Prepared for: Washington Department of Fish and Wildlife, Olympia, Washington 

Needs Assessment and Scoping Study for Sinking 

Ships as Diving Sites in Puget Sound 

By Steve Rubin, Eric Grossman, Lynne Koontz, Anthony Paulson, Natalie Sexton, and 

Reg Reisenbichler 

Open-File Report 2008-1020 

U.S. Department of the Interior 

U.S. Geological Survey 
U.S. Department of the Interior 

DIRK KEMPTHORNE, Secretary 

U.S. Geological Survey 

Mark D. Myers, Director 

U.S. Geological Survey, Reston, Virginia: 2008 

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its natural and living resources, natural hazards, and the environment: 

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Suggested citation: 

Rubin, Steve, Grossman, Eric, Koontz, Lynn, Paulson, Anthony, Sexton, Natalie, and Reisenbichler, 

Reg, 2008, Needs assessment and scoping study for sinking ships as diving sites in Puget Sound: 

U.S. Geological Survey Open-File Report 2008-1020, 43 p. 

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endorsement by the U.S. Government. 

Although this report is in the public domain, permission must be secured from the individual 

copyright owners to reproduce any copyrighted material contained within this report. 

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Contents 

Executive Summary............................................................................................................................................................1

Introduction .........................................................................................................................................................................4

Background .....................................................................................................................................................................4

Action Being Considered...............................................................................................................................................4

Objectives.........................................................................................................................................................................4

Feasibility Study Objectives..........................................................................................................................................4

Scoping Study Objectives .............................................................................................................................................5

Scoping Study Methods and Format...............................................................................................................................5

Feasibility Study Questions, Tasks, and Costs ..............................................................................................................5

Project Costs ...................................................................................................................................................................5

Ship Selection and Acquisition ................................................................................................................................5

Contaminant Removal and Effects...........................................................................................................................6

Ship Preparation, Towing, and Sinking.................................................................................................................11

Siting............................................................................................................................................................................11

Pre-Deployment Ship Stability and Integrity Analysis .......................................................................................14

Permits ........................................................................................................................................................................14

Liability ........................................................................................................................................................................15

Infrastructure.............................................................................................................................................................16

Maintenance..............................................................................................................................................................17

Monitoring..................................................................................................................................................................17

Project Life Span and Post-Project Cleanup .......................................................................................................20

Environmental Impacts ................................................................................................................................................20

Physical Processes ..................................................................................................................................................20

Biological Impacts ....................................................................................................................................................20

Socio-Economic Factors .............................................................................................................................................23

Social Issues..............................................................................................................................................................23

Suggested Methods and Costs of Studies to Address Social Issues .............................................................25

Economics..................................................................................................................................................................28

Economic Data Collection Methods and Costs ...................................................................................................31

Feasibility Study Budget..................................................................................................................................................34

Discussion..........................................................................................................................................................................36

Recommendations............................................................................................................................................................38

Acknowledgments............................................................................................................................................................38

References Cited ..............................................................................................................................................................38

Appendixes ........................................................................................................................................................................40
Needs Assessment and Scoping Study for Sinking 

Ships as Diving Sites in Puget Sound 

By Steve Rubin, Eric Grossman, Lynne Koontz, Anthony Paulson, Natalie Sexton, and 

Reg Reisenbichler 

Executive Summary 

There is growing interest in starting a program to sink one or more large, steel ships in Puget Sound 

to create underwater dive sites, thereby attracting divers to Washington State with attendant 

economic benefits. The State legislature reviewed this possibility during the 2006 session and 

directed several State agencies to undertake a preliminary scoping study of the feasibility. The 

Washington Department of Fish and Wildlife (lead State agency) in turn asked the U.S. Geological 

Survey to conduct the study. 

The objectives of the scoping study are to design a feasibility study and estimate the cost to conduct 

such a study. Specifically, the scoping study assembles the questions that a feasibility study should 

address, develops approaches or tasks to address each question, and estimates the cost associated 

with each approach or task. The main objective for the feasibility study would be to provide 

sufficient information for the legislature to decide whether to go forward with actual ship sinking. 

Specifically, the objectives of the feasibility study would be to (1) estimate the costs (initial and 

ongoing) of sinking ships, (2) estimate the economic benefits that would be derived, (3) identify 

political and community stakeholders and gauge their support or opposition, and (4) develop 

detailed information about environmental (physical, water quality, biological) impacts. 

Initial and ongoing costs of ship sinking include ship selection, acquisition, preparation, and 

deployment; site selection; permitting; liability coverage; developing necessary infrastructure; 

maintenance; and monitoring. Contaminant removal is a key element of ship preparation, and ease 

of contaminant removal is an important ship selection criterion. Contaminants are retained in Puget 

Sound due to basin morphology and current circulation patterns, and sediments and biota show 

elevated levels of contaminants. Major initiatives are underway to prevent contaminants from 

entering the Sound and to clean up those that are already present. For these reasons thorough 

contaminant removal is imperative. The Environmental Protection Agency and the Maritime 

Administration (MARAD) recently established best management practices (BMPs) for contaminant 

removal from ships destined for sinking. Whether these BMPs are sufficient for Puget Sound needs 

to be evaluated. There is also growing concern about polybrominated diphenyl esters (PBDEs) and 

other “emerging contaminants,” so called because their effects are less well known than those of 

older contaminants such as polychlorinated biphenyls (PCBs). BMPs have not yet been established 

for emerging contaminants. PCBs and PBDEs bio-accumulate and are found at high levels in 

southern resident killer whales which spend much of their time in Puget Sound and are listed as 

endangered under the Endangered Species Act. Contaminants are considered a major threat to this 

whale population. The feasibility study needs to estimate the inventory of contaminants on each of 

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the candidate vessel classes, which for emerging contaminants will likely require onboard sampling 

of ship materials, and determine the feasibility and cost of contaminant removal. 

The largest navy ships (e.g., aircraft carriers) are hard to clean of contaminants which may make 

these ships poor choices. Furthermore, total cost (acquisition to sinking) is directly proportional to 

ship weight, making large ships expensive. Ships may be available from the U.S. Navy or 

MARAD; however, subsidies currently offered by these agencies for cleaning and transport cover 

only a small fraction of the costs. Two types and sizes of ships have been suggested as potentially 

good choices for Puget Sound. The first is Washington State ferries (~250 feet long; ~2,000 tons). 

They have an open structure that may allow for easy cleaning, were rebuilt recently which may 

have removed some contaminants, and have a known service history which should facilitate 

contaminant assessment. The second is medium sized destroyers as have been sunk in the Strait of 

Georgia (~350 feet; ~3,000 tons). However, the smallest destroyers currently available from the 

Navy or MARAD may be ~500 feet long (3000-6000 tons). 

A number of factors must be considered in selecting a site. Physical characteristics must ensure 

ship stability and provide safe and desirable diving conditions. Navigation lanes and sensitive 

species and habitats must be avoided. We propose a two stage approach for locating suitable sites 

and confirming their suitability. First, use existing data to construct a Puget Sound-wide map to 

roughly identify areas that may be physically suitable and don’t conflict with navigation or 

sensitive species or habitats. Note that existing data, with the possible exception of depth, lack 

sufficient resolution at the scale needed to ensure suitability for ship sinking. Second, conduct field 

surveys at five of the potentially suitable sites, selected to provide some geographic variability, to 

confirm whether sites identified from the Sound-wide map meet requirements of substrate type, 

seafloor structural integrity, water clarity, current speeds, and biological community. 

