Thank you for responding to “Fun With Numbers” (Publisher’s Page, Erosion Control May/June 2006); selected responses follow here. To view the original article, go here . Dear Publisher,
I appreciate your initiation of an effort to quantify economically the values of erosion control. A few of my own thoughts, questions, and ideas follow: In seeking an “economic” value to which actions can be compared, it becomes necessary to assign economic values to factors for which it may often be difficult to find dollar amounts. In some methods of erosion control, designing can incorporate elements of (1) aesthetics; (2) wildlife habitat, including game species, non-game species, and T&E species; (3) cultural/historical values; and (4) control or reductions of potential pathogens or contaminants in water later used for municipal or recreational uses, which then reduces economic costs of disease treatment. Assigning such economic values is difficult and controversial, as different interests may assign different values to the factors. But including such factors is essential in holistic evaluation of costs and benefits to erosion control. As an extreme example, one might compare the directly observable economic costs associated with flood and stormwater management and erosion control in the Los Angeles basin as undertaken in the last century. There, the primary method of erosion control was structural concrete. The direct costs and benefits could be calculated. But no dollar value was integrated to include impacts on aesthetics, wildlife habitat, water temperature, historical values, groundwater recharge, regional hydrology, or other factors for which assignment of economic values was more difficult or obscure. Dollars are the measurement standard most often selected, for dollars are measurable, are something for which comparative values are often readily available, and are a measurement that generally holds fairly universal value among a great diversity of citizens of the community. In the Los Angeles basin, these holistic factors of value in stream habitats, aesthetics, or natural hydrology were not quantified with an economic value in the past, and therefore in large part they no longer exist.However, though non-monetary factors may be difficult to translate into the numerical monetary standards, that does not necessarily equate to their being valueless. At this very moment you are paying nothing (or very little) for oxygen to be in your room-the oxygen you breathe constantly. While that air, oxygen, has an apparent direct monetary value of zero, I believe most persons would consider that access to air with good oxygen to be of utmost and essential value. If it came down to it, you and I and they would pay anything, everything, to keep access to that “free” oxygen. It is of no monetary value, as long as there is plenty of it to be readily acquired elsewhere. But when and where there is no other source, its value is beyond quantification! Likewise, many of the functions and values of erosion control such as those named previously may have limited measurable direct economic value. But as water quality, wildlife habitat, cultural and historical sites and scenes, and recreational opportunities become more and more limited, the values of these factors become more evident and greater.I do not propose to know how to appropriately give an economic value to such factors, any more than I can give an economic value to the air we breathe. But we must somehow seriously consider such values and factors and find ways to protect, preserve, and enhance such values and resources-before we cut off those vital “breaths of air” that we as individuals and as a society must preserve to survive and thrive.
Rand Fisher
Utah Department of Environmental Quality / Division of Water Quality
Salt Lake City, UT Dear Publisher,
With respect to your editorial, “Fun With Numbers,” I want to comment on one item that immediately comes to mind.One factor of COES that is not explicitly included in your formula is the cost of government staff non-compliance response time. That might be included in “RC,” costs associated with road closures, etc., but it’s not really listed there.Now, maybe your formula is more sophisticated than I am thinking, and you have deliberately excluded government costs and have sought to include only hard costs (materials, sales, etc.), or sought to exclude regulatory costs (although I see that’s included somewhat under COPES).And/or there may be an argument that government staff costs are part both of the erosion and sedimentation costs (COES) and of cost of preventing erosion and sediment in the first place (COPES). Sort of.And so government staff costs are a wash.So, if you don’t include government staff costs, that’s OK with me, but I wanted to point out that non-compliant construction sites take up government staff time. Time to deal with non-compliant sites is, depending on factors of course, from three to 10 times more time-consuming than compliant sites. That is my estimate. It could go higher for a recalcitrant operator where the full process of enforcement proceeds.Sometimes the government has specifically allocated resources to this problem-staff, etc. Sometimes not, in which case the government hardly deals with it and that creates other problems, or they do deal with it, taking time from other tasks.Hmmmm, a side thought: If all construction operators automatically (as automatically as they get dressed in the morning, say) maintained good erosion prevention and sediment control (EPSC), then I suppose there would be no need for EPSC regulations, to speak of, no need for government resources to that non-problem. (There are regulations against public nudity, I suppose, but the cost to enforce this must be near to nil. If we could make operators ashamed of poor EPSC…)I need to get back to establishing a better education program, construction-site EPSC inspection protocols, enforcement policies, and administrative procedures-all to deal with a local government construction-site runoff control program. All to prevent water pollution and to an extent other local government costs like the cleanup and traffic issues.
