Green, Clean, and Dollar Smart

By Lynn Scarlett
Prepared for Environmental Defense Fund
Washington, DC (January 1, 2010)- As the 21st century opens, cities are restoring nature and its functions to the metropolis. Across the country, urban “greening” is gaining considerable momentum. Moreover, urban greening initiatives are often taking place within broader regional and increasingly ambitious ecosystem restoration efforts, where their success both depends upon and contributes to landscape-scale, non-urban conservation.


Climate change, continuing challenges with air and water quality, high energy costs, loss of open space and wildlife habitat, and other challenges are prompting a rethinking of urban landscapes and their relationship to surrounding areas. Natural landscapes such as wetlands and sea marshes, watersheds of free-flowing rivers and streams, forests, grasslands, even urban parks and greenways purify water; absorb pollutants from the air; protect communities from flooding; and prevent erosion.
Yet the connection between these benefits-called ecosystem services-and the natural world around us is often invisible and sometimes neglected, resulting in underinvestment in environmental protection and increased impacts from land, water, and coastal transformation. Through this neglect, cities have also missed opportunities for infrastructure cost savings and other economic, environmental, and community benefits.
Numerous federal, state, and local policies, many outlined in this paper, at least implicitly recognize the value of intact ecosystems services and the services those ecosystems provide to human communities. Many city greening efforts embody ecosystem services concepts, but much more could be done.
Four Opportunities-Integration, Metrics, Regions, and Policy Tools
Four areas present significant opportunity to enhance urban greening and contiguous regional ecosystem restoration efforts:

  • Integration: Greening activities often unfold as a set of distinct or separate initiatives rather than as an integrated suite of activities that address climate change, energy, air quality, water supplies and quality, wildlife, and other issues on an urban landscape scale.
  • Multi-benefits measures: Many urban efforts could benefit from more finely tuned measures, metrics that integrate multiple benefits, and monitoring to estimate and track benefits of greening investments. Such integrated metrics could better support opportunities to “market” the services generated through urban greening and take advantage of some Environmental Protection Agency regulatory innovations.
  • Regional Restoration: These urban efforts are often not integrated into regional strategies that link urban greening to non-urban, contiguous landscape-scale ecosystem restoration, limiting the potential to optimize ecosystem services benefits in terms of both environmental outcomes and revenue streams to support greening goals.
  • Policy Leveraging: Many city efforts have not fully utilized various federal policy tools available in Clean Air Act, Clean Water Act, and other laws, regulations, and policy guidance to generate possible ecosystem services revenue sources, use incentives to support investments in ecosystem services, or seek regulatory credits for these efforts. Full leveraging of policy opportunities could also benefit from development of some new federal, state, and local policy tools.
  • This guidebook offers cities, counties, states, and stakeholders some discussion, examples, and a summary of tools and policy recommendations that may stimulate further interest in expanding, integrating, and refining the greening of urban infrastructure using an ecosystem services framework.
    Key goals that shape that framework include:

  • facilitating regional, landscape-scale, or watershed-level actions;
  • enhancing local and state decision-making coordination across jurisdictional boundaries;
  • strengthening performance accountability through a focus on outcomes rather than prescriptions;
  • nurturing private stewardship and ecosystem services markets; and
  • sustaining place-based decision-making to take advantage of existing institutions and situational knowledge.
  • Why Urban Greening? Why Now?
    Several circumstances augment the relevance and timeliness of urban greening efforts. Aging infrastructure means cities face prospects of expensive replacement. Budget constraints strain the capacity of cities to supply services. Traditional infrastructure has not consistently performed well, as storm surges breach levees, storm water overflows, stream waters exceed EPA temperature standards, and water quality falls short of desired goals. Climate change; challenges of managing water supplies, water quality, and water flows in extreme storm events; and escalating energy costs and associated impacts all strain current urban infrastructure and resource management.
    Cities are seeking new solutions to meet their economic, social, and environmental goals. Tapping the services of Nature through urban greening offers potentially cost-effective, high-performing options to meet these goals. At the same time, landscape-scale conservation adjacent to cities presents linkage opportunities to improve results in cities and on these larger landscapes.
    Going for Green-Policy Context
    While the nation’s major environmental laws generally do not explicitly reference ecosystem services, several agencies have launched projects that use ecosystem services concepts. Several federal laws may also hold potential to support urban greening, ecosystem services investments, and associated landscape-scale conservation. In addition, new local, state, and federal tools could further strengthen urban greening efforts and their links to landscape-scale conservation and restoration.
    Opportunities for Action-Protecting and Enhancing Ecosystem Services
    Many federal, state, and local tools are available to cities and regions to: 1) provide a more holistic context for urban greening efforts and measure their benefits, and 2) integrate urban greening with regional and landscape-scale conservation and restoration. These tools offer examples for possible replication or adaptation to local circumstances and provide some potentially useful policy and governance concepts.
    These tools include mechanisms to establish structures to coordinate the different components of urban greening initiatives. They also include tools to develop, refine and combine metrics across multiple performance dimensions that include air quality, greenhouse gases, energy conservation, stormwater runoff, water quality and supply. In addition, cities and states should assess the applicability of existing federal, state, and local regulatory and financing tools that facilitate urban greening. Options include:

  • Clean Air Act: Air Quality Credits and Trees. Evaluate the applicability of Clean Air Act “emerging measures” provisions that allow tree planting to qualify for ozone-reduction credit.
  • Clean Water Act 2003 Phase II Stormwater Regulations. Consider using the Environmental Protection Agency’s model stormwater permit guidance to support tree-planting for purposes of improving runoff control.
  • Clean Water Act pollution trading and permit bundling opportunities. Develop state and local policies that build upon EPA pollution trading and related tools. In 2003, the EPA issued a Water Quality Trading Policy. In 2004, EPA issued a Water Quality Trading Assessment Handbook to facilitate water trading to improve water quality.
  • Clean Water Act and Safe Drinking Water Act grant provisions. Use EPA grant and loan programs under the Clean Water Act and the Safe Drinking Water Act that allow infrastructure greening and land acquisition to protect water supplies.
  • Green infrastructure and ecosystem services funds, bonds and surcharges. Develop funding provisions through utility or other state and local fees that support green infrastructure and land protections.
  • Ecosystem services evaluation laws. Develop state laws that create a framework to evaluate and protect ecosystem services. One model is SB 513-Oregon’s Ecosystem Services Bill. In the first state bill to focus specifically on ecosystem services, SB 513 states that “it is the policy of this state to support the maintenance, enhancement and restoration of ecosystem services throughout Oregon, focusing on the protection of land, water, air, soil and native flora and fauna.” (SB 513, Sec. 2)
  • Watershed-based framework. Use Clean Water Act watershed permitting guidance to develop a watershed framework for evaluating, planning, and implementing greening strategies that link urban and non-urban actions.
  • Clean Water Act Total Maximum Daily Loads. Develop state and/or local laws, policies, and regulations regarding nonpoint source pollution, which can provide impetus to water quality credit trading.
  • Offsite Mitigation Banking. Consider opportunities to implement Clean Water Act Sec. 404 wetlands mitigation requirements through banking to complement on-site requirements and improve ecosystem results. Section 404(b)(1) Guidelines promulgated in 2005 provide regulatory authority to consider ecosystem services benefits of wetlands, such as water purification.
  • This paper also recommends further federal actions that could encourage protection of and investment in ecosystem services. These include:

  • EPA development of infrastructure greening guidelines, including provisions to strengthen use of state revolving fund grants under the Clean Water Act and Safe Drinking Water Act for ecosystem and infrastructure greening.
  • EPA development of Safe Drinking Water Act incentives or requirements for states to implement the Source Water Assessment Plans that they have already developed.
  • Development of Coastal Zone Management Act incentives to states to include ecosystem services criteria in their coastal management plans developed under the Coastal Zone Management Act.
  • Creation of Federal ecosystem services guidance and support for ecosystem services that could include: 1) developing an Overall Performance Guidance on Integrated Ecosystem Services; 2) improving federal budgeting to support ecosystem services and landscape-scale restoration through multi-year and cross-agency integrated budgets; 3) developing guidance on how to incorporate ecosystem services evaluations into National Environmental Policy Act evaluations.
  • Improvements to Federal conservation grants to: 1) focus on ecosystem priorities and performance effectiveness; and 2) strengthen integration of ecosystem services investments by focusing grant awards on landscape-scale initiatives. A model could be the USDA State Forestry program that uses competitive grants for a portion of its funding, with a focus on awarding grants to landscape-scale initiatives.
  • Related Resources:
    Green, Clean, and Dollar Smart