Potential environmental impacts (other than contaminants which are addressed above) include 

scouring or deposition, increased turbidity, harm to sensitive or harvested species or to sensitive 

habitats or aquatic communities (e.g., eel grass beds), loss of the benthic community at the sinking 

site (i.e., under the ship), changes in ecological processes, promotion of invasive species, and 

cumulative effects of multiple ships. Ship colonizers might compete with or prey upon organisms 

in the area surrounding the ship or passing by the ship, thus altering the food web. Sunken ships 

may attract organisms away from hard substrate habitat in surrounding areas which would be 

especially problematic if attraction resulted in reduced survival, a circumstance that could result 

from increased harvest rates if harvest were allowed. A potential benefit of ship sinking might be 

promotion of sensitive species such as rockfish. It might be possible to design ship sinking to 

maximize any such benefit if it were identified as a secondary objective and did not conflict with 

creation of the dive site or the well being of other sensitive species. 

Important considerations in evaluating support or opposition to ship sinking are the regulatory 

framework for sinking ships; the policies, structures, and incentives that will likely drive the 

decision process; the identity of stakeholders; and the perceptions, attitudes, and preferences of 

nearby communities as well as key stakeholders. This report proposes comparative studies of 

similar ship sinking programs in other areas, focus groups to qualitatively explore attitudes and 

perceptions of divers and other stakeholders, and surveys of divers and local community members 

to quantitatively assess attitudes and perceptions. 

Because the costs associated with sinking ships to create dive attractions can be substantial, the 

economic benefits must be examined to determine if the project would be an advisable investment. 

To estimate anticipated economic benefits it is necessary to estimate the number of divers and 

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average spending per diver currently (pre-deployment) and after deployment. Sampling of dive 

charter logbooks, and on-water sampling to determine the ratio of charter to non-charter divers, is 

proposed to estimate the current number of divers. Surveys of divers are proposed to estimate the 

number of future divers and the average spending per diver currently and in the future. The best 

(and most expensive) option is to survey divers nation-wide as well as in Washington. This may be 

the only way to estimate the post-deployment influx of non-residents into Washington. Surveys will 

also allow evaluation of how economic benefit varies among regions within Puget Sound. Once the 

gross economic benefit is determined (i.e., anticipated additional funds attributable to ship sinking), 

the net economic benefit can be determined by subtracting out anticipated project costs, including 

costs of new infrastructure. 

We present three funding options for the feasibility study: “full” with consideration of two ship 

types (ferries and destroyers), “minimal for two ship types”, and “minimal for ferries only”. The 

ferries-only option is included to provide a cheaper alternative and because ferries may offer 

greater ease of cleaning than destroyers. Both minimal options rely mostly on existing data whereas 

the full option includes significant development of new data for tasks associated with siting, 

evaluation of community support or opposition, and estimation of economic benefits. The purpose 

for these new data is to validate, refine, or provide critical information for making predictions and 

conclusions. The full option will provide the most reliable assessment of feasibility across Puget 

Sound. The minimal options include field sampling at only one site rather than at five sites, which 

seems most appropriate if that one site has been selected as the desired location for sinking a ship, 

subject to final field verification. The estimated total cost of the feasibility study is $2.8 million for 

the full level, $1.4 million for the minimal level with two ship types, and $1.2 million for the 

minimal level with ferries only, assuming an overhead rate of 100%. Overhead rates vary among 

potential contractors from less than 50% to well over 100%. 

Other funding levels are possible. We described the tasks that we think should be included in a 

feasibility study, along with a cost estimate for each task and information on how we derived the 

estimate. From this information the reader may wish to adjust, eliminate, or even add tasks, or to 

adjust cost estimates to create other alternatives for study intensity or cost. 

The feasibility study could be conducted in stages. Contaminant issues might be evaluated first 

because of their overriding importance. Only if thorough cleaning were found to be feasible for 

ships of interest would other components of the study proceed. Alternatively, economic benefits 

could be evaluated first, and the other components of the study proceed only if economic 

projections were favorable. A sequential strategy would obviously save money if thorough cleaning 

isn’t feasible or if economic projections are disappointing; however, the strategy would extend the 

duration of the study if neither of these factors preclude ship sinking. If all feasibility components 

were conducted concurrently, the duration of the study should be approximately 18-24 months. We 

recommend the sequential strategy if cost efficiency is more important than minimizing the time 

required to complete the feasibility study. We also recommend choosing the full budget option for 

evaluating economic benefits because of the increased accuracy of predictions relative to those 

from the minimal options. 

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Introduction 

Background 

There is growing interest in starting a program to sink ships in Puget Sound to create one or more 

underwater dive sites. Experience in other parts of the world has indicated that sunken vessels are 

highly popular with divers and could provide a basis for increased recreation and attraction of outof-state divers with attendant economic benefits to the State. The Washington State legislature 

reviewed this possibility during the 2006 session and determined that more information is required 

before the legislature could determine if this activity is feasible or desirable. The legislature 

directed several State agencies to undertake a preliminary study of the feasibility. The Washington 

Department of Fish and Wildlife (WDFW, lead State agency) in turn asked U.S. Geological Survey 

to conduct the study. 

Action Being Considered 

Sinking large (200 feet or longer), steel ships at one or more sites in Puget Sound (all inland marine 

waters of Washington State east of Cape Flattery) to create recreational diving sites. The ships 

would be obtained from the U.S. military or other sources, cleaned of contaminants and moved to 

Puget Sound where they would be intentionally sunk at predetermined locations. The locations 

would be chosen to provide safe and ready access for divers with minimum disruption to other uses 

of Puget Sound. 

Sinking ships would have an impact on the biological resources and the economics of the area, so 

these two factors must be considered in determining the feasibility of this activity. However, the 

motivation for considering ship sinking is economic development, not creation of habitat for 

aquatic species. Therefore, the primary biological concern is negative impacts on existing biota. 

Any biological benefits (e.g., promotion of “desirable” species) will be viewed as a bonus but not 

as a reason to proceed with ship sinking. 

Objectives 

This scoping study describes a feasibility study and estimates the cost for conducting such a study 

(i.e., for assessing the feasibility of sinking ships in Puget Sound to serve as dive sites). Because the 

objectives for the scoping study follow from the objectives of the feasibility study, the latter are 

presented first. 

Feasibility Study Objectives 

Provide information to decision makers about the potential costs, benefits, and environmental 

impacts of sinking ships. Specifically: 

• Estimate the costs (initial and ongoing) of sinking ships. 

• Estimate the economic benefits that would be derived. 

• Identify political and community stakeholders and gauge their support or opposition. 

• Develop detailed information about environmental (physical, water quality, biological) impacts. 

This information must be sufficient for programmatic compliance with SEPA. 

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Scoping Study Objectives 

Design the feasibility study and estimate the cost to conduct it. Specifically: 

• List the questions or topics that must be addressed by the feasibility study. 

• Suggest approaches or tasks to address each question or topic. 

• Estimate the cost for each approach or task. 

Scoping Study Methods and Format 

We have been instructed that the feasibility study is to use pre-existing data unless a critical need 

for new data exists. Therefore, the primary methods of the feasibility study designed herein are 

literature review, consultation with experts or authorities, and analysis of pre-existing data. 

In the main section of the scoping study we list the questions and topics that should be addressed by 

the feasibility study, suggest approaches to address them or tasks that must be executed to complete 

them, and estimate the costs of the approaches or tasks. This main section is divided into three 

subsections that roughly correspond to feasibility study objectives: 

1. Projects costs: Initial costs of ship selection, acquisition, preparation, and deployment; site 

selection; permitting; liability coverage; and infrastructure development. Also, ongoing costs of 

maintenance and monitoring. 

2. Environmental impacts: Physical effects such as changes in flow and sediment scouring or 

deposition; water quality impacts from residual contaminants and ship decomposition or ship 

colonizers; and biological impacts from colonizers, including competition with and predation 

on other species using the area. 

3. Socio-economic impacts: Anticipated economic benefits; assessment of political and 

community support or opposition. 

Cost estimates are derived by various methods (Appendix A). Estimates for several tasks under 

“project costs” were obtained from Jeff Dey of REEFMAKERSTM. 

Following the main section is a budget section containing a table where line item costs are listed 

and cumulated to estimate total study costs, a discussion section where findings are summarized 

and important issues highlighted, and a recommendations section. 