Robert Haley III, P.E.
Murfreesboro Water & Sewer Dept.
Murfreesboro, TN Dear Publisher,
Considering that cost is part of the definition of a BMP, it would make sense to have this information available in order to assist people in making the wisest decisions in the planning and implementation phases of a project (and the stormwater pollution prevention plan).However, the cost of controlling accelerated erosion and the cost of the impacts from inadequate control are difficult to measure. Someone may spend a significant amount of money on materials but still have impacts due to improper design or installation/maintenance of those control measures. I’ve heard contractors insist that they went above and beyond the measures in the plan, while the result (actual performance) in the field was grossly inadequate. They could have installed gold bars at that location, but it wouldn’t make a difference in the amount of sediment leaving the site, only in the price of the measure.I notice that there seems to be a general perception that erosion and sediment control is still something extra that has to be done on a development site, that it’s not part of the overall project management of the site. And in many cases, it is cost-effective to the bottom line to do the job without effective erosion and sediment control measures. So, it becomes a “risk management” issue (cost of non-compliance versus cost of a compliant site). I don’t agree that it has to be this way, though. I think that many times the cost of erosion and sediment control is unnecessarily higher than it needs to be due to the fact that it’s not implemented properly. In many cases, it’s more of a “damage control/Band-Aid approach” to attempt to demonstrate compliance, rather than a well-planned and well-executed effort to reduce impacts.It would be beneficial to see some actual numbers that reflect true costs. Measuring the costs from a global perspective is difficult, but there are opportunities for case studies from very localized, specific site conditions, and we could learn from those cases. We are already documenting practically every aspect of the construction process, and “data is the number-one cause of statistics” (to quote a cheeky professor from my past). This data could be compiled into some useful information. However, most people that I know in the industry are stretched so thin that even if they think it would be valuable information, they don’t have time to organize it and make sense of it.I’m not offering anything of use to this topic, only my thoughts! Perhaps it’s a really great post-graduate thesis topic.
Patricia Hardy, CPESC
Project Scientist, E Sciences Inc.
Orlando, FL Dear Publisher,
The article you wrote is very interesting, as I have been playing with these same issues on our projects for the past 10 years. Things that we have come to address are seasonal issues, type of soil, contour, and grade of site, and most important is the impact on adjacent environmental areas, such as wetlands, streams, and vernal pools. When you break down the cost by quarters, it also lets the customer know that different issues will affect the overall cost of erosion/sediment control and now stormwater treatment/processing, based on our climate here in northern California.It is our feeling here at Wetland & Erosion Technologies Inc. that we need to provide our customers with as much data as possible.
Gene Steuben, CPESC
Wetland & Erosion Technologies Inc.
