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HOUSTON INCENTIVES FOR

GREEN DEVELOPMENT

Message from the Mayor August 2019

In the aftermath of Hurricane Harvey, we have taken critical steps to address our flooding and drainage challenges. As Houston has rapidly developed, we have relied on traditional gray infrastructure systems to keep us safe. However, as we build forward, we must consider new and innovative approaches for achieving greater flood resilience in Houston. While we continue to pursue large-scale projects to reduce flood risk, Hurricane Harvey and other floods have highlighted the necessity to employ a holistic stormwater management approach which integrates green infrastructure into our existing drainage systems.

Through the generous support of the Houston Endowment, the City of Houston conducted a one-year study that provides recommendations to encourage the use of green infrastructure by the private sector through incentives. More green infrastructure in private land development projects will bring economic, social, and environmental benefits to our city while enhancing the resilience of our neighborhoods. The proposed incentives are our next step toward achieving our vision of a better Houston. This report details the work of a team led by Stephen C. Costello, P.E., the City’s flood czar and chief recovery officer. This work included engagement with development industry partners and extensive review by City departments. We will work across departments to move forward with the implementation of the Houston Incentives for Green Development, following the proposed schedule. However, these incentives are only the beginning as the City intends to lead by example with a green infrastructure program that focuses on infrastructure projects, training and development, coordination with local agencies, and partnerships with the private sector.

I see the incentives as an integral part of my vision of a sustainable, safer, stronger, and smarter Houston that will complement the goals of the City’s forthcoming Resilience Strategy, Climate Action Plan, and Harvey recovery programs.

- Mayor Sylvester Turner

© City of Houston, August 2019

Suggested Citation:

Bloom, M.; Clements, J.; Valderrama, A. Houston Incentives for Green Development. Houston: City of Houston, May 2019.

Prepared for:

Stephen Costello, P.E. and Laura PatiñoCity of Houston, Mayor’s Recovery Office

Prepared by:

Michael F. Bloom, P.E.R. G. Miller Engineers, Inc.

in association with

Keiji Asakura, PLA and Abigail Phillips, PLA Asakura Robinson CompanyJanet Clements, Corona Environmental Consulting Alisa Valderrama, Neptune Street Advisors

Financial Support Provided by:

Acknowledgments

The authors of this report gratefully acknowledge the support, input, feedback, and advice provided by the leadership of the following City of Houston departments:

• Houston Public Works• Houston Permitting• Planning and Development Department• Administrative and Regulatory Affairs Department• Mayor’s Office• Chief Development Officer• Chief Sustainability Officer• Chief Resilience Officer• Parks and Recreation Department and by the participating members and leadership of the following external stakeholder groups:

• American Council of Engineering Companies – Houston Chapter• Bayou City Water Keeper• Bayou Preservation Association• Buffalo Bayou Partnership• Galveston Bay Foundation• Greater Houston Builders Association• Houston Advanced Research Center• Houston Apartment Association• Houston Audubon Society• Houston Parks Board• Houston Real Estate Council• Houston Wilderness• Katy Prairie Conservancy• Houston Land and Water Sustainability Forum• Urban Land Institute – Houston District Council

We would also like to thank the managers and staff of the cities of Austin, Chicago, Milwaukee, Nashville, New Orleans, New York, Philadelphia, Portland, and Seattle, who took time to answer our questions during the peer city benchmarking effort.

Rain gardens in a private school parking lot. Steve Albert, P.E.

“I see the incentives as an integral part of my vision of a sustainable, safer, stronger, and smarter Houston that will complement the goals of the City’s forthcoming Resilience Strategy, Climate Action Plan, and Harvey recovery programs.”

- Mayor Turner

Contents1.0: Introduction 02

2.0: What is Green Stormwater Infrastructure? 08

3.0: Houston Incentives for Green Development 16

4.0: Integrated Green Stormwater Infrastructure Development Rules 20

5.0: Property Tax Abatements 26

6.0: Award and Recognition Program 30

7.0: Increased Permitting Process Certainty and Speed 34

8.0: Summary 40

About the Authors 42

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Green space along Buffalo Bayou. iStock/Davel5957

Greater implementation of green stormwater infrastructure (GSI) in private land development projects will allow project sponsors, the City, and the area around these projects to realize economic, social, and environmental benefits, as well as enhanced resilience.

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1.0Introduction

PurposeThrough funding from the Houston Endowment, the City of Houston’s Chief Recovery Office (CRO) commissioned a one-year study to identify and recommend incentives to encourage the use of green stormwater infrastructure (GSI) in private land development within the corporate boundaries of the city. Greater implementation of GSI in private land development projects will allow project sponsors, the City, and the area around these projects to realize economic, social, and environmental benefits, as well as enhanced resilience.

The CRO retained R. G. Miller Engineers, Inc. in association with Asakura Robinson, Corona Environmental Consulting, and Neptune Street Advisors to perform the work. The team started work in May 2018 and completed work in May 2019.

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Research and BenchmarkingThe project team conducted interviews with 9 peer cities across the U.S. to learn more about existing GSI incentive programs, including program successes, challenges, and lessons learned. This exercise also reinforced that the team should identify incentives that will help developers and the City achieve their financial objectives and general welfare objectives, respectively; collaborate with the development community to understand factors that will encourage or discourage participation; and, coordinate with all implementing city departments to set the stage for smooth implementation. Results of this work are available in Appendix A via digital download at http://www.houstontx.gov/igd.html.

Stakeholder Engagement Through a participatory approach, the project team and the City identified and assembled a development industry stakeholder group. The project team also conducted multiple group stakeholder meetings to obtain feedback about drainage rules, detention requirements, GSI rules, GSI incentives, and project financial information. The team then conducted private interviews with stakeholders, requested redacted financial statements for various types of development or redevelopment projects within Houston limits, and evaluated information to develop initial recommendations for a suite of incentive programs for development industry stakeholders. Results of this work are available in Appendix B via digital download at http://www.houstontx.gov/igd.html.

Evaluation Process The project team evaluated alternative GSI incentive program models as follows:

• Reviewed redacted financial statements for various types of development or redevelopment projects inside the city.

• Identified costs and benefits of alternative program models.

• Identified potential threshold points that would trigger GSI use by private developers in various types of real estate projects.

• Identified legal, policy, or procedural barriers or challenges to implementing the considered incentives or regulatory approaches.

• Identified possible implementation strategies to overcome barriers and challenges.

Results of this work are available in Appendix C via digital download at http://www.houstontx.gov/igd.html. This work helped guide the team in preparing the final proposed incentives.

Draft Report The project team developed potential program models and a suite of GSI techniques and facilitated development industry stakeholder group review. The results of this work formed the basis for a draft of the current final report.

Work EffortsWith the goal of recommending the most effective and applicable green stormwater infrastructure (GSI) incentives for Houston, the project included the following work products:

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Final Report The team engaged with council members, internal departments, and external stakeholder groups and prepare the current final report with recommended incentives. In addition, the team engaged with external stakeholder groups who reviewed the report and provided comments on the overall study effort. Responses to stakeholder comments are available in Appendix D via digital download at http://www.houstontx.gov/igd.html.

City of Houston VisionThe City of Houston aims to set the stage for the implementation of green stormwater infrastructure (GSI) to become an integrated part of “business as usual” for private property developers in Houston. To accomplish this, the City seeks to create a suite of incentives aimed at motivating developers to use GSI as well as recognize and celebrate five marquee private developments that utilize GSI within the next five years. The GSI incentive programs are the focus of this paper. The City’s hope is that recognition of the five marquee projects, in combination with a suite of incentives aimed at motivating developers to use GSI, will set the stage for the private use of GSI to become an integrated part of “business as usual” for property developers in Houston. The City envisions the GSI program as related to and compatible with other current initiatives, including the Resilience Strategy (in development) as part of the 100 Resilient Cities Program and the Climate Action Plan (in development).

GSI can provide habitat for turtles. iStock/Karl Spencer.

The City of Houston aims to set the stage for the private implementation of GSI to become an integrated part of “business as usual” for property developers in Houston.

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What Can Green Stormwater Infrastructure (GSI) Bring to Houston?Green stormwater infrastructure (GSI) is an important stormwater management tool that can enhance economic performance of real estate projects while improving drainage system performance in the project vicinity. GSI can help real estate projects realize higher operating income, faster lease-up or sales, higher occupancy, higher amenity values, greater lot or unit yield, “green” marketing benefits, and reduced drainage system costs. At the same time, GSI can improve neighborhood resilience, reduce drainage concerns from small storms, reduce potable water use, reduce urban heat island impacts, improve neighborhood aesthetics, and improve public health. 1

Recommended IncentivesAfter 10 months of effort including interviews with peer cities with GSI programs, multiple meetings and interviews with external stakeholders, interviews with city leadership, and a quantitative analysis of costs and qualitative assessment of benefits, the development and implementation of the following incentive programs is recommended— any of which might be utilized in conjunction with any another to achieve optimum increased developer uptake of GSI:

• Integrated GSI Development Rules • Property Tax Abatements • Award and Recognition Program • Increased Permitting Process Certainty and Speed

¹ See Burgess, Katharine, et. al. Harvesting the Value of Water. Washington DC: Urban Land Institute, 2017; Ring, Justin. Talking Dollars and Sense: LID Construction Costs. Proceeding of the American Society of Civil Engineers, International Low Impact Development Conference, Houston, Texas. Washington DC: ASCE, 2015; US. EPA. City Green: Innovative Green Infrastructure Solutions for Downtowns and Infill Locations. Washington DC: EPA, 2016; Bloom, M. The Business Case for Natural Drainage Systems in Houston Area Land Development Projects. Houston: Realty News Report. January 4, 2017; Clements, Janet, et. al. The Green Edge: How Commercial Property Investment in Green Infrastructure Creates Value. New York: Natural Resources Defense Council. 2013.

Wildflowers can be incorporated into GSI landscaping. iStock/fstop123

Green infrastructure is an important stormwater management tool that can enhance the economic performance of real estate projects.

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Organization of This ReportThis document includes the following sections:

• PART 2.0: What is Green Stormwater Infrastructure (GSI)?Provides an overview of the GSI techniques recommended for use in the City’s GSI program.

• PART 3.0: Houston Incentives for Green DevelopmentSummarizes the recommended GSI incentive programs as a result of this study.

• PART 4.0: Integrated Green Stormwater Infrastructure Development RulesPresents the proposed program, implementation considerations, and proposed implementation schedule.

• PART 5.0: Property Tax AbatementsPresents the proposed program, implementation considerations, and proposed implementation schedule.

• PART 6.0: Award and Recognition ProgramPresents the proposed program, implementation considerations, and proposed implementation schedule.

• PART 7.0: Increased Permitting Process Certainty and SpeedPresents the proposed program, implementation considerations, and proposed implementation schedule.

• PART 8.0: SummarySummarizes the steps undertaken in this study, restates the recommended incentives, and discusses considerations for future green infrastructure program development.

The following appendices provide additional supporting details and information and are available via digital download at http://www.houstontx.gov/igd.html.

• APPENDIX A: Research and BenchmarkingPresents a detailed summary of findings from interviews with other cities implementing GSI programs.

• APPENDIX B: Stakeholder EngagementPresents a detailed summary of project cost data provided by developers and the results of interviews with developers engaged in development and redevelopment in Houston.

• APPENDIX C: Evaluation ProcessPresents the detailed results of an incentive screening process, an evaluation of legal or policy authorities and limitations, project and incentive program financial performance information, threshold points that would motivate private use of GSI, and implementation challenges and strategies.

• APPENDIX D: Response to Comments DocumentPresents a detailed summary of stakeholder comments and consulting team responses.

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Trail and landscaping along Brays Bayou. Asakura Robinson

GSI techniques aim to mimic how rainfall behaves when it falls onto an undeveloped, green landscape.

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2.0What is Green Stormwater Infrastructure (GSI)? Green stormwater infrastructure (GSI) is a design philosophy and a toolbox of techniques for stormwater management that can be applied in real estate development projects (including redevelopment and retrofitting projects). GSI techniques aim to help minimize the downstream impacts of development and mimic how rainfall behaves when it falls onto an undeveloped, green landscape. These techniques include green roofs, rain gardens, bioretention systems, vegetated filter strips, permeable pavements, rainwater harvesting, urban forests, constructed wetlands, soil amendment practices, and other strategies to manage rainwater on or near the site where the rain falls. The techniques that are most applicable to Houston are described in more detail in the following pages.

This report uses the term green stormwater infrastructure (GSI); however, the term is synonymous with other terms such as low impact development (LID), green infrastructure (GI), sustainable urban drainage (SUDs), and natural drainage systems. These other terms may appear in cited sources or in other publications.

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Stormwater washes pollution into rain garden and reduces runoff to other sites.

Plants help absorb and filter stormwater and look good!

Collected stormwater reduces irrigation demand.

Plants reduce heat island effect.

To storm drain

MulchSandGravelFabric

Water Storage Area

BioretentionBioretention systems, also called rain gardens in the Houston region, are shallow, vegetated depressions in the ground that are used to slow and sometimes infiltrate stormwater runoff to native soils or, often, to a nearby storm sewer. They change the timing and volume of stormwater runoff while adding a beautiful landscaped amenity to a development project. Bioretention can help achieve detention volumes requirements while enhancing the aesthetics of a project.

DESIGNBioretention systems typically consist of hard wood mulch, a layer of engineered soil media, planted with native vegetation, some separation gravel and fabric, and an underdrain. Impermeable areas of a development are designed to divert runoff to the bioretention system, where it is allowed to pond and filter through the system. These systems should be designed by a professional engineer.

• Reduces stormwater runoff rate and detention volume

• Achieves city imposed stormwater pollution control requirements

• Reduces stormwater management costs

• Reduces site development costs

• Enhances site aesthetics • Increases lease-up or

sales rates • Increases retail

establishment sales • Increases property value • Achieves open space

requirements

INSTALLATIONInstallation elevations of all components are important for correct operation. The top of the media should be wrapped with an impermeable liner until the site is completely stabilized and no additional construction generated sediment will be generated. The infiltration rate of the installed soil media should be tested for quality control.

LIMITATIONSBioretention systems in Houston generally will require an underdrain system that routes filtered stormwater to a nearby storm sewer, bayou, or channel.

RELATIVE COST ($-$$$)

Costs of bioretention systems can vary depending on multiple factors, including the size and design of the system, the location (parking lot, road median, near buildings), and depth of water table.

• Improves stormwater management

• Reduces burden on public drainage system

• Reduces pollutant loads to local waterways

• Reduces heat island effect

• Enhances wildlife habitat

• Improves neighborhood aesthetics

• Increases resilience • Increases property tax

revenue

DEVELOPER BENEFITS PUBLIC BENEFITS

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Green Roofs

DESIGNThere are two main types of green roofs: extensive and intensive. Extensive green roofs are much more shallow, less than 6 inches, and support low growing plants, like sedums. Intensive green roofs have a soil or growing medium depth from 6 inches to 4 feet, accommodating grasses, shrubs, and trees. The structural support for these systems should be designed by professional engineers.

INSTALLATIONGreen roofs may be specified and built layer by layer or pre-engineered, modular green roof systems can be utilized. Installed elements include: water proofing, a separation layer, a drainage layer, a soil matrix, and plants

LIMITATIONSThere are some limitations to consider when using green roofs. The structural design of the building must accommodate the extra

weight of a green roof. Plants should be carefully chosen in order to thrive in the rooftop environment.

RELATIVE COST ($-$$$$)

Costs of green roofs vary greatly depending on multiple factors, including but not limited to, new or existing development, type of roof system, and desired size. Long term savings include reduced utility costs and flood control measures.

Vegetation

Growing Medium

FabricDrainage Layer

Insulation Layer

Waterproof Membrane

Structural Support

Plants absorb and slow stormwater runoff.

Excess water is retained in the soil and drainage layer.

Remaining water is re-used or flows to storm drain.

Green roofs, also known as living roofs, are layers of growing medium and vegetation installed on top of a conventional roof. Green roofs function to reduce stormwater runoff, filter pollutants, reduce the carbon footprint, reduce energy costs, and add aesthetic quality. While initial installation costs are higher for green roof systems, the long-term benefits and savings surpass conventional roofs.

• Reduces building operation cost

• Decreases roof replacement and repair frequency




sales rates • Increases retail

establishment sales• Increases property value • Achieves open space

requirements








revenue


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DESIGNDesign should accommodate anticipated traffic loads, sediment loading, and the contributing drainage area. Large drainage areas tend to require more frequent maintenance than permeable systems that only receive direct rainfall. Pretreatment of runoff may be required for larger drainage areas with heavy leaf litter or other solids loadings. Underdrain system must be designed to accommodate anticipated flows and should flow to a public storm sewer, bayou, or channel.

INSTALLATIONPermeable paving installations should be conducted by installers and contractors credentialed to do so by the American Concrete Institute, the National Asphalt Pavement Association, or similar national organizations.

LIMITATIONSThe ratio of the contributing drainage area to the permeable pavement area should be less than 3 to 1, to avoid excessive loading and maintenance requirements. Underdrains

will likely be required in most parts of Houston, unless field infiltration testing demonstrates adequate native soil infiltration.

RELATIVE COST ($$-$$$)

Installation costs are generally higher than traditional paving in the Houston region because of the need to provide an underdrain system connected to the storm sewer. When both pavement costs and detention costs are compared together, permeable paving can sometimes be more cost effective.

Stormwater slows as it flows through pores in pavement.

Subgrade Soil

UnderdrainStones

Porous parking or walkwaysreduce area required for stormwater management.

To storm drain

Some stormwater may flow to the soil below.

Permeable PavementPermeable pavement a layer of concrete, asphalt, or paver stones designed to allow stormwater to flow through the material to the underlying material. Permeable pavement replaces conventional impervious materials. It reduces the volume of stormwater runoff, alters the timing of runoff, and can reduce site development detention requirements. Where soil conditions are unfavorable for infiltration, permeable pavement is frequently combined with an underdrain or below grade detention storage.


• When combined with parking, detention, and landscaping reduces site development costs


• Increased resilience


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DESIGNRunoff is channeled from impervious surfaces to cisterns and rain barrels, where the storage and release of water is controlled by valves. The systems are simple to install and use, and can be put in almost anywhere. Rainwater harvesting systems are great to use in conjunction with other GSI techniques, such as bioretention systems, that improve infiltration and remove runoff pollutants.

INSTALLATIONAlways check with city or county permitting for underground cistern installations. There are a variety of options when it comes to choosing a rainwater harvesting system, including above and below ground storage tanks, different sized tanks, and systems to mitigate peak runoff

LIMITATIONSCisterns and rain barrels require an overflow system to be installed in order to accommodate large rainfall events when the tank reaches

capacity. Because of the amount of pollutants that are found in runoff, harvested rainwater cannot be consumed or used as a potable source unless treated.

RELATIVE COST ($-$$)

Rainwater harvesting costs depending on the size of the barrel or cistern being used, as well as the set up. Because of the simplicity of these systems, it is a more affordable BMP option for urban areas with limited space.

Rainwater Harvesting

To storm drain

Water collected on sitecan be used for irrigation,lowering landscapemaintenance costs.

Collection (From roof drainage)

Excess water is diverted to landscape or storm drains.

Cisterns reduce the

Parking Lot Drain

Overflow Drain

amount of runoff on streets or entering storm drains.

Cistern (Above or Below Ground)

Rainwater harvesting uses cisterns, rain barrels, and other storage tanks to capture and store stormwater runoff for non-potable water uses such as irrigation, toilet flushing, or industrial processes. Rainwater capture is ideal for urban areas since it reduces stormwater runoff and potable water use. There are numerous sizes and styles of rainwater harvesting systems to meet different goals.

• Reduces building operation cost


• Reduces potable water consumption and costs



• Conserves water


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DESIGN Amendments are made using soil organic matter, which comes from various sources, including compost, composted woody material, biosolids, forest product residuals, etc. It is best to reduce disturbance to the topsoil as much as possible, but graded topsoil from the site can be held and reapplied when a project is finished. Planting native vegetation improves the quality and maintains the soil health with reduced maintenance.

INSTALLATIONWhen using soil amendments, the depth of soil and quality should be established post-construction. It is important to limit the use of heavy machinery once the soil is in place. If topsoil is being imported from another source, making sure it has only a small amount of clay will help with infiltration.

LIMITATIONSExisting soil infiltration characteristics, storage properties, and the high clay

content of soils in the Houston area presents challenges. This means that a larger volume of amendments may be needed to achieve desired soil properties. This may increase the overall cost of the materials and the blending process used.


Costs associated with soil amendments depend on the project size, type of amendments used, need for machinery, and soil tests. These costs are mitigated by the improved management of stormwater runoff.

Quality soil promotes healthy plant growth reducing need for fertilizer and pesticide.

Organic matter in soil holds onto stormwater longer.

High quality soil is porous so it absorbs stormwater faster and reduces erosion.

Microbes and roots create tunnels for water infiltration.

Composted material adds nutrients.

Nutrient dense soil holds more water.

Soil AmendmentsSoil amendments are added to native site soils to improve stormwater management, landscaping, plant health, and aesthetics. Amendments such as organic materials, sand, woodchips, compost, shredded bark, and timber product residuals are added to existing site soils using traditional excavation or farm equipment, using processes such as cutting and filling, tilling, blending, and mulching. Soil amendments seek to increase water storage and infiltration as opposed to engineering amendments, such as lime, which seek to increase soil strength and bearing capacity.





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DESIGNThe most effective way to maintain urban forests is to minimize the impact of construction on existing vegetation as much as possible. Planting trees and allowing them to establish can improve air quality and provide cooling to adjacent buildings and impervious surfaces. This in turn reduces stormwater runoff and improves water quality. The more trees that are planted or maintained, the greater the effect on

stormwater management and environmental health.

INSTALLATIONSpace is a factor when using an urban forestry approach. Soil depth and properties, utility lines, space, and sunlight should be evaluated. Native species are desirable since they will generally require less maintenance than non-native species.

LIMITATIONSWhile low maintenance, urban forests still require long-term care in order to

see high survival rates. Poor quality soils may require amendments before trees can be established, and young trees take time to mature.