Feasibility Study Questions, Tasks, and Costs 

Project Costs 

Ship Selection and Acquisition 

The feasibility study should recommend criteria for ship selection, and investigate the availability 

and acquisition cost of ships. Because thorough contaminant removal will be required before 

sinking a vessel (see below), one of the most important ship selection criterion may be ease of 

cleaning — i.e., ease of identifying and locating all onboard contaminants, ease of removing them, 

and cost for these tasks. We note several points that relate to this criterion: vessels constructed after 

1979 don’t contain polychlorinated biphenyls (PCBs), those constructed after 1980 do not contain 

asbestos, and combatant vessels may be harder to clean than non-combatant vessels (DEMA 2006). 

5 
Another important criterion is ship size. Total cost of past ships-to-reefs projects averages about 

$500 per ton for ships ranging from 3,700 to 34,000 tons (Appendix B); thus cost is likely to be 

proportional to ship size with no cost efficiency gained for larger ships. Ship size also bears on 

siting (size of site required; ship stability under local conditions), diver safety (<80 feet wide 

recommended for safe, line-of-sight exit) (DEMA 2006), and diver preferences. Historical or 

cultural values may also be an important selection criterion. For example, crews that served on 

navy ships might prefer scuttling to scrapping when the ships are decommissioned (DEMA 2006). 

Ships for scuttling may be available from the U.S. Navy or the Maritime Administration (MARAD) 

(DEMA 2006). These agencies offer partial subsidies for cleaning and transport; however, current 

offerings cover only a small fraction of the costs (Jeff Dey, REEFMAKERSTM; personal 

communication). Other sources of ships also should be investigated. Two types and sizes of ships 

have been proposed as potentially good choices for Puget Sound (Mike Racine, Washington Scuba 

Alliance; personal communication). The first is Washington State Department of Transportation 

steel electric class ferries (~250 feet long; ~2,000 tons). They have cultural value in Washington 

and a relatively open structure that may allow for easy cleaning. One has been retired and several 

others remain in service but will be phased out in the next few years. They were purchased in the 

1920s and have been rebuilt three or four times since. Some contaminants (e.g., PCBs; asbestos) 

may have been removed during the rebuilds. It should be possible to consult with the people who 

maintain these ferries, and service records should be available, thus facilitating the assessment of 

onboard contaminants. Introduction of invasive species is not an issue since the ferries are already 

in Puget Sound. 

The second proposed vessel class is Canadian-class destroyers (~350 feet; ~3,000 tons). Several 

have been sunk in the Strait of Georgia in British Columbia. Note that all currently available 

decommissioned United States destroyers may be closer to 500 feet long (3000-6000 tons) (Jeff 

Dey, REEFMAKERSTM, personal communication). Larger combatant ships (e.g., aircraft carriers) 

may not be a good choice for reasons given above. 

Tasks and costs: Identify appropriate classes of ships and determine their availability and 

acquisition cost: $20,000. 

Contaminant Removal and Effects 

Ships contain a variety of materials known to be harmful to marine organisms. Furnishings that are 

easily detached from the ship’s structure must be removed to prevent them from breaking free later 

and becoming marine debris. The U.S. Environmental Protection Agency and U.S. Maritime 

Agency (2006) note that buoyant debris can endanger marine mammals and waterfowl. Toxic 

materials sometimes are an integral part of a ship's structure or its furnishing. The difficulty of 

removing these contaminants and the cost to prepare a ship for scuttling increases with the degree 

to which toxic materials are attached to the ship's structure. 

The history of contaminant issues in scuttling Navy vessels for the construction of artificial reefs or 

dive attractions is informative. In 1972, the Liberty Ship Act (Public Law 92-402) provided for the 

transfer of Liberty vessels to coastal States for use as artificial reefs. Between 1974 and 1978, 26 

Liberty Vessels were sunk off the Gulf Coast and eastern Florida. In 1977 the Toxics Substances 

Control Act was passed, and the production of polychlorinated biphenyls (PCBs) ceased in the 

USA. Between 1978 and 1992, only six former Navy vessels were sunk for artificial reefs. This 

decline was partially a result of the growing concerns about the environmental effects of the ships. 

Beginning in 1989, the Navy conducted an extensive sampling of ships and found PCBs in 

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insulation, paint, gaskets, caulking, and sound-dampening felt materials. In 2001, the 

Environmental Protection Agency (EPA) Office of Pollution, Prevention, Pesticides and Toxics 

decided to consider the scuttling of a ship to create an artificial reef as a disposal action under Code 

of Federal Regulations 40 Part 761, for which a limit of 50 ppm (μg kg-1) applied to all items 

remaining onboard. This level contrasts with a limit of 2 ppm PCBs for products whose actions are 

considered continued use, rather than disposal (Atlantic States Fisheries Commission, 2004). A 

study conducted in South Carolina found that PCBs in organisms collected around sunken Navy 

ships were not elevated relative to control sites even though materials onboard the ships were laden 

with PCBs (Atlantic States Fisheries Commission, 2004). Under EPA’s 2001 disposal provision, 

the 510-ft landing ship dock Spiegel Grove was stripped of all items having a PCB concentration 

greater than 50 ppm at a cost of $550,000 in removal activities and $75,000 in PCB sampling (U.S. 

Environmental Protection Agency and U.S. Maritime Administration 2006). In contrast, some 

materials with > 50 ppm PCBs were left on the larger 911-foot aircraft carrier ex-Oriskany that was 

sunk off the coast of Pensacola, Florida on May 17, 2006, after the Navy developed a PCB Model 

and Risk Assessment (at a cost of $3.74 million) (U.S. Environmental Protection Agency and U.S. 

Maritime Administration 2006) that showed little biological effect from the presence of those 

materials (U.S. Navy 2006). 

Recent efforts to reduce the release of contaminants from scuttled vessels have focused on asbestos, 

copper, lead, petroleum products, PCBs, tri-butyl tin, and zinc. The introduction of iron from 

rusting steel can also alter the ecosystem by stimulating primary productivity in iron-limited marine 

systems. Radioactive material is present in certain classes of Navy vessels but such vessels will not 

be addressed in this document. The feasibility study should assess the extent to which the 

contaminants listed above must be removed from the proposed classes of vessels to be scuttled and 

the ecological risk from materials remaining onboard. The U.S. Environmental Protection Agency 

and the U.S. Maritime Administration (2006) recently published a set of guidelines for preparing 

vessels for scuttling to create artificial reefs. These Best Management Practices (BMPs) were 

largely based on regulations under the Clean Water Act; the Clean Air Act; the Comprehensive 

Environmental Response, Compensation, and Liability Act; the Resource Conservation and 

Recovery Act; and the Toxic Substance Control Act. For the majority of vessel types and 

contaminants, BMPs for preparing vessels for use as artificial reefs have already been identified 

and biological assessments of the most toxic materials (e.g., PCBs) have already been conducted. 

The feasibility study must estimate the inventory of toxic materials that are likely to be onboard 

each class of vessel examined in the feasibility study. These estimates probably can be derived 

from recent exercises undertaken for EPA disposal permits. The costs of removing materials known 

to contain any of the contaminants, and of any sampling needed to establish the presence and 

concentration of contaminants in particular materials, must be examined for each vessel class. 

During the implementation of any proposed project, the estimated inventory of hazardous materials 

must be verified with additional sampling. 

The clean-up goals listed in the BMPs for each class of hazardous materials are summarized here. 

All debris that is not permanently attached to the vessel, including peeling paint, must be removed. 

The goal for petroleum products is to prevent any sheen from appearing on the water during 

sinking. All petroleum spills must be cleaned so that no visible sheen appears on decks and 

bulkheads. In general, all liquid petroleum products should be drained, flushed, and cleaned from 

fuel, lube, and fluid system equipment. Piping and interior fittings must be drained and flushed so 

that no product drains from the lines. Combustion engines must be drained of oil, filters and screens 

must be removed, and engine sumps must be flushed. During cleanup, strict operation procedures 

7 
for handling materials must be observed to prevent spills, and flushed liquids require pre-treatment 

before disposal to municipal wastewater treatment plants. 

