EcoShelf developed a calculation strategy, and applied EPA's BEN Model, to calculate the so-called economic benefit of noncompliance to assist in settlement of a matter involving alleged violations of both stormwater and wastewater pretreatment limits over a nine year period. The calculation strategy was complicated by the fact that the apparent exceedences of the permit limits occurred only sporadically with significant periods of compliance (exceeding two or more years) between the episodes, and involved three different controlled pollutants, each of which required different treatment technology. Moreover, there was no apparent correlation between the exceedences of the three pollutants. Our calculation showed a significantly lower economic benefit than that alleged by the government, and resulted in a significant reduction in the government's settlement demand.

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Economic Benefit Analysis:: Case Briefts