Supplementary Material Appendix A. Tables Table A1 - Test for Discontinuity at Thresholds 1000 and 1500 (Bandwidth of 20). Threshold 1000 (Bandwidth 20) mean α 1.0584 -0.39 140.6507 -61.663 12.9578 -9.313 13.2676 -3.054 13.4887 -2.501 Variable Active Share Flood Risk Payroll Income Housing Value Population Density 4400 -3900 ∗∗∗p < 0.01, ∗∗p < 0.05, ∗p < 0.1. p 0*** 0*** 0*** 0*** 0*** Threshold 1500 (Bandwidth 20) mean α 0.773 -0.096 97.3842 -5.335 11.2467 2.35 9.8025 0.63 10.4656 1.12 p 0.14 0.611 0.029** 0*** 0*** 0*** 426.0833 0.753 156.6 Table A2 - Test for Discontinuity at Thresholds 1000 and 1500 (Bandwidth of 30). Threshold 1000 (Bandwidth 30) mean α 0.9461 -0.288 86.214 -3.455 17.0471 -4.627 10.2649 -0.016 11.7061 -0.572 Variable Active Share Flood Risk Payroll Income Housing Value Population Density 2800 -2200 ∗∗∗p < 0.01, ∗∗p < 0.05, ∗p < 0.1. p 0*** 0.532 0.001*** 0.912 0.005*** Threshold 1500 (Bandwidth 30) mean α 0.6829 -0.002 94.0945 -3.653 9.6834 4.04 10.0526 0.365 10.6591 0.904 p 0.977 0.709 0*** 0.005*** 0.001*** 0*** 557.5361 0.871 80.43 1 Table A3 - Falsification Test: Arbitrarily Determined Threshold of 723 (Bandwidths 20, 25, 30). Variable Active Share Flood Risk Threshold 723 (Bandwidth 20) mean α p Threshold 723 (Bandwidth 25) mean α 0.409 p Threshold 723 (Bandwidth 30) mean α p 0.254 0.004*** 0.507 0.141 0.102 0.5805 0.043 0.595 95.064 0.499 0.912 103.172 -4.916 0.612 96.6333 -0.016 0.998 Payroll 12.961 -2.092 0.365 12.647 -1.383 0.501 13.128 -1.803 0.327 Income 10.049 0.177 0.326 10.027 0.231 0.222 10.1832 0.028 0.893 11.022 0.052 0.891 10.866 0.217 0.608 11.1843 -0.153 0.716 980.925 38.602 0.974 1300 -230.091 0.809 1100 -358.119 0.714 Housing Value Population Density ∗∗∗p < 0.01, ∗∗p < 0.05, ∗p < 0.1. Appendix B: Tiered Incentive Schemes. Theoretical Model We assume that all communities have an equilibrium level of (public) flood risk management activity, Y*. Most communities have Y*=0. For those communities with Y*>0, we suppose that the (political) process generating Y* draws from a smooth distribution of positive Y values, such as a lognormal distribution or chi-square. In other words, we remain agnostic about the process for determining Y* except that positive values of Y* be distributed continuously and that increasing net benefits to increasing Y will not diminish Y*.1 We further consider that Y is observable, while a latent index of optimal flood management effort, Z, exists but is no directly observable. Z*, unlike Y*, can take negative values in equilibrium. Under the CRS, the federal government subsidizes Y. This results in a new distribution of flood risk management activity, Y**. We expect that Y** Y* at all levels. The cumulative distribution function (CDF) for Y* is entirely at or to the left of the CDF for Y**, or Y** first-order stochastically dominates Y*, as some communities will not be affected by the CRS discount, but others will take the encouragement of CRS to upgrade their Y attainment. In practice, we do not observe Y*. We only observe Y**. Under our theory, where CRS never leads a community to do even less flood management, we have Y*= Y** for all CRS nonparticipants. But for all participants, we observe Y** and never Y*. Estimating the effect of CRS on effort Y is thus problematic because the counterfactual (Y*) is not observed for the communities that volunteer to be “treated” and neither the actual (Y**) and the counterfactual (Y*) are observed for the untreated nonparticipants. Being unable to observe the counterfactual of what communities would have done in the absence of CRS constrains our evaluation of the CRS program. 1 Note that this allows for a discontinuity to occur when Y*=0 and for Y* to remain constant even if net benefits from raising Y* also increase. 2 Looking at the CRS program’s arbitrary thresholds is a way around this problem. A dominant feature of the CRS program – and many other nonlinear incentive schemes – is the tiered nature of the subsidy. Every additional 500 credit points raise the subsidy by a discrete 5% increment. This “step function” introduces a particular set of incentives that revolve around those thresholds. Contrasting it with a linear incentive scheme, where the subsidy is a constant proportion of credit score (e.g., credits/100 = % discount), the reward for investing additional effort in Y is generally continuous rather than “lumpy” or discontinuous at the thresholds. To sharpen this comparison, consider two alternative incentive schemes: a linear and a tiered system. Figure A1 depicts the subsidy rate (s, a discount on flood insurance premiums here) on the vertical axis and the credit score (Y) on the horizontal axis. Hold equal the area under the two alternative subsidy lines in order to keep total program spending comparable between the alternatives.2 Under the linear system, suppose that a community achieves some level of Y = Y’. This value Y’ is either “near” a threshold for the tiered system (e.g., 500, 1000) yet below that threshold or it is not. If the incentive scheme was switched from linear to tiered, let the new credit scores be Y’’. Communities with values of Y’ near a threshold from below may find it worthwhile to invest in additional Y in order to obtain the discrete jump in s at the next threshold. Other communities will reduce their Y’’ to the minimal Y in their tier as long as costs rise in Y and they seek lower costs. Notice that for either type of community, the resulting Y’’ value is necessarily at a tier threshold. For some communities, that means Y’’ < Y’ as they just barely cross the threshold of Y’. For other communities, that means Y’’ > Y’ as they upgrade their Y to obtain the jump in subsidy. What constitutes “near” or how large the ranges are where it is worthwhile to upgrade Y to take advantage of the nonlinear jump in subsidy depends on the communities’ decision making process – likely weighing the costs of the marginal upgrade in Y against the benefits of the much larger subsidy. On net, whether a linear subsidy induces more effort than a tiered subsidy (i.e., Y’ > Y’’) depends on many contextual factors and remains an empirical question. 2 Keeping the areas under the curve equal is the simplest way to highlight the effect of nonlinear incentives without confounding it with different subsidy levels as well. In this set-up, the subsidy lines cross at the midpoint of each tier. Of course, the linear subsidy line could be drawn to intersect the upper corners of the tiered subsidy line – along the lines apparently envisioned by Zahran et al. (2009) – but such a comparison is an implicitly more generous subsidy program (i.e., that linear subsidy amount is always as great or greater for every Y) and implies a positive subsidy at Y=0. 3 Fig. B1 - Linear and Tiered Subsidy Incentives. s linear system 10 tiered system above 5 “near” and below 500 1000 1500 Y While Figure A1 helps clarify the effect of switching from a linear to a tiered incentive system, the effect of introducing a tiered subsidy when no previous subsidy existed is more involved. The basic logic remains. Suppose that Y* is the initial credit score in the absence of the CRS subsidy. Some initial Y* values will be near-yet-below a CRS threshold, while others will be above a threshold. As before, those communities near-yet-below a threshold will upgrade to a Y** > Y* just above the threshold. The other communities, however, will not reduce their Y** to the lower threshold value because Y* was optimal in the absence of a subsidy. Introducing a subsidy will not induce a Y**<Y*. We should expect to see many communities’ optimal Y values remain unchanged with the tiered subsidy simply because they subsidy amount is insufficient to induce a jump to the next tier. (For these communities, the subsidy is not affecting behavior and amounts to a wealth transfer.) Those communities “near” a threshold from below might upgrade to the next tier. How large the “near” neighborhood is depends again on relative costs of upgrading and the decision processes for communities. Regardless, Y** Y* for all communities, and Y** > Y* for some. Except for some communities whose optimal Y* in the absence of the CRS happened to be at a CRS threshold, the bulk of the communities achieving Y values at the thresholds can be seen as communities responsive to the CRS (as Y** > Y). Finally, if the CRS subsidy were linear, it might be seen to change the Y behavior of more communities, but the tiered system’s larger effect on fewer, “near” communities may amount to more or less of a cumulative impact on Y.3 3 Aside from the theoretical ambiguity in comparing the power of linear or tiered subsidies to alter behavior, there are some compelling theoretical predictions that follow from the tiered system. The threshold induces upgrading behavior to just above the next threshold and never downgrading behavior. If the CRS subsidy were linear, we would not have these threshold effects which allow us to identify the communities responsive to the subsidy. Identifying the communities responsive to a linear subsidy would require knowing both the counterfactual Y* and the actual Y’ values. The tiered system makes it easier to identify the responsive communities (although there will be fewer of them and knowledge of Y* is still needed in order to estimate the magnitude of the responses). 