Asbestos on ships built before 1980 is found in sound and thermal insulation, insulation for air and 

exhaust handling systems, and in packing used for a variety of purposes. All loose asbestos must be 

removed and friable asbestos must be sealed. The primary source of friable asbestos is pipe 

wrappings around the main boiler and steam fittings. 

For ships built before 1980, PCBs are found as liquids in transformers, in a variety of insulation 

and gaskets throughout the ship, in electrical cables, and in paint. All liquids containing PCBs, 

including spills and transformers, are required to be removed. Solid materials containing PCBs at a 

concentration of greater than 50 ppm must be removed to receive a disposal permit, or a biological 

risk assessment must be undertaken to demonstrate that the biological effects of the release of 

PCBs from material left onboard would be minimal. In the case of the ex-Oriskany, electrical 

cables and paint contained the majority of the PCB inventory, but these materials released PCBs at 

the slowest rate in two-year tests with various materials and a variety of oceanographic conditions. 

Ship paints are a source of metals including lead, copper, tri-butyl tin, cadmium and zinc. Antifouling coatings applied to the exterior hull below the water line are designed to release their 

biocides to prevent buildup of biological growth that can hinder hydrodynamic performance. If the 

coating on the hull was applied more than 12 years ago and if biological growth and diversity are 

evident on the hull, it is likely that the release rate has diminished to levels that are ineffective in 

controlling growth or harming marine organisms. In contrast to hull paints, superstructure and 

interior primers and paints are designed to last many years and their rate of release to water should 

be low. Nevertheless, blistering or peeling paint should be removed so that the metals in the paint 

do not enter the food chain when they are deposited in sediments near the ship. 

Several other types of materials that contain hazardous materials should also be removed. Lead 

ballast bars should be removed and the area thoroughly cleaned to remove any lead particles that 

may have oxidized and been scraped off the bars. Thermometers, gauges, switches, and gyroscopes 

should be removed to limit the release of mercury. Sacrificial anodes should be removed to limit 

zinc release. The BMPs also suggest removing the fire extinguishing systems, which Moody and 

Field (2000) suggest might contain perfluorooctane sulfonate (PFOS) that is found in aqueous filmforming foams heavily used by the military. 

The coastal areas of the mid-Atlantic, south-Atlantic and Gulf of Mexico, where the majority of 

artificial reefs in the United States have been created, are different from Puget Sound in two major 

respects, both of which indicate that contaminants are a greater concern in Puget Sound. The 

Atlantic coast and, to a lesser degree, the Gulf coast are continuously swept by strong surface 

currents that remove aqueous contaminants from the area. In addition, the shallow, near-shore 

coasts where many artificial reefs have been created are zones of erosion, and thus small particle 

debris from a scuttled ship will be transported in the direction of the prevailing currents. In contrast, 

Puget Sound is an inland sea with several sills. The sills in Admiralty Inlet, near the Hood Canal 

Bridge and in Dalco Passage near Tacoma tend to mix the outgoing surface water, which has the 

affect of retaining contaminants within Puget Sound (Cokelet et al., 1991; Paulson et al., 1993). 

Particulate contaminants are also retained within the deep basins of Puget Sound (Paulson et al., 

1988) because of the bathtub-like shape of the basins. Hood Canal and south Puget Sound are 

particularly susceptible to retention of contaminants. 

8 
The second way in which Puget Sound differs from other coastal regions is that contaminants pose 

a threat to several species listed under the Endangered Species Act (ESA). Both southern resident 

killer whales and Puget Sound Chinook salmon are listed (the former as endangered and the latter 

as threatened) and spend a significant part of their lives in Puget Sound. Primary conservation 

measures identified in the proposed recovery plan for the southern resident killer whales are to 

clean up existing contaminated sites, minimize continuing inputs of contaminants, and monitor 

“emerging contaminants” (contaminants whose effects are less well known than for older 

contaminants such as PCBs) (National Marine Fisheries Service 2006). PCBs are of particular 

concern because they bio-accumulate through trophic transfer and occur at high levels in killer 

whales at the top of the food chain. Chinook salmon with extended residency in Puget Sound also 

have elevated PCB levels and are a preferred prey of the listed killer whale population (National 

Marine Fisheries Service 2006). PCB levels in sediments are higher in Puget Sound than farther to 

the north (e.g., in the Strait of Georgia), and so are levels in southern resident killer whales 

compared to other resident populations farther to the north which also primarily eat salmon 

(National Marine Fisheries Service 2006). PCB levels in Puget Sound peaked around 1960 and 

have since declined, levels in harbor seal pups from Puget Sound declined from 1972 to 1990 but 

have since leveled off, and recent modeling suggests that levels in killer whales have declined since 

1970 (National Marine Fisheries Service 2006). 

Polybrominated diphenyl esters (PBDEs) may be present on ships and are emerging contaminants 

of concern for killer whales (National Marine Fisheries Service 2006). PBDEs have been linked to 

health problems, and like PCBs they bio-accumulate and occur at higher levels in the listed killer 

whale population than in other resident populations farther to the north (National Marine Fisheries 

Service 2006). Unlike PCBs, their use has not been banned and their prevalence in the environment 

is increasing. PBDEs are flame retardants and are found in plastics, computer plastics, small 

appliances and upholstery foam (National Marine Fisheries Service 2006). It seems likely that they 

occur in materials on ships, but their presence and concentration levels have not been established, 

and in fact they are not even mentioned in the EPA BMPs for ship preparation. PFOS, also 

considered an emerging contaminant of concern for killer whales, is an aqueous film-forming foam 

used in fire extinguishing systems (U.S. Environmental Protection Agency and U.S. Maritime 

Administration 2006). Although the BMPs suggest removing all fire extinguishing systems, residue 

PFOS might be present on ships, especially if the fire extinguishing system was activated. The 

feasibility study must address the inventory of PBDEs and PFOS on a vessel and the cost of 

removing them. Accomplishing this will likely require collecting and processing samples (i.e., 

conducting hazardous material sampling) from each prospective vessel class. 

If the proposed ship sinking program is implemented, permitting will require biological 

assessments of the program’s potential effects on ESA listed species. Biological assessments 

synthesize existing data to evaluate whether the proposed action will affect the listed species, and if 

so the likely effect. The feasibility study should conduct biological assessments for killer whales 

and Chinook salmon similar to those required under the ESA and should consult with the National 

Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NOAA Fisheries), 

the listing agency for both species. The feasibility study should include a review of the literature 

and consultations with experts on potential PCB introductions from materials left onboard (i.e., 

materials containing < 50 ppm PCBs) to assess whether EPA BMPs are acceptable for Puget 

Sound. The cost of more thorough PCB removal (i.e., beyond the 50 ppm limit) should also be 

investigated. The feasibility study should also review and synthesize all existing studies on the 

biological effects of PBDEs and other emerging contaminants. However, the long term multimillion dollar studies needed to establish acceptable levels of PCBs have not been conducted for 

9 
emerging contaminants. If onboard sampling indicates widespread PBDE occurrence it is possible 

that regulators will invoke the precautionary principle and withhold permits for ship sinking until 

those data become available. 

We note that concerns about PCBs and emerging contaminants are not limited to killer whales and 

Chinook salmon. Other species (e.g., rockfishes and herring) have higher PCB levels in Puget 

Sound than elsewhere (National Marine Fisheries Service 2006). Major initiatives are underway to 

prevent contaminants from entering the Sound and to remove or otherwise inactivate those that are 

already there (Puget Sound Action Team 2006). In addition to consulting with NOAA Fisheries 

about the listed species it will be necessary to consult with the Washington Department of Ecology 

(DOE), the agency responsible for Puget Sound water quality (i.e., ship sinking will require a water 

quality permit from DOE), and with other interested parties including those involved with cleanup 

activities. 

