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OCR for page 291
ECONOMIC CONSIDERATIONS
_ MANAGING CONTAMINATED MARINE SEDIMENTS
Thomas A. Grigalunas and James J. Opaluch
University of Rhode Island
ABSTRACT
Contaminated marine sediments pose highly uncertain but
potentially serious threats to public health and the environ-
ment. However, cleanup of these sites is very expensive and
costs increase rapidly with level of effort. Thus, impor-
tant tradeoffs are faced in the social decision concerning
appropriate cleanup level. This paper discusses the applica-
tion of economic analysis as input to the social decision
process for managing contaminated marine sediments. Two
general approaches are outlined: cost-benefit and cost-
effectiveness analysis. Both approaches can provide valu-
able input into remedial action decisions at a site and in
allocating efforts among multiple sites (fund balancing).
However, significant diffi culties and uncertainties charac-
terize all approaches for managing contaminated marine sedi-
ments and economics is no exception. The difficulties and
potential for application of the two economic approaches are
discussed, along with the potential role of strict liability
for damages in providing incentives for source control to
avoid creation of new sites.
INTRODUCTION
Contaminated sediments occur in marine coastal areas throughout the
United States and in the Great Lakes (A. D. Little, 1987; U.S. Environ-
mental Protection Agency [EPA], 1985; Office of Technology Assessment
[OTA], 1987; U.S. Dept. of Commerce [DOC], 1988~. This contamination
stems from a variety of point and nonpoint sources including day-to-day
releases from industry, sewerage treatment plants, urban runoff, riv-
ers, federal facilities, shoreline erosion, atmospheric sources, and
periodic spills from vessels, pipelines, and shoreside facilities. The
substances contained in sediments include heavy metals, synthetic or-
ganic compounds, petroleum hydrocarbons, and other materials.
Concern with contaminated sediments stems from the threat they pose
to public health and the environment. At sufficient concentrations,
toxic substances give rise to health threats to individuals exposed
either directly through contact with contaminated materials or much
more likely, indirectly via the food web. Risks to health from con-
sumption of contaminated shellfish or finfish have caused public offi-
cials to close fishing grounds or restrict the catch of certain
291
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292
species, thereby imposing economic losses on commercial and recrea-
tional users of the affected species (e.g., Freeman, 1987; OTA, 1987
A.D. Little, 1987~. Indeed, even the perception of a possible but
uncertain threat to health from consuming fish exposed to toxic sub-
stances can impose losses (Schwartz and Strand, 19811.
Other losses also can result from contaminated marine sediments.
Direct lethal effects on adult fish and shellfish, juveniles, eggs and
larvae can cause short- and long-term commercial and recreational fish-
ery losses (Grigalunas et al., 1987, 1988~. Indirect or ecological
effects can lead to losses of commercial and recreational fisheries,
waterfowl, and other marine resources through loss of habitat (Kahn and
Kemp, 1985) and via the food web (Grigalunas et al., 1987, 1988~. Con-
cern about exposure to toxic materials also may impose losses on recrea-
tional beach users, and a reduction in property values can occur as a
consequence of a loss in amenity services at or near a contaminated
site (e.g., Freeman, 1987~.
Although the presence of contaminated sediments can impose a var-
iety of losses, remedial actions typically are very costly and in many
cases the cost increases rapidly as additional levels of remediation or
treatment are sought. For example, remedial actions described or pro-
posed for New Bedford Harbor (EBASCO Services, Inc., 1987~; the Hudson
River (Mark Brown, New York State Department of Environmental Conserva-
tion, personal communication); and Commencement Bay (Lukjanowicz et
al., 1988) could cost millions of dollars. An analysis of alternative
levels of cleanup of Hudson River polychlorinated biphenyls (PCBs) show
rapidly increasing unit costs with increasing levels of cleanup (Na-
tional Research Council [NRC], 1979~. Hence, additional degrees of
public health protection and environmental benefits can be achieved--
but typically only at far greater cost. Given limited funds to use in
cleanup of the rapidly increasing number of contaminated sites through-
out the country, higher expenditures on cleanup at one site implies
smaller remaining budget for cleanup at other sites. Thus, important
tradeoffs are faced in determining the level of cleanup that should be
carried out at any particular site.
Given the potential significance of public health effects and envi-
ronmental costs at contaminated marine sites, on the one hand, and the
potential high costs of taking corrective action at all sites, on the
other hand, issues relating to the management of contaminated marine
sediments are of major national importance. This importance is ref-
lected in the passage of the Comprehensive Environmental Response, Com-
pensation and Liability Act of 1980, CERCLA (PL 96-510) and is given
additional emphasis by the enactment of the Superfund Amendments and
Reauthorization Act of 1986, SARA (PL 99-499~. SARA adds a new crite-
rion to the hazardous ranking system, which is used to assess sites to
determine whether they should be included on the National Priorities
List (NPL). Under the act, consideration must be given to "the damage
to natural resources which may affect the human food chain" (Sec. 105
(a)~2~. As a consequence, SARA increases the likelihood that marine
contaminated sediment sites will be included on the NPL and thereby be
eligible for use of fund-financed remedial actions.
Deciding how, to what extent, and whether to remediate at a site on
;
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293
the NPL unavoidably confronts decision makers with very difficult deci-
sions and tradeoffs. SARA mandates that the remedies selected must
1. protect human health,
2. be cost-effective,
3. meet federal and state standards, and
4. utilize permanent remedies and alternative technologies ''to the
maximum extent practical" (Sec. 121 Obey.
