Arguments for inclusion of economic criteria in the total maximum daily load (TMDL) allocation phase

Abstract

The idea of including economic analysis in pollution control studies is not new. There is a long tradition of research modeling least cost load allocation for water pollution control that has led to a substantial awareness that failure to take costs into account in load allocations can greatly increase the costs of water pollution control. Despite this understanding, the current load allocation approach adopted under United States Environmental Protection Agency total maximum daily load (TMDL) program allocates pollutant loads among different polluters in the absence of economic criteria. Many water quality professionals question the appropriateness of including economic criteria into an already complex and cumbersome TMDL allocation process. The question is not why we do not include economics into waste load allocations, rather the question is why we should? This paper attempts to identify and present the benefits associated with the incorporation of economic criteria into the traditional TMDL allocation process. The TMDL process is considered to be a holistic watershed approach and as such should not overlook the economic consequences of pollutant allocation alternatives. This paper attempts to focus less on the mechanism of optimizing the costs and more on the benefits derived as a by-product of doing so. The advantages of incorporating economic criteria for a bacteria load allocation in the Roses Creek watershed in the Commonwealth of Virginia are presented in this paper.