We provide the following guidance for literature reviews on the biological effects of PCBs and 

emerging contaminants. An assessment of biological effects follows the risk assessment outline of 

source, transport, exposure, effect and biological endpoint. The source term would include releases 

of contaminants to the water column and weathering of paint coatings and steel structures that 

produce particles of various sizes that settle to the sediments. The release rates of contaminants to 

the aqueous phase should be coupled to a hydrodynamic model which would simulate the transport 

of each contaminant to the near- and far-field regimes of the study area around the proposed site. 

The concentrations modeled by the hydrodynamic model would suggest the level of exposure for 

affected marine organisms. In most cases, bioaccumulation of contaminants of hydrophobic 

compounds occurs between trophic levels of the food web. The initial step of bioaccumulation of 

hydrophobic compounds through the food web is uptake by primary producers, such as algae 

present in the euphotic zone. The bioaccumulation of hydrophobic compounds should be modeled 

through the food web to Chinook salmon and killer whales. For some metals and volatile 

compounds, such as mercury, the pathway of exposure and entrainment into the food web may be 

through direct uptake by the gills. In such cases, the transport model should be coupled to a variety 

of biological models, such as the Biotic Ligand Model (Di Toro et al., 2001). 

In a somewhat independent pathway of transport and exposure, flakes or particles containing 

contaminants from the ship settle near the ship. Depending on the mass of settling particles and the 

local net and maximum tidal currents, these particles will either be transported away from the ship 

or be buried. A variety of approaches including total sediment concentrations, pore water 

concentrations, changes in benthic community, and toxicity tests have been used to evaluate the 

effects of contaminants on the biological community. The uptake of contaminants by benthic 

organisms would ultimately flow through the food web to Chinook salmon and killer whales. 

Likewise, the direct uptake of contaminants from benthic organisms that attach directly to the 

surfaces of the ship that contain contaminants must also be included in the food web model. 

Tasks and costs: Estimate inventory of PCBs and the other “established” contaminants (i.e., those 

addressed in BMPs), and estimate removal costs for those contaminants, for each prospective 

vessel class. Cost assuming two vessel classes (WA State ferries and medium sized destroyers): 

$11,000. 

Review literature on biological effects of PCBs, PBDEs, and other emerging contaminants, consult 

with experts, regulatory agencies (NOAA Fisheries, DOE), and other interested parties, and prepare 

a synthesis document. Cost: $18,000. 

10 
Total cost of studies using existing data (i.e., estimating “established” contaminant inventories and 

removal costs, and reviewing and synthesizing effects of “emerging” contaminants): $29,000. 

Conduct onboard hazardous material sampling to establish presence and concentration of PBDEs 

and other emerging contaminants, and estimate removal costs. Cost assuming two classes of vessel:

$150,000. 

Ship Preparation, Towing, and Sinking 

Preparation for diver safety will include removing sharp or protruding objects that might snag 

divers; removing doors and hatches and widening openings; widening corridors and removing wall 

paneling; providing holes in the ship exterior for light penetration; and sealing off restrictive 

compartments (U.S. Environmental Protection Agency and U.S. Maritime Administration 2006). 

Towing the ship to the cleaning and preparation yard will happen before the ship is cleaned, so the 

contractor will need to purchase and show proof of insurance for any mishaps that occur in transit 

(e.g., contaminant spills). 

Towing the ship from the cleaning yard to the final destination and sinking the ship will require a 

towing and sinking plan, final regulatory approvals, and adequate towing stability and watertight 

integrity. Other towing preparations may also be necessary, such as a plan for (i) a tertiary stop (if 

needed for final preparation and setting of charges), (ii) pre-anchoring at the permitted site, (iii) 

security, (iv) final positioning and sinking, and (v) any actions needed to prevent harm to marine 

mammals or other marine life in the vicinity. It will also be necessary to purchase navigation buoys 

(if required, see “permitting” below), determine how many mooring buoys will be needed, and 

purchase and deploy the buoys. 

Tasks and costs: Obtain specifications (e.g., minimum width for openings) and estimate diver 

safety preparation costs by consulting with dive groups and persons from past ships-to-reefs 

programs, and by collecting bids from contractors. Cost assuming two vessel classes: $1,000. 

Estimate costs of towing to the cleaning yard by evaluating towing contractors and collecting bids 

from those that are qualified. Cost, assuming two vessel classes: $2,000. 

Estimate costs associated with towing from the cleaning yard to the final destination, including 

purchasing and deploying buoys. Cost, assuming two vessel classes: $6,000. 

Total cost to estimate cost of ship preparation, towing, and sinking: $9,000. 

Siting 

A number of factors must be considered in selecting a site. Physical characteristics must ensure 

ship stability and preclude ship burial, provide safe diving conditions, and avoid undue scouring or 

deposition. Conflicts with navigation must be avoided. Distributions of sensitive species and 

habitats should be considered and avoided. Socio-economic factors also bear on siting. We propose 

a two stage approach for locating physically and biologically suitable sites and confirming their 

suitability. First, collect and synthesize existing data to suggest acceptable sites for scuttling, then 

conduct field surveys to assess the reliability of these predictions. 

11 
Puget Sound-wide map: Use existing data to conduct a general Puget Sound-wide query in a 

Geographical Information System (GIS) to roughly delineate areas that may be physically suitable 

and don’t appear to conflict with navigation or sensitive species or habitats. 

Query digital elevation models (DEM) for depth ranges suitable for diving and allowing adequate 

navigational clearance above a ship. Within that result query, calculate and remap the slope, and 

within that result, query and display areas with a footprint adequate for the larger vessel class 

(medium sized destroyer). 

Cost: $2,500. 

Assess water clarity and currents qualitatively by taking this map to dive shops and diver groups to 

highlight areas known for good water clarity and currents and to eliminate areas generally 

considered undesirable. 

Cost: $2,500. 

Further assess currents and circulation at potential sites on the map using University of 

Washington’s PRISM model and “Tides and Currents” boater’s guide. Each of these has 

uncertainties which are not necessarily published and the data may not be representative of the 

range of conditions that occur throughout the year and at the range of depths that divers and the 

sited ship will experience. However, this exercise should be useful for suggesting areas to avoid or 

favor. 

Cost: $5,000. 

Assess substrate characteristics of potential sites on the map to the extent possible from existing 

information. Data on substrate type are sparse and generally consist of isolated deeper basin 

sediment monitoring sites of DOE and a few sites recently monitored by King County. Several 

video surveys for fish exist and include information on substrate (Pacunski and Palsson 1998), but 

will require significant effort to review, analyze, and map substrate if the surveys were conducted 

within the potential sites queried above. Data on sediment thickness (sub-bottom sediment type and 

structural competency) occur along only a few transects generally in deeper basins. This 

information is essential for siting a ship and must be obtained through field surveys (see below). 

Cost: $7,500. 

Assemble geo-referenced data on areas to avoid because of navigation (e.g., shipping lanes) or 

other restrictions (e.g., military). Also assemble available data on distributions of sensitive or 

important species or habitats (e.g., geoduck beds) and on spatial variation in water quality. 

Particularly important for the latter would be minimum dissolved oxygen levels. Regardless of 

whether ship sinking has an effect on water quality (see “biological impacts below”), water quality 

may be relevant to siting. Areas that periodically experience poor water quality (e.g., south Hood 

Canal; Puget Sound Action Team 2006) may not be good sites for sinking ships because of diver 

reaction to the periodic fish kills. Add the data for restricted areas, sensitive species and habitats, 

and water quality to the map. 

Cost: $12,000. 

Total cost of Puget Sound-wide map from existing data: $27,500. 