However, the level of risk to health will depend on the amount commit-
ted to an action and the technology used, and remedial actions will dif-
fer in their cost and degree of permanence. SARA expresses a clear
preference for permanent remedies, but permanent actions are not re-
quired and have been avoided because of their high cost, at least in
the short run. Hence, implicit--if not explicit--tradeoffs among goals
cannot be avoided in making a decision at any site. The difficulties
involved are underscored by the evolving state of the art for remedial
action technologies; the formidable problems inherent in quantifying
risks to human health and the environment (Lave, 1987~; the need to
make remedial action decisions among multiple sites in the context of
fund balancing; and the requirement under SARA that the public and
potentially responsible parties be actively involved in the decision
process.
Clearly, site-specific factors are critical considerations in reme-
diation decisions at a given location. The case studies presented at
the workshop illustrate the particular concerns that drive the desire
for remedial actions, the strategies considered, and the institutional
factors that influenced the decisions made or the actions considered in
specific cases. Nonetheless, there are general principles which tran-
scend particular applications.
This paper examines some of the economic principles and issues that
arise in deciding whether, how, and to what extent to remediate at a
site. These approaches could be used to complement current approaches
to evaluating sediment management alternatives (EPA, 1985b, 1985c,
1986~. A generally applicable, economics-based methodology using con-
cepts from benefit-cost analysis and cost-effectiveness analysis is
developed, and suggestions are made concerning how this methodology
could be applied so as to capture the special characteristics of parti-
cular sites. The potential usefulness and limitations of the economics
methodology for assisting in decisions concerning the management of con-
taminated marine sediments is described.
To make economic considerations more applicable to contaminated
marine sediment issues, it is particularly important that the various
components be quantifiable. Hence, particular emphasis will be placed
on measurement, and the potential for quantifying these arguments for
particular applications will be discussed. It is recognized that quan-
tification of benefits from remedial actions is exceedingly difficult,
and may not be possible in all cases. Hence, the use of economic analy-
sis is limited in some cases. However, it also is recognized that
considerable uncertainty surrounds the use of any approach--whether
based on concepts from the natural or the social sciences--used to make
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294
decisions at and among sites, and thus substantial use must be made of
imprecise information and informed judgment.
In keeping with the scope of the workshop, particular attention is
given to the role of cost-effectiveness analysis in making management
decisions at particular sites. However, remediation decisions at indi-
vidual sites are made within a broader framework. This broader frame-
work involves, for example, fund balancing among sites and implicit if
not explicit judgments concerning relative public health and environ-
mental benefits and costs. In another vein, the liability provisions
established under CERCLA and the Clean Water Act, as amended, have
potentially important implications for encouraging source control to
help avoid the creation of new contaminated sediment sites (Grigalunas
and Opaluch, 1988~. Recognizing the importance of this broader frame-
work, this paper goes beyond consideration of cost-effectiveness and
outlines
1. the potential contribution and problems which arise from the use
of benefit-cost analysis to help guide remediation decisions,
and .
2. the use and limitations of liability as an approach for source
control.
GENERAL ECONOMIC CONSIDERATIONS
As noted, contaminated marine sediments are widespread and can
impose a number of public health and environmental costs, and in par-
ticular cases, these costs can be substantial. For example, New Bed-
ford Harbor, an area heavily contaminated with PCBs, is the marine
Superfund site that has been most carefully studied by economists.
Research funded by the National Oceanographic and Atmospheric Adminis-
tration (NOAA) estimated the present value of damages to marine
resources (using a 3 percent real rate of discount) to range from a
total of $39.6 million to $52.4 million in 1985 dollars (Freeman,
1987~. These damages resulted from injury to
1. the lobster fishery,
2. public beaches and recreational fishing, and
3. reduced amenity services experienced by people living near the
harbor alleged to arise from high concentrations of PCBs.
Direct losses to striped bass recreational fishermen alleged to have
resulted from Hudson River PCB contamination have been estimated by New
York State to be more than $4 million annually (OTA, 1987, p. 43~.
New Bedford Harbor and the Hudson River are among the most dramatic
examples of contaminated marine sediment sites. However, numerous
other cases exist of restrictions imposed on harvesting marine re-
sources from areas contaminated with metals and organic chemicals,
particularly for shellfish and bottom species near urban and industrial
centers (see, e.g., OTA, 1987; A. D. Little, 1987; Haberman et al.,
1983~.
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295
On the other hand, remedial action alternatives can require a major
commitment of resources, and the costs are very sensitive to the remov-
al and disposal option selected. To illustrate, in the case of Ever-
ett, Washington on Puget Sound, it was found that the construction cost
of $55 million for upland disposal was almost four times larger than
the $14.5 million construction cost of the selected alternative, con-
tained aquatic disposal in the deep waters of Puget Sound (Lukjanowicz
et al., 1988, p. 389. Further, available estimates suggest rapidly
increasing costs with additional degrees of remediation. For example,
an NRC report of PCB contamination (NRC, 1979) concludes that cost per
pound of PCBs removed from the Hudson River vary from $65 per pound
PCBs removed for initial cleanup of hot spots to $3,153 per pound for
complete removal of low-concentration river sediments, as shown in
Table 1.
Ideally, one would like to measure the economic damages at a site
prior to remediation, and the reduction in damages (the resultant bene-
fits) expected at different levels of remediation. With this informa-
tion, it would be possible to compare the increments in benefits from
greater levels of remediation with the associated increments in cost.