RELATIVE COST ($-$$)

Maintaining or restoring urban forests is relatively inexpensive, especially if trees are already established. Costs associated with tree plantings depend on soil health, location, maintenance requirements, and survival rate.

Urban Forestry

Trees increaseproperty values.

Tree canopy intercepts rain before it hits theground, reducing theamount of stormwaterentering city drains.

Tree cover reducessurface and air temperature in urbansettings.

Tree canopy absorbs air pollutants through leafs.

Tree roots take up waterfrom soil making space formore stormwater to infiltrate.

Dense urban forestry promotes healthy lifestyles and activity

Urban forestry is the management of trees and other vegetation in developed areas. Maintaining and enhancing the population of trees intercepts rainfall, reduces stormwater runoff volumes, increases evaporation, increases plant use of stormwater, improves air quality, and reduces the urban heat island effect. Incorporating native trees into urban developments is an easy way to add aesthetic value and mitigate the effects of increasing impervious cover.



• Enhances site aesthetics

• Increases lease-up or sales rates

• Improves retails sales • Increases property

value • Achieves open space

requirements








revenue


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DESIGNThe lower end of the contributing drainage area must include a level-spreader, which is an engineered border constructed at a consistent elevation. This is required to achieve consistent sheet flow conditions and to avoid uneven flow that can lead to discrete erosion problems and gullies. Filter strip slopes should be minimized to avoid high flow velocities (less than 3%). Native vegetation is preferred however any dense grasses can be used.

INSTALLATIONMaintain detailed grade control for impermeable area, level spreader, and filter strip area. Protect area from heavy equipment to avoid soil compaction. Use construction erosion and sedimentation control practices to avoid adverse impacts to the filter strip. Develop and implement appropriate construction phasing to avoid adverse impacts from sediment, equipment traffic, or material laydown practices.

LIMITATIONSVegetated filter strips should not be used on steep slopes. They

should not intercept runoff from an impermeable area that does not generate sheet flow, unless a level-spreader is provided. The filter strip flow path should exceed the impervious surface flow path draining to it. If soil characteristics are not favorable to promote infiltration, consider using soil amendments in the filter strip area.


Vegetated filter strips are relatively low cost to install, especially when using native plants. Costs will vary depending on the size of the filter strip and the conditions of the site location (slope, soils, impervious surfaces).

Level spreader evenly distributes stormwater collected on impervious surface across vegetated slopes.

Plants slow and filterstormwater and addcolor to landscape.

Vegetated area can function as recreational amenity.

Some stormwater may flow to the soil below.

Vegetated Filter StripsVegetated filter strips are gently sloping, planted areas located between a source of stormwater runoff, like a parking lot, and a stormwater inlet, conveyance, or bayou. Filter strips are designed so that stormwater runoff travels across them in a shallow layer. This type of flow path is known as “sheet flow.” Sheet flow conveyance slows stormwater runoff down, promotes infiltration and evaporation. The filter strip also removes particulates through physical barriers and by attracting and holding sediment, pollutants, and particles to the surfaces of soils and organic material.



• Reduces stormwater management costs


sales rates • Improves retails sales • Increases property value • Achieves open space

requirements





• Enhances wildlife habitat • Improves neighborhood

aesthetics • Increases resilience • Increases property tax

revenue


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3.0Houston Incentives for Green Development The four recommended incentive programs are:

• Integrated Green Stormwater Infrastructure (GSI) Development Rules • Property Tax Abatements • Award and Recognition Program • Increased Permitting Process Certainty and Speed

These four incentives programs are the core of Houston’s Incentives for Green Development. They should be an integral part of the City’s Resilience Strategy (in development) and a key element of Build Houston Forward (www.buildhoustonforward.org). Although this study presents four incentive programs, they are only the first step towards achieving a more robust green infrastructure program. The incentives and their implementation plans outlined in this report are considered the beginning and can be further expanded on as the City takes a more active leadership role with respect to green infrastructure.

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Urban bioretention design in Midtown. Asakura Robinson

The implementation of the green stormwater infrastructure (GSI) incentives will be led by the Mayor’s Office of Resilience.

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As the program is launched, the new incentives can be marketed as an opportunity for developers, who will benefit from enhanced economic performance of their projects, while, at the same time, providing additional public benefits as outlined in the fact sheets presented in the prior section.

In order to evaluate effectiveness and to improve the programs, they should be implemented with a “monitor, assess, and revise” strategy, that includes stakeholder input.

Lastly, the Mayor’s Office of Resilience will continue to lead and drive implementation of green stormwater infrastructure incentives to effectively coordinate cross-departmental actions.

The following four sections outline the details of these four incentive programs.

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Green space along Buffalo Bayou. iStock/Sean Pavone

The alternative set of GSI development rules should seek to encourage the planning and design of development features that provide more than one function through the use of GSI.

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4.0 Integrated Green Stormwater Infrastructure (GSI) Development Rules Extensive developer stakeholder engagement determined that current development rules and design criteria are not perceived as conducive to green infrastructure implementation. By enacting an integrated set of green stormwater infrastructure (GSI) development rules that harmonize parking, landscaping, open space, drainage design, detention design, and stormwater quality design requirements the City would be able to incentivize developers to use green stormwater management techniques more often.

Developers could be offered the option of applying for a development permit using the existing set of rules or, if green stormwater approaches are implemented, the City would then allow the developer to proceed using an alternative set of rules.

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The alternative set of green stormwater infrastructure (GSI) development rules seeks to encourage the planning and design of development features that provide more than one function through the use of GSI. The integrated GSI rules can provide both inherent cost savings and benefits to the project because design elements that perform more than one function can reduce costs while increasing benefits. For example, under current rules, a project developer might need to provide a minimum number of parking spaces, a certain area of landscaping with a specific number of trees, a minimum volume of detention, and a stormwater treatment device at the end of underground pipe system. Under the envisioned GSI rules the developer might be able to provide a smaller number of parking spaces with a permeable2 surface and underdrain, a landscaped bioswale with bioretention and trees that would serve to convey and treat stormwater as well as meet open space and landscaping requirements, a smaller volume of detention, a shorter lengths of underground piping, and no end-of-pipe stormwater treatment device.

While the exact details of the proposed integrated rules will need to be considered by all relevant city departments and interested stakeholders, the following general provisions should be achieved by the GSI development rules.

Landscaping and Open Space • Impose a lower or no open space fee for

sites that utilize GSI.

• Grant credit for GSI techniques towards open space requirements.

• Omit the perimeter shrubs requirement if the parking lot is served by GSI along the interface between the public right of way and the private parking area.

Parking • Offer reduced parking requirements if GSI

is implemented onsite.

• Allow permeable paving systems including asphalt, concrete, stone aggregate, and pavers (all with underdrains) in parking bays and driveways.

Drainage and Stormwater Quality • Allow beehive inlets and other specialty

inlets to accommodate GSI systems.

• Allow smaller diameter private storm sewer leads to accommodate shallower and more visible GSI flowlines.

• Include consideration of Atlas 14, Volume 11, Version 2.0 rainfall depths, frequencies, and intensities.

• Allow the use of a hydrological analysis of the pre-development and post-development conditions to determine peak flows, total runoff volume, and detention requirements, down to a minimum detention rate of 0.35 acre-feet of volume for each acre of impervious area (within the disturbed area), if technically demonstrated as sufficient.

• Explicitly allow drainage design calculations to consider GSI features designed to retain, detain, convey, or infiltrate stormwater to be permeable.

2 IDM, Chapters 9 and 13 use the word “porous pavement” instead of permeable pavement. This report uses the term “permeable surface” or “permeable pavement” or “permeable paving systems” to refer to porous paving systems made with asphalt, concrete, stone, or blocks

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• Harmonize drainage and stormwater quality design provisions with Harris County.

• Allow bioretention to be sized and designed in a manner similar to that required by Harris County.

• Require an underdrain connected to a storm sewer below all permeable paving.

• Require an operations and maintenance plan for all private GSI facilities, as currently required for stormwater quality devices.

• Require annual certification of private GSI facilities by a professional engineer, as currently required for stormwater quality devices.

Design Criteria for GSI Techniques • Develop detailed design criteria for GSI

techniques allowed in private development;

• Define specific criteria that must be met for any site design feature to be considered GSI for the purposes of receiving any incentive; and,

• Allow the use of real-time weather data controlled “smart” stormwater systems to facilitate the operation of both rainwater harvesting systems to reduce potable water consumption and stormwater detention systems.

Green roof on the Houston Permitting Center building. Asakura Robinson

The integrated GSI rules should provide both inherent cost savings and benefits to the project because design elements that perform more than one function can reduce costs.

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No legal, policy, or procedural issues were identified that would preclude the implementation of the proposed integrated GSI rules. This incentive should be implemented in parallel with the others outlined in this report to maximize the benefits of the green incentives program.

Detailed cost estimates were prepared for a conventional design using current rules and a GSI design using an assumed set of GSI development rules for a 2.6-acre mixed use development with surface parking and a two-story building.

The exercise demonstrated that implementation of the GSI development rules could reduce overall project costs (land acquisition, soft costs, financing costs, site work, and building construction) by about 2% while also providing aesthetic enhancements (Appendix C). The use of the GSI rules reduced site costs (landscaping, paving, and stormwater management) by 34%; therefore the implementation of an integrated set of GSI development rules would serve to motivate developers to use GSI.

The City will encounter several challenges in implementing this incentive. First, adoption of ordinance and design criteria requirements will take time and consensus-building across various stakeholder groups. Second, once adopted, staff training will likely be required. Third, developers and various real estate professional service firms will need to learn the new procedures and requirements.

These challenges can be addressed as outlined below. First, consensus for the adoption of ordinance and design criteria requirements could be accomplished using the Redevelopment and Drainage Task Force established before Hurricane Harvey.

The stakeholder group is very well versed in drainage and development issues and represents a broad group of community advocates, engineers, architects, contractors, and developers. Stakeholder agreement can be facilitated through this task force while leveraging City expertise and the Infrastructure Design Manual revision process. Lastly, staff training and industry education can be accomplished at a reasonable cost or low cost, especially with the involvement of entities such as the Houston Land and Water Sustainability Forum, the Urban Land Institute, the Houston District Council, the Houston-Galveston Area Council, and the American Council of Engineering Companies, and the Greater Houston Builders Association.

As noted for each incentive program, this incentive program could be bundled with others presented in this report because a combined set of incentives will motivate the use of GSI more than one alone.

GSI can provide habitat for water fowl. iStock/Citysqwirl

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The consulting team recommends proceeding with the implementation steps outlined in Table 4-1.

TABLE 4-1: SUGGESTED INTEGRATED GSI RULES IMPLEMENTATION STEPS

NO. ACTION RESPONSIBLE PARTY DUE DATE

1 Assemble Stakeholder Group Planning Department and Chief Resilience Officer 4Q 2019

2 Develop Revised Ordinance Language Planning Department and Chief Resilience Officer 1Q 2020

3 Adopt Ordinance City Council and Chief Resilience Officer 2Q 2020

4 Develop Revised Infrastructure Design Manual Provisions

Houston Public Works and Chief Resilience Officer 1Q 2020

5 Adopt Revised Design Manual Houston Public Works and Chief Resilience Officer 2Q 2020

6 Conduct Internal Staff Training Houston Public Works and Chief Resilience Officer 3Q 2020

7 Conduct Stakeholder and Industry Training

Houston Public Works and Chief Resilience Officer 3Q 2020

8 Implement New RulesPlanning Department, Houston

Public Works, and Chief Resilience Officer

4Q 2020

The schedule for this incentive program is shown in combination with the other three incentives in the timeline on page 37.

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GSI can connect to existing public green space. iStock/RoschetzkylstockPhoto.

The value, duration, and terms of the abatements offered to future projects should be established using a detailed business case evaluation for each future project.

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5.0Property Tax Abatement Tax abatements have been used to help stimulate land development projects in many real estate markets around the world. They reduce the owner’s property tax bill by a certain amount for a certain duration in exchange for some public benefit. Accordingly, developers can be incentivized to implement green stormwater infrastructure (GSI) in their projects if the City delays or reduces the developers’ property tax bill. Current city ordinances, policies, and procedures do not appear to limit the ability to offer this incentive. This program could be implemented through the enactment of an explicit GSI tax abatement or through the City’s existing authority to issue abatements for general economic development reasons. This incentive should be implemented in parallel with the others outlined in this report.

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Throughout the study, the team estimated the value of property tax abatements and compared that to the cost of implementing green stormwater infrastructure (GSI) (Appendix C). This cost comparison illustrated that this incentive program would create a meaningful trigger point across most project scales. The magnitude of the incentive driver will depend upon the scale of the project, the pre- and post- appraised value of the land, and the size of proposed GSI facilities.

Tax abatements should be marketed to developers who are planning to build projects with anticipated appraised values sufficient to cover some or all of the anticipated GSI costs. Like the residential apartment tax abatement that was implemented in 2010, a clear business case should be developed to illustrate that the investment in private GSI will catalyze nearby property value increases and, hence, increase city tax revenue and public good. This incentive program can be bundled with others outlined in this report because a combined set of incentives might motivate the use of GSI more than one alone.

The value, duration, and terms of the abatements offered to future projects should be established using a detailed business case evaluation for each future project. This is because each project, project site, and project area will have their own unique conditions, constraints, and opportunities. The abatement can be granted on the tax bill increase arising from the redevelopment project and should be offered for a period of 5 years.

This incentive should be marketed in discussions with the Urban Land Institute – Houston District Council, the Houston Real Estate Council, and other stakeholders.

Additional policy implications of establishing different abatement durations and amounts for new development and redevelopment during the creation of the program should be addressed.

Wetland plants can be incorporated into GSI landscaping. iStock/earleliason

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TABLE 5-1: SUGGESTED PROPERTY TA X ABATEMENTS IMPLEMENTATION STEPS


1 Assemble Stakeholder Group Chief Development Officer and Chief Resilience Officer 2Q 2020

2 Develop Program Details and Name Chief Development Officer and Chief Resilience Officer 3Q 2020

3 Conduct Publicity and Outreach and Recruit Participants

Chief Development Officer and Chief Resilience Officer

3Q 2021

4 Negotiate Initial Agreements Chief Development Officer and Chief Resilience Officer

3Q 2021

5 Evaluate Program Chief Development Officer and Chief Resilience Officer 4Q 2021


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Green roof on Carnegie Vanguard High School. Asakura Robinson.

Site tours, public events, and media events that include project sponsors and senior elected officials from the city should be conducted.

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6.0Award and Recognition Program An award and recognition program for developers who implement green stormwater infrastructure (GSI) in their projects can also be an effective incentive. This incentive should be implemented in parallel with the others outlined in this report in order to maximize developer and public benefits.

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City ordinances and state law do not appear to create any limitations on the City’s ability to offer and grant recognition or awards to private developers for the use of green stormwater infrastructure (GSI).

Initial program elements should include:

• Widespread publicity about the award program and why it was created.

• Recognition or branding of projects that participate in the incentive program.

• A tiered implementation process that will publicly recognize the first five marquee GSI projects, followed by an evolution into a more formal program with a consistent and open nomination and application process that allows for self-nominations and nominations from any citizen, organization, or entity.

• The number of awards to be issued each year or other appropriate time interval.

• A process for issuing and announcing the award or recognition in concert with the recipient to maximize exposure and benefits realized by the recipient.

• Ongoing educational programming featuring the award recipients to foster additional GSI use.

Site tours, public events, and media events that include project sponsors and city elected officials should be conducted. Social media should be used to promote the projects and the developers receiving recognition.

The initial program should be expanded later by adding:

• Clear eligibility requirements, including project status, extent of GSI use, location, size, and similar considerations.

• A clear application process that is not overly burdensome.

• A procedure for independent, non-biased, judging of applications.

It may be challenging to convince the first potential award recipient to invest in GSI solely in hopes of receiving an award. The likelihood that a developer will move forward with GSI will marginally increase as the scale and cost of the award publicity increases; more publicity might lead to more potential applicants. In addition, the City’s revenue cap and general budget constraints will limit its ability to implement this program using the larger, more elaborate options.

The program can be administered with internal resources and staff time, however, if these are found to be limited, a non-profit organization could be identified as a partner to facilitate the recognition and awards for specific projects. As noted previously, all incentives, including the one described in this section, could be bundled with the others described because a combined set of incentives might motivate the use of GSI more than one alone.

Due to the limited use of GSI in Houston thus far and the time required to create and implement the other incentives outlined in this report, it is recommended that the launch of the awards program is delayed until other incentives have been formulated and developers have had a chance to plan, design, and build projects. The first five marquee projects, which can be considered as pilots of these incentives, could be publicized throughout the implementation timelines proposed below. All awards and recognition will need to consider a variety of project types and scales as this will help motivate developers that work at all scales to use GSI.

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TABLE 6-1: SUGGESTED AWARD / RECOGNITION PROGRAM IMPLEMENTATION STEPS


1 Develop Program Details and Name

Office of Sustainability, Mayor’s Office of Communications, Chief

Resilience Officer, and Green Building Resource Center

3Q 2020

2 Conduct Publicity and Outreach and Recruit Applicants



3Q 2021

3 Grant Awards and Publicize Winning Projects



4Q 2021


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Urban forestry in Houston. iStock/Sean Pavone.

Developers should be incentivized to implement green stormwater infrastructure (GSI) in projects by providing a more consistent and faster plan review process.

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7.0Increased Permitting Process Certainty and Speed During stakeholder engagement, developers indicated that they could also be incentivized to use green stormwater infrastructure (GSI) in projects if they could obtain a more consistent and faster plan review process.

This could help achieve better economic performance on private development projects while delivering higher public benefits more quickly.

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The alternative permitting program would charge a higher fee than the current program, but it would assemble all project design professional and all reviewers for a team review session lasting from two to four hours (depending upon the scale of the project). The City of Dallas has created a very similar program that could be adapted for use in Houston.

Prior to scheduling and conducting the expedited team review meeting, plans will need to be evaluated for completeness. Once plans are deemed sufficiently complete, the expedited team review meeting can be scheduled. The review team should include plan reviewers from all departments and disciplines who will meet with the applicant and the applicant’s design professionals to conduct a full review of all plans. If the review requires relatively minor changes in the plans, then these changes can be made during the review and city staff would sign them prior to the end of the meeting. If revisions cannot be completed at the meeting, a follow up review with the same team should be scheduled. If the plans meet the relevant requirements of city codes and ordinances, and necessary changes are

made on the spot, permits should be issued immediately following the meeting. Reportedly this is similar to the review process used by Houston Permitting for telecommunications infrastructure projects.

In order to incentivize green infrastructure within an expedited team review program developers would need to be charged a higher set of fees for traditional development and a lower set of fees for green stormwater infrastructure (GSI) developments as outlined in Appendix C.

This incentive program will require additional staffing with specialized training. Five full time employees currently conduct all stormwater reviews; two for public projects and three for private projects. Because the Office of the City Engineer reportedly utilizes a team review approach for telecommunications infrastructure projects, this approach should work for all other development projects, both with and without GSI. This incentive program would be bundled with others outlined in the report to maximize both developer and public benefits.

Wildflowers can be incorporated into GSI landscaping. iStock/Richard McMillin

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TABLE 7-1: SUGGESTED PERMITTING TIMELINE IMPLEMENTATION STEPS


1 Assemble Stakeholder Group Houston Permitting and Chief Resilience Officer 4Q 2019

2 Develop Program Details and Name Houston Permitting and Chief Resilience Officer 1Q 2020

3 Hire and Train Staff Houston Permitting and Chief Resilience Officer 2Q 2020

4 Initiate Pilot Program and Fee Schedule Houston Permitting and Chief Resilience Officer

2Q 2021

5 Evaluate Pilot Results Houston Permitting and Chief Resilience Officer 3Q 2021

6 Revise Program and Fee Schedule Houston Permitting and Chief Resilience Officer 4Q 2021

7 Implement Revised Program Houston Permitting and Chief Resilience Officer 1Q 2022


Bioswale in single-family residential development. R. G. Miller Engineers, Inc.

GSI is an important stormwater management tool that can enhance economic performance of real estate projects.

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ACTIVITY RESPONSIBLE PARTY

INTEGRATED GSI DEVELOPMENT RULES

Assemble Stakeholder Group Planning Department and Chief Resilience Officer

Develop Revised Ordinance Language Planning Department and Chief Resilience Officer

Adopt Ordinance City Council and Chief Resilience Officer

Develop Revised Infrastructure Design Manual Provisions Houston Public Works and Chief Resilience Officer

Adopt Revised Design Manual Houston Public Works and Chief Resilience Officer

Conduct Internal Staff Training Houston Public Works and Chief Resilience Officer

Conduct Stakeholder and Industry Training Houston Public Works and Chief Resilience Officer

Implement New Rules Planning Department, Houston Public Works, and Chief Resilience Officer

PROPERTY TAX ABATEMENTS

Assemble Stakeholder Group Chief Development Officer and Chief Resilience Officer

Develop Program Details and Name Chief Development Officer and Chief Resilience Officer

Conduct Publicity and Outreach and Recruit Participants Chief Development Officer and Chief Resilience Officer

Negotiate Initial Agreements Chief Development Officer and Chief Resilience Officer

Evaluate Program Chief Development Officer and Chief Resilience Officer

AWARD AND RECOGNITION PROGRAM

Develop Program Details and Name Office of Sustainability, Mayor’s Office of Communications, Chief Resilience Officer, and Green Building Resource Center

Conduct Publicity and Outreach and Recruit Participants Office of Sustainability, Mayor’s Office of Communications, Chief Resilience Officer, and Green Building Resource Center

Grant Awards and Publicize Winning Projects Office of Sustainability, Mayor’s Office of Communications, Chief Resilience Officer, and Green Building Resource Center

INCREASED PERMITTING PROCESS CERTAINTY AND SPEED

Assemble Stakeholder Group Houston Permitting and Chief Resilience Officer

Develop Program Details and Name Houston Permitting and Chief Resilience Officer

Hire and Train Staff Houston Permitting and Chief Resilience Officer

Initiate Pilot Program and Fee Schedule Houston Permitting and Chief Resilience Officer

Evaluate Pilot Results Houston Permitting and Chief Resilience Officer

Revise Program and Fee Schedule Houston Permitting and Chief Resilience Officer

Implement Revised Program Houston Permitting and Chief Resilience Officer

Houston Incentives for Green Development: Implementation Schedule

38

2019 2020 2021 2022

4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q

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Trails connecting private development to large scale green infrastructure. Asakura Robinson

The recommended incentives provide the City of Houston with the opportunity to help make GSI implementation an integral part of “business as usual” for property developers in Houston.

