Sunday, January 2, 2011

Low Impact Development– Policy Memo

Summary of Problems
              On 14 July 2010, a flood struck Somerville, inundating public safety buildings, two schools, and the Central Library with raw sewage and rainwater; it caused 10 million dollars of damage (Byrne 2010). Yet, it was not the only flood this year. Most parts of our sewage system date back a century ago, when Somerville still had plenty of natural lands for rainwater infiltration. Today, with 78% of impervious surface, this city has become one of the most heavily urbanized cities in the U.S.; our stormwater infrastructure has been long overwhelmed. The combined sewer overflow (CSO) problem, which directly exposes people to sewage, is threatening our public health and safety. We have to take action now.
              There are several alternatives. If we are not concerned of cost, we can make extensive expansion of our sewer capacity, which is likely to be a several-hundred-million project[1]. We can also carry out a bunch of small sewer separation projects as we did in Baffle Manhole Separation project, which cost us about $400,000 but proved trivial effectiveness (Massachusetts Water Resources Authority 2009). I propose that we spend money more wisely by investing on the more resilient Low Impact Development (LID) practices to fight flood from its source – the 78% impervious surface.
              LID is a set of environmental sensitive design techniques that can maintain or replicate the pre-development hydrologic condition through mimicking the previous hydrologic landscape (US EPA 2000). Common practices of LID include bioretention facilities, grass swales or channels, vegetated roofs, rain barrels and permeable pavements[2].
              It has been demonstrated that LID practices can lead to a resilient stormwater system to prevent floods and CSO (US EPA 2007). They can also improve the water quality of the receiving water body, the Mystic River, by reducing pollutant loadings and stream channel degradation[3]. Additionally, US Environmental Protection Agency (EPA) conducted a cost analysis and found 11 out of 12 projects cost less than conventional stormwater management practices, with savings ranging from 15% to 76% (US EPA 2007). Therefore, I propose the following policies to promote wide adoption of LID in Somerville.
Revision of Zoning Ordinances and Making Bylaws of LID
              The current zoning ordinances of Somerville restrict the development of LID. For example, stormwater connection, minimum road width, and minimum parking spaces are mandated in Article 5, 8, 9, respectively (City of Somerville 2010). These articles deter developers and other municipal departments who intend to implement LID practices. Therefore, the first thing we need to do is to thoroughly review our zoning ordinances and modify articles that restrict the adoption of LID practices.
              Furthermore, we can write separate stormwater bylaws incorporating LID designs to further reduce the perceived risks developers face from uncertainty. When writing bylaws to regulate LID, it is preferable to use flexible performance-based standards rather than precise prescriptive ones. For example, a bylaw that requires restoration of pre-development hydrology works better than a specific rule that mandates the use of green roof, because they provide more flexible choices for developers, while achieving the same results (Stone 2001, p 289). To assure long-term effectiveness of LID features, maintenance requirements should also be included in bylaws.
Public Sector Taking the Lead through Public Demonstration Projects
              LID is cutting edge in stormwater management. With 78% impervious surface, Somerville can create a model of best practices to get ahead of curve in progressive policies. We can start from demonstration projects, which can not only raise public awareness but also test out the effectiveness of LID techniques under local climatic and geographic conditions. Design techniques used in demonstration projects should be as diverse as possible. Furthermore, we should coordinate with other municipal departments and the state government as early as possible to integrate LID to their new infrastructural or housing developments. Early adoption of LID practices can further lower the construction costs (MacMullan 2007). Finally, we should take the opportunity to integrate LID demonstration projects with brownfield redevelopments (Petho et al. 2005) and promote environmental justice in low income neighborhoods.
Capacity Building through Training and Research
              To build up a local workforce for LID practices, we can collaborate with Tufts University to initiate training programs for designers, developers, maintenance personnel, and government officials. Certificates can be issued to designers and maintenance personnel who have gone through the training processes and demonstrated their capability of LID design and maintenance. Preference can be given to certified landscape architects or maintenance personnel in municipal projects. Moreover, we can fund Tufts University to build up Geographic Information System (GIS) and monitoring database for LID projects. Tufts planning students can also get hands-on experiences through these projects.
Incentivize the Private Sector through FAR bonus and TIF
