A pilot program, by definition, is to be short-term, small-scale, and experimental. They are feasibility studies, done to help determine whether or not the proposed project will work if implemented on a large scale. Since these programs are experimental, it is expected that the hypotheses are tested and comprehensive reports are published detailing successes and failures. It can be argued that programs such as the Parking Lot Stormwater Pilot Program have been deliberately ignored, and perhaps never intended to be experimental after all.
Because the Parking Lot Stormwater Pilot Program was implemented under the umbrella of New York’s Green Infrastructure Plan, one would expect that data collected regarding feasibility would be included in the Green Infrastructure Annual Reports. In 2012, the first year after the pilot program was introduced, the GI report noted that the DEP was still identifying stand-alone parking lots which were to be charged for runoff starting in 2013. In 2013, a rate increase from $0.05 to $0.06 per square foot was reported, as well as an increase in the number of lots being charged, and the total revenue generated from the program. The 2014 GI report noted another rate increase ($0.06 to $0.063 per square foot) and the usual statistics on revenue.
Notably, the 2014 report provided the first piece of useful information about the Parking Lot Stormwater Pilot Program- that it wasn’t working. Of course, the DEP did not outright state that the program was a failure. Instead, the report reads, “no green infrastructure exemptions have been given to date.” This means that parking lot owners would rather pay the stormwater fee than install green infrastructure on their properties. However, the purpose of the Green Infrastructure Program as a whole was to promote the development of GI throughout the city, not to devise revenue-generating tactics. In order for this program to be successful, the prospect of being exempt from the charge needs to actually entice people to install GI.
After the 2014 report, the pilot program should have ended or been modified to spark the desired change. The hypothesis was tested, and it failed. Perhaps the fee was not high enough for anyone to feel burdened by it, or retrofitting parking lots was more expensive than the fee itself. Nonetheless, the pilot program continued. The 2015 GI Annual Report states that, “previous annual reports describe the Parking Lot Stormwater Charge Pilot Program and can be found on DEP’s website.” What this reads is that the DEP gave up. They had seen no results from the pilot program, but were unwilling to cease collecting the revenue it generated. In 2016, the annual report again failed to include any relevant study, and it is safe to expect the 2017 report won’t either.
As of now, the Parking Lot Stormwater Pilot Program isn’t much of a pilot program. It has been in place for seven years, and its short-term feasibility was disproved back in 2014. The program continues, unfairly charging people while no research is being done and no dedicated reports are being put together. Instead, each year a short sentence is dedicated to the program in GI reports, which somehow passes as enough of a report to keep the program running under the guise of being a pilot.
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Allegra Miccio
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