It then would be possible to assess whether remedial action at a site
was worthwhile on economic grounds and to use economic principles to
help guide the extent of remediation--a textbook solution to the "how
clean is clean" dilemma. Difficulties inherent in measuring the full
spectrum of damages make such an ideal approach beyond the reach of the
state of the art in many cases. Nonetheless, in a number of instances
some of the potential benefits from remediation can be quantified, and
this information can be used as part of the decision process concerning
proposed remedial actions.
As part of any analysis, attention must be given to several impor-
tant factors. Particularly important is the potential for uncertain
future costs. For example, landfilling or disposal of contaminants in
marine waters may cause adverse environmental impacts at some future,
uncertain date if the substances become re-released. SARA recognizes
TABLE 1 Incremental Costs of PCB Control in Hudson River (in 1978
Dollars)
Incremental Incremental Incremental
quantity control cost
controlled costs per kg
Policy (kg) ($ million) (dollars)
A. Maintenance dredging 23,100 $ 2.5 $ 108
B. Removal of remnants 7,700 $ 0.5 $ 65
C. Removal of stabilized
remnant deposits 15,100 $ 3.3 $ 219
D. Hot spot dredging 77,000 $ 22.4 $ 291
E. Removal of all
river sediments 55,600 $17S.3 $3,153
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296
this possibility and requires that in addition to short- term costs,
long-term costs must be considered when selecting a remedial action.
Such long-term costs include potential adverse health effects, long-
term maintenance costs, and potential future remedial action costs
should the selected alternative fail (Sec. 121 Ably. A rigorous
examination of long-term costs thus would include an analysis encom-
passing all feasible options and an assessment of the probability of
their failure at points in time. Further, the analysis must include
the probability that damages would result, given failure of each
alternative; the chance that further remedial action would be taken;
and the cost of such action and maintenance costs at each point in
time. Clearly, the data requirements for such an analysis impose a
truly major research burden on scientists and others charged with
assessing remedial action alternatives.
Other factors also must be considered. Potential beneficial
effects in addition to health and environmental benefits could result
in particular cases. For example, it may be possible to use removed
materials to construct islands or provide other natural resource en-
hancement (e.g., Landin, 1988) or to recover materials for reuse, as is
planned for uranium contained in sediments at Port Hope, Canada (Or-
chard, 1988~. Another factor to be considered is the availability and
capacity of upland disposal sites. Given the limited availability of
landfills and the difficulty in siting new facilities, the opportunity
costs of use of the disposal site must be considered in evaluating the
social impacts of alternative remediation strategies when upland
disposal is being considered.
Finally, it is important to recognize that in some cases, sediment
contaminants may degrade/dilute over time or become covered with clean
material as a result of natural deposition. In these cases, the bene-
fits to be achieved through remedial action can be negligible--or, in
fact, severe health or environmental costs could result should resus-
pension occur. The James River kepone case is an important example.
Natural sedimentation and dilution have reached the point that commer-
cial fishing in the James River will be allowed for the first time in
more than a decade (Huggett, 1988~.
Thus, the simplified contaminated sediment management problem can
be depicted in two stages;
1. public health and environmental effects--sediments are perceived
to cause public health and other social losses.
2. removal and remediation--these actions result in health and envi-
ronmental improvement but are costly, in terms of monetary costs
of the action and possibly environmental costs associated with
ecosystem disruption from physical removal and disposal in case
of nonpermanent actions. Landfilling, nearshore, and offshore
disposal may imply further uncertain costs or possible benefits.
Although it is easy to enumerate possible costs and benefits that
might arise in particular cases, it is difficult to provide quantita-
tive- economic information to assess net social impact. In this regard
the potential use of uncertain economic information is on the same
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297
footing as the use of uncertain information from the natural sciences
for making management decisions at sites. Hence, the choice is not use
of one approach that provides precise information versus another that
yields inexact information. Rather, all available approaches necessar-
ily involve important elements of imprecision, subjectivity, and judg-
ment. Important social decisions must necessarily be made within this
uncertain environment since no amount of research can completely re-
solve the uncertainty faced by society.
Clearly, a great deal of scientific and technical information is
needed to describe the problem and the tradeoffs that result from the
management alternatives for addressing the problem. However, the final
choice among the alternatives is necessarily a social decision based on
a weighing of these tradeoffs. The next section describes two general
frameworks that have been used by economists to address such issues.
ALTERNATIVE ECONOMIC FRAMEWORKS FOR ADDRESSING
THE CONTAMINATED MARINE SEDIMENTS PROBLEM
Benef it - Cos t Analys is
Benefit-cost (B-C) analysis attempts to quantify all important bene-
ficial and detrimental impacts of a proposed action in dollar terms.
This approach potentially can be very valuable because it is very flex-
ible, and, moreover, it is the only approach that can indicate whether
or not remediation is a good investment of society's resources. Hence,
to the extent B-C analysis can be used as part of remediation deci-
sions, it puts investments in this area on the same economic footing as
public investments for environmental improvement in other areas and for
public projects in general.
However, B-C analysis is limited in its potential applicability due
to the difficulty of providing a monetary measure of damages when eval-
uating commodities that are not sold in established markets, as is typ-
ically true when evaluating many environmental damages. Despite the
extreme difficulty in quantifying environmental damages in dollar
terms, a great deal of progress has been made in measuring these non-
market effects.
