2015 Clean Water Rule Economic Analysis

Fortune 500 Agricultural Chemical Company; National


The 2015 Clean Water Rule sought to resolve uncertainty with Clean Water Act (CWA) enforcement by defining “Waters of the United States” (WOTUS) to include certain isolated wetlands and ephemeral streams. A regulated community member engaged members of Roux’s Economic & Complex Analytics Team to review the United States Environmental Protection Agency (USEPA) and United States Army Corps of Engineers (USACE) economic analysis of the rulemaking’s private costs and social benefits. Among Roux’s key findings were:

• Estimated social benefits accruing annually from wetlands protection and mitigation (between $306.1 million and $501.2 million) resulted from faulty benefits transfer and benefits aggregation methodology; and
• Failure to normalize permitting data from the Great Recession to baseline economic conditions significantly underestimated wetland permitting and mitigation costs borne annually by the regulated community (between $83.1 million and $329.7 million).

The regulated entity relied on the Roux ECA Team’s findings for its comments on the proposed rulemaking’s impact.

Learn more about Economic & Complex Analytics and Water Resources.




Fortune 500 Agricultural Chemical Company

Roux Services

Regulatory Impact Analysis

Ecosystem Service Valuation