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8.0Summary Support from the Houston Endowment has allowed the City of Houston to establish a more robust green stormwater infrastructure (GSI) program. The Houston Incentives for Green Development study has prioritized four practical, cost-effective and regionally appropriate incentives for private development that will lay a greener foundation for future development within the city. These incentives include:

1. Integrated Green Stormwater Infrastructure (GSI) Development Rules

2. Property Tax Abatements3. Award and Recognition Program4. Increased Permitting Process Certainty and Speed

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Green space along Buffalo Bayou. iStock/Sean Pavone

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Integration of green stormwater infrastructure into the planning and development of public and private assets needs to become “business as usual” for all property developers in Houston. The incentives would increase the chance of for GSI to become an integral part of how Houston “builds forward” to address our flooding challenges, while addressing water and air quality, urban heat island effect, and neighborhood beautification. Houston has taken strides towards a more holistic storm water management approach thanks to engagement with peer cities and key industries. Every property owner in developed environments now has an opportunity to blend green infrastructure components into retrofitted or future projects.

While improving storm water management, GSI would also boost economic performance, provide Houstonians with a better sense of safety and resilience, and make the city more attractive.

This report culminates the first steps towards building a robust green infrastructure program for Houston. The City now will take the lead by implementing the four incentives across departments, foster relationships with the private sector, and incorporate green techniques into public projects. This includes taking the opportunity to highlight green building actions in the upcoming Resilience Strategy and Climate Action Plan and ensuring implementation through Harvey recovery programs.

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Michael F. Bloom, PEMr. Bloom directs the Sustainability Practice for R. G. Miller Engineers, Inc., where he plans and designs natural drainage systems that increase operating income, reduce detention requirements, increase developable land, and provide an anchor for natural amenities that improve health outcomes and social connectedness. He recently served on Urban Land Institute (ULI) National Technical Assistance Panel for the municipality of Toa Baja, Puerto Rico, which was subject to catastrophic flooding during Hurricane Maria. He was an expert contributor to and reviewer of the ULI report Harvesting the Value of Water: Stormwater, Green Infrastructure,

and Real Estate (May 2017). He assisted with the preparation of Addressing Flood Risk: A Path Forward for Texas After Hurricane Harvey, published by the Texas Section of American Society of Civil Engineers. Michael is the current chair of the Houston Chapter of the Environment & Water Resources Institute of the American Society of Civil Engineers. Michael currently serves on the Public Policy Committee of the ULI Houston District Council and is a member of ULI’s National Community Development Council (Black Flight).

Janet ClementsMs. Clements has more than 18 years of experience in water resources planning and economics. She conducts benefit-cost, triple-bottom line, and economic impact analyses to evaluate the economic, social, environmental implications of water-related policies and programs. Her focus areas include integrated water resource management, green infrastructure and stormwater financing, and affordability of water and wastewater services. Ms. Clements has conducted several studies to quantify and monetize the benefits of green infrastructure and to develop market-based incentive programs for green infrastructure

implementation. Her clients include local, state, and federal governments, research foundations, and non-profit organizations. Ms. Clements received her B.S. in sustainable resource management from The Ohio State University and her M.S. in agriculture and resource economics from Colorado State University.

Alisa ValderramaMs. Valderrama is Founder and Principal of environmental advisory firm Neptune Street Advisors. Prior to launching Neptune Street, Alisa was the Director of Water Infrastructure Finance at the Natural Resources Defense Council (NRDC). At the NRDC from 2010 to 2018, Alisa initiated and led the organization’s work with cities focused on innovative urban water infrastructure finance. Alisa is best known for helping the Philadelphia Water Department structure its Greened Acre Retrofit Program, a reverse-auction inspired approach that helps the City locate and fund low-cost and socially-beneficial stormwater management projects.

Alisa has worked in partnership with a wide range of cities to design and implement markets in avoided stormwater runoff.

About the Authors

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Houston Incentives for Green Development

Financial Support Provided by:

NEPTUNE STREET ENVIRONMENTAL MARKETS ADVISORS

Page 1

PROJECT MEMORANDUM

Date: August 31, 2018 (Finalized April 30, 2019)

To: Laura Patiño

From: Michael Bloom, P.E. (R. G. Miller Engineers, Inc.)

Janet Clements (Corona Environmental Consultants)

Alisa Valderrama (Neptune Street Advisors)

RE: Results of Task 001: Research and Benchmarking

City of Houston Green Stormwater Incentives Study

Contract Number: 2018‐0351

RGME Project Number: R04333.00

This memorandum presents the findings from interviews with peer cities that have offered incentive

programs to encourage implementation of green stormwater infrastructure (GSI) at private development

and redevelopment sites. The following sub‐sections describe the interview process, the GSI incentive

programs that peer cities have implemented, city‐specific findings, and a synthesis of the general findings

from all interviews.

1.1 Interview Process

Over the course of eight weeks, the research team interviewed municipal staff from a selection of cities

that have offered (either in the past or currently) incentives for private property developers to use GSI to

manage stormwater at new development or redevelopment sites. The cities were selected on the basis

of having or having had incentives for developers to use GSI, being large enough to be relevant to a city

of Houston’s size, and based on the authors’ personal contacts within those cities. As shown in Figure 1,

the cities represent a diverse range of incentive strategies across the U.S., as well as a range of motivations

for promoting the use of GSI, mostly addressing Clean Water Act (CWA) compliance related to mitigating

combined sewer system overflows (CSO’s), reducing the discharge of pollutants in municipal stormwater

runoff under municipal separate storm sewer system (MS4) permits, achieving pollutant load reductions

to achieve watershed restoration goals established under total maximum daily loads (TMDLs),1 or to

achieve resiliency objectives.

1 Implementing load reductions required to achieve established total maximum daily load, which define the amount of a particular pollutant that can be assimilated by a waterbody without violating applicable surface water quality standards.

HOUSTON INCENTIVES FOR GREEN DEVELOPMENT: APPENDIX A - RESEARCH AND BENCHMARKING

Laura Patiño April 30, 2019 Page 2

Figure 1. Peer cities interviewed.

Through the interviews, the research team gathered information about the factors that led to program

success, as well as program challenges, and synthesized this information into a set of principles relevant

to the City of Houston regardless of topography or regulatory environment. The research team asked each

City interviewee the same set of questions about how local incentive programs were structured, whether

they were successful in motivating the use of GSI in development, and reasons for the program’s success

or failure.

2.0 Incentive Types and Terminology

For this research, we focused on programs that incentivize the use GSI practices at new and re‐

development sites, rather than the modification of existing facilities to incorporate GSI. Interviewees

identified a variety of incentives, which fall into four main categories as described below. Because cities

use differing terminology to refer to similar incentives, rather than use city‐specific terms we use more

general descriptive terms to explain the incentives and we define these in the text.

2.1 Intensity Incentives

Some of the most common GSI‐related incentives for new and redevelopment projects are intensity

bonuses. Intensity bonuses provide opportunities for greater intensity of development in exchange for

including public benefits, such as GSI, in a development or redevelopment project. Intensity bonuses offer

the option to include a greater number of apartments, more condominiums, larger retail space, more

finished floor area, or even more building height in exchange for the use of GSI. Three main types of

intensity bonuses include density bonuses, floor‐area‐ratio (FAR) bonuses, and height bonuses:



Relaxed Density Restriction (“Density Bonus”). A GSI density bonus allows a developer to provide

more dwelling units on a given size tract than would otherwise be permitted, in communities that

regulate development in this manner, in exchange for incorporating GSI. Density bonuses can allow

developers to add additional units to a building without adding to its’ size (e.g. creating smaller

dwelling units to fit more sellable units into a development). In the case where there are no height

restrictions or the height limit has not been met, a density bonus can also result in the opportunity to

build additional stories.

Relaxed Floor Area Ratio Restriction (“FAR Bonus”). A FAR bonus allows a developer to provide a

larger amount of floor area on a given size tract than would otherwise be permitted, in communities

that regulate development in this manner, in exchange for the use of GSI.

Relaxed Height Restrictions (“Height Bonus”). A height bonus allows a developer to build a taller

building than would be otherwise allowed in a location were building height is restricted in exchange

for the use of GSI.

2.2 Expedited Plan or Permit Review

Expedited reviews provide for a faster overall entitlement process including plan review, platting, permitting, and other required steps, in exchange for the use of GSI. Private development or redevelopment projects almost always rely on financing mechanisms that become more expensive as the duration of the loan is extended. This means that every day of delay in the permitting timeline directly impacts the project bottom line; therefore, obtaining an accelerated overall entitlement process in exchange for the use of GSI could be an effective incentive.

2.3 Alternative Standards

An alternative standard incentive allows a project to proceed under alternative platting rules, alternative

permitting rules, or alternative provisions of both, in exchange for the use of GSI. This approach must seek

to ensure that the project still achieves overall public health, safety, and welfare objectives, while

achieving GSI implementation objectives. Pathways for alternative standards may include reduced

parking, landscaping, or other requirements if a developer uses GSI to manage stormwater on‐site.

2.4 Fee Reductions

Fee reductions allow the development and redevelopment project to proceed with reduced permitting, platting, and impact fees in exchange for the use of GSI. The effectiveness of this approach depends on the existing fee structure and the amounts collected for various project types.

2.5 Direct Financial Incentives

Cities sometimes provide direct financial incentive, using a variety of methods, to encourage the use of

GSI on specific projects. Examples of direct financial incentives encountered during the interview

process include:

Tax Abatement. A tax abatement incentive delays, defers, or rebates property tax due on the finished

project in exchange for the use of GSI on the project. This directly benefits project sponsors that plan



to hold the finished project but has no incentive to project sponsors who plan to sell the asset upon

project completion.

Grant Program. Grants, rebates, or subsidies can be offered to project sponsors in exchange for the

use of GSI.

3.0 Findings by City

Table 1 below provides a summary of the key context and elements of the incentive programs in the

cities we interviewed.



TABLE 1 PEER CITY INTERVIEW RESULTS

City Driver Incentive Descriptions Other Remarks and Key Findings

HOUSTON: Population: 2.3 million / Land area: 674 square miles / Topography: Flat / Annual Rainfall: 50 inches / Hydrologic Soil Group In‐City: Type D / Surrounding: Type D

NEW YORK

Population: 8.18 million Land area: 303 square miles Topography: Flat Annual Rainfall: 46.2 inches Hydrologic Soil Group: In‐City: No Data Surrounding: Type A & C

CSO, MS4 Tax Abatement: Offered for 1 year on projects that use a green roof at a rate of $5 per square foot, up to $100,000 or the building's tax liability, whichever is less. Program ended because it was under‐utilized by property owners who saw it as too administratively burdensome.

Grant Program: Provides 100% reimbursement of design and construction costs for GSI that manage 1.0” of rainfall. The city is expanding program with a new category of dedicated funding focused on “greening” parcels over 50,000 square feet.

Coordinating projects with other agencies (e.g., City Law, Fire Department, Department of Buildings) is a major challenge to getting GSI projects on the ground.

Lack of political will also a factor limiting success of both incentive programs, with Mayoral attention focused on other topics.

Grant Program application process and restrictive covenants are burdensome which limits participation.

AUSTIN

Population: 790,390 Land area: 272 square miles Topography: Extremely hilly Annual Rainfall: 34.2 inches Hydrologic Soil Group: Dominant: Types B, C, D

MS4 FAR Bonus: Offers FAR bonus for each square foot of green roof provided on a sliding scale, with the largest bonus for green roofs that meet all design specifications and are visible to the public. FAR bonus can take the form of additional building height and is available in downtown area only.

Alternative Standards: Allows developers to implement GSI in area that would otherwise be reserved as a setback from the creek. Available in suburban watershed where large creek buffers are required.

Only one building has taken advantage of Height Bonus by using GSI because other developer decisions (like providing housing for lower income residents) can also provide this bonus.

NEW ORLEANS

Population: 343,829 Land area: 350 square miles Topography: Flat Annual Rainfall: 62.7 inches Hydrologic Soil Group: Dominant: Types C & D Notable: Types A & A/D

Resiliency Height Bonus: Offers height bonus to planned developments larger than 5 acres, located in certain areas of the City, that use GSI to store at least 25% more stormwater than required by ordinance or that provide water quality treatment for currently untreated off‐site areas.

Alternative Standards: Offers 15% reduction in parking requirements in exchange for GSI for projects meeting same requirements for the Height Bonus.

No developer has taken advantage of Height Bonus program. Not many developments are larger than 5 acres, and most developers are not aware of the opportunity.

New Orleans does not require GSI, but City’s encourages GSI by providing an online Stormwater Calculator helps developers demonstrate compliance with local Stormwater Ordinance, and the calculator makes only GSI options available.

SEATTLE

Population: 608,660 Land area: 84 square miles Topography: Rolling hills Annual Rainfall: 37.7 inches Hydrologic Soil Group: In City: Insufficient Data Surrounding: Type B

CSO, TMDL Alternative Standards: “Green Factor” program offers flexible landscaping code that encourages the use of GSI. The code includes a scoring framework that allows the developer to achieve a certain “Green Factor” score in various ways. It is generally easier to achieve the required score using GSI. Can result in implicit density bonus because the flexible landscaping code that encourages the use of GSI frequently frees up additional land for development by implementing multi‐functional design elements.

Cities considering programs like Green Factor should conduct a sensitivity analysis on some example projects to develop an appropriate scoring approach and refine the various GSI techniques that will be included.

Implementation of the Green Factor program required 18 months of meetings with architects, landscape designers, and developers to help build capacity and make sure new policies were understood.




PHILADELPHIA

Population: 1.53 million Land area: 142 square miles Topography: Hilly1 Annual Rainfall: 41.5 inches Hydrologic Soil Group: In‐City: Insufficient Data Surrounding: Type B, C

CSO

Height Bonus: Relaxed height restriction available in one area of city to developers who manage runoff from the right‐of‐way.

Density Bonus: Green roof density bonus available in three areas of city for developments that green 60% or more of the roof; provides exceptions to certain residential density rules.

Tax Abatement: Offers one‐time tax credit for green roofs; 2007 through 2015, tax credit was 25% of all costs incurred to construct green roof, not to exceed $100,000. For tax years 2016 and after, credit increased to 50% of all costs incurred to construct green roof, not to exceed $100,000. Implemented by Department of Revenue.

Expedited Review: For developments that meet onsite stormwater management regulations using GSI practices (applies to redevelopment projects only).

Alternative Standards: Exemption from flood and channel protection requirements for redevelopment projects that reduce impervious area by 20% compared to the pre‐construction impervious area.

Height bonus must be coordinated with City Planning Commission.

Tax abatement has not been widely used; provides credit on business taxes, so many institutional properties cannot benefit.

Density bonus and expedited permitting have both been relatively effective:

‐‐‐ Density bonus has been popular and beneficial to the City; 67% of the projects that have applied for the bonus would otherwise have been exempt from onsite stormwater management requirements.

‐‐‐The expedited review incentive has been effective—about 25% of developments take advantage of this incentive. Review by the water department is expedited, however, reviews by other departments are not.

Meetings with development community were key to effective program design for all incentives programs.

PORTLAND

Population: 583,776 Land area: 145 square miles Topography: Flat Annual Rainfall: 36.0 inches Hydrologic Soil Group: In‐City: Insufficient Data Surrounding: Type C, D

CSO

Rebate Program: Eco‐roof rebates ($5 per square foot offered from 2008‐2012)

FAR Bonus: Offered developers a larger development footprint or additional floor area than otherwise would have been allowed by code if the building proposal included an eco‐roof that meets specific requirements. Was only available in Central City Plan District area of city.

Alternative Standards: In some cases, city will allow developers to setback from street if they “green” the setback area.

Both the Rebate and FAR bonus were considered successful. Both could be used together, which provided further incentive/increased participation. Both programs have sunsetted. Eco‐roofs area now required for developments over 20,000 SF.

Incentive programs helped pave way to developer acceptance of GSI requirements.

Before incentives were turned into requirements, Portland Development Commission undertook a study of costs of the new regulatory requirements—found that eco‐roof adds 1‐2% to building costs. This helped to demonstrate benefit/cost ratio for developers. Also released a manual comparing eco‐roof maintenance costs to traditional roof—manual showed that eco‐roof have much longer useful life.

Educating key stakeholders including local politicians was key to getting regulations passed. Information was shared about how GSI improves public health, provides wildlife habitat, reduces localized flood risk, enhances aesthetics, and reduces heat island impacts. This was important for City Council.

MILWAULKEE

Population: 594,833 Land area: 97 square miles Topography: Flat Annual Rainfall: 34.8 inches Hydrologic Soil Group: In‐City: Insufficient Data Surrounding: Type C, C/D

CSO, MS4

Grant Program: Offers about $2.5M each year in a competitive grant program with awards made to only the top‐scoring projects. Grants cover 20‐50% of GSI construction costs, dollar amount varies based on type of practice.

The utility created the website: www.freshcoastguardians.com that offers tools for developers to decide how to comply with stormwater management ordinance.

Grant program helps dispel urban legends about GSI not working and perceived costs. Perceived high cost has been biggest challenge in getting developer community to adopt GSI.

Grant program is working, program is meeting its goals but they are still working on tracking longer‐term performance.




NASHVILLE

Population: 601,222 Land area: 526 square miles Topography: Hilly Annual Rainfall: 47.2 inches Hydrologic Soil Group: Dominant: Types B & C Notable: Type A

CSO

Fee Reductions: Certain stormwater and water / sewer plan review and application fees were waived if GSI is used. Stormwater user fees were reduced by up to 75% if GSI was used to manage stormwater. This program is no longer in place because GSI is now a requirement (as of 2016)

Alternative Standards: City offered bonus runoff reduction percentage above the actual reduction rate of green roofs (i.e., developer got credit for meeting regulations if they used a green roof, even if not met). In addition, city offered reductions in stormwater detention requirements if developer used GSI. This program is no longer in place because GSI is now a requirement (as of 2016)

Maintenance of GSI has been an issue, with property developers not maintaining the GSI once they install. City is currently working to improve design specifications so that the GSI is lower‐maintenance.

Incentives were not very successful. Neither the plan review fees nor the ongoing stormwater fees were high enough to make the GSI incentive economically attractive.

CHICAGO Population: 2.7 million Land area: 234 square miles Topography: Flat Annual Rainfall: 39.0 inches Hydrologic Soil Group: In‐City: Insufficient Data Surrounding: Type C & D

CSO

Expedited Review and Fee Reductions: Green Permit Benefit Tier Program offers expedited permitting and development fee waivers. Participants must obtain LEED® or Green Globes® certification and complete a selection of additional projects/requirements (e.g., GSI, affordable housing, bike parking, water management). Participants receive a dedicated Green Permit Project Administrator who helps guide the process and serves as a single point of contact for expediting the permit. In Tier 1, the goal is to provide the final building permit in 30 days or less. Tier 2 is aimed at projects that are looking to achieve higher levels of LEED® or Green Globes status. These projects are required to perform fewer of the city’s additional requirements. In addition to Tier 1 expedited permitting, Tier 2 projects can receive up to $25,000 in waived building permit fees.

Expedited Review: Green Elements Program aims to provide a one‐week turnaround for comments on plans submitted to the Building Department for projects that include green technologies. There is no dedicated project administrator to help guide the process. However, there is also no requirement to obtain LEED® or Green Globe certification.

At its peak, city processed about 50 Green Benefit Tier permits each year, and 150 Green Element permits.

City’s Green Permit Benefit Tier program was initially successful but changes to the underlying permitting process, such as the addition of online applications and third party facilitators, made it faster.

Neither program focuses solely on GSI but applies more broadly to “green strategies or green technologies,” (e.g., green roofs, solar panels, rain water harvesting, and other initiatives).

Multiple departments are involved in plan review; building department is only responsible for some aspects and can only expedite what they control.

City investments in online forms/processes and rise of third‐party expeditors have reduced need for expedited permitting.

City is focused on other priorities; new policies, codes, and regulations compete with voluntary program requirements.

Development standards for intensity, parking, landscaping, and other site design factors are often far upstream of program, making it difficult to incorporate.

NOTES:

1. Population estimates from U.S. Census. 2. Topography qualitatively characterized based on visual assessment of “Terrain” setting in Google Maps and Google Earth. 3. Annual Rainfall obtained from U.S. Climate Data. 4. Hydrologic Soil Group obtained from Environmental Systems Research Institute. 5. CSO: Obligations under a Combined Sewer Overflow mitigation Consent Order with state or federal regulators. 6. MS4: Obligations under a Municipal Separate Storm Sewer System permit issued under the Clean Water Act. 7. TMDL: Obligations imposed in a Clean Water Act wastewater or stormwater permit to achieve load reductions required by an adopted total maximum daily load.



4.0 Synthesis and Lessons Learned

The interview process revealed four main lessons which are described below.

4.1 Engage Local Stakeholders to Understand Local Needs and Build Program Support

Multiple interviewees stressed the importance of engaging local stakeholders to identify incentives that

will meet the needs of the local development community. For example, in Philadelphia, developers

communicated a high value for additional developable area. As such, the density bonus for green roofs

has been effective. In response to developer feedback, Philadelphia also recently enacted a height bonus

in one overlay district that allows developers to build additional building height if they provide open space

that manages stormwater runoff from offsite (i.e., the public right‐of‐way).

Conversely, in Austin (TX), staff noted that no developers have implemented green roofs to take

advantage of its Downtown Density Bonus Program, in large part because there are multiple other ways

to obtain the bonus (e.g., by providing affordable housing, cultural amenities) that are easier for

developers to adopt. New Orleans reported that no developers have used GSI to obtain the density bonus

because the bonus only applies to planned developments which are 5 acres or more and developments

this large are relatively rare. In Chicago, as the permitting process has gotten faster overall, the expedited

Green Permit process seems less enticing compared to the additional time it takes to coordinate with the

Building Department and follow design changes to meet additional requirements for the Green Permit

program.

