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A COST-BASED STRATEGY FOR TMDL ALLOCATION
Published by the American Society of Agricultural and Biological Engineers, St. Joseph, Michigan www.asabe.orgCitation: Pp. 223-231 in Total Maximum Daily Load (TMDL) Environmental Regulations–II Proceedings of the 8-12 November 2003 Conference (Albuquerque, New Mexico USA), Publication Date 8 November 2003. .(doi:10.13031/2013.15563)
Authors: A. Z. Zaidi, S. M. deMonsabert, and R. El-Farhan
Keywords: Fecal coliform TMDL, Economic analysis, Optimization, Mathematical modeling
Many states are actively involved with the load allocation phase of the Total Maximum Daily
Load (TMDL) Program. The Environmental Protection Agency (EPA) directs that TMDLs must
“include establishment of reasonable and equitable load allocations among point sources that
will, alone or in conjunction with other management and restoration activities, provide for the
attainment of designated water uses (water quality standards) and the restoration of impaired
waters”(FDEP, 2002). Allocation of load reductions must include an evaluation of the most costeffective
approach, however, specific guidelines do not address how this should be
accomplished. The TMDL process is technically complex enough without the inclusion of cost
optimization. What are the benefits to be derived from including cost into the allocation?
Preliminary EPA reports project a median savings of 75% (with a range of 21% to 92%) in
implementation cost for BOD and Nutrients reduction when a “Cost-effective TMDL Program”
approach is followed (EPA, 2001). The EPA evaluation involved a simple linear comparison of
allocation alternatives. Unfortunately, the highly non-linear nature of the implementation costs
was not taken into consideration. With the potential for savings, it is imperative to develop a
systematic optimization approach that seeks to minimize costs of implementation while
incorporating the non-linear nature of the cost functions.