Will This Rain Barrel Fix My Flooding: Designing Effective Programs to Incentivize Private Property...

Will This Rain Barrel Fix My Flooding: Designing Effective Programs to Incentivize Private Property Stormwater Interventions

Abby Crisostomo1*, Josh Ellis1, Caroline Rendon1 1Metropolitan Planning Council, Chicago, Illinois. *Email: [email protected]. ABSTRACT Addressing rainfall at source though private properties is essential for stormwater management. However, requirements for private property stormwater interventions do not address the majority or existing urban properties. Incentive programs to encourage actions by private property owners are increasingly being adopted across the country, but research and guidance on designing such programs to be effective uses of public funds does not exist. Through a literature review, interviews and a scan of stormwater incentive programs nationwide, this research began to comparatively assess incentive program designs and identified key considerations for development of successful programs. Lessons learned include the role of regulatory mandates in creating incentive programs, the importance of dedicated funding streams, the need for one-on-one technical assistance for property owners, the role of third parties in program implementation, the need for more robust program evaluation, and the ability of such programs to actually incentivize new actors. KEYWORDS: Stormwater, green infrastructure, incentive programs, private property engagement, grants, rebates, homeowner, rain garden, rain barrel INTRODUCTION Stormwater policy advocates have long touted the benefits of green infrastructure (GI) best management practices (BMPs) as effective tools to complement, and sometimes replace, typical grey infrastructure. The use of GI has increasingly entered mainstream practice at utilities and communities throughout the country. The U.S. Environmental Protection Agency (U.S. EPA), defines GI as stormwater management systems that mimic nature by soaking up and storing water to manage stormwater and create healthier urban environments, reducing water quality problems due to pollutants and erosion and reducing the financial and material cost of piping that water to be treated at a central location (2014). For GI to be effective, it needs to be implemented where rain falls, which for most urban locations, means largely on private property. While requirements often exist to require installation of stormwater management controls with new construction and major redevelopment, there tend to be few or no requirements for GI retrofits—installing GI on existing properties. Absent these requirements, local agencies have undertaken a variety of methods to incentivize the installation of GI and more traditional infrastructure retrofits on existing properties, reflecting the need for local agencies to rely on the actions of private property owners to comprehensively manage their community’s stormwater issues. In some cases, these actions have been mandated by regulatory compliance with U.S. EPA policies. In fact, many of the country’s oldest and largest programs were created based on consent decrees

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with the U.S. EPA. The regulatory pressure of impending requirements as the U.S. EPA moves down its list of cities will result in more communities needing to create stormwater strategies. As more communities adopt stormwater strategies that include stormwater solutions on private properties, there is a need for more robust data and recommendations on how governments can get better returns on their investments of public dollars, communicate better with local property owners about effective stormwater management, and encourage better and use of GI, all ultimately in the service of mitigating the negative and maximizing the positive effects of rain. This research identifies existing methods to incentivize and encourage stormwater interventions at the private property scale; assesses their effectiveness in actually achieving their specified goals, whether those be quantifiable improvements in stormwater volume reduction or improving public understanding of stormwater management, both valid and laudable goals achieved and assessed differently; and, understanding when and how to use these programs in conjunction with other stormwater infrastructure investments in the most sensible and effective ways. Stormwater Incentive Programs When determining the appropriate approach to stormwater management in a community, the local agencies in charge of dealing with stormwater—whether they be local units of government (municipal or county) through public works departments or independent public utilities (WEF, 2013)—must weigh a number of options to determine the best approach for spending limited dollars on the problem. These local agencies face competing challenges and responsibilities for addressing stormwater—from regulatory requirements to infrastructure investments and maintenance to damage done to constituents’ properties. Local agencies understandably prioritize the more straightforward and cost-effective solutions, which tend to be large-scale investments on agency-owned or other publicly-owned land, such as right-of-ways, and time-tested grey infrastructure solutions (Roy, et al., 2008). Because precipitation falls regardless of property ownership and urban areas tend to be dominated by private property, after a certain point, local agencies find that they must find a way to work with private property owners to implement stormwater solutions in a more distributed fashion (Jaffe, et al., 2010). Research has shown that decentralized programs have been shown to be more cost-effective than a centralized facility in most scenarios (Baerenklau, et al., 2008). This paper focuses on this part of the multi-faceted stormwater solution portfolio, after local agencies have assessed the array of solutions and have identified that private properties are a necessary part of the solution. There are a wide variety of types of stormwater interventions that can be implemented on private properties, ranging from traditional grey infrastructure installation and repair to the burgeoning array of GI solutions. This research is mode neutral to the type of stormwater intervention and encompasses incentive programs that encourage either or both grey and green solutions. The types of solutions addressed in this research include, but are not limited to: rain gardens, rain barrels, cisterns, permeable or porous paving, green roofs, bioswales, trees, native plants, detention/retention basins, downspout disconnection, sump pump disconnection, lateral line repair and overhead sanitary sewers. How local agencies encourage private property owners to implement these stormwater interventions can take many forms. According to the U.S. EPA, stormwater incentives are a tool local governments can use to encourage the use of stormwater practices on private property.

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Incentive mechanisms allow municipalities to act beyond the confines of their regulatory authorities to improve stormwater management on properties that may not fall under stormwater requirements or other state and municipal policies, codes and ordinances. They are meant to work alongside regulatory programs to encourage people to take part in stormwater management voluntarily (U.S. EPA, 2009). These incentive programs can generally be broken down into two overarching types: financial and non-financial. Financial Stormwater Incentives Financial incentives for stormwater management are generally used to share the costs of stormwater interventions between the property owner and the local agency. The way the costs are shared defines some of the different types of programs. Direct cost-share: In direct cost-share programs, the local agency will pay for a portion, often 50-75 percent, of the cost of one or one of a menu of specific stormwater interventions. The local agency will often pay a third-party contractor directly for their portion and require the property owner to pay their portion directly to the third-party, as well. These types of programs are often paired with property assessments free to the property owner so that both the local agency and the property owner know that the specific solution being installed is the right one for that property. Grant or upfront grant: Grant programs are used for more customized solutions on private property. Generally, the local agency starts with a set amount of money and announces the availability of that money for specific purposes. Property owners must then complete an application process that often requires the property owner to submit designs and costs for a project. The local agency will select the best applications and pay entirely or partially for the projects, generally directly to the property owner either in a lump sum or installments. Many grant programs require highly technical design specifications that require the involvement of an engineer or landscape designer, as well as extensive tracking, including maintenance agreements, specific calculations for stormwater volume managed and regular inspections (U.S. EPA, 2009). Rebate: In a typical rebate program, local agencies offer a limited amount of money to residents who make specific stormwater management property improvements to cover or alleviate the costs of the improvements. Many rebate programs are geared toward GI and limit what qualifies for the rebates to specific BMPs. The total amount of the rebate may be determined by the total amount of rainwater controlled, the costs of the improvements or other factors. In contrast to grant programs, rebates rarely cover the full cost of a BMP and are typically paid after the fact to the property owner, who fronts the cost of the installation. Reimbursement grant: A combination of a grant and a rebate program, reimbursement grants function more similarly to a grant program with customized stormwater designs and an extensive application process, but the project is paid for by the property owner who is then reimbursed by the local agency after the fact. While the barriers to the upfront application process for reimbursement grants is more similar to typical grant programs, the barriers relating to financial burdens for property owners are more similar to rebate programs. Coupon or discounted sale: A coupon or discounted program is similar to a rebate in that it allows the property owner to pay a smaller portion of the cost of very specific stormwater

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interventions. With a coupon program, the local agency identifies specific products, such as rain barrels or native plants, which it wants to encourage property owners to use and then works directly with local retailers to provide a coupon or discount for those products. Both the local agency and the retailers advertise the coupons or discount to property owners who can then buy the products at the reduced price at those specific retailers. The local agency reimburses the local retailers for the coupons or discount and doesn’t deal directly with property owners. Other than tracking sales, participation tracking is rarely part of this type of program (Goetz, 2014). Reverse/uniform auction: A reverse auction is a way to set the price for what ultimately becomes a direct cost-share, rebate or agency-installed stormwater intervention. It attempts to find the right balance of property owner versus local agency cost mix for each property. Auctions can function in either direction with local agencies offering up a specific stormwater intervention, such as the installation of a rain garden by the agency or its third-party contractor, and the property owners bidding on it. In the willingness-to-pay model, property owners bid on how much they’re willing to pay for it, in which case, the local agency selects the highest bids closest to the actual cost and cost-shares the rest. In the willingness-to-accept model, property owners bid on the lowest amount they’d have to be paid to allow the local agency to install it on their property, in which case the local agency selects the lowest bids, which result in the local agency paying for the installation plus paying the property owners an additional amount (if the bid is above $0) to “host” the infrastructure. Loan: Much like a grant program, low-interest loans from local agencies or their partner community financial institutions (regular private loans are always an alternative) function as a way for private property owners to get money for installation of stormwater interventions upfront. In this case, however, they must pay the amount back, making this a less common option for small-scale projects. Loans tend to favor large, high-costs projects by more sophisticated property owners who are able to support loan repayments. Tax credit: While structured differently throughout the country, property tax credits are another way, while uncommon, to incentivize GI. In this case, property owners are entitled to a state or local tax credit for a percentage of installation costs for a period of time for installing certain GI BMPs. These programs tend to be geared toward commercial properties and often focus on large-scale, property improvements, such as green roof installations. Often they require them to be of a certain size threshold or include public amenities (U.S. EPA, 2009). Stormwater utility fee credit/discount: This is a very common mechanism for structuring the cost-share that is often paired with another upfront program to help pay for the startup costs. A stormwater utility fee, or user fee, is an alternate way to fund stormwater programs by charging property owners based on use of the stormwater service, rather than a property tax or general revenue-based mechanism for paying for stormwater services. As of 2013, there were more than 1,400 active stormwater utilities in 39 states (Campbell, 2013). The fee is generally set based on the amount of impervious surface on each property and is set to create enough revenue to fund operations. In some places where a stormwater utility fee is applied, residential and/or commercial customers can apply for credits or discounts to this fee for adopting stormwater management practices on their property. The amount of the discount or credit varies widely as do the criteria for determining the discount. The availability of a credit or discount is both a way for