Stakeholder engagement can help to build support for incentive programs and ensure effective program

design. Seattle began meeting with stakeholders (including design and engineering firms, developers,

commercial owners, and environmental advocates) as early as 18 months before it introduced the Green

Factor Program; Seattle credits private sector involvement as a key to program success. Conversely, New

Orleans indicated that a key reason that developers have not participated in their incentive programs is

because most are not aware of the opportunity.

Philadelphia continues to work with developers to adaptively manage it’s incentive programs.

Philadelphia formed a development services committee in 2012 to gather feedback and to understand

what could be improved. Philadelphia also reports that developers played a crucial role in working with

city council members to support the utility’s density bonus program.

4.2 Understand the Development Process

It is important to understand the development process so that a new GSI incentive does not add additional

steps or red tape to the process, thereby discouraging participation. A representative from the National

Association of Home Builders (NAHB) suggests that utilities and municipal departments should map and

understand each step in the development process, and the parties involved, to identify where and how

an incentive program would best fit. The NAHB representative also noted that development plans are

always changing, and developers are less likely to participate in GSI incentive programs if they are overly

prescriptive, time‐consuming, and/or inflexible.2

2 Project team member spoke with an NAHB representative as part of research on incentive programs for the water Research Foundation; publication is forthcoming.



Several utilities have experienced difficulties integrating incentive programs into the development

process and timeline. For example, Chicago found that development standards for intensity, parking,

landscaping, and other site design factors were often addressed early in the development process, while

GSI site design often was not incorporated until later. This made it difficult for the city to incorporate

incentives that would allow for alternative standards or offer intensity bonuses. With its grant program,

Milwaukee Metropolitan Sewerage District (MMSD) has found that when projects go into final design,

they often change and become smaller. This affects the amount of funding needed by the applicant,

making it difficult for MMSD to fully allocate funds under its grant program. Similarly, the Northeast Ohio

Regional Sewer District has found that the one‐time annual application and contracting process

(contracting process typically takes six months) for its grant program does not fit in well with the timeline

of development projects. The District therefore receives very few applications from new and

redevelopment projects, and typically only funds retrofits.

Others have found that it is also important to understand the role of different departments in the

permitting and plan review process. For example, cities such as Chicago and Philadelphia that offer

expedited permitting note that their stormwater departments are only responsible for one aspect of the

review process; if other departments are slow in reviewing plans or issuing permits, then expedited

stormwater plan review or permitting process will not provide much of an incentive.

4.3 Understand and Show Value

To help set the stage for success, many utilities have promoted incentive programs by modeling the

potential impacts of a successful program in terms that local stakeholders value. For example, if there is

strong community support for protecting water quality, as there is in Austin, frame the impacts of the

incentive in terms of improved water quality. If there is a core group of advocates who are organized

around urban heat island impacts, or localized flooding in a specific set of neighborhoods, modeling and

analysis can help these groups understand how proposed incentives policies can make a positive impact

on the issues they care most about. Portland also found that most stakeholders do not care about

stormwater management per se, and that framing GI as a way to improve public health and ecosystems,

and reduce the urban heat island impacts was much more effective in gaining buy‐in.

Demonstrating the cost savings and benefits associated with GSI can also help developers understand what else they might receive. According to NAHB, cities who can clearly demonstrate how an incentive will provide value to a developer or building owner are more likely to see uptake. In addition, the project team’s previous research with private‐sector representatives has revealed a need for more information on how GSI can add value and/or increase their financial return on investment.

Working closely with local developers can help a city understand the benefits and costs of GSI from the

perspective of a developer. For example, Portland analyzed project costs for eco‐roofs (the practice they

were focused on motivating), finding they added only between 1‐2% to a development’s total cost.

Portland also put together a two page handout that compared the cost of maintaining an eco‐roof with

the cost of a traditional roof—the handout showed how the maintenance costs were similar, but the eco‐

roof had a much longer useful life, which resulted in significant cost savings. Having these local cost figures

available can help the City “sell” the incentive programs, both internally and to developers. It can also

help to calibrate incentives so that the cost of responding to the incentive does not outweigh the benefit

conferred by the incentive.



Finally, several interviewees also noted that one or more highly visible initial projects can help to

demonstrate the benefits and effectiveness of GSI to all stakeholders.

4.4 Anticipate Incentive Evolution

The level of community awareness around stormwater issues and GSI is an important factor for utilities and municipalities to consider when figuring out “where to start.” For example, Philadelphia credits early stormwater‐related efforts (such as establishing an impervious area‐based stormwater fee; GSI‐based development requirements; and the rollout of its Green City, Clean Waters plan) as a key factor in its ability to develop a large‐scale grant program and incentives for new development and redevelopment projects. Portland serves as another example of a utility that has successfully built public support over time by targeting easy interventions and creating education opportunities.

In many cases, a city began with one specific

incentive and only saw uptake once the first

incentive was bundled with additional

overlapping incentives. For example, in

Philadelphia, a developer who uses GSI can not

only exempt themselves from certain permit

requirements, but they also receive an ongoing

financial benefit in the form of reduced

stormwater fees, so long as they maintain the

GSI on their site (this is somewhat unique to

Philadelphia, where stormwater fee reductions

provide substantial motivation to implement

stormwater management practices). In

Portland, developers were able to take

advantage of the city’s eco‐roof rebate program

as well as the eco‐roof density bonus. Staff

maintains that this greatly increased

participation in both programs.

Many cities interviewed also now require GSI

for meeting on‐site stormwater management

requirements, including Nashville, Portland,

and San Francisco. These cities report that

incentive programs helped to pave the way for

developer acceptance of regulations that the

cities later introduced. Alternatively, a City may

Adding Incentives Incrementally in Portland

The City of Portland’s Ecoroof incentive was developed as a way

for the City to expand the use of green stormwater management

infrastructure by increasing the frequency and affordability of

green roofs on private and public buildings within the City. The

City hoped that the incentive would promote the development

of a small, local, industry of contractors and installers by

decreasing installation costs while the industry developed.

Beginning in 2008, Portland offered property owners and

developers an Ecoroof construction incentive of $5 per square

foot in the form of a subsidy. The program had specific project

selection criteria including: (1) The project had to be within in

the Portland city limits; (2) Designed to manage stormwater;

and (3) feasible and buildable within two years of receiving

funds.

Portland also evaluated projects based on cost estimates, size,

ratio of green roof to total roof area, visibility, innovation, and

the opportunity to engage diverse communities.1

In 2001, an additional incentive was added to the Eco‐Roof

program, in the form of a floor‐area‐bonus. The FAR bonus

allowed to a developer or builder depended on the percentage

of Ecoroof coverage in relation to the building footprint.

Building proposals in the Central City Plan District with an

Ecoroof were eligible to receive bonus floor area as follows: 10‐

30% Ecoroof coverage earns one (1) square foot of additional

floor area per square foot of Ecoroof; 30‐60% Ecoroof coverage

earns two (2) square feet additional floor area per square foot

of Ecoroof; and 60% or greater Ecoroof coverage earns three (3)

square feet of additional floor area per square foot of Ecoroof.1

The combination of the direct subsidy with the density bonus

was successful in compelling many developers to install eco‐

roofs. From 2008‐2014, Portland granted almost $2 million in

incentives, which helped fund over 130 projects, creating more

than 8 acres of Eco‐Roofs, managing an average of 4.4 million

gallons of stormwater each year. In 2011, when regulations

were being updated, Portland opted to turn the incentive into a

requirement. A key to this shift was that developers had already

gotten used to Eco‐Roofs through the incentive programs.

Today, any new development over 20,000 SF is required to use

an Eco‐Roof.



want to raise the bar for meeting incentives after several years if the City believes that developers could

be doing more.

4.5 Coordinate Internally

Other city processes and programs can affect the success of incentive programs. In New York City, there

has been scant uptake of either GSI incentive ‐‐the Green Roof Tax Abatement or Green Infrastructure

Grant—in large part because of weak coordination across city departments and pushback from some city

agencies (including Department of Buildings, Fire Department, and others). To successfully implement

incentive programs requires top down direction (e.g., from the Mayor’s office) and strong coordination

across all relevant city departments or agencies that must make platting and permitting decisions.

In addition, if GSI is a high priority for a municipality, it is important to ensure it is not eclipsed by other options available to developers seeking development incentives.

4.6 Innovative Practice: Consider the ROW

Getting creative with how the city’s ROW can be developed to meet mutual goals of enhanced stormwater quality and working with the development community to utilize more of a site’s lot area can pay dividends. Seattle’s Green Factor allows bonus points for installing GI in the ROW. This helps the city provide a greater water quality benefit for water flowing across the ROW to the storm sewer, and also allows the developer to count the ROW as part of the required lot area that must be vegetated. In Philadelphia, developers can get a height bonus if they manage runoff from the public ROW. 5.0 Summary Only a few of the cities interviewed reported great success in using incentives to encourage the use of GSI

on private property. The interview results suggest that, while the specific reasons across cities are

nuanced, the core issues cities have struggled could be boiled down to, either a failure to draw adequate

developer attention to the incentives; or a lack of attention to GSI economics from the perspective of

developers (i.e., ensuring that the installation of GSI not too costly relative to the benefit offered by the

incentives).

Understandably, cities impose a range of requirements on developers to help ensure that public health,

safety, and welfare is maintained and preserved, that life sustaining utilities (power, water, sanitary

service, transportation, etc.) can be effectively provided, that hazards from fire or floods are adequately

mitigated, and so that cities can grow and evolve in an orderly manner. Private development projects

must comply with this very long list of requirements, while delivering a finished project that pleases users,

visitors, tenants, occupants, customers, all the while, providing expected financial performance to

investors, lenders, and partners. This creates a natural tension between the interests of the city and the

private developer.

The key challenge for all of these programs appears to be determining how and to what extent the use of

GSI on private property can help achieve both private developer project goals as well as city objectives.

For these programs to work, it is important to:



Identify incentives that will help developers achieve financial objectives and help the city achieve its

general welfare objectives;

Collaborate with the development community to understand factors that will encourage or

discourage participation; and,

Collaborate across all implementing city departments to help set the stage for smooth

implementation.


Page 1

PROJECT MEMORANDUM

Date: October 3, 2018 (Finalized April 30, 2019)

To: Laura Patiño

From: Michael Bloom, P.E. (R. G. Miller Engineers, Inc.)

Kaitlin Obrien‐Friesenhahn (R. G. Miller Engineers, Inc.)

RE: Results of Task 002: Work with Private Developers

City of Houston Green Stormwater Incentives Study

Contract Number: 2018‐0351

RGME Project Number: R04333.00

The following memorandum summarizes the findings from our interviews with private real estate

developers working in the City of Houston. Interviews were conducted to obtain information on project

costs, familiarity with green stormwater infrastructure (GSI), challenges with permitting projects in the

City of Houston, and ideas for how to incentivize the use of GSI.

1.0 Process Overview

On May 16, 2018, the City of Houston convened a meeting with real estate development trade

associations to identify participants in the GSI incentives study. The meeting was attended by

representatives of the American Council of Engineering Companies, the Urban Land Institute – Houston

District Council, the Greater Houston Builders Association, and the Houston Real Estate Council (the “trade

groups”). During the meeting project team, led by R. G. Miller Engineers, Inc. (RGME) explained the

purpose of the study, the types of developer participants desired, the level of effort required by

participants, and the overall schedule. RGME explained that the team hoped to obtain information from

developers working at all scales and types of development, including commercial, residential, and

institutional projects.

On July 11 and 12, 2018, the city convened a kick‐off meeting with the developers identified by the trade

groups. The consulting team presented an overview of GSI, discussed some of the incentive concepts

under consideration, reviewed a detailed Project Information Template form (provided in Enclosure A)

that participants were asked to complete for each project they agreed to share with the project team,

reviewed the level of effort required to complete the effort, and reviewed the schedule.

From August 1, 2018 to September 25, 2018, the project team conducted in‐person debrief meetings with

each of the developers who had completed a Project Information Template to discuss the content of each

template and to more thoroughly understand project details.

HOUSTON INCENTIVES FOR GREEN DEVELOPMENT: APPENDIX B - STAKEHOLDER ENGAGEMENT


2.0 Findings

The following subsections provide a summary of the findings from each of the Project Information

Templates and debrief meetings. Due to the limited number of completed Project Information Templates

received and the lack of existing GSI projects, the results of this process should not be viewed as definitive.

These findings will likely help to inform the development of incentives and to estimate threshold points

in later phases of this project.

2.1 Single Family Residential Development with Public Infrastructure

A non‐profit developer of a 26‐acre subdivision with about 111 small lot homes intended for low to

moderate‐income owners indicated that their developer participation contract (DPC) with the city was a

key element of their business model. The developer reported that their DPC provided a cash

reimbursement from the city of 70% of the cost of water, sewer, and drainage utilities on the tract, plus

$2,500 per home. The developer reported that the city assumed ownership and operation of these

utilities and the roadways after project completion. The developer reported that the project did not

include any GSI on the private lots; however, the developer expressed interest in implementing grey water

and rainwater‐harvesting systems in future projects.

The developer reported that the project included three 7,500 square foot pocket parks to meet the

required landscape area reserve requirements. The developer reported that they provided two trees in

the front yard of each home as required by city code.

The developer reported that they purchased the land for $500,000 ($19,230 per acre), constructed the

streets and utilities, and the homes, with much of the labor and materials necessary to build the homes

donated. Total estimated costs for the land, site development, and home construction was reportedly

$3.18 million (prior to city reimbursement). The developer indicated that they sold the finished homes

for $120,000 each, realizing $13.32 million in gross proceeds.

Stormwater flowed over building roofs, across yards and driveways, along public streets, into public curb

inlets, through public traditional concrete storm sewer pipes, into a traditional, end‐of‐pipe, public dry

detention basin, with a trash rack for stormwater quality control, and hence to a HCFCD channel. The city

currently does not utilize GSI in public rights of way and storm sewer systems, except in a very small

number of pilot projects. The project sponsor’s use of GSI in the public rights of way and storm sewer

system serving this type of development, if acceptable to the city, might help reduce the overall capital

cost of the infrastructure, as illustrated in prior studies.1 The city and the developer could pass these

savings on to the homeowners or the savings could help reduce project‐financing costs and defray other

development costs incurred by the non‐profit.

1 See Stonebrook Estates case study in Burgess, Katharine, et. al. Harvesting the Value of Water. Washington DC: Urban Land Institute, 2017 and Ring, Justin. Talking Dollars and Sense: LID Construction Costs. Proceeding of the American Society of Civil Engineers, International Low Impact Development Conference, Houston, Texas. Washington DC: ASCE, 2015.



The developer indicated that they built stormwater conveyance systems and the developer indicated that

the City of Houston accepted the system as a public utility and reimbursed the developer for 70% of the

associated costs. The developer indicated that they provided traditional end of pipe stormwater detention

with a trash rack. The developer indicated that the City of Houston accepted the system as a public utility

and reimbursed the developer for 70% of the associated costs.

2.2 Urban Patio Homes

A developer‐builder of an urban, 12 lot, patio‐home, single‐family residential development inside the loop

was most concerned with permitting time delays. They reported that permits for each home in their

development took 80 days to obtain. The developer‐builder said they sold the two‐story patio homes,

which sit on 25 ft. by 131 ft. lots, for about $500,000 each. The developer said they did not provide any

detention on the project because the development type and lot size did not trigger detention

requirements under Chapter 9 of the Infrastructure Design Manual in effect at the time. The developer

reported detention costs on other projects as ranging from $5/cubic feet for a simple excavated earthen

basin to $20/cubic feet for underground vault type systems.

The developer suggested that the developer’s authorized use of the public alley, for improvements or for

GSI, would add value to the project and the neighborhood. The developer suggested that the poor

condition of public alleys currently hinders development and home sales and ally improvements, such as

GSI implementation would help the situation. The developer also indicated that the city was inflexible in

their enforcement of the setback line requirement for the garage door (relative to the public right of way).

The builder also suggested that the required setback between the building envelope on a corner lot and

the public right of way should be more flexible. Current rules require that a building sitting on a corner

lot be located the same distance from both property lines. The city might be able to relax this requirement

in exchange for GSI use.

The developer indicated concern about the city‐imposed “open space” fee of $800 per unit. The developer

understood that the city used this fee to create new parkland, but questioned whether this was actually

occurring. The developer suggested that the city should provide more choices, more flexibility, and

quicker permitting to incentivize GSI. The developer suggested that a 17 ft. setback for garages was too

large and that it should be changed to 15 ft.

The developer said they did not provide stormwater conveyance system cost. The developer said they

provided no stormwater detention on this project because none was required by Chapter 9 of the

Infrastructure Design Manual.

2.3 Urban Town Homes

The developer of an urban, three‐unit, town home development with one detached and two attached

units and a shared driveway was most concerned with permitting time and a building code issue that was

not identified until very late in the construction process. This developer reported that permitting took

five months. During plan review, framing review, and other inspections the developer reported that the

city failed to notify them that the windows on the second floor were not large enough to serve as fire



escape routes as required by the applicable building code. The developer said the city did not inform the

developer of this issue until project construction was substantially complete.

The developer reported that they used a permeable driveway product consisting of aggregate secured

with a plastic lattice structure at a cost of $8 per square foot, instead of traditional concrete at a cost of

$5 per square foot to eliminate the requirement to install detention. The engineering plans showed a

concrete shared driveway with 949 cubic feet of detention provided in the driveway, in the backyards,

and in the storm sewer system. The design plans indicated that 818 cubic feet of detention was required

by code.

The developer reported a concern with the tree and shrub requirements imposed by the city under

Chapter 33, Article V, of the City Code of Ordinances. The city required planting of three trees, one for

each unit, along the public right of way, instead of in the side yards or backyards of the units. The city

could encourage GSI use by adding some flexibility to this requirement.

The developer suggested that the city might consider allowing green roof areas with public access to serve

as open space for the purposes of complying with the open space reserve requirements in city platting

regulations. This would help reduce developer fees to the park fund and would help free up additional

developable land.

The developer said they did not provide stormwater conveyance system cost. The developer said they

provided 949 cubic feet of stormwater detention at no additional cost because it was provided in the yard

and driveway grading and in the conveyance pipes.

2.4 Retail Shops and Bar

A civil engineer performed a feasibility study evaluating the site development costs to convert an existing

warehouse into retails shops and a bar. The engineer reported that the project did not get built. The

engineer reported the lot size was 39,200 square feet, with about 9,000 square feet of finished interior

building space. At the time of the feasibility study, the city did not require any stormwater quality facilities

on sites less than 1 acre, so the work would not require any stormwater quality facilities. The engineer

estimated that about $7,000 of detention would be required, utilizing a permeable paving system with

aggregate porosity providing the required volume of 2,178 cubic feet, at a cost of $3.21 per cubic foot.

The engineer suggested the installation of a $2,000 rainwater harvesting system. The engineer reported

that the change in property use triggered the need to add additional parking spaces that would not fit on

existing paved areas. The engineer reported that about 19,600 sq. ft. of parking would be needed for code

compliance.

The engineer examined methods to avoid an increase in impervious area and, thus, to avoid the

requirement to add additional detention. The engineer reported that the requirement to install shrubs

and trees around and in parking lots is very prescriptive and the city should consider modifying the list of

shrubs and trees to include types appropriate for GSI installations. The city currently requires the use of

24‐inch reinforced concrete pipe or larger, to connect private storm sewers to public storm sewers. The



city should consider changing this, because that size is frequently much larger than necessary to convey

the actual discharge rate.

The engineer suggested that the city should add more flexibility to rules governing use of the public right

of way and perhaps allow more encroachment agreements that would maximize the public and private

benefits in the boundary between public land and private land. The engineer also suggested that fee

reductions should be granted in exchange for the installation of electric vehicle charging stations,

permeable paving systems, and GSI. The engineer suggested that GSI could be installed in public alleys.

The engineer also suggested that a city‐run awards or recognition program might help incentivize GSI.

The engineer estimated that the project would require a stormwater conveyance system costing about

$26,000, about 25% of total estimated project rehabilitation costs. The engineer estimated that no

detention would be required on the project, based on the date of the study.

2.5 Four‐Story Office and Apartment

A civil engineer performed a feasibility study of a four‐story building that would include both apartments

and office space. The developer proposed to build the project on a 24,800 square foot (0.57 acre)

greenfield site along a bayou with some floodplain encroachment. The engineer determined that the

project should provide about 15,000 square feet of parking and 2,600 square feet of landscaping to meet

code requirements. The planner envisioned an elevated parking structure wrapped around the building

to achieve the parking requirement. The engineer proposed a traditional project with no GSI.

The site did not require any stormwater quality facilities due to its small size. The engineer expressed

concern that stormwater conveyance was limited to reinforced concrete pipe that was no less than 24”

in nominal diameter. The engineer reported that this particular project was planned with a zero‐lot line

setback, due to the surrounding publicly owned open space along the bayou.

The engineer estimated that stormwater conveyance systems would be required at a cost of $26,000,

representing about 2% of total estimated project costs. The engineer estimated that about 15,680 cubic

feet of detention was required to mitigate floodplain fill at a cost of $180,000 and about 10,454 cubic feet

of detention was required to mitigate the increase in impervious cover at a cost of $120,000. The engineer

proposed a below grade vault system to provide the required total 26,136 cubic feet at a cost of about

$11.48 per cubic foot.

2.6 Low Rise Commercial Redevelopment

The developer purchased a 6.5‐acre site with an existing 45,000 square foot building and parking lot and

rehabilitated the building to serve a new commercial tenant. The developer planned to hold the asset,

earn lease revenue, and eventually sell the project to realize asset appreciation. The developer reported

that customers would access the site, which is located outside of the IH‐610 loop, via automobile. The

developer reported that an existing private storm sewer system drains the building roof and 40% of the

120,000 square foot surface parking lot to an existing detention basin with about 35,000 cubic foot of

surface storage. About 60% of the existing parking lot drains via sheet flow to adjacent public rights of



way. The developer reported total construction costs were $6 million. The developer reported that they

built a traditional project with no GSI.

