Two Perspectives on the Cost Benefit Analysis for San Diego Regional Bacteria TMDLs
Draft results of the Cost Benefit Analysis (CBA) for the San Diego Region’s wet-weather bacteria TMDLs have very recently been released for public review. Results include the cost effectiveness, tangible benefits in terms of regained recreation trips, avoided illnesses and co-benefits, and net benefits (in dollars) of a dozen scenarios for treating bacteria. During this presentation, two Steering Committee members will interpret the results of the analysis and prompt audience members to consider how this analysis may affect water quality management across California. Results are expected to inform a proposal for cost-effectively achieving the REC-1 beneficial use in the San Diego Region and may have state-wide implications.
As a result of the Triennial Review of the San Diego Water Quality Control Plan for the San Diego Basin, a Steering Committee was charged with guiding development of a credible and unbiased Cost-Benefit Analysis (CBA) using best available science to inform potential policy decisions surrounding this Bacteria TMDL. Roughly a dozen scenarios for implementing the Bacteria TMDL were analyzed to understand the resulting costs and benefits of compliance. For example, the CBA analyzes several scenarios focused on addressing human-waste sources of bacteria such as leaking sewage pipes, failing septic systems, and transient/homeless community contributions. The CBA also included scenarios focused on reducing bacteria through stream channel restoration instead of traditional stormwater BMPs. The CBA further examined several scenarios focused on stormwater treatment to achieve a variety of different regulatory endpoints; such as using the BMPs defined in Water Quality Improvement Plans to achieve the 2010 TMDL targets, EPA’s 2012 Recreation Criteria and using site-specific water quality objectives. For each scenario, the analysis quantified the benefits of: (1) public health illnesses avoided, (2) lost recreation trips to the beach due to health advisories after wet weather, and (3) quantifiable co-benefits such as habitat enhancement, reductions in non-bacteria pollutants and wildfire resiliency. These benefits were presented as numbers of illnesses or recreation trips lost, as cost per unit of benefit and as overall net benefit (in dollars) for each scenario.
Results were intended to inform the way that the REC-1 beneficial use can be attained and may support a proposal to the Regional Board for changing the bacteria TMDL or strategy to achieve it. The CBA analysis does not capture all considerations, integrate scenarios, and results are not expected to result in a unified recommendation for change to the Bacteria TMDL without synthesis of further evidence and stakeholder engagement. Additionally, results are not expected to provide rationale for (1) not achieving designated beneficial uses, (2) delisting polluted waters, (3) or allowing water quality to degrade.
The application of cost-benefit analysis to San Diego’s Bacteria TMDL is a potentially precedent-setting application of economic tools to better understand the environmental benefits of dollars spent and the most cost-effective strategy to achieve TMDLs in California. Both regulators and permittees can benefit from lessons learned about the analysis process, results and applications.
Chris Crompton is the manager of Water Quality Compliance Division at OC Environmental Resources, OC Public Works, County of Orange. He manages county-wide water quality compliance activities including total maximum daily loads and stormwater programs.
James (Jimmy) Smith is the Assistant Executive Officer of the San Diego Water Board, serving as the head of enforcement and as the Chief Operations Officer. Prior to his 16 years with the Board, Jimmy worked for Analytical Luminescence Laboratories, the National Estuarine Research Reserves and the Monterey Bay Aquarium Research Institute. Jimmy holds a Bachelor of Science in Biochemistry and Cell Biology from the University of California at San Diego and a Masters in Biological Oceanography from the Moss Landing Marine Laboratory.