Sacramento, CA Dear Publisher,
I read your article “Fun With Numbers” with great interest. I have often thought about the same question and am anxious to see where you take it. I personally deal with the COES side of the equation and have estimated the costs of increased dredging resulting from specific construction projects within our lake’s 25-square-mile watershed.I have two thoughts on the subject:The degree to which the benefits of proactive erosion and sediment control outweigh the expenses varies by more than location-it varies by methodology. On one extreme, there are things that cost little money that can greatly reduce erosion, such as waiting to expose soil in a specific section of a job site until construction is planned for that area. Temporary seeding and mulching also fall near this end of this spectrum. On the other extreme are expensive vortex separators that are costly to maintain, don’t trap fines, and go into bypass mode when you need them most (high-flow conditions).Unlike conventional cost/benefit analysis where a single entity pays for the prevention and reaps the benefits, that’s not generally the case with erosion control. So in some ways traditional cost/benefit analysis is not appropriate here because it weighs the cost of one group against the benefit of a different group. Suppose that a developer needed to spend $100,000 in erosion controls to prevent $50,000 worth of sedimentation in a nearby private lake. This scenario would make no sense from the cost/benefit standpoint but might make good sense from an administrative standpoint.Mark Rumreich, President
Indian Lake Improvement Association
Indianapolis, IN Dear Publisher,
You’re off to a good start, but I’m sure there are many more variables to be considered, some of which may include: For costs of erosion and sedimentation: Loss of nutrients, fertilizer, and arable land from agricultural settings Impacts to or loss of navigable waterways, where they are not dredged Water treatment costs should include residential, municipal, and industrial. Dredging costs are just one category of costs of habitat restoration (dredging is often inappropriate in streams). Loss of pond and reservoir storage capacity (including reduced functional lifespan of dam, cost of dam removal and/or replacement, increased flood risk when storage loss exceeds approximately 25%, lost hydroelectric generating capacity and cost of replacement power, lost real estate value for frontage owners, subjective/aesthetic impacts, etc.) Impacts to and loss of fish habitat, spawning habitats, and fish recruitment Loss of or reduced lifespan of impacted buildings or other infrastructure Increased threats to and loss of endangered species (fish, mussels, amphibians) Increased dispersal and human exposure to contaminated sediments (natural and/or anthropogenic metals, nutrients, chemicals), and increased costs of containment and treatment of dispersed materials For costs of preventing erosion and sedimentation: Overhead (Contractors and engineering firms often charge about 30% overhead or profit on top of the actual costs of labor, materials, and maintenance.) Planning and permitting costs should include legislative costs, regulatory costs, pro-rated taxes and administration, legal costs, and the cost of the highest foregone alternative uses of all of the above funds, resources, and manpower. Dave Braatz
Streamside Systems
Boonville, NC
I appreciate your initiation of an effort to quantify economically the values of erosion control. A few of my own thoughts, questions, and ideas follow: In seeking an “economic” value to which actions can be compared, it becomes necessary to assign economic values to factors for which it may often be difficult to find dollar amounts. In some methods of erosion control, designing can incorporate elements of (1) aesthetics; (2) wildlife habitat, including game species, non-game species, and T&E species; (3) cultural/historical values; and (4) control or reductions of potential pathogens or contaminants in water later used for municipal or recreational uses, which then reduces economic costs of disease treatment. Assigning such economic values is difficult and controversial, as different interests may assign different values to the factors. But including such factors is essential in holistic evaluation of costs and benefits to erosion control. As an extreme example, one might compare the directly observable economic costs associated with flood and stormwater management and erosion control in the Los Angeles basin as undertaken in the last century. There, the primary method of erosion control was structural concrete. The direct costs and benefits could be calculated. But no dollar value was integrated to include impacts on aesthetics, wildlife habitat, water temperature, historical values, groundwater recharge, regional hydrology, or other factors for which assignment of economic values was more difficult or obscure. Dollars are the measurement standard most often selected, for dollars are measurable, are something for which comparative values are often readily available, and are a measurement that generally holds fairly universal value among a great diversity of citizens of the community. In the Los Angeles basin, these holistic factors of value in stream habitats, aesthetics, or natural hydrology were not quantified with an economic value in the past, and therefore in large part they no longer exist.However, though non-monetary factors may be difficult to translate into the numerical monetary standards, that does not necessarily equate to their being valueless. At this very moment you are paying nothing (or very little) for oxygen to be in your room-the oxygen you breathe constantly. While that air, oxygen, has an apparent direct monetary value of zero, I believe most persons would consider that access to air with good oxygen to be of utmost and essential value. If it came down to it, you and I and they would pay anything, everything, to keep access to that “free” oxygen. It is of no monetary value, as long as there is plenty of it to be readily acquired elsewhere. But when and where there is no other source, its value is beyond quantification! Likewise, many of the functions and values of erosion control such as those named previously may have limited measurable direct economic value. But as water quality, wildlife habitat, cultural and historical sites and scenes, and recreational opportunities become more and more limited, the values of these factors become more evident and greater.I do not propose to know how to appropriately give an economic value to such factors, any more than I can give an economic value to the air we breathe. But we must somehow seriously consider such values and factors and find ways to protect, preserve, and enhance such values and resources-before we cut off those vital “breaths of air” that we as individuals and as a society must preserve to survive and thrive.