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property owners to opt out of some of the services (distinguishing the user fee from a tax), as well as a way to attempt to incentivize stormwater interventions on individual properties. Non-Financial Stormwater Incentives Another way to encourage the installation of stormwater interventions on private property is to incentivize participation through non-financial mechanisms. These mechanisms for behavior change range from provision of information and materials at no cost to regulatory concessions. These types of incentives tend to be paired with financial incentives. Awards/recognition: These types of program seek to highlight exemplary projects as a way of recognizing the work of particular property owners, use them as models for others, and spread the word about stormwater as a whole. The programs range from certification processes based on property owners meeting certain criteria to annually selected award winners. An important aspect of these programs is the visibility of the recognition, which is often achieved by signage on the property, as well as announcement of winners on websites and newsletters. Education/outreach: Educational programs emphasize the importance of understanding urban water systems and the potential of individuals to make a difference in their community by adopting green practices. Such programs might include workshops on installing rain barrels or rain gardens, with a free or discounted barrel or installation offered upon completion. Many organizations and local agencies that give away or discount rain barrels or other BMPs do presentations upon request at churches, Rotary Clubs, public libraries, and others. Although some educational programs include an incentive, many do not, and rely instead upon individuals’ interest in adopting sustainable practices. These programs are a critical addition to all incentive programs and can be administered by local agencies, but are increasingly supported by independent nonprofit and community organizations. Property assessment: The property assessment (also called a site assessment or site visit) is often the point of entrance into stormwater incentive programs and involves individualized advice for property owners to improve their ability to take part in other incentive programs. In these programs, homeowners can request a (usually free or low-cost) assessment of stormwater runoff on their property. The assessment may include information such as soil types and depth, average annual rainfall, total impervious area, and most importantly, recommendations for stormwater interventions tailored to the property. Some programs pair these with existing energy assessment programs. By identifying what the problems are on the property and the best solutions to address them, property owners are put in a better position to choose to install a solution and are more likely to choose the right ones to be successful. The assessment itself can be conducted directly by the local agency or done by a third-party private contractor or nonprofit partner. Giveaways: The provision of free materials, such as rain barrels or native plants, by local agencies to property owners is a way of creating awareness about stormwater management and demonstrating how it works. While giveaways are good at introducing concepts to those who might not necessarily be familiar, they are not as good long-term, as there is rarely any follow up by the local agency to ensure proper installation and maintenance, and the lack of financial contribution from the property owner tends to devalue the item, leading to lack of investment.

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Local agency-owned/maintained: For local agencies with very specific geographic needs for their stormwater interventions, it is sometimes easier for them to fund and install solutions on private properties within an entire neighborhood in a way akin to typical right-of-way grey infrastructure assets. This involves identifying specific properties on which stormwater BMPs need to go and negotiating contracts and easements with property owners to allow the local agency to install stormwater interventions directly on the property and have ongoing access for maintenance. On the one hand, there are procurement and logistics benefits for the local agency for doing installations and maintenance in bulk, but on the other hand, there are legal and administrative burdens in trying to work with so many individual property owners. In some cases, this is paired with a payment for services in which local agencies pay property owners for the use of land and/or maintenance of what is essentially being used as public infrastructure. Development regulations/policies: This refers to the range of regulatory and planning tools that local agencies have to proactively incentivizing stormwater interventions on existing property rather than those rules requiring installation on new or redeveloped property. This includes negotiated development concessions, such as density bonuses and zoning leniency in exchange for the installation of oversized or green stormwater infrastructure, as well as procedural benefits, such as permit and plan review expediting for projects and plans that include GI components. These tend to favor larger properties with owners more versed in development negotiations. They are largely dependent on the state of the development market, as less demand for development means less opportunity for negotiation with developers (U.S. EPA, 2009). Between the various types of stormwater interventions and program structures, there are countless variations on the types of programs that exist. There are some more common examples of program structures. Many of the non-financial mechanisms are generally paired with financial incentives. In particular many of the most successful programs pair property assessments with any of the various cost-share options, be they grants, rebates or direct cost-share. Rebate and coupon programs tend to focus on stormwater BMPs that can be standardized in some way, such as rain barrels, native plants and trees. Grant programs are some of the most flexible and can be paired with most stormwater interventions. Problems Addressed by This Research As more and more communities and local agencies are considering incorporating private property solutions into their arsenal of stormwater solutions, they are looking to existing programs as models to design their own. While some of the country’s largest and oldest programs are commonly cited as examples of stormwater incentives in the literature to be contacted for more specifics, there does not exist a compendium of the lessons learned from those programs that can be applied to the creation or improvement of other programs. Nor has there been an assessment of existing programs to comparatively determine their effectiveness, identify the variables that affect success, or generally establish more nuanced ways of approaching private property stormwater solutions (Bakacs, et al, 2013). The research discussed in this paper attempts to begin addressing this need. There are a number of issues and variables to consider when creating a stormwater incentive program. And while good models exist, they are sometimes difficult to identify and access and overwhelming to sort through for local agencies that likely do not have dedicated staff to

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determine how to structure a program. There is a need for guidance for local agencies, which tend to be municipalities without much extra capacity or utility managers not accustomed to dealing with stormwater or private property owners, on incentive programs. This includes: information on how and why to implement one in the first place; the types of data about both the community and the local agency that should be considered in the program design process; model example programs and what about them can and should be replicated; and, a resource that combines both the technical considerations for stormwater solutions, as well as the program management and social aspects of running a program that deals inherently with the public. Of the programs that do exist, there is a need for comparative assessments of existing models. This includes: identifying why local agencies are choosing to create incentives for stormwater management; how local agencies articulate the goals for their incentive programs; how the impetus for starting a program and the goals of that program influence the design of the program; who designs stormwater incentive programs and what variables influence how they do it; and what barriers prevent local agencies from creating successful stormwater incentive programs. An assessment such as this helps determine stormwater incentive effectiveness by identifying whether these programs are actually incentivizing new behavior change, whether they are an effective use of limited dollars, and whether programs are effective at accomplishing their self-defined goals. Drilling down into the effectiveness of a program involves identifying the variables that affect success. This can range from demographic factors within the community to organizational capacity constraints at the local agency. Ultimately, it comes down to identifying the barriers that prevent private property owners from participating in stormwater incentive programs specifically, as well as site-scale stormwater solutions more generally. METHODOLOGY This research was conducted by first compiling a review of existing literature assessing successes and failures of both stormwater incentive programs, as well as non-stormwater private property incentive programs with similar limitations as stormwater in terms of geographic scale, local agency authority, and the need for community cooperation. Academic literature and white papers were identified and collected by doing journal and internet searches for key terms related to stormwater incentives as a whole, and broken down by specific technologies as well as program types. When relevant literature was identified, its reference lists and bibliographies were filtered for more sources. Additional sources were identified via recommendations from experts in the field. Additionally, academic literature and white papers related to incentive programs not involving stormwater were also identified and collected for review. This included literature related to incentive programs related to energy efficiency, wetlands banking, recycling, historic preservation, water conservation and efficiency and invasive species removal. In addition to literature on the general topic of stormwater incentive programs, there was noted that no comprehensive catalog of stormwater incentive programs exists nationally, let alone any assessment of those programs. Information on various programs throughout the country was collected to build a repository of case studies. In contacting individual incentive program managers, the original intent was to collect program evaluation data from the various programs to compare and assess, but it was quickly determined that almost no programs collect enough