The developer indicated concerns regarding the adequacy of the existing detention facility, which the

original site developer installed prior to 2000 and which only serves 40% of the property. The developer

reported a $1.0 million additional cost to upgrade the detention to meet current requirements. The

developer reported that the project financials did not support this added cost, so the developer elected

not to perform these upgrades.

The developer reported that the inefficient and uncoordinated permitting process took five months. The

developer indicated that permitting should have taken only two months. The developer paid $150,000

for plans and permitting and $50,000 in impact fees.

The developer reported that the redevelopment reduced impervious site area from 215,000 square feet

to 210,000 square feet. Because permitting occurred prior to September 1, 2018, the developer reported

that site work did not include additional detention.

The developer expressed concern about the detention and floodplain requirements that became effect

on September 1, 2018. The developer indicated that the city should impose detention requirements using

a hydrologic basis, so that the post‐development flowrate does not exceed the pre‐development flow‐

rate, instead of using the impervious area in the calculation. This would sometimes allow a smaller volume

of detention to be provided while still achieving the objective of no increase in the peak site runoff rate.

They suggested that a property tax deduction or deferment would incentivize GSI use. They also suggested

that a certain amount of the City of Houston’s collected drainage fee could provide a cash reserve that

could be used to incentivize GSI. The developer also suggested that imposing a reduced detention

requirement in exchange for the use of GSI would incentivize its use.

The developer also suggested that the city should allow multiple property owners and public entities to

collaborate and cooperate on drainage issues. The city should include the use of GSI in development

agreements it executes with developer partners. The developer also suggested that the city should allow

the use of natural vegetation that requires less irrigation.

The developer evaluated the costs associated with rehabilitation of the existing building along with reuse

of the existing site parking and drainage facilities and compared that total cost with the cost of clearing

the site and building all new site parking, drainage, and a new building. The project team reported that

the cost to build new (approximately $1.5 million higher) was not justified by the higher quality end

product; therefore, the developer elected to reuse site facilities and the building instead.

The developer maintained existing stormwater conveyance systems at essentially no additional cost. The

developer maintained 35,000 cubic feet of existing stormwater detention at essentially no additional cost.

2.7 Low Rise Mixed Use Redevelopment



The developer demolished an existing development and then constructed this five story mixed use

redevelopment constructed on about 14 acres inside the 610 loop. The developer reported that the new

project included 662,000 square feet of finished interior space, a 1,068‐space parking garage, about 1.3

acres of landscaping. The developer reported the parking area provided met commercial requirements

and exceeded code requirements. The developer considered adding a green roof to both the main

buildings and the parking garage, in order to reduce the impervious surface area, but the added cost to

add a roof to the top floor of the parking garage precluded this option. The developer’s design team

indicated that the allowed trees and shrubs don’t perform well in GSI applications and additional or

alternative species should be added to the regulations. Details regarding this issue were not provided.

The developer reported that the project team sought to provide a private valet parking lane in the public

right of way, but that request was denied by the city. The developer reported that the design team

indicated that the city should enter into encroachment agreements with private developers to allow for

creative potential use of portions of the public right of way for GSI and other purposes that achieve public

and private functional objectives, such as parking, stormwater management, bike lanes, pedestrian areas,

open space, etc.

The developer reported that the project incurred impact fees for water of $46,900 and for wastewater of

$95,500, and permitting costs of $250,000. The developer reported a total construction cost for the

project was $320 million. The developer did not provide any stormwater quality facilities because the

project was permitted prior to a rule change.

The developer reported that the minimum width of the loading dock driveway forced a redesign of that

portion of the site. The developer reported that they provided 45,600 cubic feet of detention at a cost of

$550,000, representing about 0.20% of total project costs. The developer reported that they provided

stormwater conveyance systems at a cost of $500,000, representing about 0.16% of total project costs.

2.8 Gated Single‐Family Residential Development

The developer provided information about a 5‐acre development with 51 lots. The developer reported

that they built a gated, single‐family residential development with private roads and utilities. The project

reportedly provided homes of average floor plans of 2,700 square feet and an average sale price between

$500,000 and $600,000 each. The developer indicated they provided two off‐street parking places for

each residence in individual two‐car garages. The developer indicated they provided a total of six

additional parking spaces for visitors in common areas. The developer suggested that parking city‐

imposed requirements could be reduced in exchange for the use of GSI. The developer indicated that

association rules will prohibit on‐street parking.

While the developer reported that tree and shrub requirements did not lead to challenges on this project,

they suggested that the use of GSI could be used to address lost trees. They also suggested that permeable

paving systems be allowed in more circumstances. The developed suggested that the city should add

additional flexibility to the width requirements for permanent access easements (PAEs) to help promote

the use of GSI. The developer expressed concerns about the 25‐ft. set‐back requirement along major

thoroughfares, which prohibits building construction in that space. They suggested that the set‐back



distance should be reduced in exchange for GSI use. The developer suggested that a reduction in required

detention volume would serve to incentivize the use of GSI.

The developer reportedly provided stormwater conveyance systems at a cost of $566,000, representing

about 2.4% of total project costs of $23 million. The developer reportedly provided 17,500 cubic feet of

stormwater detention at no additional cost, because detention was provided in the conveyance system

and in the private streets. The developer indicated if the project was permitted after September 1, 2018,

then 68,800 cubic feet of detention would have been required; an increase of almost 300%.

2.9 Mid Rise Multifamily and Commercial New Development

The developer reported information regarding a 1.9‐acre portion of a larger urban infill project that will

include residential, office, retail, food and beverage, and hotel space for rent, lease, and purchase. The

developer reported that the 1.90‐acre portion of the project will include multi‐family residential with

some commercial space. The developer reported that the project will include both below grade and above

grade garage structure parking. The developer reported that office space will be LEED certified to attract

tenants and that green space will be central to development to attract retail and food and beverage

customers. The developer reported that the development will include private interior roadways.

The developer reported that entitlement schedule certainty was more critical than overall duration. Total

construction costs are reportedly estimated to be about $150 million. The developer reported that they

almost always provide more parking spaces than code requires for business reasons. The developer

reported that the multi‐family residential platting requirements are flexible and they don’t see the need

for any changes.

The developer estimates that about 1.05 ac‐ft of pumped detention will be required to serve the 1.90 acre

portion of the development (in accord with post‐September 1, 2018 requirements). The estimate is based

on 90% impervious cover. The develop indicated that stormwater quality will be addressed with a trash

rack or a similar device.

The developer indicated they provided stormwater conveyance systems at a cost of $244,000,

representing about 0.16% of project costs. The developer indicated they provided 45,717 cubic feet of

below grade, pumped stormwater detention at a cost of $379,077, representing 0.25% of total project

costs.

2.10 Large Waterfront Multi‐Family Development

The engineering team for a large, waterfront, multi‐family development still in design provided

information about a 136‐acre portion of a 308‐acre overall development program. The engineer reported

that the 136‐acre tract would include 66 buildings on piers with a total of 6,000 living units. About 12,000

parking spaces are planned in elevated structures below the living spaces but elevated above the natural

ground surface to minimize wetland impacts. The engineer reported that the project will include about

13 acres of landscaped areas, but planners oriented the project to preserve as much of the natural areas

around the tract as possible.



The engineer reported total finished floor space will be about 5.9 million square feet and the cost for the

development of the 136 acres will be $551 million. The engineer reported that onsite stormwater

conveyance will cost $7 million, or about 1.3% of total costs. The engineer reported that pond systems

will provide about 70 acre‐feet of detention for stormwater mitigation and 105 acre‐feet for flood

mitigation purposes at a cost of $1.2 million. Ponds and trash racks will provide stormwater quality

treatment. Engineer reported that impact fees for water and wastewater combined will likely equal $4

million.

Engineer wanted to place wet utilities under the roadway pavement to reduce the project footprint and

impacts to existing wetlands, but was unable to do that because of current city rules. The engineer

reported that the city’s revised floodplain ordinance and elevation requirements has significantly

increased project costs. Engineer indicated that natural area preservation should be incentivized.

Engineer suggested that tree replacement will be challenging to accomplish giving the extent of the site

wetlands and natural areas. Other incentives mentioned included: expedited permit reviews, reduced

impact fees, and reduced property taxes.

3.0 Discussion of Developer Feedback

Developers shared feedback on the land development entitlement process and provided thoughts about the types of incentives that could be implemented to encourage the use of GSI. 3.1 Incentive Ideas The key ideas developers shared for how the City could motivate developers to use GSI are summarized below: Open Space Reserves: Provide reduced dedication of open space reserves in exchange for GSI use,

perhaps by building upon or modifying the existing park funding program. Developer Participation Contracts or Agreements: Provide incentives in the terms and conditions of

DPCs or DPAs, perhaps with GSI built in the public right of way and long term maintenance agreements and bonding.

Permitting Time Certainty: Provide a more certain time frame for the permitting process (as opposed to shortened permitting time).

Set Back Lines: Reduce setback line distances in exchange for GSI use. Cash Incentives: Provide cash incentives realized from either deferred property tax bills, waived or

reduced utility impact fees, or payments from some other dedicated fund would all be helpful. Tree & Shrub Requirements: Provide plant list that is more consistent with GSI facilities. Provide

options to relocate trees or shrubs away from the public right of way in exchange for GSI use along public right of way.

Right of Way Use: Use encroachment agreements (including long term operations and maintenance provisions) to enhance the use of the boundary between private and public property. Encourage creative GSI use of the public right of way that is not used for vehicle or pedestrian traffic.

Rainwater Harvesting: Encourage the use of rainwater harvesting systems and provide streamlined entitlement process.

Gray Water: Encourage use of gray water systems and provide streamlined entitlement process.



Parking Requirements: Provide reduced parking requirements in exchange for GSI. This may be underutilized in some types of development, because mixed use, beverage and food, commercial developments tend to provide more parking than required by code for business reasons.

Detention Requirements: Provide reduced detention requirements in exchange for the use of GSI. Detention Volume Trading: Provide banking and trading platform for detention volume. Xeriscaping: Allow the use of low water‐demand plants in plant lists and other landscaping

requirements. 3.2 Summary of Cost Information Table 3‐1 presents a summary of the cost information obtained from the participating developers.



Page 1

Table 3‐1 Summary of Cost Information



3.3 Unit Cost Ranges Developer feedback and cost information indicates the full costs associated with stormwater conveyance systems, detention facilities, and stormwater quality facilities should be examined to determine the design of incentive programs. Table 3‐2 presents a summary of the key unit cost information obtained from developers.

Table 3‐2 Summary of Unit Cost Information

Unit Cost Low Average High

Onsite, Private Drainage Conveyance System

Cost/Acre $28,889a $67,074a $128,421a

Onsite, Private Detention Cost/Cubic Foot $0.39b $5.90b $12.00b

Onsite, Private Stormwater Quality Facilities

Cost/Acre ‐ $14,706c ‐

NOTES: a. Based upon six projects with necessary information to calculate unit costs. b. Based upon five projects with necessary information to calculate unit costs. c. Only one project provided the necessary information to calculate the unit cost.

4.0 Next Steps The consulting team will use the developer information received during this phase of work to proceed with a further review of financial information, identify implementation barriers, and challenges, develop draft incentive programs, and identify potential GSI techniques to be incentivized. These future tasks will be outlined in subsequent memoranda.



ENCLOSURE A DEVELOPER PROJECT INFORMATION TEMPLATE


July 2, 2018 Page 1

HOUSTON GREEN STORMWATER INFRASTRUCTURE INCENTIVES STUDY

REAL ESTATE DEVELOPMENT / REDEVELOPMENT

PROJECT INFORMATION TEMPLATE

The City of Houston’s Chief Resilience Officer is conducting a study to develop a suite of green

stormwater infrastructure incentives that will propose changes to the development and redevelopment

process sufficient to create meaningful financial, economic, business, or similar benefits so that private

development or redevelopment projects utilize green infrastructure for business reasons while achieving

a similar or better stormwater management level of service.

This form is intended to collect information from real estate development and redevelopment

professionals about a variety of things, including: ideas about what incentives might include or look like;

current process challenges and permitting challenges; perceived opportunities for process changes; ways

to save time; ways to obtain relief from platting, design, or permitting requirements while achieving a

similar or better stormwater management level of service; and selected project financial information.

This form is designed to collect detailed project‐specific information in an anonymous format. Please do

not include any company or project information (such as the address or proper name) that would reveal

confidential business information.

1. Project Characteristics:

1.1. Project Type? Circle One (or both, of you develop both types of projects):

1.1.1. Development

1.1.2. Redevelopment

1.2. Product Type? Circle One:

1.2.1. Single Family Residential

1.2.2. Multi‐Family Residential

1.2.3. Low Rise Commercial

1.2.4. Mid Rise Commercial

1.2.5. Industrial

1.2.6. Low Rise Office

1.2.7. Mid Rise Office

1.2.8. High Rise Office

1.2.9. Other (Specify): _____________________________________________


Project Information Template

July 10, 2018 Page 2

1.3. Business Model:

1.3.1. Lease Income?

1.3.2. Sale Proceeds?

1.3.3. Rental Income?

1.3.4. Other (Specify): _____________________________________________

1.4. Marketing / Target Customer:

1.4.1. What is the demographics of this project’s target individual customer (if applicable)? Age, general, life stage, etc.

1.4.2. What are the main characteristics of this project’s target business customer (if applicable)? Business size, employee count, business type, planned property uses, etc.

1.4.3. What aspects of your project do you emphasize when marketing to your target customers?

1.4.4. Would nature, environmental conservation, open space, and sustainability resonate with this project’s target customers? If so how, if not why not?

1.5. Ownership Plan:

1.5.1. Hold

1.5.2. Sell

1.5.3. Other (Specify): _____________________________________________

2. Property Characteristics

2.1. Total Lot Size?

2.2. Area of Construction Disturbance?




2.3. Finished Building Height?

2.4. Finished Interior (non‐parking) Area?

2.5. Parking Area Type (Offsite Street, Onsite Surface, Onsite Belowground Garage or Onsite Aboveground Garage)?

2.6. Parking Area Size?

2.7. Landscaped Area Size?

3. Project Timing

3.1. Duration of feasibility study period?

3.2. Duration of design?

3.3. Duration of platting process?

3.4. Duration of permitting process?

3.5. Any specific concerns about City of Houston process durations?

3.6. How much time savings would be sufficient to motivate you to use green infrastructure techniques?

4. Project Financials

4.1. Pre‐Project Costs:

4.1.1. Appraised value?

4.1.2. Property tax?

4.1.3. Landscape Maintenance Costs? ($/sf/year)

4.1.4. Drainage Fee?

4.2. Project Costs:

4.2.1. Construction Costs?

4.2.1.1. Site Work, Excavation, Paving, Foundations, Parking

4.2.1.2. Water, Sewer, Dry Utilities




4.2.1.3. Building Envelope?

4.2.1.4. Onsite Storm Sewer?

4.2.1.5. Stormwater Quality?

4.2.1.6. Detention?

4.2.1.7. Rainwater Harvesting?

4.2.1.8. Mechanical, Electrical, Plumbing?

4.2.1.9. Furnishings and Finishes?

4.2.1.10. Other?

4.2.2. Lease, Sale, or Rental Costs?

4.2.3. Permitting, platting, licensing, or other City fees?

4.3. Post‐Project Costs:

4.3.1. Appraised value?

4.3.2. Property tax?

4.3.3. Landscape Maintenance Costs? ($/sf/year)

4.3.4. Drainage Fee?

5. Parking Requirements (Chapter 26)

5.1. What concerns about the parking arose on this project?

5.2. What impediments do you see with current parking requirements that discourage you to use green stormwater infrastructure?

5.3. What opportunities do you see for changes to parking requirements that would encourage you to use green stormwater infrastructure?




6. Tree and shrub requirements (Chapter 33, Articles V and VI).

6.1. What concerns about the trees and shrubs arose on this project?

6.2. What impediments do you see with current trees and shrubs requirements that discourage you to use green stormwater infrastructure?

6.3. What opportunities do you see for changes to trees and shrubs requirements that would encourage you to use green stormwater infrastructure?

7. Alleys (Chapter 40, Article XV).

7.1. What concerns about the alleys arose on this project?

7.2. What impediments do you see with current alley requirements that discourage you to use green stormwater infrastructure?

7.3. What opportunities do you see for changes to alley requirements that would encourage you to use green stormwater infrastructure?

8. Use of Public right of way (Chapter 40, Article XXI).

8.1. What concerns about the right of way use arose on this project?

8.2. What impediments do you see with current right of way use provisions that discourage you to use green stormwater infrastructure?

8.3. What opportunities do you see for changes to right of way use provisions that would encourage you to use green stormwater infrastructure?




9. Streets and Driveways (Chapter 42, Division 2).

9.1. What concerns about the streets and driveway provisions arose on this project?

9.2. What impediments do you see with current streets and driveway provisions that discourage you to use green stormwater infrastructure?

9.3. What opportunities do you see for changes to streets and driveway provisions that would encourage you to use green stormwater infrastructure?

10. Building Line Requirements (Chapter 42, Division 3).

10.1. What concerns about the building lines arose on this project?

10.2. What impediments do you see with current building lines requirements that discourage you to use green stormwater infrastructure?

10.3. What opportunities do you see for changes to building lines requirements that would encourage you to use green stormwater infrastructure?

11. Lots and Reserves (Chapter 42, Division 4).

11.1. What concerns about the lots and reserves arose on this project?




11.2. What impediments do you see with current lots and reserves requirements that discourage you to use green stormwater infrastructure?

11.3. What opportunities do you see for changes to lots and reserves requirements that would encourage you to use green stormwater infrastructure?

12. Multi‐Family Residential Platting (Chapter 42, Division 6).

12.1. What concerns about the MF platting arose on this project?

12.2. What impediments do you see with current MF platting requirements that discourage you to use green stormwater infrastructure?

12.3. What opportunities do you see for changes to MF platting requirements that would encourage you to use green stormwater infrastructure?

13. Residential Buffers Platting (Chapter 42, Division 8).

13.1. What concerns about the buffers arose on this project?

13.2. What impediments do you see with current buffer requirements that discourage you to use green stormwater infrastructure?

13.3. What opportunities do you see for changes to buffer requirements that would encourage you to use green stormwater infrastructure?




14. Stormwater Information

14.1. Elevation of Nearest 1% Annual Chance Floodplain?

14.2. Post‐Project Lowest Finished Floor Elevation?

14.3. Area of Pre‐Project Imperviousness?

14.4. Area of Post‐Project Imperviousness?

14.5. Volume of Detention Provided?

14.6. Stormwater Quality Facility Provided?

14.7. What concerns about the stormwater management arose on this project?

14.8. What impediments do you see with current drainage and stormwater quality design requirements that discourage you to use green stormwater infrastructure?

14.9. What opportunities do you see for changes to current drainage and stormwater quality design requirements that would encourage you to use green stormwater infrastructure?

14.10. Do drainage or flooding issues hinder the success of your project? If so, please describe how:

15. Building Code Concerns and Opportunities:

15.1. What concerns about the applicable building codes arose on this project?

15.2. What impediments do you see with current building codes that discourage you to use green stormwater infrastructure?




15.3. What opportunities do you see for changes to current building codes that would encourage you to use green stormwater infrastructure?

16. Key Terms or Provisions of Any Agreements with Public Agency Partners

16.1. How could your agreement with the city be modified to incentivize you to use green infrastructure?

17. Other Incentive Ideas?

17.1. What have you seen in other cities?

17.2. What other ideas do you have?


Page 1

PROJECT MEMORANDUM

Date: February 18, 2019 (Finalized April 30, 2019) To: Laura Patiño, City of Houston, Chief Recovery Office From: Michael Bloom, P.E., Alisa Valderrama, Janet Clements, Abigail Phillips RE: Legal and Policy Issues, Financial Performance, Barriers, and Challenges

Houston Green Stormwater Infrastructure Incentives Study

PART 1: INTRODUCTION AND KEY FINDINGS 1.1 Introduction Through funding from the Houston Endowment, the City of Houston’s Chief Resilience Officer (CRO) commissioned this study to identify and recommend incentives to encourage the use of green stormwater infrastructure (GSI) in private land development within the corporate boundaries of the city.1 Greater implementation of GSI in private land development projects will allow project sponsors, the city, and the area around these projects to realize economic, social, and environmental benefits as well as enhanced resilience. In May 2018 the CRO retained R. G. Miller Engineers, Inc., in association with Asakura Robinson, Corona Environmental Consulting, and Neptune Street Advisors to perform the work. This memorandum summarizes activities associated with Task 003 of the study, as follows: Screen draft incentive program models Research legal, policy, and procedural issues Review redacted financial statements for various types of development or redevelopment

projects inside the City of Houston (COH) Identify potential threshold points that might trigger GSI use by private developers in the various

types of real estate projects Identify legal, policy, or procedural barriers or challenges to implementing the considered

incentives or regulatory approaches Identify possible strategies or approaches to overcome barriers and challenges

1 This study was commissioned prior to the naming of Houston as one of the Rockefeller Foundation’s 100 Resilient Cities (100 RC) and prior to the naming of the city’s 100 RC CRO.

HOUSTON INCENTIVES FOR GREEN DEVELOPMENT: APPENDIX C - EVALUATION PROCESS

r. g. miller engineers, inc. Laura Patiño April 30, 2019 Page 2

1.2 Key Findings The memorandum finds, after detailed screening of initial incentive programs, researching potential legal or policy limitations, assessing the ability for incentive programs to exceed associated threshold points to motivate developers to utilize GSI approaches, that the City of Houston should move forward with the development and implementation of the following incentive programs: Permitting Timeline Certainty Property Tax Abatements Award and Recognition Program Integrated GSI Development Rules

The balance of this memorandum describes the incentive program screening process and the evaluation of selected incentive programs.



PART 2.0 INITIAL SCREENING OF DRAFT INCENTIVES Based on the results of Task 001 – Research and Benchmarking Regarding Incentives and Regulatory Approaches and the results of Task 002 – Work with Private Developers, the consulting team developed an initial list of draft incentive programs for consideration. The draft incentives list included the following: Timing Incentives

o Expedited platting or re‐platting. Developer implements GSI in exchange for faster plat or re‐plat approval.

o Expedited permitting. Developer implements GSI in exchange for faster plan review and approval.

o Enhanced permitting certainty and speed. Developer implements GSI in exchange for a more consistent reviews and faster permit issuance.