Economic Methods for Evaluating Nonmarket Environmental Goods
Many environmental damages involve nonmarket goods and services--
that is, goods and services that are not traded in the marketplace,
such as sports fishing or public beach use. Values of nonmarket goods
are sometimes viewed as "subjective," and it is often claimed that
these values cannot be measured in monetary terms, as is the case for
market goods. However, values for market goods in many respects are no
less subjective than those for nonmarket goods. For example, consumer
preferences for taste, texture, color or other attributes of salmon are
no less subjective than preferences for viewing wildlife; consumer will-
ingness to trade off price differences for salmon attributes could
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298
reveal the value of these attributes (Anderson, 1988~. The difficulty
in measuring values for nonmarket goods does not derive from the fact
that they are more subjective, but rather from the fact that these
preferences are not directly revealed in market transactions.
Two general approaches have been developed for evaluating nonmarket
commodities: the revealed preference approach and contingent valuation
approach. A brief description of each approach follows.
Revealed Preference Approaches
The basis of the revealed preference concept is that through an
individual's actions, his or her preferences are revealed. Use of
revealed preference is most straightforward for economic valuation of
goods and services sold in the marketplace since it is relatively easy
to infer preferences from these market decisions. However, the concept
of revealed preference also can be used for nonmarket goods by using
related-market techniques. This approach is based on the concept that
the value a good or service which is not traded on a market can be
inferred from closely-related goods which are sold on the market
(Freeman, 19799. Two related-market approaches are outlined and
illustrated in the following paragraphs.
Travel cost approach. Suppose the problem is to evaluate a non-
market recreational experience, such as a fishing trip to a particular
site. If a fishing experience could be bought in the marketplace, such
as through an entrance fee, then the observations on the decisions
individuals made, given this market price of participation, could be
used to value the fishing experience. Although there may be no en-
trance fee for most fishing sites, the cost of participating can be
measured, since in order to fish at a particular site one must travel
to the site and incur certain costs in the process. Thus, the travel
cost can be viewed as the price of participating, and usual market
valuation approaches can be applied by examining participants revealed
behavior. A recreational fisherman's value for changes in catch rates,
for example, can be measured in terms of willingness to travel longer
distances to more remote sites, which have higher catch rates (Brown
and Mendelsohn, 1984~.
An example of the application of this related-market approach to
the problem of contaminated marine sediments is provided by the econ-
omic damage assessment study of New Bedford Harbor PCBs. It was hypo-
thesized that public awareness of the PCB contamination in the harbor
affected recreational beach users and recreational fishermen. Damages
would be reflected in a decrease in the demand for these recreational
activities relative to the no pollution situation. For recreational
beach use, the study focused on three beaches adjacent to waters or sed-
iments with significant PCB concentrations. Telephone interviews were
conducted with a random sample of residents of nearby communities. The
results revealed that "among those aware of the PCB pollution, up to
twice as many households would have visited the beach in 1986 if the
PCBs had been cleaned up' (Freeman, 1987, ply. The estimated total
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299
damages to beach users alleged to have resulted from the PCB pollution
of the sediments was $8.3 million (Freeman, 1987, p.lO).
For recreational fishing, it was estimated that the PCB pollution
resulted in the diversion of 41,935 trips to other sites with an aver-
age cost of diversion per trip of $1.60. Using this approach, annual
damages alleged to result from the PCB pollution were estimated to be
$67,100, and the present value of these alleged damages was $3.1 mil-
lion in 1985 dollars.
Hedonic-price approach. This related-markets approach is based on
the concept that a particular market good is composed of various nonmar-
ket characteristics, and that given market prices for similar goods
with differing levels of the characteristics, one could calculate the
implicit '"price" people are willing to pay for the characteristics.
For example, the characteristics of a house can be described in terms
of square footage, style, age, number of bathrooms, yard size, and
neighborhood characteristics. Given data on a large number of house
sales, statistical techniques could be used to relate price differen-
tials to each of the characteristics in order to identify the implicit
price of these characteristics. If one of the characteristics is, for
example, sediment quality of the adjacent marine waters, then the value
of sediment quality to an individual can be estimated in terms of the
additional amount the individual would be willing to pay for a house in
an area of high sediment quality, as compared to a house that has iden-
tical characteristics, or after correcting for other differences in
characteristics, except for the one "neighborhood" characteristic, sedi-
ment quality. Note that willingness to pay in this context is based on
actual or revealed behavior as reflected in the sales price of homes.
This approach is particularly useful for valuing the effects of con-
taminated marine sediments and, in fact, was applied in the New Bedford
Harbor PCB damage assessment study. Any reduction in the amenity ser-
vices of the harbor should be reflected in relative decreases in the
prices of nearby residential properties. It was hypothesized that the
effect of the pollution on housing prices would be stronger for those
houses near the more contaminated harbor waters. The study area was
divided into three zones of diminishing levels of pollution, and data
were assembled on residential sales prices for single family dwellings
located within two miles of the New Bedford harbor shoreline. The
results indicated that the estimated total damages (reduction of pro-
perty values) alleged to result from PCB contamination of marine sed-
iments was between $26.2 million and $39.0 million in 1985 dollars
(Freeman, 1987, p.17~.
Contingent valuation approach. This survey-based approach asks
individuals how they would behave under some set of given circumstances
in an attempt to elicit the individual's preferences. A contingent
valuation study of a fishing experience, for example, may ask whether
an individual would participate in fishing at a particular site if it
costs $X to do so; or the individual could be asked whether they would
pay $X to experience (or avoid experiencing) a specified increase
(decrease) in the catch rate. The responses to the questionnaire are
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then used as though they were actual market behavior to assess the
value of the resource issue in question. Note that this approach, in
contrast to the approaches outlined in preceding paragraphs, is not
based on revealed behavior. A detailed assessment of the state of the
art in contingent valuation, including the importance of sources of
potential bias and "reference operating conditions" for controlling
bias, is contained in Cummings et al. (1985~.