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data for enough time to be robust and the few that do don’t have data consistent enough to compare. As a result, the research switched to focus on collecting qualitative data. To identify programs around the country, large, model programs were pulled out from the literature review, as well as identified by contacting experts in the field for recommendations, and general internet searches using key terms. In order to focus the search, an emphasis was placed on model programs that were large and robust enough to have done some level of self-evaluation. Once identified and cataloged at a high level, information on each program was turned into in-depth case studies both to share the lessons learned from each program in a thorough, standardized and nuanced way, as well as collecting consistent qualitative data for comparison. Background research was conducted on each program based on materials available to the public and found on the internet. Then hour-long phone interviews were conducted with each program manager based on a standardized script of questions with follow up with other program staff or departments as relevant. From the background research and interviews, case study profiles were created for each program, highlighting the main aspects of the program, as well as the key lessons for others to learn. The information was also categorized and cataloged into a database for comparison and analysis. The first level of assessment was to compare and contrast aspects of the programs, identifying key differences and commonalities. The results of this assessment follow. From this first level of assessment, a modified multi-criteria analysis is being developed to conduct a more robust comparative analysis, as well as develop common hypothetical program structures and assess them through scenario planning. RESULTS AND DISCUSSION Based on the review of literature and intensive interviews and qualitative data collection for several case studies around the country, there are a number of lessons learned and common themes to begin to assess programs that already exist, as well as identify issues to be considered in the formation of new or improvement of existing stormwater incentive programs. At the very least, this research provides a compilation of those lessons learned for local agencies looking to other programs for advice, as was the case for several programs studied (Table 1). Importance of Thoughtful Program Design For the most programs generally considered to be the most successful around the country based on specified goals, there was considerable thought, budget, and staffing devoted to creating and implementing incentive programs. Rather than one-size-fits-all or stand-alone incentive programs, local agencies with successful overarching stormwater strategies tailor separate strategies for separate purposes, which means that incentive programs are part of larger stormwater strategies, tailored to local conditions and treated as formal, professional programs. The most stormwater incentive programs most successful at meeting specified goals are part of broader stormwater strategies, not simply one-off distributions of grant funds or GI materials. Programs from communities as varied as St. Paul, Minn. to Elkhart County, Ind. to Lancaster, Pa. to New York City created incentive programs as part of larger stormwater programs that included public right-of-way investments and both grey and green infrastructure installations.

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Table 1: Summary of incentive reviewed

Program Tier Impetus for Starting

Goal(s) of program

Type of incentives

Green Infrastructure Grant Program, New York City, NY

First Regulatory requirement

stormwater volume reduction

grant

Green Infrastructure Partnership Program, Milwaukee, WI



reimbursement

Rain Check, Philadelphia, PA First Regulatory requirement

education cost share

RainWise, Seattle, WA First Regulatory requirement

education rebate

RiverSmart Homes, D.C. Department of Environment, Washington, D.C.


education cost share

Stewardship Grants, Saint Paul, MN

First Response to stormwater problems

water quality improvement and education

grant/reimbursement

Stormwater Management Incentives Program, Philadelphia, PA



grants and utility fee credits

Stormwater Quality Cost Share Program, Raleigh, NC

First Stormwater utility fee water quality improvement

cost share/reimbursement

Stormwater Utility Fee Credit, Lancaster, PA

First Stormwater utility fee stormwater volume reduction

utility fee credit

Water Quality Protection Charge Credit and RainScapes Rebate, Montgomery County, MD


stormwater volume reduction and education

utility fee credit and rebate

Conservation@Home, The Conservation Foundation, suburban Chicago, IL

Second Non-profit environmental mission

education assessment and certification

Milwaukee Avenue Green Development Corridor, Metropolitan Planning Council, Chicago, IL

Second Response to supply stormwater volume reduction and education

grant/reimbursement

Rain Barrel and Rain Garden Incentive Program, Elkhart, IN

Second Stormwater utility fee education reimbursement

Rain Barrel Reimbursement Program, Glen Ellyn, IL

Second Response to demand water use reduction

reimbursement

RainCatchers, Durham, NC Second Stormwater utility fee water quality improvement

reverse auction

Stormwater Cost-Share Program, Glenview, IL

Second Response to demand basement backup reduction

cost share/reimbursement

Stormwater Credit, Kitchener, ON

Second Stormwater utility fee education utility fee credit

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In D.C. and Montgomery County, the primary private property incentive programs were part of portfolios of incentive programs for varied users. D.C.’s RiverSmart Homes program exists alongside sister programs RiverSmart Schools and RiverSmart Communities, which bring the property audit and cost-share model to schools and neighborhoods, leading to fewer, but larger projects and incorporating additional components, such as professional development for teachers. Montgomery County’s RainScapes program is primarily a rebate program, but encompasses four other programs: a targeted neighborhood program, a schools-focused program that incorporates green job training, a professional training program for landscape designers, and a consumer outreach and education program. These multi-pronged approaches to stormwater management address the wide range of property owners that are part of a broad stormwater strategy. Well-designed incentive programs also take into account local conditions as part of the program design, addressing social, political, and technical barriers to stormwater incentive programs. The role of each of these is discussed throughout this section, but overarching considerations include:

• Land use and property type of the dominant or targeted private properties; • Physical site properties, such as soil type, groundwater table and site contamination; • Local agency capacity, including the number of staff dedicated to a program, the types of

staff expertise available from planners to soil scientists to engineers to architects, the support of elected officials, assistance from local organizations and access to consultants;

• Local demographics, including income, housing tenure and age; • Legal issues, such as zoning requirements, existing regulations or ordinances that require

stormwater management solutions, and mechanisms for formalizing stormwater projects into the future, such as deed restrictions, easements, and restrictive covenants; and,

• Funding for both the program administration and for individual projects, including the source of funding, the amount dedicated to the program, the longevity of the source of funding, and any overriding requirements attached to the funds.

What was clear from the national scan of stormwater incentive programs, there appear to be two tiers of program design types. While there is not a uniform distinction between the two types, they tend to be split between a tier of professionalized programs that are in larger locales, focus on stormwater and regulatory goals, and are municipal or planner-led programs that incorporate program management, community engagement, and other aspects of development beyond stormwater. The second tier of programs consists of less formal programs in smaller communities that are simpler, focus on outreach goals, and might be utility or public works-led programs isolated within a department. Similar to energy efficiency incentive programs that have existed longer in the US, the programs that might be considered model stormwater incentive programs, such as New York City, Milwaukee, Philadelphia, Seattle, or D.C., are all professionalized programs with relatively robust performance-based goals, and are examples of the first tier of program types (US DOE, 2014). While smaller local agencies may not have the capacity, funding, or desire to create programs as robust as this first tier of programs, even second tier programs can learn to incorporate aspects of and lessons from these model programs into their own. And while the more robust and professional first tier of programs makes for good models, there are still pitfalls that come from their scale. This first tier of programs tend to focus on larger properties and higher-priced investments; they tend to cost more to run due to more dedicated staff and more

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one-on-one technical assistance; and, they tend to require more of their private property applicants, resulting in fewer eligible applicants that tend to be commercial or higher-income. To enable more local agencies to adopt effective incentive programs that reach broader populations, first tier programs will likely need to incorporate multi-scale components that use different incentive mechanisms for different scales of projects. And while not all agencies have the capacity to create first tier programs, rough templates or guides should be developed for second tier programs to help them be more robust without needing much more capacity. Reasons for Creating Stormwater Incentive Programs There are a number of reasons why local agencies create stormwater incentive programs. The impetus for starting a program has implications for the goals and structure of the program. Most of the reasons fall under five broad categories. Have a regulatory requirement: For many local agencies, the reason for creating a stormwater incentive program is as straightforward as being legally obligated to by the state or the U.S. EPA as part of a larger stormwater strategy to address regulatory compliance goals. For a majority of the case study programs, including programs in St. Paul, Lancaster, Milwaukee, Philadelphia, and Raleigh, regulatory requirements were the impetus for creating an incentive program. Often, the regulatory agencies, however, do not specify structure or goals of incentive programs, leaving many local agencies to design programs according to secondary goals. Have a stormwater problem: For many local agencies, the impetus for creating an incentive program is simple as having a stormwater program that the agency wants to address. In this case, the stormwater problem is one that the agency wants to fix simply because it is the right thing to do, or because it is part of an internal capital improvement plan. Response to demand: For some local agencies, there are demands for private property stormwater programs from others in the community outside of the agency. This might include environmentally-minded people or committees that encourage agencies to create “green” or “sustainability” initiatives; reports of local flooding for which owners of flooded properties are looking to the local agency for solutions on their properties; and, for those property owners that implement stormwater solutions without an incentive and for whom the local agency wants to reward or use as a model for others. Response to supply: For many local agencies, the decision to create an incentive program is essentially decided for them in the form of offers from other entities. In some places, third parties offer incentive programs to local agencies to adopt as their own, such as the homeowner education and rebate programs provided by The Conservation Foundation’s Conservation@Home program, or the Metropolitan Water Reclamation District of Greater Chicago’s (MWRD) consent decree-mandated rain barrel program, which MWRD intends to partner with local communities to implement. Other times, local agencies will acquire dedicated funding, such as through a grant program, or donated materials, such as rain barrels or native plants, and create programs to distribute them.