Financial Incentives o Reduced permitting fees. Developer implements GSI in exchange for reduced permitting

fees. o Reduced platting fees. Developer implements GSI in exchange for reduced platting fees. o Reduced utility connection fees. Developer implements GSI in exchange for reduced

water or wastewater connection fees. o Reduced drainage utility parcel fees. Developer implements GSI in exchange for a

reduced monthly parcel fee for the life of the completed project. o Reduced impact fees. Developer implements GSI in exchange for reduced stormwater

impact fee charges. o Property tax abatements. Developer implements GSI in exchange for a city property tax

abatement for a certain set period of time. o Grants to private developers. Developer implements GSI in exchange for direct city

funding of the construction of the project. Here, the additional city funding would be obtained from a revenue‐neutral funding source in the form of principal forgiveness granted by the Texas Water Development Board on a large‐value wastewater project loan from the Clean Water State Revolving Fund that includes a bundled set of small‐scale GSI project subsidies in the same project area.

Award/Recognition Program o City issued award and public recognition. Developer implements GSI in exchange for

public recognition by the city. This could be through a formal awards program and/or through public acknowledgment/branding efforts.

Municipal Ordinance Incentives o More flexible parking requirements. Developer implements GSI in exchange for the city

imposing a more flexible set of parking requirements (either more or less area) on that project.

o More flexible landscaping requirements. Developer implements GSI in exchange for the city imposing more flexible requirements on the project.

o More flexible park dedication, park dedication fund, and compensating open space regulations. Developer implements GSI in exchange for the city imposing a more flexible



set of park dedication, fund payment options, and compensating open space provisions on that project.

Infrastructure Design Incentives o Modified drainage design requirements. Developer implements GSI in exchange for

modified drainage design requirements. For example, the city might allow the use of bee‐hive inlet grates or other specialty inlets in exchange for the use of GSI on a particular project.

o Modified detention requirements. Developer implements GSI in exchange for the city agreeing to impose a modified detention volume requirement. For example, the city might calculate the required detention volume as the difference between the total runoff volume after development, less the total runoff volume before development, rather than based merely on the post‐project impervious area.

o Modified stormwater quality requirements. Developer implements GSI in exchange for the city agreeing to impose modified stormwater quality requirements. For example, the city might allow a broader range of appropriately sized GSI techniques to meet stormwater quality requirements, than is currently allowed.

Building Code Incentives o More flexible grading requirements. Developer implements GSI in exchange for the city

imposing a more flexible set of grading requirements. Developer Contracts

o Special provisions to city‐developer contracts. Developer implements GSI in exchange for special concessions granted by the city and documented in project‐specific developer agreement.

Detention Volume Trading or In‐Lieu Fee Programs o Detention volume trading program. Developer implements GSI above and beyond

existing stormwater requirements in exchange for participation in a city‐administered detention volume‐trading program. The city‐administered program would track the construction of excess GSI‐based detention volume in subwatersheds across the city. The city would approve the purchase and sale of excess detention within each subwatershed among participating development sites. The city would grant participating new development or redevelopment sites the option of building the required detention volume or purchasing it from developers who implement GSI in excess of existing standards. Developers who implement GSI could also bank excess capacity for later use.

o Fee in‐lieu program. Rather than meeting detention standards onsite, city allows developer to participate in a city‐administered fee in‐lieu program for detention. The city‐administered program would track and collect fees from city‐authorized development projects that elected not to construct onsite detention. Fees would be tracked on a subwatershed basis. The city would then construct subregional GSI‐based detention facilities using the collected fees. This results in more GSI than otherwise would be implemented because developers implementing detention onsite would likely be using gray infrastructure solutions.

After the City of Houston’s CRO and staff vetted the list, the consulting team conducted an initial screening process to narrow down the list of potential incentive program models. The consulting team developed a



set of evaluation criteria to determine which incentives would be subject to further, more detailed evaluation. The evaluation criteria were established with two parts. The first part qualitatively assesses the incentive using various criteria on a scale of 1 to 10 with 10 being the best outcome for each criterion. The second part indicates how much that particular outcome would motivate developers to use GSI. This can be considered a priority weight or in this case a motivation factor on a scale of 1 to 10, with a 10 weight assigned the factor that would provide the most motivation. The criteria and their respective motivation factors are described below. Developer Benefits: Qualitatively expresses the anticipated magnitude of benefits to the

developer and the developer’s proposed project. This might include a direct subsidy, tax savings, reduced regulatory burden, or reduced construction/development costs. Higher is better. Developer benefits are a very high important consideration when evaluating how GSI incentives might motivate developers to utilize GSI, therefore, a motivation factor of 10 out of 10 was assigned to this criterion.

Ease of Implementation: Qualitatively expresses how easy it will be for the city to create the incentive. Additional work reduces the ease of implementation. For example, the need for drafting and passing a revised or new ordinance, revising the building code, revising the Infrastructure Design Manual, staff training, or the creation of a new tool, all would tend to drive the ease of implementation down, therefore higher is better. Ease of implementation is a moderate consideration when evaluating the feasibility of GSI incentive programs, therefore, a motivation factor of 4 out of 10 was assigned to this criterion.

Ease of Administration: Qualitatively expresses how easy it will be for the city to run the incentive program. Additional work reduces the ease of administration. For example, hiring additional staff, performing data management activities, conducting additional reviews, generating additional paperwork, or performing additional interdepartmental coordination all would tend to drive the ease of administration down, therefore higher is better. Ease of administration is moderate consideration when evaluating the effectiveness or feasibility of GSI incentive programs, therefore, a motivation factor of 4 out of 10 was assigned to this criterion.

Degree of Cost or Revenue Neutrality: Qualitatively expresses to what extent the city can execute the program without incurring additional costs or without revenue shortfalls. For example, incurring increased salary costs, additional software costs, or a reduction in tax proceeds, all would drive the program neutrality down, therefore, higher is better. Degree of cost or revenue is moderate to high consideration when evaluating the feasibility of GSI incentive programs, therefore, a motivation factor of 6 out of 10 was assigned to this criterion

Net Public Benefits: Qualitatively expresses the anticipated magnitude of the difference between any increase in public benefits from the implementation of GSI; less any reduction in level of services arising from any flexibility granted from existing ordinance or design requirements. Higher is better. Net public benefits is a low to moderate consideration when evaluating how GSI incentives might motivate developers to utilize GSI, therefore, a motivation factor of 2 out of 10 was assigned to this criterion.

The consulting team scored all incentives based on professional judgement and feedback from private land development companies who participated in an earlier phase of this project and provided information and ideas to the process. Table 2‐1 illustrates the results of the screening process.



Table 2‐1. Qualitative Incentive Screening



The initial screening process eliminated all draft incentives except for the following: Timing Incentives

o Enhanced permitting certainty and speed. Financial Incentives

o Reduced impact fees. o Property tax abatements. o Grants to private developers.

Award/Recognition Program o City issued award and public recognition.

Municipal Ordinance Incentives o More flexible parking requirements. o More flexible tree and shrub list. o More flexible park dedication, park dedication fund, and compensating open space

regulations. Infrastructure Design Incentives

o Modified drainage design requirements. o Modified detention requirements. o Modified stormwater quality requirements.



PART 3.0 EVALUATION OF INCENTIVES The following sections present the results of the consulting team’s work to address the following items for each of the incentive concepts remaining from the initial screening process: Legal, policy, and procedural issues. This includes a discussion of how the incentive might be

implemented using current or modified legal authorities, using current or modified policies, or under current or modified city procedures.

Benefits and costs. This includes a discussion of the costs and benefits of the proposed incentive, from the perspective of both developer and the city.

Threshold points. This considers how the proposed incentives can grant a certain amount of subsidy, a certain amount of regulatory flexibility, or a certain amount of reduction in required detention volume, to change developer behavior. This section defines the “threshold point” as the value or quantity of the granted concession or subsidy that would feasibly result in a behavior change because it creates a cost savings, an increase in revenue, or some other benefit that is material to the developer’s project pro‐forma. To assess possible threshold points for each incentive program the consultant team designed a hypothetical new commercial site using current City of Houston planning and design provisions related to landscaping, parking, and stormwater management. The team designed and estimated construction costs for the hypothetical site using GSI techniques and alternative planning and design provisions. These two designs and cost estimates then allowed the consulting team to compare the anticipated costs to the value of the offered incentive to see if the developer benefits outweighed the developer costs. (See Enclosure A for details.)

Barriers or challenges. This includes an assessment of the factors that would increase the required level of effort to implement the incentive program, the factors that would thwart implementation, and the factors that might lead to program failure.

Implementation strategies. This includes a discussion of how the city might proceed with implementation, despite the identified barriers.

The consulting team’s deeper dive into each of the incentives generated additional information about potential program models. The consulting team used this additional information to help guide the selection of incentive recommendations, which are presented at the end of this memorandum. The consulting team created a detailed design comparison to help evaluate each incentive program. The design comparison and example scenario that helps us determine the effectiveness of each incentive can be found in appendix A.



PART 4.0 ENHANCED PERMITTING CERTAINITY AND SPEED During interviews for this project, representatives from in‐city development companies expressed a strong desire for more certainty in the plan review process and a faster process. Many developers indicated that uncertainty regarding when city comments would be received, the completeness and consistency of comments, and how many times plans would need to be submitted for review to obtain a permit, and how long the overall process might take, had a negative impact on their cash flow and project performance. The city might incentivize developers to use GSI in projects if the city provided a more consistent plan review process and a faster process. 4.1 Legal, Policy, or Procedural Issues Current city ordinances, policies, and procedures do not appear to limit the city’s ability to offer this incentive. 4.2 Cost Information A more consistent plan review process and a faster permit issuance process would allow the project sponsor to more accurately estimate the cost of loans, to establish the timeline of equity partner payouts, plan the timing of funding actions, reduce the cost of planning and design services associated with multiple design revisions and plan submittals, and generally enhance the economic performance of their project. The current permitting process is illustrated in Figure 4‐1 on the following page.



Figure 4‐1: Permitting Process Flow Diagram



Developers currently claim that while the city may provide comments in a reasonable amount of time, the city provides inconsistent and incomplete comments during each plan review cycle. This causes developers to address comments on plans, resubmit, and then receive new comments on elements of the plans that were acceptable during the prior review cycle. Assuming site civil and landscaping construction costs of $1.5 million (as shown in Enclosure A for the hypothetical project) and engineering and landscape architecture services might cost about 10% of that amount, say $150,000, the consulting team estimated that revisions to address comments received during each plan review cycle might cost $15,000 (1% of professional service fees). Assuming the city reviews each set of plans three times, the developer might incur $45,000 in additional professional service fees, plus the debt service on the full amount of outstanding debt times the duration of the review process. The consulting team made the following assumptions to estimate the time value of money to the developer: Borrowed Amount: $2 million Annual Interest Rate: 10% Permit Review Time: 30 days Time to Address Review Comments: 15 days Number of Review Cycles: 3

Based on the assumptions above, the consulting team estimated that the overall permitting process would take 135 days or 37% of a year and the total cost to borrow $2 million dollars at a 10% annual interest for 135 days would be $74,000. The consulting team estimated the total cost of the process by adding the professional service costs to the time costs, yielding $119,000. If the city implemented an alternative, higher fee‐based permitting process, similar to that provided by the City of Dallas, the City of Houston could offer developers who enter into a contract to utilize GSI a discounted fee structure for this enhanced permitting service. Reportedly, the City of Dallas offers an expedited plan review performed by the “Q‐Team” in a single review session. Reviewers specializing in building code, zoning, mechanical, electrical, plumbing, landscaping, sanitarian, and fire safety participate and meet with the applicant and the applicant’s design professional and conduct a full review of all plans. Site civil engineering review is currently conducted separately, but the developer can choose to bundle that into the main meeting. If the review requires changes in the drawings, the changes may be made during the review and signed off on as required. If revisions cannot be completed at the meeting, a follow up review with the same team can be scheduled. If the plans meet the relevant requirements of city codes and ordinances, and necessary changes are made on the spot, permits can be issued immediately following the meeting. A prequalification Q TEAM Review is required as part of the process of accepting an application for Q TEAM Review. This provides a review for “completeness” of documents submitted with the permit application. This process typically takes 5 to 12 days. Developers must pay for the expedited review process. Fees include the standards application plan review



fees plus an additional pre‐qualification fee (that is non‐refundable). Maximum prequalification fees vary based on the size of the development, as follows: 0 – 10,000 sq. ft.: $500 10,001 – 50,000 sq. ft.: $750 50,001 – 100,000 sq. ft.: $1,000 100,001 + sq. ft.: $1,250

There is an additional charge of $1,000 per hour for the actual Q‐Team Review meeting. This is due right after the meeting. Maximum review fees also vary by development size: 0 – 10,000 sq. ft.: $2,000 10,001 – 50,000 sq. ft.: $12,500 50,001 – 100,000 sq. ft.: $27,500 100,001 + sq. ft.: $50,000

The Dallas program is staffed by ten technical staff, three coordination staff, and two administrative assistants. Dallas reports that they typically conduct between 55 and 65 reviews per month. Meetings typically take between 1.5 to 2.5 hours with some taking 8 hours. Meetings typically include 20 people at a time. If the City of Houston implemented such a permitting approach, it could be implemented with a higher set of fees for traditional development and a lower set of fees for GSI developments. 4.3 Threshold Points As outlined in Section 4.2, the current costs associated with multiple reviews and schedule impacts outlined on appears to be high enough to motivate developers to utilize the proposed alternative, higher fee‐based permitting process discussed above. If the city charged a high enough fee for this process and offered a high enough discount for the use of GSI, this might also motivate developers to utilize GSI. 4.4 Barriers or Challenges Developers may want to use the expedited permitting process, however, they may submit incomplete or low quality plans for consideration. This will consume staff time and may lead to team review meetings that must be terminated because of the quality of the plans. Implementing the proposed alternative, higher fee‐based permitting process discussed above would pose several challenges. Five full time employees currently conduct all stormwater reviews; two for public projects and three for private projects. Current staffing levels might not be sufficient to accommodate requests for the team, expedited review described above. The city will face many comments from all stakeholders regarding the fee structure and the discount offered for GSI use. The city will face a challenge in getting developers to execute a contract to implement GSI in exchange for the discounted permitting fees, however, that may be the only way to help ensure that the promised GSI actually gets built after the developer secures their permit.



4.5 Implementation Strategies Because the Office of the City Engineer reportedly utilizes a team review approach for telecommunications infrastructure projects, this approach should work for all other development projects, both with and without GSI. This incentive program will require additional staffing with specialized training as only five full time employees currently conduct all stormwater reviews; two for public projects and three for private projects. Additional stakeholder engagement as well as thought on how to create the program must take place. Once program is created, prior to scheduling and conducting the expedited team review meeting the city should require plans to be evaluated for completeness. Once plans are deemed sufficiently complete, the city should proceed to schedule the expedited team review meeting. The city should bundle this incentive program with others outlined in the memorandum because a combined set of incentives will motivate the use of GSI more than one alone.



PART 5.0 FINANCIAL INCENTIVES The city might incentivize developers to implement GSI on their projects if the city provided direct financial support for such projects, including reduced drainage impact fees, property tax abatements, or grants to developers. These options are discussed in more detail below. The following subsections present the results of the evaluation of the following incentives: Reduced drainage impact fees. Property tax abatements. Grants to private developers.

5.1 Reduced Drainage Impact Fees. The city might incentivize developers to implement GSI on their projects if the city reduced their drainage impact fees. State law allows cities to impose drainage impact fees to new development projects to help offset the cost of providing new drainage capacity to serve those projects. Under this approach the city would agree to trade a reduced public good arising from improved public drainage facilities funded from impact fee collection in exchange for an increase in public good arising from the use of GSI. The discussion below explores this potential incentive in more detail. 5.1.1 Legal, Policy, or Procedural Issues City ordinances2 allow the city to require developments to pay a portion of the costs to build public drainage facilities required to serve the new development project. It allows property owners in defined watershed areas to enter into development agreements with the city to connect to the drainage system. Agreements can direct the developer to construct public drainage facilities or pay charges equivalent to drainage impact fees, as defined in a city prepared drainage impact fee improvement plan. 5.1.2 Cost Information Impact fees established in current city ordinances3 range from $0.00 per 1,000 square feet of increased impervious area in Addicks, Barker, or the Ship Channel watersheds to as high as $18.50 per 1,000 square feet of increased impervious area in the Sims / Vince Bayou watersheds. Expressed on a per acre basis, these fees range from $0.00 to $805.86 per acre of new impervious area. 5.1.3 Threshold Points The range of charged fees does not appear to be high enough to create a meaningful trigger point. Take, for example, a relatively large, green‐field, development site of 4 acres. The city would charge a developer proposing to convert 4 acres of grass to pavement, at most, $3,223.44 in drainage impact fees. That cost is less than 2% of the cost of installing the bioswale included in the hypothetical GSI design of the

2 Chapter 47. Water and Sewer, Article XV. Drainage Impact Fees, Division 2. 3 Chapter 47. Water and Sewer, Article XV. Drainage Impact Fees, Division 2.



commercial site outlined in Enclosure A. This means that any reduction in impact fee would not likely be sufficient to trigger a behavior change and the private use of GSI. 5.1.4 Barriers or Challenges The city imposes small drainage impact fees for increases in impervious area. The charged fees are so small that reductions in them would not result in any changes to site design decision or the use of GSI. 5.1.5 Implementation Strategies State law currently allows the city to charge a drainage impact fee that is based on the full cost of drainage facilities required to support new development. If the city completed a new drainage impact fee study that included an estimate of the full cost of existing and planned drainage facilities in each watershed, the city might be able to justify a sizable increase in the fee, if the total cost of service included consideration of flood damage reduction facilities. The city could consider bundling this incentive program with others outlined in the memorandum because a combined set of incentives might motivate the use of GSI more than one alone. 5.2 Property Tax Abatements. The city might incentivize developers to implement GSI on their projects if the city deferred or reduced their property tax bill. Under this approach the city would agree to trade a reduced or delayed public good arising from deferred tax revenue in exchange for an increase in public good arising from the use of GSI and future increases in tax revenue resulting from enhanced property value. The discussion below explores this potential incentive in more detail. 5.2.1 Legal, Policy, or Procedural Issues City ordinances4 allow the city to provide tax abatements to owners of certain projects in order to achieve economic development objectives; to owners of projects that create new or increased property value; and to owners of new or expanded sites or improvements if proven to be essential to the entity's or the facility's economic survival. Abatements are granted to owners of buildings, structures; fixed machinery and equipment, site improvements; office space and related fixed improvements necessary to the operation and administration of the facility; and tangible personal property. The city may not grant abatements on bare land, supplies, tools, vehicles, vessels, or aircraft. To establish the term and value of granted abatements the city must evaluate the costs and benefits realized by the project sponsor and the net public benefits realized from the project. Depending on an analysis of such factors and data, the city may grant an appropriate amount and duration of abatement up to a period of ten years. The city may grant abatements for the following project types:

4 Chapter 44. Taxation, Article IV. Tax Abatement.



Projects that provide an economic benefit to the city (considering value of the abatement, sales

tax income, franchise fee income, and the cost of public services to the project); Projects that will increase the value of the real or tangible personal property; Projects that increase (or prevent the decrease in) the number of permanent jobs; Projects in Texas Enterprise Zones in accordance with the provisions of their enabling legislation; Brownfield redevelopment projects; and, New or refurbished projects that obtain Leadership in Energy and Environmental Design (LEED)

certification. These ordinance provisions suggest that the city would have the legal authority to create an explicit GSI tax abatement to incentivize GSI if desired, or simply rely upon the general economic development provision outlined above. 5.2.2 Cost Information The city currently collects a property tax of $0.588310 for every $100.00 of property valuation. This means that a property with an appraised value of $1 million pays $5,883.10 per year in taxes to the city (not including taxes owed to other taxing entities). To illustrate the costs associated with this incentive concept, Table 3‐1 presents publicly available information from the Harris County Appraisal District website for a few randomly selected properties.

Table 5‐1. Example Property Tax Information

No. Property Type Address Land

Area (sf) Building Area (sf)

Appraised Value

Annual Tax Due to City

1 Residential, Multi‐Family

150 W. Sam Houston Pkwy. North, Houston, TX 77024

183,823 284,221 $44,775,027 $263,416

2 Hotel, Convention Center Marriott

1777 Walker St. Houston, TX 77010

113,186 1,091,726 $215,482,937 $1,267,708

3 Vacant Land 3028 Washington Ave. Houston, TX 77007

56,541 0 $2,827,050 $16,632

4 Single Family Residence

Shenandoah Subdivision Houston, TX 77081

8,640 1,397 $138,572 $815

5 Retail Shopping Center with

Surface Parking

3249 SW Freeway Houston, TX 77027

173,112 60,691 $17,311,200 $101,844



5.2.3 Threshold Points The owner of a project or property will incur property tax in proportion to the appraised value of the completed development or redevelopment. The developer’s annual tax bill must be equal to some reasonable fraction of the cost of any proposed GSI facilities for a tax abatement to provide a meaningful economic benefit. If, for example, the developer installed the bioswale described in Enclosure A, the upfront capital cost would be approximately $256,000,5. (Assuming implementation of the new GSI development rules.) The developer would compare this cost (less the cost of a conventional stormwater system, approximately $713,0006 in the conventional design presented in Enclosure A) with the value of the abated taxes to decide if she should use GSI. The site design comparison presented in Enclosure A illustrates a cost savings of $457,000 on a project estimated to cost a total of $25 million, without the tax abatement. This illustrates that a city‐granted tax abatement provides an additional cost savings, above and beyond that realized by designing the project under the proposed integrated GSI development rules. If the city enacted a policy to provide the incentive over a three‐year period, the tax abatement would pay for 100% of the Enclosure A hypothetical bioswale if the appraised value of the project was $14.3 million. The consulting team anticipates that the applicable threshold point for this incentive program would be achieved if 100% of the installation cost of the GSI project elements could be funded via tax abatement over a period of less than three years. Since the cost and scale of installed GSI typically varies with the scale of the overall project, the consulting team believes that the value of the tax abatement would exceed the threshold point and motivate developers to implement GSI. 5.2.4 Barriers or Challenges Developers that plan to own the finished project, to earn lease income and to realize value appreciation over time, would benefit directly from a tax abatement, most likely in situations where the taxable value of the completed project is sufficient to receive an abatement over three years that covers a reasonable fraction or all of the cost of GSI. The consulting team estimated that if the city granted abatements equal to the value of the property tax increase from the associated development project for a period of 5 years to one property per year for 10 years, revenue would decline by about $4.6 million over that time period. This would be offset by the increase in property tax revenue and public good from the use of GSI on the subject properties and nearby tracts. Smaller projects need less costly GSI, so the abatement concept would likely work at most scales. The consultant team understands that tax abatements are granted to owners of property, rather than the property itself and that an owner with an active tax abatement can transfer that abatement agreement to a new owner, if performance conditions associated with the agreement continue to be achieved.