Rand Fisher
Utah Department of Environmental Quality / Division of Water Quality
Salt Lake City, UT Dear Publisher,
With respect to your editorial, “Fun With Numbers,” I want to comment on one item that immediately comes to mind.One factor of COES that is not explicitly included in your formula is the cost of government staff non-compliance response time. That might be included in “RC,” costs associated with road closures, etc., but it’s not really listed there.Now, maybe your formula is more sophisticated than I am thinking, and you have deliberately excluded government costs and have sought to include only hard costs (materials, sales, etc.), or sought to exclude regulatory costs (although I see that’s included somewhat under COPES).And/or there may be an argument that government staff costs are part both of the erosion and sedimentation costs (COES) and of cost of preventing erosion and sediment in the first place (COPES). Sort of.And so government staff costs are a wash.So, if you don’t include government staff costs, that’s OK with me, but I wanted to point out that non-compliant construction sites take up government staff time. Time to deal with non-compliant sites is, depending on factors of course, from three to 10 times more time-consuming than compliant sites. That is my estimate. It could go higher for a recalcitrant operator where the full process of enforcement proceeds.Sometimes the government has specifically allocated resources to this problem-staff, etc. Sometimes not, in which case the government hardly deals with it and that creates other problems, or they do deal with it, taking time from other tasks.Hmmmm, a side thought: If all construction operators automatically (as automatically as they get dressed in the morning, say) maintained good erosion prevention and sediment control (EPSC), then I suppose there would be no need for EPSC regulations, to speak of, no need for government resources to that non-problem. (There are regulations against public nudity, I suppose, but the cost to enforce this must be near to nil. If we could make operators ashamed of poor EPSC…)I need to get back to establishing a better education program, construction-site EPSC inspection protocols, enforcement policies, and administrative procedures-all to deal with a local government construction-site runoff control program. All to prevent water pollution and to an extent other local government costs like the cleanup and traffic issues.
Robert Haley III, P.E.
Murfreesboro Water & Sewer Dept.
Murfreesboro, TN Dear Publisher,
Considering that cost is part of the definition of a BMP, it would make sense to have this information available in order to assist people in making the wisest decisions in the planning and implementation phases of a project (and the stormwater pollution prevention plan).However, the cost of controlling accelerated erosion and the cost of the impacts from inadequate control are difficult to measure. Someone may spend a significant amount of money on materials but still have impacts due to improper design or installation/maintenance of those control measures. I’ve heard contractors insist that they went above and beyond the measures in the plan, while the result (actual performance) in the field was grossly inadequate. They could have installed gold bars at that location, but it wouldn’t make a difference in the amount of sediment leaving the site, only in the price of the measure.I notice that there seems to be a general perception that erosion and sediment control is still something extra that has to be done on a development site, that it’s not part of the overall project management of the site. And in many cases, it is cost-effective to the bottom line to do the job without effective erosion and sediment control measures. So, it becomes a “risk management” issue (cost of non-compliance versus cost of a compliant site). I don’t agree that it has to be this way, though. I think that many times the cost of erosion and sediment control is unnecessarily higher than it needs to be due to the fact that it’s not implemented properly. In many cases, it’s more of a “damage control/Band-Aid approach” to attempt to demonstrate compliance, rather than a well-planned and well-executed effort to reduce impacts.It would be beneficial to see some actual numbers that reflect true costs. Measuring the costs from a global perspective is difficult, but there are opportunities for case studies from very localized, specific site conditions, and we could learn from those cases. We are already documenting practically every aspect of the construction process, and “data is the number-one cause of statistics” (to quote a cheeky professor from my past). This data could be compiled into some useful information. However, most people that I know in the industry are stretched so thin that even if they think it would be valuable information, they don’t have time to organize it and make sense of it.I’m not offering anything of use to this topic, only my thoughts! Perhaps it’s a really great post-graduate thesis topic.