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Stormwater utility fee: Local agencies create stormwater utility fees or other user-fee-funded stormwater programs for a number of reasons, but the decision to add a credit or discount component is generally based on a couple reasons (WEF, 2013). Often, a credit or discount is added as a way for property owners to get out of paying a portion of the fee—an important component that distinguishes the fee from a tax and improves public perception of a user-based fee. Local agencies also add credits or discounts to their programs as a way to encourage adoption of private property stormwater interventions. The ability of the credit or discount to act as an incentive often depends on its size. At the very least, incentive programs created in connection with stormwater utility fees are often more successful because the fee provides a stable funding source for the incentive program. Goals for Stormwater Incentive Programs There are two main stated goals that ground most stormwater incentive programs. The first and most obvious is the stormwater goal. Most of the major programs examined have stormwater management, either through volume reduction or water quality improvement, as their primary goal, and many of those focus on stormwater as part of compliance with regulations. For example, the stated goals of Philadelphia’s Stormwater Management Incentive Program (SMIP) are for stormwater volume reduction in their CSO service area and water quality improvements in their municipal separate storm sewer system (MS4) service area, as required through their Consent Order-mandated CSO long-term control plan and MS4 National Pollutant Discharge Elimination System (NPDES) permit. Because volume control can be used as a proxy for pollutant discharges in NPDES permits, there tends not to be much difference in program design in CSO versus MS4 communities. For most programs, there are also secondary goals, such as education or co-benefits, as is the case for New York City’s Green Infrastructure Grant Program in which stormwater is the primary goal and any additional co-benefits are a bonus. Even for programs created as part of regulatory requirements, stated goals, program design, and success are not necessarily dictated by the mandate, and projects created as part of incentive programs are often not even counted toward the local agency’s mandated stormwater storage goals. The other main primary goal for the stormwater incentive programs examined is education, outreach, and awareness. In these programs, there is an explicit acknowledgement that the actual stormwater benefits of the private property interventions, whether they be volume or water quality based, will not be significant or reliable enough to count toward a stormwater goal. In that case, awareness and participation among private property owners is an aim in and of itself. For example, Philadelphia created a complementary program to its main SMIP program, Rain Check, specifically to focus on the goal of education. A smaller number of programs state water conservation and reuse as goals for private property actions, such as rainwater harvesting systems or conservation landscaping. This goal is less common, particularly in areas with abundant water supplies or low rates for drinking water, and is generally a secondary benefit to private property incentive programs. The goals of the local agency in establishing a program tend to differ drastically from the goals of individual property owners participating in a program. That gap is generally bridged as part of the marketing of stormwater incentive programs. While regulatory compliance or public education may be program goals, alleviation of property damage and general environmental benefits are more typical property owner goals. In this way, communicated goals of incentive

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programs may differ from official program goals, as a way to reach private property owners not familiar with stormwater policy jargon. Other benefits of stormwater solutions may be emphasized, such as habitat creation, landscape beautification, water conservation, and job creation, as a means of improving awareness by public officials and the general public of stormwater solutions in general and the incentive program in particular. While the reasons for property owners to participate in an incentive program may differ from the local agency’s goal for having the program, both goals are critical to the design of the program, dictating the types of outreach strategies pursued, data collected, means of program evaluation, and more. For programs with stormwater goals, it is critical for the actions taken by private property owners to be predictable, reliable, and consistent over time so that the volume captured or water quality improved can be robustly calculated. This requires more investment on both the part of the local agency, which will need to ensure the design and long-term reliability of these systems, and the private property owner, who will need to implement the project on a scale that meets the needs and requirements of the local agency. These types of programs must be designed to include clear design guidelines or performance-based requirements, as well as thorough long-term monitoring, maintenance, and inspection components. For programs with education and awareness goals, the actual stormwater benefits of the private property actions are less critical and reaching a broad audience with consistent information is more important than counting gallons stored. For example, in Elkhart County, Ind.’s Rain Barrel and Rain Garden Incentive Program, the program doesn’t calculate total gallons removed or the amount of impervious area managed, as they are not required as part of the program’s goals. For programs for which the primary goal is education or awareness, the program should be designed to emphasize the efficient distribution of relevant information to the property owners who need it. Signage, educational literature, informational events, and a connection to the broader issue—whether that be stormwater management in general or the specific efforts of the local agency—need to be the focus of the program design, rather than calculating stormwater volumes or creating overly technical requirements. Elements of Program Design: Targeting Because of the limited funding available for the private property components of stormwater programs, some local agencies choose to target their incentive programs to specific populations and properties, rather than trying to address entire communities. In some cases, eligibility for programs is specifically limited to certain geographies or property types, whereas in other cases, programs are open to all properties, but outreach is targeted to specific locations or populations. In some cases, geographic targeting allows local agencies to focus their efforts on the parts of the communities that are in the most need of private property interventions or in which private property efforts will contribute best to addressing program goals. For example, Seattle’s Rain Wise program is targeted to specific key neighborhoods that Seattle has identified through hydrologic and hydraulic modeling to be CSO hot spots. In some cases, local agencies will start a program by targeting it to a specific geography and then scale it up once the pilot is successful. This was the case for Philadelphia’s Rain Check program, which was piloted first in ten CSO neighborhoods, and then eventually made open to all property owners in the service area. In Montgomery County, their neighborhood-based program targeted specific neighborhoods, but

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based on feedback from potential applicants in and around the targeted neighborhood, they expanded the target boundaries to improve participation rates. Targeting can also be based on property type. Local agencies tend to favor participation by nonresidential properties, as property owners tend to be more stable and long-standing, have more staff and capacity to make substantive improvements and conduct maintenance, have more funding for upfront costs, are more savvy to deal with legal issues, and have larger properties for larger, more impactful stormwater investments. In a stormwater utility fee credit system, nonresidential properties have more to gain in terms of fee savings (WEF, 2013). In contrast, according to research by Bowman Cutter, et al. and the Water Environment Foundation, incentive programs tend not to be as cost-effective for single-family homes as for other property types because monitoring and enforcement are difficult. Single-family residential properties have less capacity to participate as equally as a partner to the local agency in terms of costs and maintenance. They tend to need more upfront education and guidance on design, as they may or not be able to get outside assistance. Residents tend to have less stable tenure, even more so for rental properties, which have the added complication of multiple responsible parties. Ultimately, the properties themselves are smaller, generally not built large enough to capture stormwater from the public right-of-way, and would require more in number to get the same amount of stormwater capacity (Bowman Cutter, et al., 2008; WEF, 2013). While many programs prioritize nonresidential properties, it is often necessary to include residential properties, either because they dominate the property ownership in the community and are necessary to meet area- and volume-based goals, or because the public requests it. The latter was the case in Kitchener, Ontario, which originally targeted its Stormwater Credits program to nonresidential properties, but expanded it to include residential in response to a local movement. Targeting can happen across multiple variables, as well. In Durham, North Carolina, the Rain Catchers program began in a pilot neighborhood that was chosen based on its impact on the watershed, primary home tenure (primarily long-term homeowners), presence of robust neighborhood associations, a socioeconomically diverse population, and clustered properties for easy materials staging. Behavioral economics research on rain barrel incentive programs has shown that residents are more likely to have rain barrels installed if they are located close to a pickup site, if their neighborhood has been the target of an awareness campaign around hydrological functions, and if they own the home they occupy (Ando and Freitas, 2011). While programs can be designed to target, there are a number of factors that may limit the pool of qualified applicants based on various demographic considerations, intentionally or unintentionally. Many programs have minimum thresholds for project size, such as Milwaukee’s $5,000 or New York City’s $35,000 minimums. Local agencies set these minimums based on cost-effectiveness and impact on agency goals, but high minimum project costs also places a barrier on lower income and smaller property sizes. Glenview, Ill.’s cost-share program delineates a specific menu of fairly expensive stormwater interventions and pays 50 percent of the cost. This works in a generally higher-income community, but would not necessarily work for lower-income residents within that community or lower-income communities in general.

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Even for programs that are available community-wide, prioritizing critical areas or property types can still be done through targeted messaging and outreach. In a study of water conservation incentive programs, Thompson and Stoutemyer found that in upper/middle class areas, no significant change in water use was seen as a result of educational materials provided, but in lower/middle class areas, there was a decrease in water use, suggesting that different strategies are necessary for different types of demographics (1991). In a study on energy efficiency incentives, Stern, et al. found that homeowners are more interested in the “intangible benefits” of investment in energy efficient infrastructure, such as their sense of personal obligation, social pressure, and appearance when choosing to invest in energy efficient infrastructure (1986). In a study specific to stormwater incentives, Londoño Cadavid found that residents were not as responsive to messaging about flood risk benefits as they were to environmental benefits in general. People were willing to both pay and help for both benefits, but flood reduction was lower and depended on previous flood experience, and like with Thompson and Stoutemyer’s research, lower income groups showed more responsiveness to outreach and willingness to do both pay and help than higher income groups (2013). All of this suggests that based on the motivations of various potential applicants, stormwater incentive programs may not be best served being advertised as linked to stormwater or flooding benefits, rather homeowners are responsive to broader environmental benefits or perceived personal benefits. This was the case in the Metropolitan Planning Council’s Milwaukee Avenue Green Development Corridor GI grant program in Chicago, which faced little program participation for the first phase of the program’s existence. It was not until the program was advertised as a landscaping improvement program with “green” benefits, rather than specifically a stormwater management program, that more eligible property owners became interested. Glenview’s program is a case where solutions advertised as specific to addressing flooding works, as they tend to responsively market the program directly to properties that have flood experience. Many programs express a desire to do more targeting through outreach to improve participation numbers, enhance the application pool to allow for higher quality projects, and improve awareness goals by broadening participation. Philadelphia’s SMIP program does targeted outreach through its partner organizations, but it intends to do more. Montgomery County wants to expand its program demographics and is adopting the mantra of “inviting participation” in response to people who feel shut out without enough knowledge about the program and stormwater issues, by trying to broaden participation via translating materials into other languages, having a presence at fun community events, such as runs and bike events, and connecting directly with faith-based organizations. Many programs expressed interest in trying to improve outreach to homeowners’ associations, property managers, and renters. Regardless of the targeting type, many programs include a screening phase that allows local agencies to determine the effectiveness of the individual projects on contributing to the program’s overarching goal before moving forward. In many programs, particularly in St. Paul and Montgomery County, the first screen includes a site visit to decide whether the property is eligible based on site considerations, with a second phase of application review once the property owner knows what’s possible on their property and can make an informed plan. A similar screening process in Philadelphia’s Rain Check found that ten percent of properties that went through the screen didn’t qualify for any tools, allowing the local agency to focus on applications

