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University Stormwater Management within Urban Environmental Regulatory Regimes: Barriers to Progressivity or Opportunities to Innovate?


U.S. public university campuses are held directly responsible for compliance with many of the same federal- and state-level environmental regulations as cities, including stormwater management. While operating as ‘cities within cities’ in many respects, campuses face unique constraints in achieving stormwater regulatory compliance. To compare the abilities of campuses to comply with stormwater regulations to municipalities, we conduct mixed-methods research using primary data from five University of California (UC) campuses. Public universities constituted over 20% of California’s “nontraditional” permittees under the municipal separate storm sewer system (MS4) regulation regime in 2013. We utilize semi-structured interviews with campus and regulatory officials, a survey of campus students and staff around support and willingness to pay for innovative stormwater management, and content analysis of campus stormwater management documents to examine challenges to public university stormwater compliance. We find that, despite their progressive environmental practices in other areas like energy and water conservation, even as compared to cities, stormwater management practices on the evaluated campuses are constrained by several factors: infrastructure financing limitations, lack of transparent and coordinated decision-making, a lack of campus resident involvement, and regulatory inflexibility. Our study provides new insights, both for understanding campuses as sustainable ‘cities within cities’ and more broadly for urban environmental compliance regimes globally.

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  1. Private California universities are not subject to Phase II MS4 permits like public campuses and instead manage stormwater as any large private developer might. For example, the private University of Southern California (USC) does not have MS4 compliance requirements and follows the City of Los Angeles’ Low Impact Development guidelines like other developers (USC Sustainability Office, personal communication 2018). While free from regulatory requirements, USC still faces challenges to innovative environmental management. The campus delayed recycled water use until the city connected their purple pipe infrastructure and has found campus-wide stormwater capture to be economically infeasible (Lindberg 2019).

  2. Population values provided by the five southernmost UC Campuses in their 2013 Phase II permit Notice of Intent (NOI) letters sum to 220,063.

  3. Populations were stated by the campuses in their Notice of Intent(NOI) letters for Phase II permits in 2013.

  4. Before finalizing the study, we shared a draft with each interviewee and invited comments and criticisms; only four interviewees responded and only two had substantive comments which we incorporated into revisions.

  5. Human subjects approval was granted for this study through UCLA (IRB # 16-000773-AM-00005) and UC Irvine (IRB # 2817-1).

  6. All five UC campuses have staff assemblies, undergraduate student governments (Associated Students), and graduate student assemblies.

  7. We relied on randomized emails to students via the registrar offices at three of the five campuses. The remaining two campuses prohibited campus-wide emails to students, which resulted in the other recruitment methods and much lower response rates. No email service is available for staff members, so survey invitations were sent through the campus staff assemblies only.

  8. The survey took an average of 15 min the final sample excluded respondents spending <5 min as this was found to identify surveys with significant blank responses. Responses were also deemed invalid without a campus affiliation (undergraduate, graduate student, or staff).

  9. Respondents were presented with 4 increments of $20 each from <$0 to $100 followed by four additional $5 increments within their initially selected $20 increment. The median of the final $5 increment was calculated as the willingness to pay of each respondent. Natural treatment systems were described in the survey as an innovative form of green infrastructure for stormwater management.

  10. Respondents could select all reasons that applied, responses add up to more than 100%.


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This work was funded as part of a University of California Office of the President Grant from the Multicampus Research Programs and Initiatives (MRPI), entitled “Fighting Drought with Stormwater: From Research to Practice.”

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Correspondence to Gregory Pierce.

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Pierce, G., Gmoser-Daskalakis, K., Jessup, K. et al. University Stormwater Management within Urban Environmental Regulatory Regimes: Barriers to Progressivity or Opportunities to Innovate?. Environmental Management 67, 12–25 (2021).

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  • Environmental governance
  • Regulatory compliance
  • University campuses
  • Stormwater management