Valuing Public Health Risks
Public health effects are a primary concern in assessing remedial
actions, and SARA establishes a number of important health-related
authorities to provide a better understanding of the health effects
from exposure to toxic substances (Sec. 110~. From an economic view-
point particularly difficult issues arise when contaminated sediments
result in a threat to human health. Revealed preference is probably
not useful for valuing an individual's life, since this would be tan-
tamount to determining what one is willing to pay to continue living,
or willing to accept to die, neither of which are reasonable concepts.
However, most environmental impacts increase the risk of death for
some population, rather than directly incurring death of an particular
individual. Revealed preference may be useful for evaluating health
risks since individuals make decisions that change risks every day, for
example, through the decision to wear seatbelts, drive a car, smoke cig-
arettes, etc. It is possible to elicit values related to increments in
risk by observing how individuals behave when making decisions that
determine the level of risk.
One particularly useful related-markets approach to valuing mortal-
ity risks is to examine behavior in choosing risky occupations (Fisher
et al., 1988~. For example, bridge painters are often paid differing
amounts depending on whether they paint the more risky, top parts of
the bridge, or the relatively safer, lower parts. Thus, the individual
trades off wages for risk of death, and behavior revealed in the labor
market can provide information on the individual's preferences for
safety, or lack of risk.
The key concepts used in economic analysis on mortality risk are
the value of a statistical life and cost per life saved, which will be
discussed below. Valuing a statistical life is an example of a cost-
benefit approach that can be illustrated as follows. Suppose that
contaminated sediments lead to human ingestion of a toxic substance
through the food chain and that risk analyses show that this level of
concentration implies the probability of death through cancer is
increased by .001 percent for each of one million people. The number
of statistical lives lost by this pollutant is
.00001 X 1,000,000 ~ 10
If, on average, individuals are willing to give up $100 in wages in
order to reduce the risk of death on the job by .001 percent, then the
value of a statistical life is $10 million, as revealed by actions of
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301
the individuals. This implies that a remedial action that would remove
this pollutant from sediments, hence removing the health risk, would
result in $100 million in benefits This concept can be applied to the
problem of contaminated sediments, given a risk analysis of the
increased mortality which result from various exposure pathways.
It should be noted that the approach discussed in this section
assesses statistical lives saved, or mortality risks, not reductions in
sublethal effects, or morbidity. The concepts to be used to evaluate
the benefits from reduced morbidity--reduced medical costs, smaller
amount of time out of work due to illness, and so forth--are relatively
straightforward. Note, however, these approaches do not value the ill-
ness per se, such as the discomfort or suffering of the individual, but
only the associated monetary costs, and thus would strictly understate
the value of reduction in morbidity rates. Additionally, it can be
very difficult to establish the incremental improvements in health from
total or partial remediation of contaminants at a given site due to the
inherent difficulties in isolating the effect of exposure to one or
more contaminants from all other effects that influence health.
An alternative approach that has been employed to value mortality
is the so-called human capital approach. This approach uses the earn-
ing potential of the individual over his or her future life as the
value of human life. The human capital approach has been widely used
in the courts in cases of wrongful or accidental death. While this
approach measures potential future earnings, it does not place a value
on the loss of life, per se, nor does it measure the individual's will-
ingness to accept risk of death. In addition, the approach has an in-
nate bias against those who have little or no direct wage income, such
as a housewife whose services are not valued through the market. Thus,
the human capital approach would be expected to significantly under-
state the value of life. Indeed in practice, the value of a statisti-
cal life determined from revealed preference studies tends to be signi-
ficantly higher than the value determined from the human capital
approach. For example, the EPA uses figures of $400,000 to $7 million
as a range of reasonable values for a statistical life based on re-
vealed preference . A present value of this s ize implies a perpetual
income of $32,000 to $560,000 at an 8 percent discount rate .
Cost-Effectiveness Analysis
General Considerations
Generally, health and environmental benefits of remediation at a
site are not explicitly measured in dollar terms, but implicitly may be
judged to be worth the costs of remedial measures. In these cases,
cost-effectiveness (C-E) techniques can be used to guide the selection
of remediation alternatives by helping to assess the relative cost and
the effectiveness of the alternative removal and disposal strategies.
SARA requires that C-E is to be considered in the evaluation of reme-
dial actions, and that long-term as well as short-term costs be taken
into account.
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302
C-E analysis provides a systematic way for determining (1) the
least-cost approach(es) for achieving a given objective, or (2) the
maximum level of the objective which can be achieved for a given cost.
Correctly applied, C-E can be a powerful tool because it potentially
allows decision makers to screen remedial action alternatives on the
basis of a common measure. All else being equal, if remedial action
alternative A is less expensive than B. then A clearly is preferred;
or, if A and B are equally expensive but A results in a greater public
health and environmental improvement than B. then A would be selected.
However all else generally is not equal, comparisons rarely are so
straightforward, and as a result C-E analysis is subject to several
potentially important shortcomings.
Potential Problems with Cost-Effectiveness Analysis
C-E analysis will lead to misleading results if (1) important costs
are ignored or (2) costs for alternative actions at a site or between
sites are not estimated using a consistent approach. As noted, SARA
expresses a clear preference for permanent actions, involving thermal,
biological or chemical treatment to reduce the volume, toxicity or
mobility of the substancefs). Permanent remedies typically cost more
initially than actions that do not involve treatment (e.g., capping).
