Environmental Services Bureau 2021 Audit Status Report

Private Stormwater Management: City reliance on property owners requires review of risks and results

Report published July 20, 2018 | Follow-up report | Contact Elizabeth Pape

Our 2018 audit of Bureau of Environmental Services' approach to managing stormwater on private property found shortcomings with data collection and management, inspections, and program evaluation. We recommended that the Bureau make data available for system planning by streamlining information systems and increasing monitoring. We also recommended that the Bureau regularly assess its approaches to encouraging private stormwater management. At year two, the Bureau continued to make slow progress on data systems and inspecting stormwater structures at single family residential properties. It was in the process of evaluating Clean River Rewards through a Comprehensive Rate Study and evaluating and making changes to the permitting program based on risk assessments in a new stormwater and sewer system plan. 

On this audit there were six recommendations in process.

We recommended developing a single information system to inventory private stormwater structures. The Bureau created a list of about 140 types of data used across the Bureau and eventually will assign stewards for each type of data. The Bureau was also in the process of adding data on permitted structures to the same asset management database it used to track maintenance for public stormwater structures. The Bureau did not provide an update about tracking assets across the three systems identified in the initial audit: permitting, maintenance, and Clean River Rewards. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended developing additional risk-based monitoring programs for single-family residential stormwater permit structures and all Clean River Rewards structures like the existing program used to monitor non-single-family residential permit structures. The Bureau continued the practice of not inspecting residential properties and instead sent educational mailers. However, staff said that it was continuing work on a stormwater and sewer system plan, which will identify and prioritize business process improvements based on risk assessments for the entire collection system. The next phase of the plan will include an analysis of whether the Bureau should begin monitoring single family residential permits. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended creating a schedule and assigning staff to periodically evaluate outcomes of the private stormwater permitting program against stated goals. The Bureau identified three goals for the program: increase the equity and fairness of stormwater management charges; advance City environmental policies and commitments; and protect and enhance the long-term financial stability of the stormwater utility. The Bureau is evaluating progress towards these goals through its Comprehensive Rate Study, which has been delayed due to COVID-19 but is expected to be available in 2021. Management said that gathering meaningful data and investing in staff to evaluate outcomes or actual stormwater removed due to the program is a high-effort, high-cost activity. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended creating a schedule and assigning staff to periodically evaluate outcomes of the Clean River Rewards program against stated goals. The Bureau said that it would continue to evaluate business processes, such as requirements in the Stormwater Management Manual, as part of the continuing work on a stormwater and sewer system plan mentioned above. The Bureau is also tracking the percentage of participants in the utility financial assistance program who are also enrolled in Clean River Rewards. The Bureau will not evaluate Clean River Rewards impact on diverted stormwater. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended using the results of evaluations of the Clean River Rewards program to ensure the achievement of program goals and expectations. The status of this recommendation depends on the completion of the rate study, which is still in process. Because the Bureau is not meetings its goal for the percentage of participants in the utility financial assistance program also participating in Clean River Rewards, it increased targeted outreach about Clean River Rewards, including a direct mail campaign and translated registration materials. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended using the results of private stormwater permitting program evaluations to ensure the achievement of goals and expectations. The Bureau planned to propose an increase in the threshold for the square footage of impervious surface that will trigger the need for a stormwater permit from 500 square feet to 1,000. The Bureau said it plans to request the increase in its comments on the next permit application with the Oregon Department of Environmental Quality. If the state approves the change, the Bureau can consider it in the next version of the Stormwater Management Manual. (Private Stormwater Management: City reliance on property owners requires review of risks and results)

We recommended that the Bureau commit to an implementation schedule for components of the Stormwater System Plan, including risk assessments, asset registry, and condition assessment. The Bureau completed a stormwater risk assessment mapping project and used it to support several planning projects. It was also implementing a new process to perform consistent assessments across all systems, which it planned to complete in mid-2021. The Bureau continued to refine its stormwater asset register and expected to define data needs, establish protocols, and prepare a data repository over the next couple of years. The asset register will include data on the condition of assets. (Restoration Projects and Green Streets: Planning and evaluation needed to confirm success)

We recommended that the Bureau create a method to use the risks identified in the Stormwater System plan to evaluate capital projects. The Bureau drafted a set of selection criteria for stormwater and restoration projects but use of the criteria has been delayed due to COVID-19. The Bureau is also developing a new integrated planning process that will allow it to prioritize projects across sanitary, stormwater, and natural systems. (Restoration Projects and Green Streets: Planning and evaluation needed to confirm success)

We recommended that the Bureau ensure that all projects have quantifiable goals that are tied to the Portland Watershed Management Plan or that reduce risks identified in the Stormwater System Plan. The Bureau developed guidelines in 2019 for developing monitoring plans that included quantifiable targets. Since then, staff were required to establish monitoring plans at the start of each restoration project. The Bureau was developing a matrix of benchmarks to assist project teams with setting project objectives and targets. (Restoration Projects and Green Streets: Planning and evaluation needed to confirm success)

We recommended that the Bureau regularly report project results to ratepayers in a way that explains the connection between projects and outcomes. The Bureau was working on a web-based map to display data gathered during project monitoring. The timeline for implementation was pushed back due to delays with the City's new website, but the Bureau expected the report to be available in January 2021. The Bureau also updated its Watershed Report Cards so that conditions in 2019 could be compared to conditions in 2015. The report cards are located online. (Restoration Projects and Green Streets: Planning and evaluation needed to confirm success)