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that have some possibility of success and allowing the property owner to avoid having to go through an onerous application process. Elements of Program Design: Types of Interventions The most successful programs have gone through some level of assessment of the types of stormwater interventions or best management practices (BMPs) that are both the most appropriate for local landscapes and the most cost-effective for the local agency. It’s important to look at both site appropriateness and cost-effectiveness, as they do not always align. That said, based on the goal of the program, strict cost-effectiveness should not be the only consideration; what is cost-effective for the local agency may not be what is cost-effective for the property owner. For example, interventions that are inexpensive for the property owner may provide educational benefits not calculated in a strict cost-effectiveness assessment or BMPs cost-effective for the local agency might be too onerous for property owners to maintain. By going through this assessment, local agencies can limit the eligible BMPs in their program to those that are more likely to be successful and worth investment. Montgomery County developed BMP prioritization based on a very simple assessment of various interventions (Table 2). This chart, which is available to potential applicants in outreach materials, rates the menu of BMPs specific to the RainScapes program based on their stormwater volume storage ability, the level of effort required to maintain them, and their cost, and then ranks them based on the balance of those three variables. By doing this basic assessment and providing the information to applicants, the program helps direct applicants to the most appropriate techniques. They have also used this assessment, in addition to the number of co-benefits to determine the rebate amounts. Table 2: Simple effectiveness assessment of different BMPs in RainScapes program. Source: Montgomery County RainScapes Technique Planning Guidance

For many programs, particularly those with stormwater volume goals, performance-based targets, rather than prescriptive menus of BMPs make more sense. In these programs,

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requirements to meet numeric targets are paired with a site assessment to identify the suite of BMPs that work best for that specific property. This is essentially looking into cost-effectiveness and site conditions at the property scale and requires more work on the part of the local agency, as projects must be reviewed on a case-by-case basis, but can lead to more reliable results. In New York, projects are required to manage 1-inch of rain rather than use specific BMPs. In that case, applicants don’t get preference for interventions that manage more than 1-inch because the 1-inch standard covers roughly 90 percent of rain events, allowing the program to focus investment on what’s actually needed and not incentivizing over-sized projects. In Philadelphia, projects are selected based on greened acres, a measurement serving as proxy for stormwater volume as part of Philadelphia’s regulatory requirements. Cost-effectiveness assessments can also identify minimum project sizes or costs necessary to be worthwhile and identify project types to exclude completely. Programs in St. Paul, Milwaukee, and New York City all set minimum project cost thresholds. In Raleigh’s Stormwater Quality Cost Share program, they do not set a minimum project cost, but because of the requirements of the program, projects rarely cost less than $15,000, essentially creating a minimum threshold. In D.C., the cost-effectiveness of specific BMPs resulted in a minimum size threshold of 120 square feet for pervious pavers, a maximum of two rain barrels, and no minimum on shade trees. Another consideration for the selection of available stormwater interventions is the difference in acceptance based on different demographics. From the interviews, some programs found that foreign-born populations were more receptive to certain BMPs, such as water harvesting, over others, such as non-food producing ornamental gardens. College-educated, middle-aged people tended to dominate programs, unless otherwise targeted, likely based on their access to money, their physical fitness and energy, and their desire for property they own to be successful. Some interventions bring up specific concerns beyond cost-effectiveness and site appropriateness. For example, green roofs are not a commonly incentivized technique, largely based on the high cost of installation due to the level of technicality necessary for design. That level of technicality also presented a barrier in some programs, such as the Milwaukee Avenue Green Development Corridor, for property owners concerned about code compliance issues during inspections as part of the municipal permitting process. Rain gardens are a very common option in stormwater incentive programs. While they tend to be more approachable solutions for property owners, depending on the program’s goals, there are a number of concerns about their efficacy. For programs dependent on long-term stormwater storage, there are concerns about percolation of water through varying soil types, and failure of gardens overtime if they lack underdrains or are not well maintained. In some cases, because of soil types or topography, shallower, but wider turf replacement with conservation landscape can be more effective than deeper, but smaller rain gardens. For programs less concerned about long-term stormwater management, workarounds have been built into programs, such as creating rough rain garden layout templates and plant suggestions to guide property owners. In Glenview, the specifications for rain gardens are purposely over-designed so that even if they are not well-maintained, some retention in the amended soil will remain. If outreach and education is done correctly, however, rain gardens can be successful when property owners find them to be an amenity and as a result invest in taking care of them.

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The stormwater intervention most frequently discussed in the literature and in the scan of programs is rain barrels. On its face, a rain barrel is not a particularly bad intervention, it is a fairly simple and standard concept and relatively easy for local agencies to obtain and distribute. However, for programs with stormwater volume control goals, rain barrels are not a robust solution. Typical rain barrels are roughly 55-gallon drums, one of which is not enough to hold the water off of a typical roof in a half-inch storm, requiring either more barrels to be installed or larger ones. Because of the locations of downspouts and the need to keep barrels away from the foundations of a house, there are limited opportunities for ideal placement of barrels, let alone multiples of them. Additionally, in order to be functional storage, they must be emptied before each storm, which can be labor intensive or impractical. The ease with which they can be distributed can also be a detriment, as easy distribution may mean little to no follow up to ensure that barrels have been installed and done so correctly. Reports of barrels being sold or given away or left uninstalled in backyards were common for many programs. Most large, professional programs choose not to focus effort and money on rain barrels. While few studies have examined whether rain barrel programs can act as a catalyst for changing behavioral practices, Bakacs, et al., assessed the educational impacts of a rain barrel program through a survey mechanism with mixed results. They found that rain barrels do encourage interest in, though not always adoption of, other stormwater interventions, providing the “gateway drug” effect referenced by several program managers. They also found that the educational benefits of rain barrel incentive programs are more substantial if paired with more technical advice, as participants tended to already have a basic knowledge and that participants were more likely to use them for water reuse, rather than stormwater mitigation purposes (2013). Ultimately, many robust programs include rain barrels as an add-on service or an educational tool. The implications are more important for smaller programs, many of which focus solely on rain barrel incentive programs. If these programs have stormwater volume goals, rain barrels are not an appropriate way to meet those goals. If the program is solely an educational one, then care must be taken to design the program in such a way that education on stormwater in general, other more effective interventions, and other co-benefits are emphasized to maximize the educational benefit. Elements of Program Design: Project Selection The process for selecting which properties are able to ultimately take part in the incentive program varies across programs. Some, such as Elkhart County’s Rain Barrel and Rain Garden Incentive Program and the Milwaukee Avenue Green Development Corridor, require as an initial step in the application process attendance at a workshop. After that, many programs have a formal pre-application or other informal inquiry process to help potential applicants determine whether they are eligible for the program, and if so, for what types of projects. Because of the difficulty of the application process for many of these programs, most programs provide assistance to applicants at this point in the process. For many, including Durham, Elkhart County, Glenview, and Montgomery County, a site visit to do an audit or assessment of the property and recommend interventions specific to the property is critical for ensuring that both the property owner and the local agency get the best project possible. Montgomery County made a specific program change to remove the design plan requirement from the pre-application and conduct a site visit early on because it was too much of a technical barrier. Once in the project design phase, some programs require applicants to hire outside consultants, engineers, or landscape designers; others provide assistance directly or through nonprofit partners; others do