Patricia Hardy, CPESC
Project Scientist, E Sciences Inc.
Orlando, FL Dear Publisher,
The article you wrote is very interesting, as I have been playing with these same issues on our projects for the past 10 years. Things that we have come to address are seasonal issues, type of soil, contour, and grade of site, and most important is the impact on adjacent environmental areas, such as wetlands, streams, and vernal pools. When you break down the cost by quarters, it also lets the customer know that different issues will affect the overall cost of erosion/sediment control and now stormwater treatment/processing, based on our climate here in northern California.It is our feeling here at Wetland & Erosion Technologies Inc. that we need to provide our customers with as much data as possible.
Gene Steuben, CPESC
Wetland & Erosion Technologies Inc.
Sacramento, CA Dear Publisher,
I read your article “Fun With Numbers” with great interest. I have often thought about the same question and am anxious to see where you take it. I personally deal with the COES side of the equation and have estimated the costs of increased dredging resulting from specific construction projects within our lake’s 25-square-mile watershed.I have two thoughts on the subject:The degree to which the benefits of proactive erosion and sediment control outweigh the expenses varies by more than location-it varies by methodology. On one extreme, there are things that cost little money that can greatly reduce erosion, such as waiting to expose soil in a specific section of a job site until construction is planned for that area. Temporary seeding and mulching also fall near this end of this spectrum. On the other extreme are expensive vortex separators that are costly to maintain, don’t trap fines, and go into bypass mode when you need them most (high-flow conditions).Unlike conventional cost/benefit analysis where a single entity pays for the prevention and reaps the benefits, that’s not generally the case with erosion control. So in some ways traditional cost/benefit analysis is not appropriate here because it weighs the cost of one group against the benefit of a different group. Suppose that a developer needed to spend $100,000 in erosion controls to prevent $50,000 worth of sedimentation in a nearby private lake. This scenario would make no sense from the cost/benefit standpoint but might make good sense from an administrative standpoint.Mark Rumreich, President
Indian Lake Improvement Association
Indianapolis, IN Dear Publisher,
You’re off to a good start, but I’m sure there are many more variables to be considered, some of which may include: For costs of erosion and sedimentation: Loss of nutrients, fertilizer, and arable land from agricultural settings Impacts to or loss of navigable waterways, where they are not dredged Water treatment costs should include residential, municipal, and industrial. Dredging costs are just one category of costs of habitat restoration (dredging is often inappropriate in streams). Loss of pond and reservoir storage capacity (including reduced functional lifespan of dam, cost of dam removal and/or replacement, increased flood risk when storage loss exceeds approximately 25%, lost hydroelectric generating capacity and cost of replacement power, lost real estate value for frontage owners, subjective/aesthetic impacts, etc.) Impacts to and loss of fish habitat, spawning habitats, and fish recruitment Loss of or reduced lifespan of impacted buildings or other infrastructure Increased threats to and loss of endangered species (fish, mussels, amphibians) Increased dispersal and human exposure to contaminated sediments (natural and/or anthropogenic metals, nutrients, chemicals), and increased costs of containment and treatment of dispersed materials For costs of preventing erosion and sedimentation: Overhead (Contractors and engineering firms often charge about 30% overhead or profit on top of the actual costs of labor, materials, and maintenance.) Planning and permitting costs should include legislative costs, regulatory costs, pro-rated taxes and administration, legal costs, and the cost of the highest foregone alternative uses of all of the above funds, resources, and manpower. Dave Braatz
Streamside Systems
Boonville, NC
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