5 The prorated sum of Items 2, 3, 4, 5, 8, 12 and 17 for the green site listed in Table 7‐2. 6 The sum of Items 13, 14, 15, and 17 for the conventional site listed in Table 7‐2.



5.2.5 Implementation Strategies The city should market the tax abatement incentive to developers who plan to build projects with anticipated appraised values sufficient enough to cover some or all of the anticipated GSI costs. Similar to the residential apartment tax abatement that was implemented in 2010, the city should develop a clear business case illustrating the that investment in private GSI (through deferred or reduced revenue) will catalyze nearby property value increases and, hence, increased city tax revenue and public good. The city could consider bundling this incentive program with others outlined in the memorandum because a combined set of incentives might motivate the use of GSI more than one alone. The city should consider the policy implications of restricting the tax abatement incentive to projects that redevelop properties and excluding properties that develop previously undeveloped land. The consulting team suggests the public benefits of restricting this incentive to redevelopment projects would be greater than if the incentive was offered to both redevelopment and new development. 5.3 Grants to Developers The city might incentivize developers to implement GSI on their projects if the city funded a portion of the project’s GSI construction using a revenue neutral source of cash that is revenue‐neutral for the City, here, in the form of a loan from the Clean Water State Revolving Fund that is eligible for forgiveness and is effectively a grant from the State. Under this approach the city would agree to trade city staff time associated with the administration of a loan and grant program in exchange for an increase in public good arising from the use of GSI on private land. The discussion below explores this potential incentive in more detail. The revenue cap included in the current City Charter will limit the use of these types of incentives. As of 2005, the City Charter imposes a limit to revenue increases. Revenue increases cannot exceed the lower of either (a) the inflation rate plus the population growth or, (b) a 4.5% increase. This provision imposes a revenue cap on the city. This cap on potential revenue means the city will be unlikely to be have additional funding to spend on financial incentives for GSI. Even with the revenue cap limitation, there may be other revenue sources that could be used to provide financial incentives, therefore, the discussions below explore this type of approach in more detail. 5.3.1 Legal, Policy, or Procedural Issues Under the authority of the Federal Water Pollution Control Act (Clean Water Act) the U.S. Environmental Protection Agency (EPA) receives an annual appropriation from Congress and the President to fund the Clean Water State Revolving Fund (CWSRF). EPA shares the money in the CWSRF with states, including Texas, subject to budget considerations. The Texas Water Development Board (TWDB) administers the CWSRF in Texas and uses it as a source of funding to make low interest loans to wastewater and stormwater utilities across the state for eligible projects. The Texas SRF program typically lends about $525 million statewide and the City of Houston has borrowed about $53 million each cycle, on average. The federal and Texas SRF programs include a provision known as the Green Project Reserve (GPR), which



sets aside funds to support green infrastructure projects, as defined in technical guidance. The GSI techniques considered in this incentives study report generally would be eligible. Under the GPR program some eligible projects may receive loan forgiveness or principal forgiveness. This effectively provides a source of grant funding – funding to the borrower that does not have to be repaid to the lender. Figure 5‐1 below, illustrates this concept using a hypothetical project.

A hypothetical project might proceed as follows: The City of Houston wastewater utility applies for a $50 million loan from the CWSRF to make sanitary

sewer collection system upgrades. The application describes the full extent of collection system work [blue gray box in the diagram] and also includes a $0.5 million suite of potential GSI projects on private property in the same sewer sheds [green circles]. The application for a total of $51 million outlines the area where potential future GSI projects will be located and how they would help improve the level of service in the same sewersheds.

The TWDB reviews the loan application and then approves the loan for $50.5 million with $0.5 million of the loan “forgiven,” i.e.: not required to be paid back.

The City of Houston wastewater utility builds the sanitary sewer system work. The City enters into agreements with private developers and issues $0.5 million in GSI grants to private

developers to build projects. TWDB officials provided feedback on the concept described above at a meeting in October 2018 and indicated that it appeared very feasible to implement, however, later discussions with City of Houston officials familiar with the CWSRF identified a serious obstacle to implementation, as described below. 5.3.2 Cost Information The city’s wastewater utility typically borrows $50 million each year under the Texas SRF for conventional wastewater system improvements that are not eligible for the GPR. Initially, the consulting team believed that this might generate about $0.5 million in loan forgiveness funding, however upon further evaluation and consultation with City of Houston staff resources familiar with the Texas SRF, the team determined



that any loan forgiveness could only be for a small fraction of the estimated costs of the green project elements included in the base loan amount. This would require the city pay almost the full cost of any GSI grants issued plus the interest on those dollars. After this determination the team abandoned this incentive idea.



PART 6.0 AWARD OR RECOGNITION PROGRAM The city might incentivize developers to implement GSI on their projects if the city recognized the developer and the developer’s project in a very public manner. Under this approach the city would agree to trade a reduced public good arising from the staff time and expenditures to run the award program in exchange for an increase in public good arising from the use of GSI. An awards or recognition program would likely be most successful if implemented in coordination with other incentive programs. The discussion below explores this potential incentive in more detail. 6.1 Legal, Policy, or Procedural Issues City ordinances and state law do not appear to create any limitations on the city’s ability to offer and grant recognition or awards to private developers for the use of GSI. Constrained revenue will limit the monetary value of any award and, therefore, the ability of the city to implement this approach with a financial award; however, this program could be accomplished using a public relations or marketing approach with modest added direct costs. 6.2 Cost Information Cost for city implementation of an awards program will depend on the value of any awards issued, the frequency of award issuance, the size and complexity of any public events or media recognition conducted in association with the award, and the number of awards issued each year. Costs might range from a low estimate of $24,000 per year to $500,000 per year or more. The low estimate might cover staff time, local news coverage of a short press event with the mayor, some social media content posting by existing staff, and a modest award plaque to one recipient a year. The high estimate might include a professional public relations effort, a larger press event with city officials, professionally produced and managed social media content, and a more elaborate plaque to multiple recipients per year. The Houston Green Office Challenge (which is no longer underway), recognized office buildings and tenants who retrofitted their facilities to reduce energy and water consumption and promoted sustainable behavior change within the workplace. A former manager of the program reported that the program was a very successful, ongoing operation while it was supported by private, external funding which ranged from over $200,000 in the first year to about $10,000 in the final year. A former manager of the program reported that the successful program required the following resources: City staff time of about to 20‐30 hours per week as well as a part‐time intern; Website design, hosting, and updating; $10,000 to $15,000; Annual awards luncheon for about 50‐250 people; Annual prizes valued at about $50/each; Promotional items and printing valued at about $5,000 to $30,000.

A former manager of the program reported that as the program evolved over time, it was challenging to maintain the same level of interest as the first year but having a network of green businesses and companies share their best practices and expertise was still a huge value to participants. The Houston



Green Office Challenge was winding down because the City was considering an energy efficiency policy that would mandate energy benchmarking and transparency, which ultimately was not pursued. 6.3 Threshold Points Only certain developers, marketing to certain tenants or buyers, would be interested in this incentive program. Some developers would not change their site design approach at all, even if such an award program was available to them at the start of their project. A specific subset of developers, perhaps those who are positioning to serve younger, more active customers, might be moved to implement GSI because of the award program. They might see the award as a way to differentiate their offerings and to leverage the free media and advertising benefits of being an award winner. The threshold point for this program is difficult to determine. The city might initiate a modest program, with a focus on recognizing the first five “marquee” projects that participate in a GSI incentive program. Based on the level of interest, the city could adjust the program from there. 6.4 Barriers or Challenges The city will have a hard time convincing the first potential award recipient to invest in GSI solely for that reason. The likelihood that a developer will move forward with GSI will marginally increase as the scale and cost of the award publicity increases; more publicity might lead to more potential recipients. The city’s revenue cap and general budget constraints will limit the city’s ability to implement this program using the larger, more elaborate option. The city will need to show how recognition by the local GSI award program will be more valuable to developers that recognition obtained from LEED®, Envision®, or other third party recognition programs. The city will encounter the same challenges by the Green Office Challenge. The city will encounter challenges in promoting and advertising the program, recruiting participants, judging entries, recognizing winners, and maintaining the program. 6.5 Implementation Strategies The city might consider appropriating funds to hire a communications or marketing firm to promote, advertise the program, recruit participants, assist with event planning, and create and deliver award items (trophy or statute). The city might consider hiring interns to assist the implementing department with the required staff work. The city could use Houston Permitting or Houston Public Works staff as subject matter experts for judging entries. The Mayor’s Office of Communications could assist with recognizing winners. The city might consider combining the award program with other incentives described in this report. This might exceed the necessary threshold point and trigger developer GSI use. The city might also consider starting with a smaller award and a less elaborate publicity program and adjust the program scale after obtaining initial feedback. The city could consider bundling this incentive program with others outlined in the memorandum because a combined set of incentives might motivate the use of GSI more than one alone.



The city might consider creating and granting awards for a variety of project types and scales. This will help motivate developers that work at all scales to use GSI. The city could also combine GSI recognition with promotion of the use of the United States Green Building Council’s Leadership in Energy and Environmental Design (LEED) credit program for buildings and the Institute for Sustainable Infrastructure’s Envision credit program for horizontal infrastructure. This could include the city sponsoring or conducting both practitioner credentialing in both systems, use of both systems in city projects, and encouragement of private sector use of both programs. Lastly, the city might evaluate all existing award programs that relate to sustainability, energy, resilience, water conservation, green stormwater, parks, and related items to see if the programs could be harmonized and the communications and marketing costs could be shared. The city might realize cost savings and efficiencies by combining or otherwise harmonizing multiple award programs.



PART 7.0 MODIFIED ORDINANCE PROVISIONS AND DESIGN REQUIREMENTS After the screening step described in PART 2.0 the consulting team identified the following incentives as worthy of additional consideration: Municipal Ordinance Incentives

o More flexible parking requirements. o More flexible landscaping requirements. o More flexible park dedication, park dedication fund, and compensating open space

regulations. Infrastructure Design Incentives

o Modified drainage design requirements. o Modified detention requirements. o Modified stormwater quality requirements.

Rather than consider each of the above incentives concepts alone and in isolation, the consulting team decided to evaluate the policy issues, costs, threshold points, and implementation challenges associated with an integrated set of ordinance provisions and design requirements using the hypothetical commercial development site described in Enclosure A. The following subsections describe the current situation, the proposed, integrated approach, and presents an evaluation of the main considerations associated with this incentive concept. 7.1 Summary of Current Requirements 7.1.1 Landscaping City ordinances currently give the city the power to impose a variety of landscaping rules, in particular, the city requires a landscape plan for certain new or expanded non‐residential buildings, or multi‐family residential buildings, and for certain new parking lots.7 The city also imposes tree and shrub planting requirements for private parking lots. The developer must plant one tree for every ten parking spaces and ensure that at least one tree is within 120 feet of every parking space. The developer must plant shrubs along the perimeter of all parking surfaces to screen the parking lot from all adjacent public streets. Shrubs must be between 18 and 36 inches tall. The number of shrubs must be ten times the number of street trees (public right of way trees) required by city rules. At least 75% of the shrubs required by the city must be planted in along the parking lot perimeter adjacent to the public street. The city provides a list of acceptable trees and shrubs for landscaping work and imposes a requirement for irrigation. There may be opportunities to update the list of acceptable trees and shrubs to allow for greater biodiversity and increased resilience of Houston’s green spaces. to be more suitable for the Houston area.

7 Chapter 33. Planning and Development. Article V. Trees, Shrubs, and Screening Fences. Division 2. Building Sites. Section 33‐121. Application. and Section 33‐122. Landscape Plan Required.



7.1.2 Open Space Requirements City ordinances8 require multi‐family residential developments in the extra‐territorial jurisdiction (ETJ) to provide from 200 to 500 square feet of open space per dwelling unit. Open space (as applied to multi‐family residential projects in the ETJ) means land within the multi‐family residential development that is not covered by buildings, covered walkways, parking spaces, private streets or driveways. Under certain conditions, the city allows a reduction in the area of open space for multi‐family residential projects. The city allows multi‐family residential developments to pay a fee equal to $700 per dwelling unit, in lieu of open space dedication. The city must use the collected fees for any type of park site or improvement within a particular geographic area and in accordance with park department prioritization.9 7.1.3 Parking City ordinances10 impose private, off‐street, parking requirements for various building use classifications as outlined in the document. For example, a Class 8, Retail Service, Neighborhood Shopping Center between 25,000 and 100,000 square feet of gross floor area, must provide at least 4 spaces for every 1,000 square feet of gross floor area, plus any increase in space count if more than 20% of the gross area is a tavern, pub, or bar. Requirements range from 2 to 14 parking spaces per 1,000 square feet of gross floor area, depending upon the use classification. Some requirements are alternatively expressed as spaces per dwelling unit or spaces per seat or similar requirements. City rules allow for variances and also allow for adjustments if bicycle spaces are provided, the building is historical, parking is shared or located offsite, or is a transit‐oriented development. 7.1.4 Stormwater Conveyance Design The city’s Infrastructure Design Manual11 (IDM) requires private storm sewers and other stormwater conveyances to meet or exceed certain design requirements. Drainage systems for curb and gutter pavement must consist of underground closed conduits. The IDM requires that private development drainage systems not alter existing or natural overland flow patterns and not increase or redirect sheet flow to adjacent property. The IDM requires inlets and storm sewer system elements be sized to accommodate the two‐year recurrence interval storm event (50% annual chance rain depth) with a duration of no less than 3 hours for drainage areas of less than 200 acres (about 3.14 inches, depending upon location). The city requires that the drainage system convey the two‐year design storm without inundating any portion of the paved areas served by the inlets. The city requires that all private drainage

8 Chapter 42. Subdivisions, Development and Platting. Article III. Planning Standards. Division 6. Multi‐Family Residential Developments. Section 42‐236. Open Space. 9 Chapter 42. Subdivisions, Development & Platting. Article III. Planning Standards. Division 7. Parks & Private Parks. 10 Chapter 26. Parking. Article VIII. Off‐Street Parking and Loading. 11 City of Houston, 2018. Infrastructure Design Manual. Chapter 9 ‐ Stormwater Design Requirements and Chapter 13 – Stormwater Quality Design Requirements. Houston, TX, September.



systems conform to the City Uniform Building Code. The city requires the use of storm sewer pipe “leads” (the connection from the private sewer to the public sewer) of at least 24‐inch nominal diameter, except for single‐family residential lots. The IDM prohibits the use of beehive grate inlets and “other specialty inlets.” The city’s IDM requires an analysis of how the new development will perform during the 100‐year recurrence interval rain event (the 1% annual chance storm event, about 8.58 inches in 3 hours, depending upon location). This so‐called, extreme event analysis, must show the flow path of the extreme event overland flow, the capacity of the roadways through which the flow is routed, and define the maximum depth of inundation (peak water surface elevation) in the areas under study. The finished floor elevation of all structures in the area must be located above the peak water surface elevation. 7.1.5 Stormwater Detention Design The city’s IDM requires that developers provide onsite detention for all development that alters the existing ground surface in some manner and results in impervious surfaces within the area of ground surface alteration (known as “disturbed area”). The IDM requires the developer of a project smaller than 1‐acre to provide onsite detention at a rate of 0.2 acre‐feet per acre of disturbed area with a final impervious condition. The IDM requires the developer of a project larger than 1‐acre to provide onsite detention at a rate of 0.5 acre‐feet per acre of disturbed area with a final impervious condition. Unlike many other jurisdictions, the city’s IDM does not currently allow project sponsors to assess the volume, rate, and timing of stormwater runoff before and after the proposed project in order to size detention to mitigate any increases in runoff conditions to the public drainage system. This creates a disincentive to use some GSI techniques, such as bioswales or vegetative filter strips, which alter the timing of stormwater runoff and can reduce detention requirements without diminishing the overall level of service and public benefits. The city’s IDM allows private projects to provide detention in parking areas, private streets, and private driveways as long as the ponding depth does not exceed 9‐inches in areas used by passenger vehicles or 15‐inches in areas used only by private trucking fleets. The city does not currently provide any means to build excess detention and sell or trade the excess volume to another party, which could form the basis for a “stormwater credit trading” market. 7.1.6 Stormwater Quality Design City ordinances12 require developers and property owners to obtain a stormwater quality permit to address the discharge of pollutants from completed new development or significant redevelopment projects larger than 1 acre. Developments must provide a stormwater treatment device or implement stormwater pollutant removal practices on the property in perpetuity. City regulations require the

12 Chapter 47. Water and Sewers. Article XII. Storm Water Discharges. Section 47‐651. Storm water quality permit application generally.



property owner to annually hire a professional engineer to certify that any stormwater quality devices on the property are being maintained and are still functioning. The property owner must also pay an annual renewal fee of $150.00. 7.2 Proposed Integrated GSI Rules The city might incentivize developers to implement GSI on their projects if the city modified both the code of ordinances and the IDM to harmonize parking, landscaping, open space, drainage design, detention design, and stormwater quality design requirements. The city could offer developers the option of applying for a development permit using the existing set of rules or, in exchange for the use of GSI, the city could allow the developer to proceed using an alternative set of rules. The alternative set of “GSI rules” would seek to encourage the planning and design of development features that provide more than one function and would require the use of GSI. The integrated GSI rules would provide both inherent cost savings and benefits to the project because design elements that perform more than one function can reduce costs. For example, under current rules, a project developer might need to provide a minimum number of parking spaces, a certain area of landscaping with a specific number of trees, a minimum volume of detention, and a stormwater treatment device at the end of underground pipe system. Under the envisioned GSI rules the developer might be able to provide a smaller number of parking spaces with a permeable13 surface and underdrain, a landscaped bioswale with bioretention and trees that would serve to convey and treat stormwater as well as meet open space and landscaping requirements, a smaller volume of detention, a shorter lengths of underground piping, and no end‐of‐pipe stormwater treatment device. While the exact details of all of the proposed integrated rules should be considered by all relevant city departments and interested stakeholders, the following general provisions should be included in the GSI rules: Landscaping and Open Space

o Impose a higher open space fee for sites that do not utilize GSI and a lower fee for sites that do utilize GSI;

o Grant credit for GSI techniques towards open space requirements; o Increase the requirement for parking lots trees; o Omit the perimeter shrubs requirement if the parking lot is served by GSI along the

interface between the public right of way and the private parking area; Parking

o Offer reduced parking requirements if GSI is implemented onsite; and, o Allow permeable paving systems including asphalt, concrete, stone aggregate, and pavers

(all with underdrains) in parking bays and driveways. Drainage and Stormwater Quality

o Allow beehive inlets and other specialty inlets to accommodate GSI systems;

13 IDM, Chapters 9 and 13 use the word “porous pavement” instead of permeable pavement. This report uses the term “permeable surface” or “permeable pavement” or “permeable paving systems” to refer to porous paving systems made with asphalt, concrete, stone, or blocks.



o Allow smaller diameter private storm sewer leads to accommodate shallower and more visible GSI flowlines;

o Include consideration of Atlas 14, Volume 11, Version 2.0 rainfall depths, frequencies, and intensities;

o Allow the use of a hydrological analysis of the pre‐development and post‐development conditions to determine peak flows, total runoff volume, and detention requirements, down to a minimum detention rate of 0.35 acre‐feet of volume for each acre of impervious area (within the disturbed area), if technically demonstrated as sufficient;

o Explicitly allow drainage design calculations to consider GSI features designed to retain, detain, convey, or infiltrate stormwater to be permeable;

o Harmonize drainage and stormwater quality design provisions with Harris County; o Allow bioretention to be sized and designed in a manner similar to that required by Harris

County; o Require an underdrain connected to a storm sewer below all permeable paving; o Require an operations and maintenance plan for all private GSI facilities, as currently

required for stormwater quality devices; o Require annual certification of private GSI facilities by a professional engineer, as

currently required for stormwater quality devices; Design Criteria for GSI Techniques

o Develop detailed design criteria for GSI techniques allowed in private development; o Define specific criteria that must be met for any site design feature to be considered GSI

for the purposes of receiving any incentive; and, o Allow the use of real‐time weather data controlled “smart” stormwater systems to

facilitate the operation of both rainwater harvesting systems to reduce potable water consumption and stormwater detention systems.

7.3. Evaluation Criteria The consulting team evaluated the proposed set of integrated GSI rules using the same criteria as the prior incentives. These criteria included: Legal, policy, and procedural issues. Benefits and costs. Threshold points. Barriers or challenges. Implementation strategies.

The consulting team generated comparative cost and threshold information using the conventional and green hypothetical projects presented in Enclosure A. 7.3.1 Legal, Policy, or Procedural Issues Section 7.1 outlined the current rules and identified the relevant sections of current city ordinances and the IDM. The consulting team was not able to identify any legal, policy, or procedural issues that would



preclude the implementation of the proposed integrated GSI rules. To move forward with implementation the city would need to revise some city ordinances using established city council committees, public input processes, and procedures. The city would also need to revise some chapters of the IDM using the established revision process implemented by the Office of the City Engineer. 7.3.2 Cost Information During a prior phase of project work the consulting team interviewed developers and obtained a limited amount of project information and costs. None of the projects included GSI facilities. To provide additional cost information the consulting team devised a hypothetical project site and designed it using both a conventional approach and using a GSI approach. Enclosure A includes the details of this hypothetical project site. The main features of the hypothetical project site are summarized in Table 7‐1. The table also presents maintenance costs, which are almost always a big concern of developers and local governments. The presented cost comparison illustrates a higher cost for landscape and drainage system maintenance, however, the consulting team believes that the enhanced aesthetics and quality of the tenant and customer experience would lead to higher retail sales, higher lease income, faster lease up, and better financial performance.

