HOUSTON RISING COALITION

FIGHTING FOR EQUITABLE RECOVERY FROM HURRICANE HARVEY

To the General Land Office of Texas,

The Houston Rising Coalition is a collaboration between grassroots and membership organizations advocating
for an equitable and just recovery from Hurricane Harvey. We are submitting a comment to the GLO’s Action
Plan for funds allocated for recovery from Harvey to indicate ways in which the plan must be altered to ensure
that resources used to effectively fund recovery, promote equity and fairness, and improve the resilience of
Houston’s communities and neighborhoods. Without improving the resilience of communities, Houston will
remain vulnerable to the storms which seem to hit with increasing frequency and force.

Our Coalition believes that equity - the outcome of a process of the appropriate distribution of benefits and
burdens, within and across generations - is the bedrock of resilience. We urge you to make changes to the Action
Plan which protect people’s right to affordable and safe housing, create good jobs which will allow dollars
invested in Houston to remain here, and protect our environment so that Houston can recover.

The Action Plan must Prioritize Low and Moderate Income Communities:
Families in Low and Moderate Income communities (LMI) bear a disproportionate burden in natural disasters
and are usually left behind in long-term recovery efforts. To combat this, the state should
prioritize low and moderate income (LMI) households in its recovery activities. We believe that LMI
families should be able to exercise four fundamental rights during recovery. They include: the right to stay, the
right to choose, the right to have a say in decision-making, and the right to equal treatment.

HOUSING
New Housing
The money in the Action Plan is insufficient to redress the long standing infrastructure inequities which theses
communities face, but it is enough to cover direct housing needs. The Houston Rising coalition believes that
GLO should follow the principles below in meeting housing needs of Texas residents:

• Recovery funds should be spent on housing and not infrastructure until everyone is back in a safe place to
live
• The money should follow the damage. That is, within Harris County that Houston should get the same
percentage of funding as they had percentage of households damaged.
• The money should go to benefit low and moderate income people – that is people below 80% AMI
• (Area Median Income). The benefit should be direct, it should fund decent housing ia families neighborhood
or a neighborhood of their choice) as opposed to indirect
• The money should prioritize Black and Brown neighborhoods which need more investment to make up for
historic underinvestment.
• The money should be set aside by income levels according to who sustained damage (whether or not they
were qualified by FEMA since we know many people were hurt by flooding AND denied by FEMA). The
groupings should be: 0-30% AMI, 30-60% AMI, and 60-80% AMI.
 HOUSTON RISING COALITION
FIGHTING FOR EQUITABLE RECOVERY FROM HURRICANE HARVEY
HOUSING continued
Buy Outs
We urge the state to execute buyouts, which are likely to be funded by this allocation, in a way that is equitable.
This means that the states buyout strategy cannot be based on publicly unavailable and deeply flawed FEMA
data alone. Only 26% of applications for assistance were accepted and many households are still in the appeal
process. For LMI families, the valuation of buy outs should not rely on FEMA calculations which do not account
for the cost of relocation in a housing market with constrained supply.

Similarly, compensation for buyouts should not factor in floodplain data which greatly devalues a
property, or the value of a structure. Instead, the buyout processes should account for the realities of
low-income homeowners and homeowners and provide homeowners with the amount needed to buy
another house with the same level of indebtedness in a neighborhood of opportunity with decent schools and
a low crime rate. Lastly, the buyout program needs to be sped up so that families do not have to wait years to
have a permanent and dignified home.

The Quality of Direct Assistance

In our on-the-ground experience, the quality of repairs by officially-sanctioned contractors has been lackluster.
Some LMI homeowners report less than the bare minimum being done to make their home livable, i.e. covering
open sockets, but leaving lingering mold unaddressed). It’s our conviction that repairs made with public dollars
should make a home safe and habitable not merely cosmetically appealing. To address this shortcoming the
GLO should Mandate the State walk through the repaired property with homeowner to ensure home is safe and
complies with local, state and federal codes.

Community Engagement and Preservation

The GLO needs to Prioritize in situ community engagement. Take Texas Organizing Project, or Texas Housers
up on our offers to connect the General Land Office with directly impacted, low and moderate income Texans of
color. We encourage the state to re-build with cultural and economic preservation in mind by making an
Anti-Displacement Plan (one was meant to appear in the State Action Plan). Many LMI communities in urban
areas are already under the threat of displacement due to gentrification. We encourage the General Land Office
to implement creative solutions such as community-benefit agreements or community land trusts when
re-building in these areas.

JOBS
The recovery monies in the Action plan is a platform which can create good safe jobs which benefit all of
Houston.

Worker Safety
Considering the dangers of demolition work, the state should ensure all crews be covered by workers compen-
sation insurance, have OSHA-10 training and proper PPE. All sites should be for safety and health concerns.

