1. Analysis and Procedure: The Rise and Fall of the Stormwater Rule
“Policy Modeling in Practice”
Centre for Research in Social Simulation
December 8, 2014
Royal Academy of Engineering

2. Christopher L. Moore (Me!)
2002-
2004
Legislative staff (Waxman, Cardoza)
U.S. House of Representatives
BA: Political Science
UC Berkeley (2002)
2008-
2009
Oak Ridge Science and Education Fellow
U.S. Environmental Protection Agency
MPIA: Intl. Economics
UC San Diego (2007)
Economist/Environmental Protection Specialist
U.S. EPA: Office of Wastewater Management/ Municipal Branch
2009-
2013
German Chancellor Fellow
“Funding the Water Infrastructure Gap- Lessons for U.S. Regulators and Utilities from Germany’s Success”
Funded by:
2013-
Current

3. Organizational Players
Office of Water
Office of the Administrator
Office of Wastewater Management
Office of Management and Budget
Office of Policy
Office of Science and Technology
Executive Order (1993)
Regulatory Planning and Review

4. Urban Stormwater Management in the United States: National Research Council (NRC) Report
Source: NRC Report
Credit: Chris Crockett, City of Philadelphia Watershed Department
Source: NRC Report
Copyright: Ecological Society of America

5. Bremerton, Washington Denver, Colorado Nashville, Tennessee
Normal, Illinois
From asce.org and Kuchar, Brian; LID Practices in Urban Areas- Example Projects and Opportunities in Redevelopment; 2011 Low Impact Development Symposium; Philadelphia, September 2011

7. Draft Approach Office of Water Management Initial Approach Watershed
(NRC Recommended)
Regulatory
Non-regulatory
Individual Site
Draft Approach
Draft Specific Language
Impact Analysis
Staff
Site Visits
Public Comment
Funding
Calculated costs. Staffers full time. Rachel, Holly, Jeremy, Todd, Ashley, Erika,

8. Select low compliance cost practice
New Regulatory Requirement
Impact Analysis (Cost Benefit Analysis)
Select low compliance cost practice
Benefits to Society ($)
-avoided flooding
-water supply savings
-avoided dredging costs
-valued water quality improvements
Projected Acres of Future Development
Compliance Costs ($)
Climate and Watershed Model
Modeled Impact of Regulation (Redrawn from Abt Associaties “Development of Generic Landscape-Level Stormwater Retention/Treatment BMP in SWAT” Presented SWAT International Conference, Toulouse, France July 2013

9. May 2009 Initiated
December 2012 Planned Finalization
June 2013 Negotiated Extension (Missed)
March 2014 Rulemaking Stopped
NRC Report

11. vs vs $s
Threshold effect vs vs
Firm Organization

12. Stakeholders and Interested Parties (Differing mental models)
Understanding Risk: Informing Decisions in a Democratic Society (NRC Report)
The Demand Model
The Table
Stakeholders and Interested Parties
(Differing mental models)
Existing Models and Data
(supplied by previous academic and policy work)
Redrawn from Norton 2006 p. 470

13. Thank You!
@chmooze

14. Redrawn from Norton 2006 p. 140 (originally in NRC 1983)
Research
Risk Assessment
Risk Management
Laboratory and field observations of adverse health effects and exposures to particular agents
Hazard identification (Does the agent cause the adverse effect?)
Development of regulatory
options
Information on extrapolation methods for high to low dose and animal to human
Dose-response assessment
(what is the relationship between dose and incidence in humans?)
Evaluation of public health, economic, social, political consequences of regulatory options
Risk characterization (What is the estimated incidence of the adverse effect in the population?)
Field measurements, estimated exposures, characterization of populations
Exposure assessment (What exposures are currently experienced or anticipated under different conditions?)
Agency decisions and actions
The scientific intellectual framework behind EPA’s organizations
Redrawn from Norton 2006 p. 140 (originally in NRC 1983)