Cleaner Water Requires Collaboration, Not Confrontation

By Niree Kodaverdian, Ph.D.

Inland Empire Business Journal | Commentary

The Santa Ana Regional Water Quality Control Board has been considering stricter requirements for managing stormwater runoff across San Bernardino, Riverside, and Orange Counties. Recently, I attended my third Water Board hearing on this issue and, once again, walked away disappointed. What should be a collaborative effort to improve the region’s water quality has instead felt adversarial, jeopardizing any opportunity to reach a balanced, effective outcome that best serves the region.

For some time, the affected jurisdictions have been concerned about the cost of changing these requirements. That’s where I came in. In 2024, Beacon Economics was commissioned to estimate the potential economic costs of the proposed MS4 Permit Tentative Order, which we concluded would total nearly $11 billion over 20 years in San Bernardino County alone. We worked with stormwater management and flood control personnel and with independent engineers to understand what compliance would require and developed estimates of potential capital and ongoing costs.

The proposed changes cover a lot, including industrial, commercial, and construction site inspections, trash capture and monitoring, and more. But the largest potential costs were associated with numeric limits, which establish thresholds for pollutants in stormwater runoff.

Historically, stormwater regulation has relied heavily on Best Management Practices (BMPs). These include filtration and treatment systems, trash-capture devices, green infrastructure, inspections, and other practices intended to prevent pollutants from entering stormwater.

Numeric limits vary because the numerical outcome itself becomes the standard. You can implement extensive and expensive BMPs and still not guarantee that every pollutant will remain below a particular threshold. Stormwater is affected by rainfall, geography, hydrology, development, infrastructure, and other factors cities and counties cannot completely control.

Based on our research and consultations with technical experts, we understood the proposed numeric limits to require compliance measures similar to those already undertaken by jurisdictions in Los Angeles through their Watershed Management Programs (WMPs) and Enhanced Watershed Management Programs (EWMPs). We looked at compliance plans and estimated costs in Los Angeles to understand what similar requirements could mean for permittees in the Santa Ana region, then compared those costs with each jurisdiction’s General Fund expenditures.

We updated the analysis in 2026, and the findings were very similar. It was against this backdrop that I attended my third Water Board hearing.

Representatives from affected jurisdictions have repeatedly shown up to explain why they believe aspects of the proposed requirements are unreasonable and unrealistic. Engineers and stormwater management professionals tried to explain the practical constraints. Yet once again, it felt like the affected jurisdictions and Regional Board staff were on opposing sides of an issue where the end goal is the same.

We all want cleaner water. The question is how to get there.

If we impose numeric limits that are extraordinarily difficult, or impossible, to achieve, we don’t automatically get cleaner water. We may instead create enormous costs for local governments and their residents. Our analysis estimates billions of dollars in potential compliance costs over 20 years across the county. And after spending all that money, jurisdictions could still fail to meet the numeric limits and potentially face penalties.

And those costs can’t be ignored simply because residents don’t receive a bill labeled “stormwater compliance.” Cities and counties have limited resources. Money spent meeting one requirement isn’t spent on other local needs. Policymaking always involves tradeoffs—that’s one of the most basic lessons in economics.

After three hearings, it feels like an “us versus them” debate. It shouldn’t be. We should be able to question the proposed approach without questioning the goal—and focus on what actually matters: finding the most effective and realistic way to improve water quality.

Niree Kodaverdian, Ph.D., is a Research Manager at Beacon Economics LLC. Learn more at www.BeaconEcon.com.