Field surveys: The second stage of this two-stage process is to conduct field surveys in order to 

confirm that sites will meet requirements of substrate type, seafloor structural integrity, water 

clarity, current speeds, and biological community. Quantitative data on these variables are needed 

to establish fundamental requirements for ship stability and diver safety. The purpose of field 

12 
surveys is not to select a site for ship sinking but rather to “ground truth” the map and verify that 

sites suitable for ship sinking exist in Puget Sound. Field surveys also have great value for 

assessing potential environmental impacts. For example, knowledge of substrate type and currents 

will enable evaluation of potential scouring/deposition and how far those effects might extend from 

the sinking site (see “physical processes” under “environmental impacts” below). Field surveys will 

also be useful for pre-deployment analysis of ship stability and integrity (see below). 

The feasibility study should survey substrate type and seafloor structural integrity at five of the 

potential sites found through querying the Puget Sound DEM, selected to provide some geographic 

variability, by collection and analyses of substrate data and sub-bottom seafloor structure data. An 

area of 500 m by 500 m would be surveyed to provide data covering an area that can accommodate 

the ship footprint in various orientations. The survey would include: 

1. Substrate mapping of the entire area with sonar to identify substrate type, morphology and 

sediment bedform variability that reflects how mobile or dynamic the seafloor is. 

Cost (per site): $10,000. 

2. Video drops at 50 m spacing across the area to refine interpretation of substrate type (i.e., 

whether rock or sediment). 

Cost (per site): $1,000 (if done in conjunction with substrate mapping). 

3. Sediment grab samples at 50 m spacing (in areas characterized by a sediment substrate) to 

determine grain size and percent fine material that can be re-suspended to cause turbidity. 

Cost (per site): $7,000-$18,000 depending on the number of stations with sediment. 

4. Seismic reflection profiling across sea floor areas covered with sediment to determine sediment 

thickness and capacity of the substrate to support a ship. 

Cost (per site): $8,000. 

5. Collect sediment cores and analyze for sediment type, porosity, and organic content. Deploy a 

bulk density or an in situ pentretrometer to estimate competency if sediments are found to be 

thick and consisting of fine material susceptible to deformation. 

Cost (per site): $8,000-$10,000. 

Total cost of surveying substrate and sea-floor structural integrity: $40,500 per site x 5 sites = 

$202,500. 

Survey water clarity. Water clarity would be measured at 50 m spacing over substrates determined 

to be competent to support a ship. We suggest using a profiling CTD with OBS and PAR sensor to 

determine turbidity and light availability at two times in the year (seasons to be determined by dive 

groups based on either the influence of rivers on circulation or winds on surface currents) and over 

the range of ebb/flood tides over a neap and spring tide to determine tidal and seasonal variability. 

Cost (per site two seasons): $21,000. 

Measure currents using boat-mounted current profilers across dive sites concurrently with water 

clarity measurements to determine the range of current velocities and directions under extreme tidal 

conditions and seasons. 

Cost (per site two seasons): $15,300. 

Total cost of surveying water clarity and currents: $36,300 per site x 5 sites = $181,500. 

13 
Conduct two field surveys over one year to characterize the faunal and macrophyte communities in 

the study sites selected for physical surveys. Sampling will include 5-7 bottom grabs to characterize 

infauna, surveys along several transects with a remotely operated vehicle or video camera to 

characterize epibenthic communities, and at least two tows per site with a trawl and hydroacoustic 

gear to characterize fish communities. 

Cost for biological surveys: $22,240 per site x 5 sites = $101,200. 

Pre-Deployment Ship Stability and Integrity Analysis 

Determine what the physical characteristics of the ship will be after pre-deployment preparation is 

completed. Given the prevalent substrate types, seafloor structural integrity, and currents, as 

indicated by the site specific surveys (see above), determine whether a ship from each vessel class 

would be supported and stable, whether ballast would be required, the optimum orientation with 

respect to dominant current direction, and whether the ship should be able to withstand 25, 50, and 

100 year storm events. 

Tasks and costs: Analyze the data from the site specific surveys (see “siting” above) to verify that 

ships would be supported and stable at these sites. Estimate the cost of a rigorous pre-deployment 

ship stability and integrity analysis. Note that this analysis will be conducted only if ship sinking is 

authorized and will be specific to the permitted site. Cost assuming two vessel classes: $10,000. 

Permits 

One can jointly apply for permits to sink a particular ship at a particular site with a Joint Aquatic 

Resources Permit Application (JARPA) available from Washington State. Required permits are: 

Federal: 

• U.S. Army Corps of Engineers (Corps): Section 10 (Rivers and Harbors Act) and 404 (Clean 

Water Act). Because the permits are issued by a federal agency the ESA is triggered. The 

applicant needs to include a Biological Assessment (BA) for each ESA listed species that might 

be affected. The Corps will consult with the appropriate listing agency (NOAA Fisheries or 

USFWS) on the proposed action. The need for federal permits also triggers the National 

Environmental Policy Act (NEPA). The Corps is the lead agency and will instruct the applicant 

on preparation of materials needed for NEPA compliance. It may be possible to prepare 

materials that jointly satisfy NEPA and State Environmental Policy Act (SEPA) requirements. 

According to EPA BMPs for ship preparation (U.S. Environmental Protection Agency and U.S. 

Maritime Administration 2006), a Marine Protection, Research and Sanctuaries Act ocean 

dumping permit will not be required because sinking ships for placement as an artificial reef is 

regulated under other federal laws. 

• U.S. Coast Guard: Private Aids to Navigation. Attaching navigation buoys to the sunken ships 

may be required. 

State: 

• Washington Department of Ecology: 401 Water Quality Certifications. Issuance means that the 

project complies with State water quality standards. Consistency with the Coastal Zone 

Management Act is reviewed as an adjunct to 401 permitting. It appears that a National 

Pollution Discharge Elimination System permit will not be required because sinking a ship is a 

14 
one time action, not an operation involving continuous discharge. DOE also administers SEPA, 

which ship sinking will need to comply with. SEPA will be triggered as part of JARPA. 

• Washington Department of Fish and Wildlife: Hydraulic Project Approvals. The application 

must include plans and specifications for protection of fish and shellfish. 

• Washington Department of Natural Resources: Use Authorizations for State-Owned Aquatic 

Lands. A permit will 

Local (county or city): 

• Each local government has development regulations in its Shoreline Master Program. All Puget 

Sound bedlands fall within county jurisdictions and some fall within city jurisdictions. At least 

one of the following three permits must be obtained from the county or city where the ship is 

sited to comply with that municipality’s Shoreline Master Program: Shoreline Conditional Use, 

Shoreline Substantial Development, or Shoreline Variance. Issuance will depend on the extent 

to which ship sinking is compatible with or conflicts with a municipality’s Shoreline Master 

Program. The feasibility study should explore this question with all counties bordering the 

Sound and with the appropriate cities for candidate sinking sites. 

A task required for all permits is to determine which agency or entity will apply for the necessary 

permits and be responsible for complying with permit conditions. The Coastal Artificial Reef 

Planning Guide (Atlantic States Marine Fisheries Commission 2004) recommends that permits be 

held by State, county, or city governments because they are stable (i.e., likely to persist over time). 

Non-governmental organizations may be ephemeral. The feasibility study should explore who will 

hold the ship sinking permits. 

Permits are needed only if ship sinking is authorized. Nevertheless, prudence suggests that the 

feasibility study follow the process far enough to determine whether permits would likely be 

granted and to explore the issues involved (i.e., identify the conditions that must be met for permits 

to be granted). For each of the permits listed above, the permitting agency should be contacted to 

determine whether they would grant a permit, what information they would need to make a 

determination, and what conditions they would impose before issuing a permit. 

We have listed programmatic compliance with SEPA as a specific objective of the feasibility study. 

We think that the feasibility study designed herein will meet this objective because it will address 

all potential environmental impacts that should be addressed in an environmental impact statement 

for SEPA. 