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not require third party assistance, but suggest approved or certified partners. Only the most basic programs, often rain barrel programs, do not require upfront designs. The intensity of application review generally mirrors the complexity of the application process. Just as many programs require applicants have certain experts on their application teams, the programs themselves often have a range of experts on their review panels. New York City’s review committee includes staff, engineers, and lawyers. Philadelphia’s SMIP applications are reviewed by a team of engineers and landscape designers who determine feasibility through computerized modeling. In Raleigh, engineers, developers, environmental group representatives, and others review applications. Some programs have specific application review criteria. Milwaukee’s review panel checks for five requirements: 1) the capacity of the applicant to follow through with the project; 2) a minimum project threshold of $5,000; 3) volume of water managed; 4) the public educational benefit, including project visibility; and, 5) workforce development opportunity. Philadelphia’s SMIP program gives additional consideration to projects that improve the public right-of-way, integrate with other utility-led projects, or include educational or publicly visible components. Elements of Program Design: Maintenance Long-term maintenance of distributed stormwater interventions, particularly GI, is one of the most pressing questions in stormwater policy. In private property incentive programs, conducting and paying for maintenance often falls on the private property owner. For distributed GI to perform as reliably as typical grey infrastructure, it needs to be maintained. Mechanisms for teaching property owners how to do maintenance, financing them to do it, and following up to ensure that it occurs and occurs correctly are rarely included in stormwater incentive programs. Maintenance is typically not included as an allowable expense through an incentive program, which means additional cost for property owners that is one more disincentive to participation. The various mechanisms that do exist to ensure regular maintenance add legal complexity to already complex public-private arrangements. For incentive programs linked to a stormwater utility fee or other user fee, it’s especially important to have maintenance and inspection plans to ensure that projects continue to qualify for credit and discount as they are renewed over time. Maintenance requirements are generally paired with a range of inspection regimes. In some communities, such as Kitchener, Raleigh, and New York City, program participants are required to submit quarterly, annual or other regular reports, to report on the upkeep of the project. Other programs require regular independent or self-certification of the BMP. In D.C. and Montgomery County, property owners need only sign a simple property owner agreement or acknowledgement of receipt of public funds, which include only minimal, voluntary maintenance requirements, but inspections can be conducted every three to five years. In Raleigh, program participants decide whether they are willing to sign on to either a five- or ten-year maintenance agreement, which dictates the size of their reimbursement (50 and 75 percent, respectively). On the more formalized end, New York City’s program requires properties all to have restrictive covenants, which is meant to ensure maintenance even as properties change hands over time, and Philadelphia’s SMIP program requires strict, individualized maintenance guidelines over a 45 year period, restrictive covenants, and inspections every three years. In Durham, stormwater interventions were offered free, but acceptance required an easement on the property, which surprisingly people were not opposed to, as long as it meant that someone else

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was dealing with the long-term monitoring and maintenance of the BMP. Most of the large, professionalized programs state that they will conduct regular inspections; however, many of those admit to not having the staff capacity to keep up with regular inspection regimes, able only to respond to complaints, rather than do proactive or wholesale inspections. Milwaukee has been one of the few to establish a regular inspection process, training interns each year to inspect projects using a standardized checklist. There’s a need to strike a balance between the long-term effectiveness of stormwater interventions versus increasing barriers to participation in incentive programs. The more legal encumbrances or costly requirements for maintenance attached to an incentive, the less attractive the incentive becomes. While maintenance is especially important for programs with stormwater goals, requirements can be less burdensome for education-oriented programs for which stormwater volume management is less critical. That said, poorly installed or performing stormwater interventions, even if only meant for educational purposes, can backfire and cause distrust in the overall concept, as was seen in the case of Seattle and poorly performing rain gardens in the Ballard neighborhood, as well as countless stories of poorly disconnected downspouts that resulted in flooding of own or adjacent properties. Elements of Program Design: Data Collection, Monitoring, and Project Tracking Data collection is useful both as a mean of tracking the program’s progress toward goals, particularly regulatory requirements, as well as for evaluating the program as a whole. For programs that have stormwater priorities, including numerical targets for volume reduction or water quality, release rates, and others, goals are relatively straightforward to monitor and quantify on their face. Despite that, most individual projects are not monitored. Reasons include projects that are too small to cost-effectively install flow or volume monitors; lack of baseline data for the property before the stormwater intervention; additional cost for monitoring equipment in general; funding sources do not allow funds to be used for monitoring; regulatory compliance requirements do not mandate data collection; or program managers just didn’t think to monitor projects. On the positive end, New York’s program has very strict criteria and strong data collection components built in, including volume managed, cost-effectiveness, and efficiency. More often, programs, such as the cost-share program in Glenview, track participants, but don’t do any follow up surveys or maintenance agreements, and submit this information to the U.S. EPA without a requirement to submit more data than that. Education and awareness goals are harder to quantify. Education results are particularly pertinent when paired with an initiative like rolling out a stormwater utility fee. The simplest means of tracking the success of awareness efforts is by comparing overall counts of outreach compared to actual program participation. Surveys are the primary means of assessing educational impact of incentive programs. Philadelphia’s Rain Check program collects both pre- and post-intervention surveys to track their education goals. St. Paul collects metrics for both stormwater (total drainage area proposed and source of managed runoff), as well as for education (publicly visible, education component), and will conduct surveys to evaluate educational impacts. Overall, programs examined did little robust stormwater volume monitoring of individual projects, and even fewer collected data on educational outcomes, making it difficult for programs to be tracked with certainty for the purpose of program evaluation or comparative analysis.

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Elements of Program Design: Program Evaluation and Iterative Program Design Although few of even the most successful programs that exist collect extensive program evaluation data and those that do don’t collect consistent enough data for comparison, those programs that do even informal program evaluation gain tremendously from the exercise. Almost all of the most successful programs went through iterative design processes or an initial pilot phase to test out strategies and responsively adjust program design. Because of the still changing nature of the stormwater management field, successful programs cannot be static, but should be reflective and responsive. Part of this iterative process includes having multiple touch-points for property owners to interact with local agency program managers, incorporating feedback loops into the program process, and keeping in direct contact with program participants. For example, Milwaukee’s Green Infrastructure Partnership Program went through several iterations over its 12 years. It saw early on that rain gardens without maintenance agreements eventually became non-functional, so they added that in; they strengthened evaluation of projects to better calculate stormwater gallons managed; they added the social goals of workforce development and public awareness into the structure of their program; and they’re still working to figure out how to better track and evaluate public awareness impacts. In Philadelphia’s Rain Check program, they began by piloting the program first in ten CSO neighborhoods, then opened it to all neighborhoods; they collect data on both project applicants and actual participants to improve program, such as identifying ways to make popular downspout planters more cost-effective; they have incorporated ways to better involve residents, conduct more robust inspections, and shorten the application and installation processes. In Raleigh’s Stormwater Quality Cost Share program, they determined quickly that their stormwater fee credit wasn’t a large enough incentive to encourage private property participation in GI, so they switched their program to a cost-share program. In New York City, program managers evaluated the program by surveying the selected applicants, the applicants who were not-selected, as well as those who inquired into the program, but never applied, to identify ways to improve the application and success rates of the program. Montgomery County, Maryland’s RainScapes program went through several changes, including changing the target boundaries for their targeted neighborhood program and adjusting the incentive amounts for its rebate program based on property owner feedback through surveys. They also changed the process for applying to their program, noting that requiring property owners to create a plan before having a staff member visit the site was too onerous. Before D.C.’s RiverSmart Homes program, the local agency did a willingness-to-pay study and identified that D.C. residents would be willing to pay ten percent of any stormwater BMP on their property. As a result, D.C. structured the fee system for the RiverSmart Homes program on that study and has applied for additional funding to robustly evaluate their program. The extent to which most of the programs examined assess the success of their own programs overall is based on participation rates. Some programs measure by stormwater volume managed, others by number of projects, dollars spent, or acres improved. In the end most are only counting these participation numbers, not necessarily comparing them to cost per gallon managed or cost

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compared to stormwater interventions installed through means other than voluntary incentives. While this is an imperfect way of evaluating programs, it is not without precedent, as Stern, et al. found that early in the life of energy efficiency incentive programs, it was too difficult to track impact at the household scale and identified rate of participation as an appropriate index for program effectiveness in the case of grant and loan programs (1986). Are Incentives Actually Incentivizing? Barriers to Participation In a study of voluntary recycling programs, Ando and Gosselin found that the differences in recycling behavior between multifamily and single-family dwellings are largely attributable to convenience (2005). For private property incentive programs, anything that can be perceived as an inconvenience for property owners would likely be a barrier to participation. A natural extension of inconvenience as a barrier is a high administrative burden, including onerous bureaucratic, legal, or reporting requirements. If the property owner is required to consult with an outside expert for any part of the process (application, design, installation, maintenance, reporting), it presents both an administrative and financial burden on the potential applicant. Contrary to what advocates in the land conservation world promote, Sorice, et al. found that landowners were adverse to permanent easement and long-term contracts, a lesson that can be applied to stormwater, as seen in the case of New York’s narrow applicant pool (2013). In the Milwaukee Avenue Green Development Corridor, the program was targeted at both commercial and residential properties, but all private property applicants were residential. For the commercial properties owners that were interested, they faced problems of upfront costs (originally addressed by partnering with a community investment fund to provide low-interest loans); lack of space on their tight urban lots to install substantive interventions; and, concerns about code compliance issues when applying for permits. The technical or design requirements for interventions built through an incentive system can play a large role in whether the incentive works or not. If the requirements are perceived to be too high or higher than the benefit, whether that is actual, in the form of a stormwater fee credit, or perceived, in terms of environmental benefit, the incentive does not work. Stormwater utility fees are not in and of themselves incentives for private property retrofits and incentivizing private property action is not the driving force for them. Generally, stormwater utilities are created for dedicated revenue generation (Campbell, 2013; WEF, 2013). Doll and Lindsey’s research began to assess stormwater utility fee credit programs and the variables that affect their effectiveness (1998). Generally the fees are not high enough to incentivize on their own, as was found in Kitchener, Ontario and Raleigh. Many of the stormwater incentive programs examined, whether linked to a fee credit or not, were found to have high technical barriers, making it difficult for property owners to apply on their own versus hiring professionals. Sorice, et al. found that in a habitat conservation incentive program, there were three types of reactions to the incentive program: those with strong positive feelings, those with weakly positive feelings, and those with negative feelings. Landowners with weakly positive feelings towards the incentive program, i.e., the fence sitters most likely to be swayed by an incentive program, had the strongest preferences for high levels of technical assistance in designing and implementing the project (2011). On top of the administrative and technical burdens is the barrier of high costs of participation. Between upfront costs for planning, design and application, the financial and construction