Contractor Requirements and Screening

Disaster recovery is notorious for bad labor conditions and wage theft. The GLO should require all
Contractors funded by the Action plan to be screened for previous labor violations. Residents living in areas
impacted by Harvey and who are qualified for rebuilding work should be prioritized for contracting jobs using
public funds. Doing so assists the local economy rebuild by putting local residents back to work as quickly as
 HOUSTON RISING COALITION
FIGHTING FOR EQUITABLE RECOVERY FROM HURRICANE HARVEY
JOBS continued

Training and Development

Recovery dollars should be leveraged towards training and career development be requiring contractors to
participate in apprenticeship programs. Hurricane Harvey victims that have been displaced from work should be
placed in job training programs that will increase their options at gaining alternative employment. This training
should be subsidized by the Harvey funding.

Extended Unemployment Benefits Program

For workers that were displaced from their jobs due to Hurricane Harvey should have extended unemployment
benefits until they are placed in an alternative employment situation by their employers or find alternative
employment elsewhere.

ENVIRONMENTAL HEALTH AND JUSTICE

If we learned anything from Hurricane Harvey, it is the fact that we are unprepared to deal with the effects and
consequences of climate change. Drawing on the experience of coalition members, and on behalf of
Environmental Justice (EJ) communities Houston Rising submits these comments about the potential for
Harvey Recovery monies to be directed towards establishing environmental justice in Houston. Our hope and
desire is to be included in discussions affecting EJ communities as they rebuild from Harvey.

Air Quality
It is well known that TCEQ recommended that all air monitors be shut down and releases of unknown amounts
of air toxins were permitted to be dumped on neighboring communities, causing an “invisible flood of air
toxins.” Because communities impacted by the storm were already beset by problems caused by Hazardous Air
Pollutants, we recommend that some portion of GLO funds are used to create and develop a Regional Air Toxins
Plan. As we move towards a Regional Flood Plan we must not neglect the consequences of extreme air toxin
released into neighboring communities. To both avoid future flooding and improve quality of life, Houston
should be required to establish common sense zoning laws to create a safe environment for all citizens.

There are many examples of fence line communities in harms way, but one that really stands out is the
Manchester Community in Houston’s East End, Over a period of 15 years, numerous researchers have found
that the residents of Manchester are exposed to seven cancer causing chemicals on a daily basis, yet very little
in terms of trying to remedy the situation for the residents of Manchester is being addressed. Planning is an
eligible use of CDBG-DR funds. That planning must include environmental and land use considerations in order
to truly address the impact of Hurricane Harvey and mitigate the impact of future storms on Texas.
 HOUSTON RISING COALITION
FIGHTING FOR EQUITABLE RECOVERY FROM HURRICANE HARVEY
ENVIRONMENTAL HEALTH AND JUSTICE continued

Chemical Security
Chemical Security is a huge issue for communities bordering the Houston Ship Channel, yet very little is being
done to secure the health and safety of communities along the petrochemical corridor. We request that the
State to create a plan for addressing relocation assistance for communities bordering polluting industries.
Recovery monies should be used to ensure that communities long threatened by dangerous chemical facilities,
and who breath air polluted by those same actors, are empowered to improve the environmental conditions in
their neighborhoods

Building for a more sustainable future

It is critical that any repair or reconstruction meet modern water-efficient and energy-efficient building codes
and standards. It is also essential that the cost of meeting these standards are not passed onto LMI residents,
but instead are funded through GLO recovery money.

We appreciate that the GLO is proposing to require quality inspections and code compliance, however, any
major reconstruction or new construction should also meet other provisions required by the City of Houston,
including that any new residential buildings are solar-ready, and that all construction should also meet modern
energy codes, including the energy chapter of the 2015 International Residential Code, and/or the 2015
International Energy Conservation Codes, which have been adopted by the State of Texas through legislative
and administrative action.

Similarly, construction should meet modern plumbing codes, such as the 2015 UPC or 2015 IPC. (As an example,
the City of Houston has adopted the 2015 UPC). The 2015 energy and plumbing codes assure that any
construction will help lower utility and energy bills generally. Finally, the GLO should consider expedite and give
priority to multifamily projects which are designed to meet a more robust set of environmental standards above
and beyond minimum requirements.

Conclusion
In conclusion, the coalition Houston Rising urges the General Land office to accept the recommendations set
forth above to ensure that the recovery from Hurricane Harvey is as equitable as possible. The GLO recovery
funding must be used to rebuild housing stock in a way that enables LMI households to live in safe dignified
housing. To do this the GLO must seize on this opportunity to make small steps to address historical
inequities in investment and services. Beyond this, we urge the GLO to use recovery monies to create good jobs
for households and individuals who were impacted by Harvey. This requires both regulatory frameworks,
extended unemployment benefits and job training. In addition, the GLO must fund recovery in a way that
promotes more environmentally sustainable construction, and moves towards establishing environmental
justice for all of Houston. Finally, we urge the GLO to carry out thorough and genuine efforts to work with
communities to shape the recovery plans collaboratively. Doing so is the most effective way to ensure that
traditionally excluded communities can have a say in what happens in their city and neighborhood. Houston
Rising members have offered to assist the GLO in this effort and the GLO should take this request seriously.

Sincerely,
The Houston Rising Coalition