Tasks and costs: Estimate the cost of preparing materials needed to obtain the permits listed above 

and to obtain those permits. Explore whether ship sinking is compatible with Shoreline Master 

Programs of counties/cities where ships might be sunk. Determine whether permits would likely be 

granted and under what conditions they would be granted. Cost: $10,000. 

Liability 

Atlantic and Gulf States Marine Fisheries Commissions (1998) states that once a ship has been 

properly sunk (i.e., in the permitted location, with any needed aids to navigation attached, and with 

any required notification of interested parties) liability risk to the permits holder is low as long as 

conditions of those permits are met, including requirements for systematic monitoring . The permits 

holder shouldn’t be liable for a recreational diving accident unless the accident was caused by a 

15 
permit violation (Atlantic and Gulf States Marine Fisheries Commissions 1998). In this respect, 

liability issues for an artificial reef are like those for a public park. Most parks contain some 

dangers, and park visitors assume some risk of injury (Atlantic and Gulf States Marine Fisheries 

Commissions 1998). However, accidents probably would be evaluated on a case by case basis for 

negligence on the part of the permits holder, and negligence might be upheld depending on the 

circumstances (Atlantic and Gulf States Marine Fisheries Commissions 1998). 

New Jersey holds permits for artificial reefs in State waters. New Jersey managers recently 

published an artificial reef plan in which they stated that they would consider purchasing 

appropriate insurance coverage for artificial reefs if it became available (Figley 2005). This 

statement implies that such insurance is not currently available. 

The contactor that tows and sinks the ship should assume responsibility for the ship and be liable 

for mishaps such as missing the target site. The permits holder must write the contract 

appropriately, and the contractor should carry appropriate insurance. 

Tasks and costs: The feasibility study must clarify all aspects of liability to the permits holder, 

investigate whether appropriate insurance is offered, and determine the cost of such insurance. 

Cost: $10,000. 

Infrastructure 

Infrastructure to support diving might include boat launches, marinas or other moorage space, 

parking, services such as law enforcement and schools (needed for new workers filling jobs created 

by ship sinking as well as for dive tourists), and shore-based facilities (e.g., showers, changing 

rooms). If sunken ships are accessible from shore then shore-based facilities must be substantial; 

however, it is likely that ships will only be accessible by boat due to depth requirements of sinking 

sites (100-130 feet). 

The amount of new infrastructure needed will depend on where the ships are sited. If sites are near 

large population centers then existing facilities may be sufficient to accommodate increased use, 

but more remote sites associated with small communities may require substantial expansion of 

infrastructure. Infrastructure needs will also depend on the number of new divers expected (see 

“economic effects” section below). Any new infrastructure must be compatible with shoreline 

master programs and zoning (see “permitting” above). In addition to initial costs for any facility 

construction, ongoing maintenance costs or staffing needs also should be considered. 

The feasibility study should estimate the amount of new infrastructure required and the cost to 

construct and maintain it. Because of dependence on siting and projected diver numbers, it may be 

necessary to wait until more is known about those variables (i.e., until the latter part of the 

feasibility study) to estimate infrastructure needs. Note that if ships are sited in areas where existing 

infrastructure is sufficient to absorb anticipated need, then feasibility study costs for infrastructure 

should be lower than that given below. 

Tasks and costs: Estimate new infrastructure needs and associated construction and maintenance 

costs. Cost: $24,000. 

16 
Maintenance 

Mooring and navigation buoys must be maintained, and maintenance can be expensive (Figley 

2005). Monitoring programs must be administered (see “monitoring” below). The ship will need to 

be stabilized and loose pieces removed from the site if destabilization or break-up is detected 

during monitoring. All conditions of the permits issued for ship sinking must be met. Additionally, 

derelict nets must be removed when detected (see below). 

Tasks and costs: Develop maintenance procedures and estimate maintenance costs on an annual 

basis: $5,000. 

Derelict nets: A major initiative is under way to remove derelict nets and other lost fishing gear 

from Puget Sound because they cause significant harm to marine life (Puget Sound Action Team 

2006). Derelict gear also poses a threat to divers. Derelict nets must be removed if or when they 

collect on the ships. The feasibility study should follow DNR’s guidance on net removal to estimate 

the annual cost of removal, including an estimate of how often nets will snag and require removal. 

The study should investigate whether snagging can be minimized by site selection or predeployment ship preparation. Investigate whether voluntary reporting by recreational divers would 

provide sufficient monitoring. The latter might work since divers would benefit from prompt 

detection and removal of nets. 

An initiative also is underway to remove derelict vessels from Puget Sound bedlands because they 

collect lost fishing gear but perhaps also for other reasons (e.g., ships were not part of the original 

Puget Sound ecosystem). The feasibility study must determine the conditions under which a ship 

sinking program can be reconciled with the initiative to remove derelict vessels. A thorough 

evaluation of potential physical and biological impacts of ship sinking, as outlined below under 

“environmental impacts”, should provide sufficient information to address this issue. 

Tasks and costs: Estimate the cost of net detection and removal. Cost: $4,600. 

Total required to estimate maintenance costs: $9,600. 

Monitoring 

Monitoring is necessary to evaluate the actual environmental and socio-economic impacts of ship 

sinking, as well as to assure compliance with conditions defined in granted permits (Atlantic States 

Marine Fisheries Commission 2004). We include monitoring in the “project costs” section because 

monitoring won’t occur unless the decision is made to sink ships. The feasibility study only needs 

to design and estimate the cost of monitoring. 

Physical impacts: Of interest are changes in water velocity and circulation patterns, scouring and 

deposition patterns, substrate type and seafloor surface topography, and water column turbidity. In 

addition, monitoring ship stability and integrity (i.e., tracking whether the ship stays in the 

permitted site), and perhaps other factors as well, will likely be required as conditions of 

permitting. 

Cost to develop monitoring studies of physical effects: $8,000. 

Contaminants monitoring: Two major approaches to monitoring the environmental effects of an 

action are to 1) sample the proposed site before the action to characterize baseline environmental 

conditions and then repeat the sampling to detect a change as a result of the action and 2) sample 

both near-field and far-field conditions after the action and deduce impacts from the actions at the 

17 
site from geographical changes in the environmental conditions. The specific approach taken will 

depend on the temporal variability of the environmental parameter being studied. For parameters 

that change slowly, the before-and-after approach is more appropriate. For parameters that vary 

substantially among samples over short time periods, the geographical approach is more 

appropriate. 

Since the concentrations of contaminants in sediments change slowly in depositional zones of 

Puget Sound, where the substrate is stable as required for placement of a ship, sediments at and 

around the site should not change rapidly in the absence of the ship. Therefore, the before-and-after 

sampling approach would be appropriate for sampling sediments. Assessing the effects of 

contaminated sediments on benthic organisms usually employs the sediment quality triad: total 

contaminant concentrations, toxicity tests, and benthic community structure. At a minimum, total 

concentrations of contaminants of concern should be sampled at the proposed site, in both 

directions of the dominant tidal current, and in at least one direction perpendicular to the dominant 

tidal direction. Contaminants of concern include: petroleum products, PCBs, asbestos, copper, lead, 

mercury, tri-butyl tin, and zinc. Emerging contaminants, such as polybrominated diphenyl esters 

and chemicals in aqueous film-forming foams may also need to be addressed. Identifying changes 

in benthic community structure not only will assist in identifying effects from chemicals of 

concern, but also will allow evaluation of changes of ecological processes, such as the pathways of 

organic matter and nutrients. The replication frequency for sediment sampling should be based on 

rigorous analysis of statistical power to detect changes resulting from the sunken ship. 

The benthic organisms should also be analyzed for chemicals of concern to evaluate the pathways 

of these chemicals in the food web using the before-and-after sampling approach. However, 

changing contaminant concentrations in benthic organisms as a result of changing seasons and life 

history stage must also be considered. Marine organisms that attach directly to the surfaces of the 

ship also should be sampled after this new ecological niche is established at the site. 