For example, a recent report found that for the ten cases studied (none
marine), the average cost of the five cases involving permanent reme-
dies through treatment of the removed materials was $16 million as
compared to $7.5 million for nontreatment (impermanent) remedies (OTA,
1988~. Assessing whether permanent remedies are more cost-effective
when long-term as well as short-term costs are considered is extremely
difficult, as noted above. Nonetheless, long-term costs must be con-
sidered if C-E analysis is to be a meaningful guide for remedial action
policy.
Clearly, for C-E analysis results to lead to appropriate decisions,
it also is vital that costs be assessed consistently. A recent report
by OTA found that in some cases (none marine) different approaches were
used by contractors to estimate costs. To the extent the use of incon-
sistent approaches at marine sites causes large differences in apparent
costs, the usefulness of cost-effectiveness analysis can be severely
compromised.
Application of Cost-Effectiveness to Public Health Risks
The C-E approach does not place a value on health or other benefits
and hence cannot be used to provide an economic argument in support of,
or against, remediation at a site. However, C-E analysis can play an
important role in helping to guide the extent of remediation at a site
and among sites (fund balancing). To illustrate this, the concept of
cost-per-life-saved is used. Rather than placing a value on a statis-
tical life, the cost-per-life-saved approach ranks options according to
the number of statistical lives saved per dollar spent. Similarly, the
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303
approach could be applied for nonlethal affects, for example by evalu-
ating cost per reduced cancer case.
To illustrate, suppose there is a fund of $50 million, and six non-
mutually exclusive cleanup alternatives are being compared, as shown in
Table 2. The alternatives may represent, for example, cleanup of var-
ious subareas within some particular contaminated site, such as the
four subareas of New Bedford harbor discussed by Ikalainen and Allen
(1988~. Additionally, some alternatives may represent subareas from
differing contaminated sites, such as four subareas in New Bedford
Harbor and two subareas in the Hudson River.
For the cases depicted in Table 2, assuming no impacts other than
reduced health risks, alternatives one, two, and three would be chosen,
resulting in 14 statistical lives saved. Given these alternatives,
this is the greatest reduction in risk that would result from this
fixed expenditure of the $50 million fund. This approach implies a
social willingness-to-pay per statistical life saved between $6.7 mil-
lion, the highest cost per life saved for the alternatives chosen, and
$8 million, the lowest cost per life saved for the alternatives not
chosen. Given the same alternatives, the cost-benefit criterion out-
lined in the preceding section would justify alternatives one, two,
three, and four, using the $10 million hypothetical value per statis-
tical life derived above. This would result in 15 statistical lives
saved and would result in expenditures of $58 million, which would
require $8 million in addition to the $50 million contained in the
fund.
SOURCE CONTROL: THE ROLE OF LIABILITY UNDER CERCLA AND THE CWA
Under CERCLA and the Clean Water Act, as amended, polluters are
liable not only for cleanup and reasonable assessment costs, but also
for " damages for inj ury to, destruction of, or loss of natural
resources" (Sec.107.(a)~4~(C) (hereafter, injury to natural resources)
resulting from a spill . Briefly, CERCI-A provides for two types of
TABLE 2 Depiction of Cost-Effectiveness Strategy Using the Cost-per-
Life-Saved Approach
Alternative
One Two Three Four Five Six
Cost ($ Million) $10 $20 $20 $8 $12 $15
Number of statis-
tical lives saved 6 5 3 1 1 1
Cost per statis-
tical life saved $1.7 $4 $6.7 $8 $12 S15
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304
damage assessment regulations. The type A regulations provide a simpli-
fied approach, involving minimal field observation to be used for minor
incidents of short duration, while the type B regulations describe meth-
ods for site-specific natural resource damage assessments with poten-
tially extensive field observations, to be used for major incidents.
Since contaminated sediment problems generally arise as a result of
chronic releases over an extended period, the type B approach almost
always will be the appropriate approach for measuring damages. For
example, the economic damage assessment study of New Bedford harbor
PCBs was a type B study, the first carried out under CERCLA (e.g.,
Freeman, 1987~.
The two-tiered damage assessment approach mandated by Congress
recognizes that undertaking a damage assessment can be very expensive.
For example, the economic study of the damages alleged to result from
the presence of PCBs in New Bedford Harbor cost $0.5 million (Meade,
NOAA, personal communication). For some cases, these assessment costs
can exceed the value of the damages that can be ascertained. For
example, 5,600 barrel ARGO Anchorage oil spill cost $250,000 for
damage assessment, while the resultant damage estimate was $33,000.
Clearly, it only makes sense to spend the large amounts of money
necessary to carry out field significant investigation when assessing
damages for very large incidents, such as the New Bedford Harbor case.
The intent of CERCLA is to compensate governments for damages to
publicly controlled natural resources in their role as trustees of
these resources. Thus, the primary goal of the act is to encourage
fairness by compelling the responsible party to pay compensation for
the damages resulting from their actions; the amount recovered is to be
"available for use to restore, rehabilitate, or acquire the equivalent
of such natural resources by the appropriate agencies...'' (Sec.107(f)~.