Table 7‐1 Hypothetical Site Features

Development Type: Mixed Use

Building Uses: Food and Beverage (8,000 sf) Retail (15,120 sf) Office (23,120 sf, second floor)

Building Size: 23,120 sf (First Floor Footprint)

Building Format: 2 story

Lot Size: 2.606 acres

Location: On corner of major thoroughfare and collector street.

Pre‐Development Condition: Open space, Type D soils with poor condition turf grass.

Assumed Total Project Cost: $25 million

The consulting team prepared detailed cost estimate of both designs to allow direct comparisons of development features. Elements common to both designs, such as lighting, dry utilities, water service, wastewater service, benches, building construction, signage, annual color plantings, and similar items were omitted from the analysis. Table 7‐2 presents the cost differences for the main site development items.



Table 7‐1 Hypothetical Commercial Site Cost Comparison for Selected Elements

No. Item Conventional Site Green Site

INSTALLATION

1 Trees $ 22,800 $ 22,800

2 Shrubs $ 88,000 $ 120,000

3 Mulch $ 24,420 $ 33,300

4 Soil $ 48,840 $ 66,600

5 Decorative Stone/Cobbles $ ‐ $ 5,000

6 Irrigation $ 16,300 $ 22,500

7 Pedestrian Walkways and Patios (Concrete) $ 115,493 $ 99,582

8 Pedestrian Bridges $ ‐ $ 10,000

9 Construction Stormwater Management $ 9,800 $ 10,879

10 Parking Lot Grading and Paving $ 445,318 $ 282,993

11 Permeable Paving and Underdrain NA $ 244,530

12 Bioswale Grading NA $ 14,880

13 Drainage System Inlets $ 78,000 $ 3,500

14 Storm Sewer Pipes and Manholes $ 4,500 $ 12,120

15 Below Grade Detention $ 618,255 NA

16 Stormwater Quality Treatment Device $ 12,000 NA

17 Bioretention System NA $ 29,000

Total Initial Installed Cost $1.49 million $978 thousand

ANNUAL MAINTENANCE

1 Mulching $ 1,500 $ 2,500

2 Weeding $ 1,500 $ 2,500

3 Permeable Paving Vacuuming NA $ 3,762

4 Bioretention System Rehab NA $ 660

5 Stormwater Quality Treatment Device Maintenance $ 2,500 NA

Total Maintenance $ 5,500 $ 9,422

Note: Costs estimated by R. G. Miller Engineers, Inc. and Asakura Robinson based on site development and landscaping unit costs and vendor cost estimates from the period from June 2018 to February 2019.



Table 7‐1 illustrates a construction cost savings of $504,000 on an assumed overall project cost of $25 million. This represents a 2% cost reduction for the overall project. 7.3.3 Threshold Points Almost all developers interviewed during an earlier phase of this project reported that detention requirements created one of the biggest challenges in site design. The proposed integrated GSI rules should incentivize developer use of GSI if the new rules provide a clear cost savings and developers recognize the benefits provided by the approach to tenants, residents, and other users of the finished development. The hypothetical project site costs, along with the H‐GAC cost estimates, illustrate that GSI can reduce overall development costs from 2% to as high as 38%, depending upon the project type, scale, and other site‐specific factors. This range of cost savings would appear to be sufficient to motivate developer use of GSI. 7.3.4 Barriers or Challenges The city will encounter several challenges in implementing this incentive. First, adoption of ordinance and design criteria requirements will take time and consensus building. Second, stakeholder agreement on technical changes may be difficult to achieve. Third, once adopted, staff training will likely be required. Fourth, developers and various real estate professional service firms will need to learn the new procedures and requirements. 7.3.5 Implementation Strategies The city should be able to overcome the listed challenges as outlined below. First, adoption of ordinance and design criteria requirements could be accomplished using the Redevelopment and Drainage Task Force established after Hurricane Harvey. That stakeholder group is very well versed in drainage and development issues and represents a broad group of community advocates, engineers, architects, contractors, and developers. Second, stakeholder agreement should be facilitated through the use of the Redevelopment and Drainage Task Force and using the city’s existing IDM revision process. Staff training and industry education can be accomplished at a reasonable cost or low cost, especially with the involvement of entities such as the Houston Land and Water Sustainability Forum, the Urban Land Institute, the Houston‐Galveston Area Council, and the American Council of Engineering Companies, and the Greater Houston Builders Association. The city could consider bundling this incentive program with others outlined in the memorandum because a combined set of incentives might motivate the use of GSI more than one alone.



PART 8.0 FINDINGS The memorandum finds, after detailed screening of initial incentive programs, researching potential legal or policy limitations, assessing the ability for incentive programs to exceed associated threshold points to motivate developers to utilize GSI approaches, that the City of Houston should move forward with the development and implementation of the following incentive programs: Permitting Timeline Certainty Property Tax Abatements Award and Recognition Program Integrated GSI Development Rules



ENCLOSURE A

DESIGNS AND COST ESTIMATES FOR CONVENTIONAL AND GREEN

HYPOTHETICAL COMMERCIAL PROPERTY



ENCLOSURE A: DESIGNS AND COST ESTIMATES FOR CONVENTIONAL AND GREEN HYPOTHETICAL COMMERCIAL PROPERTY

To assist with incentive program evaluations the consulting team created a 2.6‐acre hypothetical development project with the main features shown in Table A‐1.

Table A‐1: Hypothetical Site Features

Development Type: Mixed Use

Building Uses: Food and Beverage (6,936 sf) Retail (16,184 sf) Office (23,120 sf, second floor)

Building Size: 23,120 sf (First Floor Footprint)

Building Format: 2 story

Lot Size: 2.606 acres

Location: On corner of major thoroughfare and collector street.

Pre‐Development Condition: Open space, Type D soils with poor condition turf grass.

The consulting team made the following assumptions to prepare our designs: Undeveloped site with Type D soils, poor condition turfgrass prior to project construction; No utility conflicts or relocations; No street tree conflicts; Public 30‐inch storm sewer located along collector street at an adequate depth; Surface parking lot to be utilized; Current IDM and ordinance requirements guided design decisions for conventional design; Up to 9‐inches of inundation on parking areas to help achieve detention in both designs; Proposed “GSI rules” guided design decisions for green design; For the green site used a detention rate of 0.40 acre‐feet per acre that was calculated using the

rational method and comparison of the pre‐development and post‐development hydrographs; Parking requirements reduced by 20% for the green design option; Specification of commercially available plant materials; and, Full irrigation system provided for both designs.

Figure A‐1 provides the site plan for the conventional design. Figure A‐2 provides the site plan for the green design. Elements common to both designs, such as lighting, dry utilities, water service, wastewater service, benches, building construction, signage, and similar items were omitted from the analysis. Table 7‐2 presents the cost differences for the main site development items.



FIGURE A1 – CONVENTION SITE DESIGN



FIGURE A1 – GREEN SITE DESIGN



Table A2: Hypothetical Commercial Site Cost Comparison for Selected Elements

No. Item Conventional Site Green Site

INSTALLATION

1 Trees $ 22,800 $ 22,800

2 Shrubs $ 88,000 $ 120,000

3 Mulch $ 24,420 $ 33,300

4 Soil $ 48,840 $ 66,600

5 Decorative Stone/Cobbles $ ‐ $ 5,000

6 Irrigation $ 16,300 $ 22,500

7 Pedestrian Walkways and Patios (Concrete) $ 115,493 $ 99,582

8 Pedestrian Bridges $ ‐ $ 10,000

9 Construction Stormwater Management $ 9,800 $ 10,879

10 Parking Lot Grading and Paving $ 445,318 $ 282,993

11 Permeable Paving and Underdrain NA $ 244,530

12 Bioswale Grading NA $ 14,880

13 Drainage System Inlets $ 78,000 $ 3,500

14 Storm Sewer Pipes and Manholes $ 4,500 $ 12,120

15 Below Grade Detention $ 618,255 NA

16 Stormwater Quality Treatment Device $ 12,000 NA

17 Bioretention System NA $ 29,000

Total Initial Installed Cost $1.49 million $978 thousand

ANNUAL MAINTENANCE

1 Mulching $ 1,500 $ 2,500

2 Weeding $ 1,500 $ 2,500

3 Permeable Paving Vacuuming NA $ 3,762

4 Bioretention System Rehab NA $ 660

5 Stormwater Quality Treatment Device Maintenance $ 2,500 NA

Total Maintenance $ 5,500 $ 9,422

Note: Costs estimated by R. G. Miller Engineers, Inc. and Asakura Robinson based on site development and landscaping unit costs and vendor cost estimates from the period from June 2018 to February 2019.


Page 1 of 8

STAKEHOLDER REVIEW COMMENTS ON THE MARCH 7, 2019 DISCUSSION DRAFT OF THE

CITY OF HOUSTON’S GREEN STORMWATER INFRASTRUCTURE INCENTIVES STUDY

Response Document Prepared and Finalized April 29, 2019

No. Source Document Reference (1)

Comment Response

1 Participating Developers General Various comments were received throughout the interview and project review process leading up to the completion of the March 27, 2019 discussion draft.

All comments addressed in the March 27, 2019 discussion draft.

2 City Departments General Various comments were received during internal coordination meetings leading up to the completion of the March 27, 2019 discussion draft.

All comments addressed in the March 27, 2019 discussion draft.

3

Robert Adair Chair, Houston Land and Water Sustainability

Forum

General

The only comments I have are that this is an outstanding document. I can’t imagine a better, more well researched and well thought out set of proposals. Thanks to you and all those whose time, energy and effort went into creating this. I look forward to the HLWSF Steering Committee meeting next week, where I expect that we’ll be unanimous in our support of your conclusions. I’m also confident that we’ll be ready, willing and able to assist in any way we can to get your plan implemented.

Acknowledged. No report revision required.

4 John Blount, Harris County Engineer

General

It should be noted several of the discussion points focus around greater density, currently regulated by Chapter 42. The new County Planning criteria will be allowing smaller lot sizes, reduced setbacks, as well as other incentives for Green Infrastructure, Multimodal Transportation options, Community Geothermal Heating and Cooling etc. Expedited plan reviews, reduced or eliminated permit fees, etc. are all up for consideration. This will be an alternative to following Chapter 42 outside the City limits. Binkley and Barfield will be scheduling a workshop on behalf of the County in the near future to discuss the path forward on this initiative.


HOUSTON INCENTIVES FOR GREEN DEVELOPMENT: APPENDIX D - RESPONSE TO COMMENTS DOCUMENT

Stakeholder Review Comments on the March 7, 2019 Discussion Draft of the City of Houston’s Green Stormwater Infrastructure Incentives Study

(1) Document References: D1: Results of Task 001: Research and Benchmarking; D2: Results of Task 002: Work with Private Developers; D3: Legal and Policy Issues, Financial Performance, Barriers, and Challenges;

D4: GSI Study Report. “P” followed by a numeral refers to the page number of the corresponding document. “L” followed by a numeral refers to the line of text appearing on the page, not including headings and

subheadings.

Page 2 of 8


Comment Response

5 Walter P. Moore, Inc.

(WPM) General

There can be more elaboration on the benefits of green infrastructure and why green infrastructure needs to be incentivized by the COH. It appears that many of the benefits of GSI to both the developer and to public are inherent properties of GSI (cost savings, property value increase, water quality, flow attenuation, etc.) and therefore would not need additional incentive from the city to be implemented. It may be useful to include some evaluation for the need to incentivize the use of GSI.

The GSI fact sheets will be updated to include information on both developer benefits and public benefits. GSI proponents have been advocating since 1998 for developers to utilize GSI because of the project benefits without much success. The city’s program will help further stimulate the use of GSI through knowledge, education, recognition, facilitated permitting, and aligned development rules.

6 WPM General

There can be better definition of what specific criteria must be met for a feature to qualify as GSI in the COH, and specific requirements for minimum site implementation. The criteria itself does not necessarily need to be included as part of this study, but the study should mention that specific criteria must be generated and adopted by the COH as part of the incentive implementation. This will help avoid subjective distribution of incentives. This will also help avoid a scenario where a developer implements insufficient or under designed GSI to engage the incentives, and designs and develops the rest of a project using conventional methods, but with reduced requirements.

This will be added to the implementation portion of the recommendations.





subheadings.

Page 3 of 8


Comment Response

7 WPM General

Under current regulations, there is cost incentive to develop a greenfield site as opposed to redevelop a currently developed site. However, redevelopment with GSI would have a greater and more positive impact on the system at large than new development on a greenfield with GSI. Green infrastructure incentives can be used to promote redevelopment by providing more or better incentives than would be provided for greenfield development. Our recommendation is that the tax abatement incentive only be eligible for redevelopment projects. This may also help to maintain cost/revenue neutrality.

The details of the tax abatement program will be defined during implementation; however, this suggestion will be included in the recommendation.

8 WPM D1, P3, L4 Those incentives don’t relate to stormwater impacts from development; same impervious footprint.

The listed incentives from other cities help to incentivize GSI while complying with other stormwater management rules. These programs don’t allow the developer to build projects without mitigation. No report revision required.

9 WPM D1, P3, L22 Increased density tends to decrease[d public benefits]. The report indicates that the incentives offered must ensure that desired public benefits are still achieved. No report revision required.

10 WPM D2, P2, L26 Which studies? Can these studies be referenced? References to prior studies showing the decreased costs for drainage infrastructure for single‐family residential subdivisions in the Houston area will be added.

11 WPM D3, P4, L5 + L20

What about combination of detention and water reuse volume? Allow for [real‐time weather controlled system] that would drain vaults prior to storm events. Was this evaluated?

Real time controls were not explicitly evaluated, however, provisions to allow their use should be included in the recommended integrated GSI development rules. This will be added to the recommendation.

12 WPM D3, P6, TABLE

Is there documentation for the reasoning behind these scores for those eliminated from further evaluation? It’s not evident why some are so low.

Scoring is explained in the main text of the report. No report revision required.





subheadings.

Page 4 of 8


Comment Response

13 WPM D3, P9, L1 Seems like this is a City issue that needs to be addressed regardless of GSI implementation.


14 WPM D3, P12, L11 So we’re talking actually talking about expedited permitting here.


15 WPM D3, P12, L24 City will need a strong, CLEAR definition of GSI in order for this to work. Additionally, some minimum threshold of GSI implementation will need to be set.

Agreed. Report to include these details in the implementation recommendation.

16 WPM D3, P16, L16 Program would work better for larger, high value properties.

Analysis suggested that tax abatements for both small and large projects would be successful, because the tax abatement value and the cost of GSI are both directly proportional to project scale. No report revision required.

17 WPM D3, P16, L23 Where does this [smaller projects need less costly GSI] assumption come from?

This is not an assumption, it is based on engineering cost estimates of projects of various scales. No report revision required.

18 WPM D3, P19, L22

A small residential developer putting in small bioswales would be hard‐pressed to compete with a large campus with many GSI features/elements [to obtain any award or recognition.]

Recommendations to provide awards and recognition to the entire range of project scales and types will be added to the report.

19 WPM D3, P20, L8

The City would need to show value of this program over other third‐party recognition programs such as Envision, SITES, Greenroads, etc. City award would likely need to be more easily attainable, otherwise projects already implementing GSI for other sustainability recognition entities will be the ones winning, this providing no incentive for developers new to GSI to compete.

Acknowledged. Will include consideration of this in the recommendations portion of the report.

20 WPM D3, P22, L6 Would be helpful to determine how often developers opt for [open space] fee in lieu of open space requirement; is fee enough disincentive as‐is?

Anecdotally developers use it a lot. This, coupled with the other elements of the integrated GSI rules should help to motivate developers to utilize GSI. The project team did not believe that $700 per dwelling unit would be sufficient alone. No report revision required.





subheadings.

Page 5 of 8


Comment Response

21 WPM D3, P23, L32 [The stormwater quality annual fee] varies by year. Acknowledged. No report revision required.

22 WPM D3, P24, L13 [Does a bioswale meet open space requirements now?] No. No report revision required.

23 WPM D3, P24, L14 I believe [no end of pipe treatment device is required if] LID is used.

Acknowledged. The introductory text is merely setting the stage for how the proposed integrated GSI rules would work together to incentivize GSI. No report revision required.

24 WPM D3, P24, L20 Verify [that a bioswale meets open space requirements now].

It does not. No report revision required.

25 WPM D3, P31, L13 Include design storm and IDF curves used for this analysis.

The design method will be defined in the updated Infrastructure Design Manual during the implementation of this recommendation. The consulting team would expect that the Atlas 14, Volume 11, Version 2.0 100‐year event would be used for design. No report revision required.

26 WPM D4, P5, L25 Are there any studies to back up and explain these benefits? Can they be referenced?

Yes. Supporting studies will be referenced in the final report.

27 WPM D4, P6, L1 Have these 5 projects been selected, or is this an opportunity for developers?

The vision is to recognize five future projects. No report revision required.

28 WPM D4, P11 [For a green roof] what are the minimum requirements for soil depth/porosity, storage in drainage layer, etc.?

Design details will be determined during implementation of the recommended incentive. No report revision required.

29 WPM D4, P25, L4 [Property tax abatements] should only be available to redevelop[ment] sites.

Acknowledged. Report will be revised to make this recommendation if policy consensus is reached by senior directors.

30 WPM D4, P26, L23

[Hydrological analysis should only be allowed if] GSI is implemented. Would this encourage a developer to implement very small, under‐designed GSI systems to engage this incentive?

The text requires the analysis to technically demonstrate adequacy, therefore, under‐designed systems would not be approved. No report revision required.

31 WPM D4, P26, L23 Would green roofs be considered impervious? Specific criteria for GSI imperviousness should be treated in hydrologic analysis needs to be included.

This is an important consideration. Report will be revised to include explicit discussion of whether each GSI features is considered permeable or impermeable for the purposes to detention calculations.





subheadings.

Page 6 of 8


Comment Response

32 WPM D4, P27, L5 [Add] opportunity to include combined detention/rainwater reuse system verification of functionality through this program.

Real time controls were not explicitly evaluated, however, provisions to allow their use should be included in the recommended integrated GSI development rules. This will be added to the recommendation.

33 WPM D4, P29, L30

Specify a certain level of plan completeness [for plans being reviewed in the team review permitting incentive]. Maybe this becomes second round of review if the plans met a certain standard in the first round of review.

Will add some discussion about a completeness review step prior to scheduling the team review to the recommendations.

34 Houston Advanced

Research Center (HARC) General

We suggest that retrofits should be specifically called out in this document to underline the importance of not only greenfield but also existing projects implement GSI.

Private property GSI retrofits are largely driven by court orders as part of combined sewer system overflow consent orders and would not be applicable to Houston. Private sector‐initiated retrofits would typically be considered as part of a larger redevelopment project, which is already addressed in the report. No report revision required.

35 Houston Advanced


There is an opportunity to make enhanced public benefits a more robust part of the incentives program and place more focus on building infrastructure that has larger public benefits.

The report is designed to articulate the developer benefits of GSI implementation to help motivate a voluntary change in behavior. No report revision required.

36 Houston Advanced


It is understood that this document is aimed for commercial developments. Will there be consideration to offering private homeowners incentives in the same vein? These types of residential incentives have shown to be very successful in other municipalities.

Residential development and redevelopment is covered in the proposed GSI development rules. Retrofits are not a focus of the programs, as discussed in response to Comment No. 34. The proposed programs ger commercial projects to avoid the large administrative burden of a program involving small‐scale residential projects. The city could, if desired, expand the programs to target residential property at a later date. No report revision required.





subheadings.

Page 7 of 8


Comment Response

37 Houston Advanced


The fact sheets are well designed, clear and concise. We recommend that they are one component of a broader outreach strategy to the public and developers that will help educate and explain the incentives, how to access information on implementation, benefits, etc.

Acknowledged.

38 Houston Advanced


We urge the City to increase its use of GSI in public projects, to “lead by example” as a way to showcase this project type and the public benefits concept to the broader community.

Acknowledged. Public GSI has been implemented in certain projects such as Alemeda Road, Memorial Park, Cottage Grove, and Bagby Street in midtown. Additional public GSI will be evaluated as part of the development of a broader GSI strategy and also as part of the city’s Resilience Plan and Climate Action Plan.

39 Houston Advanced


We are highlighting the strategic overlap with several the items outlined in the GSI report and the City’s Climate Action Plan (CAP), which is currently under development: Types of GSI that reduce urban heat island through trees, grasses, and plants (i.e. Urban forests, Bioretention, and Green Roofs) also lower carbon emissions by reducing the electrical demand to cool buildings in addition to sequestering carbon through photosynthesis.

Acknowledged. Comment will be shared with the City’s Chief Sustainability Officer.

40 Houston Advanced


We are highlighting the strategic overlap with several the items outlined in the GSI report and the City’s Climate Action Plan (CAP), which is currently under development. Reduced parking requirements (help implement the) CAP transportation strategy to reduce vehicle miles travelled.


41 Houston Advanced


We are highlighting the strategic overlap with several the items outlined in the GSI report and the City’s Climate Action Plan (CAP), which is currently under development. Water conservation (through controlled






subheadings.

Page 8 of 8


Comment Response

“smart” stormwater systems) overlaps with the CAP wastewater strategy to reduce electricity demand.

42 Houston Advanced


We are highlighting the strategic overlap with several the items outlined in the GSI report and the City’s Climate Action Plan (CAP), which is currently under development. “The city should consider the policy implications of restricting the tax abatement incentive to projects that redevelop properties and excluding properties that develop previously undeveloped land.” overlaps with CAP Land Conservation ‐ Crosscutting CAP strategy to support both infrastructure densification (Building Optimization, and Transportation focus areas) and natural carbon sequestration (Decarbonization focus area).



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