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inconvenience of installation, and uncertain costs of long-term maintenance, the incentive would need to be very large to overcome the costs and skepticism about potential results. Lack of awareness of the need for stormwater interventions in general, and the local agency’s incentive program in particular are more basic barriers to success. Property owners often lack specific information or confidence on what to do as the best solutions. This can be partially addressed by conducting site assessments that result in specific recommendations, but even then, not all property owners who get assessments enact the recommendations. Are Incentives Actually Incentivizing? Preaching to the Choir versus Converting Skeptics Throughout this research, it was repeated by nearly all programs examined that even some of the most successful programs were only successful at incentivizing those who might have already been inclined to act (those who already want to do it) or were sitting on the fence (those that need just a bit of a push to do it), as opposed to converting people who had no knowledge of these types of stormwater interventions, or even more extreme, were reluctant or skeptical of these interventions. Programs reported testimonials provided in which participants indicate that the incentives were helpful, but they would have likely made the improvements anyway. Many programs deliberately focused on those property owners who were already interested and self-selected by seeking out the program, rather than trying to convince those who weren’t voluntarily interested. In one case, the goal of the program was ultimately a “feel good” effort to reward good work that had already been done, rather than to incentivize new change. In one study, Fletcher, et al., used a uniform price auction pilot to determine homeowner willingness to pay, but found that while the pilot was deemed a success, the benefit received by the homeowners was not substantial enough to truly incentivize stormwater reduction behavior (2011). Furthermore, the high cost of participation and low return on investment, particularly for stormwater utility fee credits, but even more so for programs that do not charge for stormwater services, yields unconvincing payback periods, which do not incentivize property owners to invest, or even third party private entities who might play a role in financing. Ultimately, it is unclear that the wins attributed to stormwater incentive programs should be cited as successes. There is evidence that some incentive programs may not be any better than straightforward education programs to incentivize behavior change for stormwater. In a study by Green, et al. focused on the role of human, social, and cultural capital in dispersing information about stormwater solutions, they found statistically significant indications that neighbors have a positive influence on adjacent property owners’ likelihood of adopting stormwater solutions. They concluded that investments in human capital (that is, education) may be just as effective if not more so than financial or physical (infrastructural) investments in inducing stormwater management participation (2012). A study by Larson, Caldwell, and Cloninger used a survey to assess the use of stormwater remediation fees to induce private property stormwater BMP adoption and found that financial incentives alone have a low potential to initiate a high level of participation from residents to put in BMP practices on their properties (2014). And a study by Thurston, et al., found that in a willingness-to-accept model, 55 percent of the bids were $0, indicating that if local agencies wanted to pay for and install stormwater interventions on private property, they would not have to pay more than the costs of the installation to induce participation, which may indicate that this “payment for ecosystem services” type of model is not much more effective than education (2010; Fletcher, et al., 2011).

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Which is all to say that despite the nominal success of individual grant, rebate, fee credit programs and more, it is not clear that these incentive programs are actually incentivizing. It is not that the incentives do not work at all, but that the way these programs are designed may be capturing only those who were likely to have done something on their own or through more straightforward means, such as education. Current programs need to be designed with more program evaluation and tracking to truly determine whether skeptics are converted. Those designing or improving programs in the future should keep in mind the expense spent on incentives that only reach those who would have done interventions anyway. Technical Assistance: One-on-One Contact All hope is not lost, however, when it comes to the role of private properties in stormwater management. One of the most promising aspects of many of both first and second tier stormwater incentive programs is the role of one-on-one contact and technical assistance. Repeatedly as program managers described their programs, they emphasized the importance of personal relationships. Particularly clear for programs that changed their structure to include this, one-on-one contact with property owners improved awareness of the problems and potential solutions, increased the likelihood of program participation, and led to stronger applications and projects overall. This one-on-one contact could be done by local agency staff or by third party contractors, nonprofits, or vendors and still have the benefit. As found in programs such as D.C.’s RiverSmart Homes, The Conservation Foundation’s Conservation@Home, and many others, individualized participation in the co-creation of a solution produced buy-in to the concept, rather than just receiving something wholesale from the local agency. It encouraged a sense of ownership in the project and improved outreach, as programs were spread by word of mouth. Local agencies do not all understand or acknowledge the importance of direct contact with property owners, however, for most, they do not do it because of lack of capacity, especially for smaller agencies without dedicated staff or official mandates. The critical component of this one-on-one contact is the property or site assessment. Since one of the most basic barriers to participation is property owners’ lack of knowledge on what solution is best and solutions cannot be one-size fits all, individual site assessments and recommendations that come out of those are critical for a successful project. For programs that did some sort of property assessment, such as those in Philadelphia, D.C., Raleigh, Glenview, and the Conservation Foundation, the ability to tailor recommendations in more cost-effective ways toward specific goals, get to know property owners and understand their level of interest and knowledge, and professionalize the project applications upfront made for more successful projects. That personal interaction is what is more likely to convert those ignorant about stormwater interventions and the skeptics, as their specific concerns and priorities can be addressed directly. And the site assessment aspect of these programs does not necessarily have to be part of an incentive program, as some, such as Elevate Energy’s Wetrofit program, as well as many private contractors are finding. At least for those with the financial means to invest, once property owners know what would work best on their properties for their problems, they will often move ahead on their own. If those who would have done interventions otherwise are left to do it on their own, resources would be freed up to focus on those who do not have the capacity to act on their own, but do have a need. Technical Assistance: Barriers for Local Agencies

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Public agencies are chronically underfunded and under capacity, especially those that deal with stormwater, which are often times add-on responsibilities to wastewater, public works, counties, or other entities that do not have a dedicated charge to handle stormwater. Inadequate staffing and financing are constant barriers for local agencies. Ultimately the staff capacity issue, whether number of staff or skill sets, can be addressed once the financing issue is addressed. One of the biggest benefits of stormwater incentive programs connected to a stormwater utility fee or other user-based fee is a dedicated revenue stream, building longevity and sustainability into the program design. One of the best examples of this is Montgomery County’s RainScapes suite of programs, which includes outreach, workshops, site assessments and recommendations, application assistance and review, inspections, maintenance, and tracking done mostly by dedicated staff, of which they have four full time plus one 80 percent administrative staff member. The RainScapes program is funded by the Water Quality Protection Charge and is part of the County’s property taxes, with an annual budget of $385,000 per year, not including staff time or IT support for their robust database and mobile technologies. Funding constraints have largely to do with the source of funding for stormwater for the local agency. For agencies without the benefit of a dedicated revenue stream via a user-based fee, there are a number of other sources with their own limitations. One issue is the question of capital costs versus operating costs. In New York, they cannot fund educational programs or signage because the program is funded through capital dollars, limiting them to pay only for design and construction costs, no soft costs, such as outreach or ongoing maintenance. D.C.’s successful program has been funded by a number of sources, including a municipal plastic bag fee, the regional restoration fund, foundation grants, and federal stimulus dollars. While they have been successful with the program and funding it to this point, it does not have a sustained, long-term revenue source. Many other programs, particularly in smaller communities, are funded or supplied by regional, state, and federal sources. Interestingly, the Milwaukee Metropolitan Sewerage District, a regional wastewater and stormwater entity, found that funding its member municipalities to run their own programs didn’t provide as positive of results as funding directly to the property owners. Many communities are experimenting with leveraging private sources of money to fund programs, but none have done so in any substantive way to fund stormwater interventions on private properties. Technical Assistance: The Role of Third Party Entities As the importance of one-on-one contact and technical assistance to the success of private property stormwater interventions is clear, third party entities—be they nonprofit partners, local community groups, or private contractors and consultants—play a large role implementing programs. They can specialize in particular topics, geographic areas, or parts of the process chain in ways local agencies cannot. They can build local relationships focus on property owner goals, rather than having to worry about regulatory mandates. They have more flexible, less bureaucratic processes that allow for faster timelines for getting and executing on contracts. They have more freedom and flexibility to experiment with innovative techniques. For the outreach component of these programs, strong neighborhood groups or local nonprofits can help with outreach and provide an ear to the ground that helps identify opportunities for potential applicants, as well as concerns with existing programs. Seattle uses its nonprofit, local Stewardship Partners to go door-to-door to advertise their Rain Wise program.