However, as an unintended side-effect, the liability provisions of
CERCLA create a legal framework for what is akin to a "tax" on pollu-
tion incidents covered under the act. As such, the damage assessment
regulations introduce what could be an important new approach for using
economic incentives to avoid pollution for a wide range of incidents
(Opaluch and Grigalunas, 1984; Grigalunas and Opaluch, 1988~. For exam-
ple, in discussing the liability provision, the 1982 version of the
Clean Water Act requires that "the Administrator shall . . . conduct a
study and report to Congress on methods, mechanisms, and procedures to
create incentives to achieve a higher standard of care in all aspects
of the management and movement of hazardous substances."
The potential importance of incentives embodied in the liability
provisions in the CERCLA regulations for source control is made clear
by examining its applicability and unique characteristics. The regu-
lations apply to virtually all publicly controlled natural resources,
and encompass a wide span of pollution discharges. Also, CERCLA holds
polluters strictly liable for their actions, so that following an inci-
dent, there is no need to establish negligence in a prolonged and cost-
ly court trial. Moreover, CERCLA establishes joint and several liabil-
ity. Thus, any one polluter can be held liable for all cleanup or
remediation costs, even if they contribute only a small share of the
total amount released into the environment. Note, however, that these
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305
incentives are applicable only to accidental spills, and not, for exam-
ple, to routine discharges permitted under the National Pollution Dis-
charge Elimination System (NPDES) of the Clean Water Act.
Another unique and very important characteristic of the CERCLA
natural resource damage assessment regulations merits emphasis. The
regulations provide an advantage for trustees in that they carry the
force of rebuttable presumption (Sec.lll (h)~2~. That is, if the pro
cess set out in the regulations is correctly applied by the authorized
official following a spill, the resulting measure of ~
sumed to be correct, unless the potentially liable party can show other-
wise by a preponderance of the evidence. In most cases it will be very
difficult and costly to prove that the results of a damage assessment
carried out under the act are incorrect, especially for the type A
approach, by virtue of the fact that it is intended to be simplified
and based on minimal field observation. Hence, the rebuttable presump-
tion provision of the CERCLA can have important implications for the
effectiveness of the damage assessment regulations, in general, and
especially for the type A approach.
It should also be noted that under CERCLA, liability extends beyond
custody of the material to include materials spilled by those under con-
tract, directly or indirectly, with the firm. Thus, liability under
CERCLA provides incentives not only for careful handling of materials,
but also for careful choice of parties with whom to contract for waste
removal and final disposition. Hence, CERCLA recognizes the importance
of choice of contracted parties in order eliminate the obvious finan-
cial incentive to hire inexpensive "fly-by-night" contractors who prac-
t~ce midnight dumping of hazardous wastes.
There is some evidence that liability provisions have been effec-
tive in providing incentives for damage reduction. For example, in a
study of industries which produce hazardous wastes, Killory (1987) con-
cludes "[source reduction] has become an increasingly attractive envi-
ronmental policy for the organic chemical industry because of the high
costs of waste disposal and, more importantly, the greater liability
that producers now incur for generated wastes." Further, the only empir-
ical study of economic behavior under liability finds some evidence
that is consistent with provision of incentives (Opaluch and
Grigalunas, 1984~.
Thus, the liability provisions of CERCLA may provide incentives
both for source control and for careful handling and disposal of hazar-
dous materials. This is an extension of the so-called "polluter pays
principle" which holds the polluter financially responsible for costs
associated with the harmful effects of pollution emissions. Note,
however, that despite the success of incentive-based approaches in
Europe, U.S. environmental legislation does not maintain this same
incentive system for other sources of environmental pollutants, such as
pollution emission under NPDES permits. For many years economists have
argued for environmental policy based at least in part on financial
incentives. One alternative would be a mixed system of direct regula-
tion and financial responsibility that would require the firm to attain
some stated treatment percentage, but would also require the firm to
pay a fee for the remaining pollutants emitted or would pay a subsidy
damages is pre-
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306
if pollution were reduced below that required by the regulation (Baumol
and Gates ? 1975; Roberts and Spence, 1976), perhaps accounting for
potential locational differences in impacts (Tietenburg, 1978~.
Although the act is widely applicable, the type A approach cannot
be used in a number of important cases; and CERCLA itself is of limited
applicability in some cases. For example, the type A approach cannot
be used to assess damages from chronic releases, although the type B
approach can be employed. CERCLA does not apply to releases under
NPDES permits, although it does apply when the permitted release is
exceeded, nor can the act be used to assess damages from releases of
fertilizer or pesticides resulting from normal use. Where CERCLA does
not apply, other laws and approaches will have to be used to control
releases of contaminants into marine waters. However, these acts do
not generally provide incentives, such as those implied by the liabil-
ity provisions of CERCLA, the Clean Water Act, or the Outer Continental
Shelf Lands Act.
The CERCLA natural resource damage assessment regulations are rela-
tively new and, in many respects, novel. How effective they will prove
to be depends importantly upon on several factors, including how active
states are in implementing this approach. To be effective, trustees
must be appointed, staff must become familiar with the regulations, and
efforts to apply the regulations to releases under the act must be pur-
sued. If the act is not implemented, than it will be of little use.
It is not clear that trustees have fully explored the potential useful-
ness of this approach. Further, liability can only be applied in cases
where one or more responsible parties can be identified. For many
cases of illegal dumping this may not be possible.
A final note is in order. A unique part of CERCLA is the require-
ment that the damage assessment regulations be reviewed every two years
and updated, as appropriate. Hence, there is the important opportunity
to suggest new techniques or data to be included in updated natural re-
source damage assessment regulations. Also, the biennial review man-
dated for CERCLA may provide an opportunity to explore the feasibility
of developing a simplified approach which could be applied to those con-
taminated marine sediment cases which may not warrant the high cost of
a type B study but which cannot be encompassed within the present type
A framework.
