamily homes developed with CDBG-DR should not be located
in floodplains and should be infill development. The funding designated for economic
revitalization and planning should be reallocated for either homeowner/rental property
rehabilitation or reconstruction or used for drainage and mitigation improvements and
maintenance. The City should be transparent in the use of funding and provide the public
with regular updates of programs, accomplishments, and expenditures.
Staff Response: HCDD is analyzing additional data regarding unmet needs and will utilize this
analysis when developing program guidelines. The commenter’s preference for using funding for
all communities and persons regardless of income as well as the priority of serving residents on a
fixed income will be taken under consideration as guidelines are developed. HCDD works to
preserve and create quality housing and will consider these specifications and priorities for
developing new housing when developing program guidelines. The maintenance of infrastructure
is not eligible to be funded with CDBG, however constructing new or improved infrastructure is
eligible. Additional CDBG-DR funding is expected to be announced in Fall 2018, which can be
used for mitigation, such as infrastructure improvements. HCDD will continue to improve its
Page 419 of 420
public engagement process, which will include informing the public about program
implementation and expenditures. Federal requirements specify that CDBG-DR funding may not
be used to rehabilitate or reconstruct a home that has the following three conditions:1) has a
household where income is higher than 120 percent of the AMI, 2) the property is in a floodplain,
and 3) the property owner did not maintain flood insurance on the property.
Comment Received: There has not been enough information given to help homeowners make
decisions about demolishing, selling, or rebuilding their homes. Do the City and County
engage with each other to allow homeowners to understand their options? The commenter
did not like the meetings held.
Staff Response: As of the summer of 2018, CDBG-DR funding has not been provided to the City
of Houston yet, and currently HCDD is developing guidelines for its housing programs utilizing
data from storm impacts, resources made available to the City, and public input. The City works
closely with Harris County Flood Control District, which does have targeted buyout areas and
infrastructure improvements located in the city limits of Houston. We appreciate your participation
in the public engagement meetings and welcome feedback on how to improve these meetings and
better inform the public throughout the recovery process.
Comment Received: The following recommendations were made: 1) continue expanding

outreach and community engagement efforts, 2) align goals with affordable housing and
community development initiatives already underway in the city, 3) develop nonprofit
capacity in all recovery programs, 4) provide quality case management, which is essential to
recovery and investment is needed to ensure an individual’s personal route to full recovery,
5) improve data and technology to inform solutions, and 6) commit to full transparency and
accountability.
Staff Response: HCDD strives to build upon and expand its community engagement efforts in the
long-term disaster recovery process, which will include transparency and accountability to gain
public trust. As program guidelines are developed, efforts will be made to align programs to other
initiatives, as appropriate. HCDD depends on nonprofit partners to help achieve its goals and will
work to assist with providing opportunities for capacity building. HCDD agrees that case
management is an important component to help individuals with personalized assistance and is in
the selection process to hire a case management firm to supplement current staff. HCDD will
research systems to store information that will serve the recovery process.
Comment Received: Edits should be made to tables in the local action plan reflecting updated
information describing the Houston Housing Authority. Also, the total need reflected in
Table 13 is much less than the actual need due to demolition and reconstruction costs not
taken into account. This should be reflected in this table. An amount in the Multifamily
Rental Housing Program should be set-aside to develop units for extremely low-income
households.
Staff Response: Requested edits were made. As the City analyzes additional data and creates
program guidelines, staff will consider your priority to fund rental housing for extremely low-
income households.
Page 420 of 420

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State of Texas Plan for Disaster

Hurricane Harvey – Round 1

Published: March 21, 2019 Public

The Supplemental Appropriations for Disaster Relief Requirements, 2017

 Revised languge in Section 4.1 on the “General Requirements”:

 Changes in Section 5.2. “Harris County Administered Disaster Recovery programs”

 Changes in Section 5.3. “City of Houston Administered Disaster Recovery programs”

The GLO estimates the cost of damages from

Category Remaining Unmet Need % of Total Program % of Total

Economic $12,451,439,074 14% $195,628,178 4%

Harris County - Planning

Harris County Subtotal $ 1,234,813,590 $ - $ 904,439,373 $ 1,234,813,590 21.75%

City of Houston -Public Public Services $ 60,000,000 $ - $ 60,000,000 $ 60,000,000 1.06%

City of Houston - Planning

A. Cumulative Impact of Prior Disasters

B. Impact of Hurricane Harvey

Figure 3: Hurricane Harvey Peak Wind Gusts

Figure 4: Track of Hurricane Harvey8

C. Resiliency Solutions and Mitigation Needs

In the case of infrastructure resiliency solutions, improvements may include:

By percentage, the 49 eligible counties have a higher African-American population when

Figure 7: Percentage of LMI Population by Block Group (Updated in APA 2)

F. Social Vulnerability Index

1. Real Estate Market

a) State Homeless Support Services

Additionally, the Community Services Block Grant program is administered by TDHCA.

3. Social Services: 2-1-1 Texas Program

4. Interim Housing Assistance

a) Multi-Family Lease and Repair

c) Manufactured Housing Options

d) Direct Assistance for Limited Home Repair

e) Partial Repair and Essential Power for Sheltering (PREPS)

Figure 11: Hurricane Harvey Data Call Counties - Region Map

7. Texas Windstorm Insurance Association

New Closed Open % Paid Paid Average

8. Small Business Assistance Disaster Home Loans

County COG Total Home Loans

9. Public Housing Authority Data

COG Projected Cost Unmet Need

10. FEMA Individual Assistance

a. Total Unmet Needs

 Major-Low: $8,000 to $14,999 of FEMA verified loss.

 Major-Low: $2,000 to $3,499 of FEMA verified loss.

Category Multiplier Amount

b. Owner-occupied Unmet Need

Approximately 39 percent of the owner-occupied unmet need is below 80 percent LMI

c. Renter-occupied Unmet Need

d. Owners in a Floodplain with No Flood Insurance

Income Category Count % of Count

1. Governor’s Commission to Rebuild Texas

2. Texas Coastal Resiliency Study

Figure 26: Texas Coastal Resiliency Study Area

3. FEMA Public Assistance

15% Total Need

c. Disaster Unemployment Assistance

2. Small Business Administration Business Disaster Loans

County COG Business/EIDL Loans

Application Type Amount Percent

Texas has a varied