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Nonprofit partners can not only assist with outreach, but can also conduct the pre-application property assessments and provide recommendations to potential applicants. Chicago groups like The Conservation Foundation, Elevate Energy’s Wetrofit service, and the nonprofit partners in Philadelphia, Kitchener, and D.C.’s programs provide free or low-cost assessments of private properties, make recommendations on actions, and sometimes go so far as to help with planning and design or recommend contractors. In these cases, the nonprofits are often subcontracted by the local agency to conduct these on the agency’s behalf as part of the incentive program. This same role is also played by private contractors and landscape architects. In Glenview, the municipality was able to negotiate a reduced price for site assessments with a private engineering firm, the benefits of which they shared with property owners through their cost-share incentive program. In the Milwaukee Avenue Green Development Corridor program, it was not until third party landscape architects became the champions for the program and assisted property owners with completing complicated paperwork that applications started coming in. In this case and in similar ones, it was not necessarily one firm hired by the local agency, but rather individual consultants that understood the business development benefits of understanding and advertising the local agency’s incentive program. Not only do these private entities conduct site assessments, but they are generally also the ones hired to do the installations of the stormwater interventions. Some programs contract with specific contractors to do the work, but for the most part, local agencies, such as those in Seattle, D.C., Philadelphia, and Montgomery County, develop some sort of certification or approval process through which they can impart to contractors their messaging, goals, and requirements in return for recommended status for applicants to contract with directly. In some cases, the incentive benefits go directly to the third party rather than passing through the property owner. Philadelphia is just beginning to identify the job creation implications of the burgeoning responsibilities and opportunities for third party entities. Similar efforts to get local agencies to hire, mobilize, and train local job corps, either through nonprofits or private entities, to go door-to-door to provide personalized recommendations are happening in the energy efficiency field in the US and in water efficiency in the United Kingdom (US DOE, 2014; Burton, 2013). Recognizing that technical assistance and education may be more important than financial incentives to motivate meaningful action by private property owners, future investment in job creation related to enhancing technical assistance and education, rather than continuing to subsidize projects that may have been done without an incentive, would be a big opportunity for improvement in continuing maturity of stormwater incentive programs. CONCLUSIONS As public dollars continue to go into the addressing the growing problem of stormwater management and as those investments increasingly need to be put into motivating private property owners to be part of the solution, tools are needed to ensure that the money and attention being spent are done so wisely and effectively. Larger cities throughout the US are integrating large, professionalized stormwater incentivize programs into their arsenal of ways to address stormwater, largely prompted by legal and regulatory action imposed upon them. An increasing number of communities are identifying dedicated ways to fund stormwater

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management through user-based fees. More and more smaller communities are identifying the need to engage community members into being part of the stormwater solution alongside their local governments. As more and more communities identify incentives as a necessary way to encourage this collaborative means of addressing stormwater, there are several lessons to be learned to improve both existing incentive programs and inform the creation of new ones. This research seeks to address the fact that there does not exist a compendium of lessons learned from existing programs that can be applied to the creation or improvement of other programs. It also seeks to assess those existing programs to comparatively determine their effectiveness, identify the variables that affect success, and establish more nuanced ways of approaching private property stormwater solutions. As local agencies continue to develop and refine these types of programs, key tensions exist that must be considered. The first is the robustness of an incentive program as a technical solution to stormwater problems versus the need for widespread participation in and support for stormwater investments. For stormwater interventions on private properties, such as GI, to be invested in and relied upon as effective stormwater solutions, they need to be designed and maintained in such a way that their reliability over time can be guaranteed; however, to increase participation and buy-in from as many property owners as possible, barriers to entry must be lowered to make it easier to participate. Similarly, for stormwater incentive programs to be cost-effective tools to holistic stormwater management, they must be targeted to key areas and tailored to fit specific site conditions; however, the need for widespread buy-in into these types of public investments and the difficulty of applying different approaches to different areas makes it difficult to focus investments cost-effectively. Most programs are far from being able to measure their cost-effectiveness through metrics such as cost per project, cost per gallon managed, or program cost compared to intervention cost. Ultimately, the question is whether stormwater professionals and advocates are still at the point of needing to continue maximizing participation by willing participants or whether it is time to start focusing on converting unwilling or unfamiliar participants. It is not clear from programs that exist whether stormwater incentive programs as they are generally structured are actually incentivizing—encouraging stormwater practices on private properties that wouldn’t have happened anyway. If programs are not truly incentivizing, what ultimately are the benefits of investing in these types of programs? It may be the case that momentum, particularly in communities that have already adopted incentive programs, are at the point that the general public can be left to identify private property solutions on their own or guided by third parties and investments that have to this point gone to incentive mechanisms could be reduced and channeled to something else, such as focusing on lower-cost, but higher-impact education and awareness programs, facilitating more one-on-one assessments overall, and targeting more resources to lower-capacity property owners with the most need for intervention. Whereas in smaller communities that are not as familiar with private property stormwater interventions, there may still be a need to develop incentive programs, even if not ultimately cost-effective, as a means for gaining broader acceptance and furthering the cause; but, which can be designed in more informed and nuanced ways based on the lessons learned from others. An important way to integrate private property stormwater interventions into the broader suite of tools to address stormwater is to simultaneously ensure that people who have the means and motivation to do something on their own are given the tools and support to do so in ways that are

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productive and helpful, while simultaneously targeting those who would not know or want to be part of the solution and convincing them to participate. One of the biggest opportunities to address this for improvement of stormwater incentive programs, but also the field of stormwater management overall, is to emphasize the importance of one-on-one contact, and to do so in such a way that develops and relies upon the efforts of third parties, whether they be local community groups, environmentally or socially focused nonprofits, or market-driven private entrepreneurs. This requires local policies that lower the barrier for those who would be inclined to do something on their own, such as streamlined permitting processes, consistent ordinances, and support and guidance for third parties who want to market stormwater solutions on their own. This research is continuing on to additional phases of work. To continue the analysis of the national scan of incentive programs, there will be further assessment and comparison of the programs. From the case studies, hypothetical scenarios will be developed and put through an assessment process, which will be used to underpin more specific recommendations on incentive program design. Specifically in the Chicago region, there will be a baseline scan of all local incentive programs to identify how advanced the region’s local stormwater programs are. Lessons from this research can be applied locally by 1) identifying how local programs compare to national models; 2) identifying areas that do not have, but need or want incentive programs and providing recommendations from this research; and, 3) identifying those that are actively considering a program or struggling with a current one to provide them with assistance based on the research. As a timely application of the research, lessons could be applied to advise the Metropolitan Water Reclamation District of Greater Chicago (MWRD) on how to design their management of a massive rain barrel distribution program to improve outcomes for both MWRD and their local municipal partners. Because of how young stormwater incentive programs are relative to other incentive programs, a lot of future research is necessary to continue assessing the success of programs, both deeply within specific programs and broadly across all of them. Overall, more attention paid to program evaluation is necessary to truly identify whether incentives are effective above and beyond educational efforts and one-on-one technical assistance. Additionally, as more attention is paid to partnering with the private sector to fund infrastructure investments, research into how the many, but disparate, external benefits of GI and other private stormwater investments can best be captured and harnessed to increase investment, including by private investors. In the Chicago region, one of the most pressing needs is a cost-effectiveness assessment of the various stormwater interventions and incentive mechanisms, as other local agencies have done in the development and refinement of their incentive programs. The next phase of this research further assessing existing programs will lay the groundwork for conducting this type of analysis, but the hard data is still necessary. It would need to compare both program type and intervention type variables, as well as enumerate the costs to a local agency to run a stormwater incentive program—from site visits and outreach to monitoring and reporting—as well as the costs to individual property owners—including time and financial investment. All of this would need to be compared to the improvements gained from the incentive program—from reduction in stormwater treatment to the reduction in both private and public impacts of flooding to non-stormwater co-benefits.

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ACKNOWLEDGEMENTS The authors gratefully acknowledges the staff of the incentive programs included in this research for being pioneers in the development of these programs and providing their insights into how to improve them. We also acknowledge the assistance of several individuals who helped inform the research, including: Metropolitan Planning Council (MPC) colleague, Mandy Burrell Booth, and research assistants, Jamie Makatche, Rachel Carnahan, Stephanie Strauss, and Marcella Bondie; University of Chicago research partner Sabina Shaikh, and research assistants Clare Everts, Alex Murray, Jamie Manley, Fabiola Villa, Evaline Bai, David Guo, Donna Chen, Joseph Kim, and Adrian Carlsson; MPC stormwater advisors Aaron Koch, Margaret Schneemann, Bob Newport, Chris Burke, Pete Mulvaney, John Murray, Lois Vitt Sale, Mark Willobee, Jim Mann, Mike Thomas, Molly Flanagan, Tom Price, Nora Beck, Jim Yurik, John Watson, Ylda Capriccioso, and Ed Chandler; and, Aaron Burton. REFERENCES Ando, A.W. (2011). Next Generation Stormwater Management: Benefits, Costs, and Policy. RFF

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