4 To see this graphically, consider a simplified situation in Figure A2. This frequency distribution shown with a solid line represents the PDF for Y* (in a shape resembling a loglogistic distribution). We conjecture this simple counterfactual distribution (i.e., how Y would be distributed in the absence of the CRS) to reflect diminishing net returns to investment in Y or the increasing rareness of communities that heavily invest in flood mitigation. For simplicity, only two thresholds are included, at 500 and 1000. The dashed lines represent a possible frequency distribution of Y** values that results from a tiered CRS-style subsidy. Areas where the density of Y* is greater than for Y**, indicated with an Ai in Figure A2, represent the credit score regions where there is temptation for some communities to upgrade their Y scores in order to obtain the CRS subsidy. The figure shows some of the density shifting from Ai to the region Bi, just above the next threshold. The size of the “near and below” range depends on the context and the community in question (i.e., for two communities with Y* = 950, only one might find it worthwhile to upgrade to 1000). The distributions in the Bi ranges also reflect how some communities will upgrade to slightly more than the next threshold’s minimum value. This might be due to lumpiness in how points are awarded, uncertainty in how FEMA will audit scores, or other reasons. Throughout, the logic involves communities upgrading from A1 to B1 (and maybe even B2) and from A2 to B2, because they have no incentive to downgrade in the presence of a subsidy. The areas under the baseline and the tiered system lines in Figure A2 might be the same or, if the subsidy induces some communities with Y*=0 to start flood mitigation, the area under the dashed line might be greater. Fig. B1 - Stylized Shift in Distribution for Tiered Subsidy System. frequency baseline (Y*) tiered system (Y**) B1 “near” and below A1 B2 A2 500 1000 1500 Y The threshold discontinuity under the tiered subsidy of the CRS program invites the exploration of regression discontinuity approaches. First, we assume that communities participating in CRS cannot fully control their final CRS score (Y**). For instance, we can 5 assume that the final scores that communities receive from doing a particular CRS activity are determined by FEMA auditors. Based on this assumption, we then suppose that communities on either side of the threshold (to the next CRS tier) are effectively randomly assigned to their treatment class. Under these assumptions, with the help of a Regression Discontinuity Design (RDD), we claim to have found evidence of a causal effect of the subsidy discount. We can say things like “a jump from class 1 to class 2 causes more Z,” where Z is some measure of an outcome, such as the proportion of housing units in the floodplain. The use of RDD does not require control variables. An advantage to the RDD is that the assumption that the thresholds work to randomize the treatment (in this case, the CRS discount) can be tested, because under the assumption of random assignment we expect that communities just above the threshold should look identical to those just below the threshold in all kinds of non-outcome (non-Z) variables, X (e.g., property values, population densities, flood risks, income, education, form of government, etc.). We can then test whether X is different above and below thresholds. Our hypothesis is that we will reject the randomization assumption that communities above and below thresholds will look markedly different. Based on the literature on CRS, we expect that even around the thresholds, communities participating in CRS will differ based on their educational levels, financial resources, flood risks, demographic characteristics, and political (e.g., power) or economic (e.g., private property values) reasons. The basic theory is that Y** scores just above the threshold (Zahran et al., 2010 used 50 CRS points from the threshold) will tend to be strongly influenced by the discount, while Y** scores just below the threshold will tend to have weaker or no influence from additional discount. Those “just above” the threshold will tend to be there because they responded to the subsidy’s incentives; those just below are at their optimal Y regardless of the subsidy. 6