SUMMARY AND CONCLUDING COMMENTS
Contaminated marine sediments are of concern because they can
impose a variety of adverse public health effects and environmental
losses. At the same time, remediation can be very costly. Hence,
whether, how, and the extent to which sites should be remediated are
important national issues. However, quantification of public health
and environmental effects unavoidably involves considerable scientifi
uncertainty and social tradeoffs. In light of the many uncertainties
involved and the lack of clear criteria, these decisions concerning
remediation at a site necessarily are based on imprecise information
and important elements of uncertainty and subjectivity. Hence, these
C-
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307
issues are principally social decisions, and not merely scientific,
technological or economic issues.
Two economic frameworks are available for contributing to social
management decisions at contaminated marine sediment sites. The two
economic frameworks presented--benefit-cost analysis and cost-
effectiveness analysis--can contribute to the decision process by
making explicit the costs and benefits (in the case of cost-benefit
analysis) of the alternatives. Despite the many difficulties inherent
in quantifying some of the important factors, these approaches can be
used to complement the use of scientific information in making deci-
sions at or among contaminated sediment sites.
These economic frameworks provide a means of organizing the infor-
mation in ways that can be helpful to decision makers. The techniques
are particularly useful for identifying alternatives that achieve goals
at excessive costs. For example, the cost-per-life-saved approach
would identify policy options that save few lives at relatively high
costs, in favor of alternatives that result in a greater reduction in
risk per unit expenditure. To the extent that the benefits from alter-
native cleanup policies can be quantified, benefit-cost analysis can
provide a perspective on relative benefits and costs to help determine
whether goals appear to be reasonable. This can be particularly useful
when "conservative" high or low estimates can be consistently utilized
and imply an unambiguous solution. For example, if conservative, low
estimates of benefits of a remedial action exceed costs, then certainly
that level of remediation would be warranted. On the other hand, if
costs greatly exceed benefits, even when overstated benefit estimates
are used, then it is likely that somewhat less ambitious levels of
action may be warranted, with reallocation of funds for expenditure at
some alternative site. For example, complete remediation of all
tainted sediments from a particular site may be prohibitively expensive
and the costs of doing so would be beyond any reasonable level of bene-
fits which may result. Finally, if the results of a cost-benefit anal-
ysis are not conclusive, then the project can neither be justified nor
rej ected on a C-B basis, and other considerations would dominate the
.ecls Ion .
It must be recognized, of course, that quantifying benefits and
costs can be exceedingly difficult. This is particularly true when
examining long-term costs associated with nonpermanent solutions. In
evaluating costs associated with impermanent solutions, such as in situ
capping, long-term costs associated with failure must be considered to
make comparisons with costs associated with permanent solutions, such
as incineration. EPA calls for a screening of the alternative actions
to eliminate those that cost more but do not provide a "commensurate''
public health or environmental benefit. However, determining whether
these benefits are "commensurate" places a significant burden on scien-
tists and economists. To do so the probability of failure for imperm-
anent solutions must be determined, in addition to the consequences of
failure considering the potential for, and costs of, any associated
remedial action.
However, it is possible in many cases to measure the benefits from
improvement, as was illustrated by the results presented for the New
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308
Bedford Harbor damage assessment study. Moreover, it is important also
to recognize that noneconomics-based approaches must also consider the
same uncertainties and tradeoffs, but will do so in a way that leaves
the tradeoffs implicit. In contrast, an economics-based approach speci-
fies these tradeoffs explicitly, so that when choosing an action, the
decision maker can see the alternatives being given up--the opportunity
cost.
C-E analysis begs the question of whether remediation ought to take
place at a site. However, given that a decision to remediate has been
made, C-E analysis can be an important part of remediation decisions,
and under SARA C-E is given a central role in designing remedial ac-
tions. This section reviewed the C-E approach and illustrated its app-
lication to public health effects. Properly applied, C-E analysis can
provide a powerful tool for choosing among alternative approaches for
remediation at a given site and for allocating resources among sites.
However, there is the danger that the concept of cost effectiveness may
be confused with the least costly remedial action. Various actions can
only be compared on a cost-effective basis if the benefits are equal,
but the costs differ; if the costs are equal and the benefits differ;
or if the least costly alternative also results in the highest level of
benefits. Cost-effectiveness analysis cannot be used to compare two
alternatives where one is more costly but leads to greater environmen-
tal benefits.
Additionally, the role of li ability as an approach for encouraging
source control was examined. CERCLA holds polluters strictly liable
for their actions. The prospect of paying potentially very consider-
able sums for damages, assessment, and remediation actions creates a
powerful incentive to reduce the amount and the toxicity of materials
potentially spilled, as well as to handle more carefully and dispose of
the materials that remain. Another unique, and very important charac-
teristic of the act is that the natural resource damage assessment regu-
lations carry the force of rebuttable presumption. Thus, the damage
assessment process is greatly facilitated by shifting the burden of
proof.
Given the characteristics of the act and its broad potential appli-
cability, the damage assessment regulations established by CERCLA
clearly are a major development in environmental policy. CERCLA's dam-
age assessment regulations also may represent a major, and perhaps un-
precedented, expansion of the use of economic incentives to control
pollution. However, to be effective trustees must be appointed and the
act must be enforced. It is not clear that states have fully exploited
the potential of the act for assessing damages and remediating contam-
inated marine sediment sites.
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Representative terms from entire chapter:
damage assessment
