Vacation rentals do not equal a family’s home
Five years ago, the Gulf Coast absorbed the staggering impact of a hurricane that brought more than 60 inches of rain in some areas and left 88 people dead in Texas. But for Texans, Hurricane Harvey was just one of several catastrophic weather events in recent memory.
Since 2016, the state has endured a historic winter storm, two droughts, five hurricanes and 28 severe storms, inflicting an estimated $193 billion in damage. The U.S. Army Corps of Engineers is responsible for helping storm-damaged communities rebuild through the development of infrastructure projects, but its reliance on benefit-cost analysis to advance projects from concept to reality often leaves lower-income communities at risk by centering property value as a decisionmaking factor.
To put it simply, Corps flood infrastructure gets built on the side of town where houses and the dirt under them cost more. As climate disasters become increasingly frequent and destructive, all levels of government must shift to policies that put people over property values.
Environmental injustice in Houston is perpetuated when federal disaster mitigation and response agencies such as FEMA and the Corps are driven by an outdated, congressionally mandated benefit-cost methodology in making financial investment decisions in postdisaster response and pre-disaster mitigation.
This approach, firmly entrenched in federal law since as far back as 1936, converts the outcomes of a disaster into a dollar amount — regardless of who is suffering the consequence and what resources they have. By this logic, damage to a million-dollar vacation home is given more priority than a multigenerational family losing everything in a ZIP code with lower property values.
Such cost-benefit policies hide behind a false rigor that gives the impression of moral objectivity while causing harm that, like the shameful and discriminatory practice of redlining, will take generations to mitigate. But it doesn’t have to be this way. Recently, the Corps started the multi-year Administrative Procedures Act process to require that the project planning decision framework considers, in a comprehensive manner, the total benefits of project alternatives, including equal consideration of economic, environmental and social effects categories. By expanding the Benefits Cost Analysis methodology to capture total costs and benefits and eliminate inequities, the Corps would fulfill its obligation to protect communities in harm’s way.
This change would require analyses beyond the simple aggregation of property values to determine benefits. It would also require a more comprehensive view of the residual economic and social risks that emerge when communities of color are disproportionately impacted by disaster, losing wealth generation after generation, while white communities gain wealth.
Changing this policy would bring us closer to environmental justice, but more work will be needed. At every stage of the disaster cycle, vulnerable populations face barriers to recovery and struggle to influence the programs and projects meant to help them recover.
When planned projects may have adverse impacts, whether it involves dredge material placement or air emissions, the Corps must meaningfully consult with communities. In Houston and Harris County, this could take the form of active outreach to community groups and civic associations well before comment period deadlines and widespread dissemination of information about potential impacts in plain language, with opportunities for the community to understand and help shape mitigation efforts. Much like the benefits-cost analysis, the current approach to community engagement is insufficient and validates a lack of trust between residents whose interests have been overlooked and whose communities remain underrepresented.
Over its 120-year history, the Corps has evolved from building trenches, railroads and bridges to a sophisticated operation that touches our nation’s ports, dams, hydroelectric facilities and much more. It has modernized every aspect of its operation, from the bayous to the battlefield. Now, it needs to modernize its approach to the greatest existential threat in our lifetimes: the climate crisis.
Floods and other disasters don’t respect political jurisdictions or distribution methodologies. We can’t control the weather, but we can challenge a long-standing driver of inequity: the congressionally mandated formula that deprives disadvantaged communities of flood risk reduction investments.
The Corps of today did not create these antiquated policies, but it can — and it should — change them.