              LID practices are naturally fragmented, and most of them need to be implemented on private lands. Therefore, incentivizing private sector is the key to remove market barriers. One of the effective incentive schemes is to provide Floor-to-Area Ratio (FAR) bonus[4] to developers who adopt LID designs. FAR standards are used to avoid overly-dense development. However, if developers make the effort to reduce their developments’ impacts on surrounding communities, it seems reasonable to give them extra density. Another added benefit of FAR bonus is the increase of the future tax base, since more dense developments are allowed (Denzin 2008).
              Secondly, we can indirectly incentivize developers via Tax Incremental Financing (TIF), which offers incentive to redevelop areas that are “detrimental to the sound growth of the community” (City of Somerville 2003). This can be realized by integrating LID practices into our current TIF certification process as one of the assessment criteria for proposed projects. As a result, we can promote environmental justice in the redeveloped area.
              A point to note is that the city should keep the right of withdrawal incentives in case of non-compliance, so that the incentives will not become guarantees (Stone 2001, p 275).
Engage Communities through Participatory Planning
              Many homeowners choose to pave their backyards. Some of them did so to prevent flooding[5]. They didn’t realize that the risk of flooding is actually increased after they paved their yards. This kind of problem is defined by Stone as lack of awareness (Stone 2001, p 211). To raise awareness, we can extend our participatory planning process of Somervision to the LID policy making and planning process.
              Participatory planning is neither the traditional public workshops that aim at educating the public, nor public hearings that can be easily checked off on a to-do list. It is a mutual learning process that builds up partnership with communities and individuals (Arnstein 1969). We should be prepared for such a non-linear learning process where the goals may be revisited and exploratory implementation may occur (Innes and Booher 2010, p 204).
              To engage the public, we need to use all possible media (Ryan 1991; Evans-Cowley and Hollander 2010) – from newspaper, radio, and TV, to blogs, Facebook and Twitter; from door-step conversation to word-of-mouth spread. In addition, we need to work closely with grassroots organizations, who could be mediators in participatory planning processes. One of them, for example, is Somerville Climate Action. They have organized a “De-paving the Way” program in October that engaged more than 40 people to de-pave yards and create green space. Another example is Mystic River Watershed Association who has been advocating LID practices for years.
              Instead of paying for future flood damage, we can invest that money more wisely on Low Impact Development today by revisiting our zoning ordinances, building up public demonstration projects, and incentivizing private sector. Moreover, only by engaging citizens and community organizations in participatory planning can we create a resilient system.
Arnstein, Sherry. 1969. A Ladder Of Citizen Participation. Journal of the American Planning Association 35, no. 4: 216-224.
Byrne, Matt. 2010. Somerville speeds repairs to flood-damaged public safety building. The Boston Globe. Boston.
City of Somerville. 2003. Economic Development Incentive Program Tax Increment Financing (TIF) Guidelines.
City of Somerville. 2010. Zoning Ordinances.
Denzin, Brent. 2008. Local Water Policy Innovation: A Road Map for Community Based Stormwater Solutions. American Rivers.
Evans-Cowley, Jennifer, and Justin Hollander. 2010. The New Generation of Public Participation: Internet-based Participation Tools. Planning Practice and Research 25, no. 3: 397-408.
Innes, Judith E, and David E Booher. 2010. Planning with Complexity: An Introduction to Collaborative Rationality for Public Policy. 1st edition. Taylor & Francis.
MacMullan, E. 2007. The Economics of Low-Impact Development: A Literature Review. ECONorthwest.
Massachusetts Water Resources Authority. 2009. Combined Sewer Overflow Control Plan - Annual Progress Report 2009. MWRA Online.
Petho, Karen, Cameron Pratt, Carey Reeder, and Dan Schulte. 2005. Environmental Justice Inventory for Ten Communities in the Greater Boston Area. Somerville.
Ryan, Charlotte. 1991. Prime Time Activism: Media Strategies for Grassroots Organizing. Boston, MA: South End Press.
Stone, Deborah A. 2001. Policy Paradox: The Art of Political Decision Making. 4th edition. W. W. Norton & Company.
US EPA. 2000. Low Impact Development (LID)- A Literature Review.
US EPA. 2007. Reducing Stormwater Costs through Low Impact Development (LID) Strategies and Practices.

[1] City of Toledo (OH), for example, is going to invest $315 million on extensive sewer improvement projects.
[2] Refer to the literature review for LID practices and their benefits
[3] Mystic River receives Grade of C- in 2010 EPA Report Card, which is not suitable for recreational activities
[4] It has been adopted in Portland (OR), where developers can get FAR bonuses if their design incorporates a green roof
[5] Personal communication with Somerville residents

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