Since properties of the water column change rapidly due to changing physical forcing and seasonal 

effects (e.g., heat transfer and rainfall), the geographical approach is more appropriate for 

contaminants released into the water column. After some time period defined by the feasibility 

study, both near-ship and far-field samples should be collected and analyzed for contaminants of 

concern in both the dissolved and particulate phases. The concentrations of concern in the dissolved 

and particulate phases would be interpreted in relation to both the distance from the ship and other 

environmental parameters, such as salinity for dissolved constituents and particulate organic matter 

or particulate iron for particulate contaminants. While collection and analysis of samples for lowlevel concentrations of trace elements can be performed by a number of specialty laboratories, the 

analysis of samples for low-level concentrations of hydrophobic constituents that are necessary to 

provide the sensitivity to detect changes is a specialized field of expertise. The feasibility study will 

need to define the number of samples for hydrophobic chemicals of concern and the necessary 

detection limits. 

The concentrations of certain constituents in the interstitial water between sediment particles 

provide valuable information about the biogeochemical state of the sediments. Microorganisms in 

the sediment use a specified sequence of naturally occurring, oxygen-containing substances that are 

present in sediments to facilitate breakdown of organic matter. The equilibrium between the 

oxidation-reduction couples of these oxidized-reduced pairs (dissolved oxygen-carbon dioxide, 

nitrate-ammonia, sedimentary manganese dioxide-manganous manganese, sedimentary ferric 

oxide-ferrous iron, sulfate-sulfide, and carbon dioxide-methane) provides a measure of the extent to 

which the sediment column reduces biochemical compounds. The redox potential also can be 

18 
measured with a platinum electrode. The equilibrium between the oxidized-reduced pairs is 

controlled by the deposition of organic matter to the sediment and the diffusion of water across the 

sediment-water interface. The redox condition of the sediments can also affect the availability of 

certain elements of concern to microorganisms. In particular, reducing conditions in the sediment 

can increase the conversion of mercury to methyl-mercury, which is highly bioavailable. Increased 

conversion of mercury to methyl-mercury might be caused by increased organic matter in the 

sediments due to the presence of the ship and not due to release of mercury from the ship. The 

feasibility study should develop a sampling plan to detect changes in the biogeochemistry of the 

sediments due to the concentrations of organisms around the ship while taking into consideration 

the seasonal variation of the deposition of organic matter from surface primary productivity and the 

heterogeneity of the type of sediment at the site. 

Cost to develop contaminants monitoring plan: $20,000. 

Biological impacts: Evaluating the extent to which organisms colonizing a ship were attracted from 

elsewhere versus produced at the ship will likely require some form of the Before-After-ControlImpact Paired Series experimental design (Osenberg et al. 2002). This involves collecting predeployment data from at least two spatially separated reefs, one near the ship site, and then 

monitoring the ship, the nearby reef (impact) and the distant reef (control). A modification might be 

to collect pre- and post-deployment data from reefs at increasing distances from the ship since the 

rate at which attraction decreases with distance would provide an improved basis for understanding 

the effects of sinking ships. 

Another major concern is the effect of competition or predation from ship colonizers on organisms 

in the area surrounding the ship or on organisms passing the ship. Relevant species of concern 

should be identified and monitoring studies should be developed to address this concern. Changes 

in the benthic community due to ship sinking are addressed under “contaminants monitoring” 

above. The need for studies addressing other biological effects should also be evaluated. 

Cost to develop biological monitoring studies: $10,000. 

Long-term Economic Monitoring Plan: Long-term economic impacts can be assessed and 

monitored by comparing post-deployment spending by divers with their pre-deployment baseline 

spending. The monitoring design developed by NOAA for monitoring diving usage for ships sunk 

off the coast of Florida estimates total recreational diving use by using two sources: 1) dive 

logbook records from all dive charter operations in the study area; and 2) on-water survey sampling 

of diving sites in the study area on stratified random sample of days over a pre-determined time 

period (Bob Leeworthy, NOAA, personal communication). Annual log book data could be obtained 

from all for-hire dive operations that utilize dive sites in Puget Sound. The on-water data sampling 

can then be used to estimate the ratio of private household and rental boat use to charter dive boat 

use. This information is needed to extrapolate the dive charter logbook data to the population of all 

recreational users (Bob Leeworthy, NOAA, personal communication). 

The costs for logbook data collection are greatly dependent on the number of dive shops and 

operators within the study area. Costs would include monthly data collection from all dive charter 

operators located within the study area, data entry, travel expenses, and report preparation. The 

costs for on-site survey sampling include vessel rental, observer salary, and data input. Annual 

costs would depend on the number of sites within the sample area as well as the overall time period 

and number of days of sampling (Bob Leeworthy, NOAA, personal communication). 

19 
The full design of dive logbook and on-water observation would be needed for establishing the predeployment baseline diving use. Costs will depend on the number of dive shops and operators 

included in the area and the number of days and sites for on-water sampling. To minimize the costs 

for long-term monitoring of diver use, the annual logbooks can be used to yield an indicator of 

trends. Then in every select year (such as the third or fifth year), the full design can be conducted to 

gather the on-water data for extrapolating to total use (Bob Leeworthy, NOAA, personal 

communication). 

Cost to develop the sampling design and estimate the actual cost of data collection for a long-term 

economic monitoring plan: $8,000. 

Total cost to design monitoring studies: $46,000. 

Project Life Span and Post-Project Cleanup 

Subway cars sunk off the coast of New Jersey deteriorated by an average of 33% after 14 years. 

The author of that study commented that ships might last from several decades to over 100 years 

because they are made of heavier gauge steel (Figley 2005). The feasibility study should investigate 

deterioration rates and frequency of major storms to predict life span. Tasks outlined in the 

“contaminant removal” section above will assess whether post-project sediment cleanup will be 

needed. 

Tasks and costs: Obtain information on ship deterioration rates by reviewing literature and 

consulting with experts. Cost: $3,000 

Environmental Impacts 

Physical Processes 

Altered currents may affect sediment transport (i.e., scouring and deposition patterns, increased or 

decreased water column turbidity). Using data on substrate type and current speed from field 

surveys (see “siting” under “project costs” above), and on physical characteristics of the ships (see 

“pre-deployment stability and integrity analysis” under “project costs”), assess how far scouring 

and deposition is likely to extend from the ship and how much it is likely to change the original 

level of the substrate surface. Using the same approach, assess whether the presence of a ship is 

likely to increase turbidity. 

Tasks and costs: Predict effects of ship sinking on scouring/deposition patterns and water column 

turbidity. Cost: $10,000. 

Biological Impacts 

Sensitive or harvested species: The feasibility study should identify species (i.e., distinct population 

segments thereof) listed or proposed for listing under the ESA. Their physical and biological 

requirements, the factors that caused their decline, and the distribution of these species within Puget 

Sound should be determined from review and synthesis of existing information. Critical habitats 

and the primary constituent elements of those habitats should be described. Whether and how 

sinking ships is likely to impact listed species, and whether any negative impacts could be reduced 

through judicious site selection, altering ship preparation, or some other aspect of the ship sinking 

program, should be evaluated. Existing information includes species status reviews, critical habitat 

designations, and recovery plans, as well as other published and unpublished reports, and data files. 

The appropriate listing agency (NOAA Fisheries or U.S. Fish and Wildlife Service [USFWS]) and 

20 
experts on the biology of each species in Puget Sound should be consulted. Currently listed or 

proposed species are southern resident killer whales, Puget Sound Chinook salmon, Hood Canal 

summer chum salmon, Puget Sound steelhead, bull trout, marbled murrelets, and bald eagles. 

Interviews with personnel from both listing agencies and a cursory review of literature indicated 

that southern resident killer whales and Puget Sound Chinook salmon are the species most likely to 

be negatively impacted, primarily because of concerns about contaminants (e.g., PCBs; see above). 

The study should identify other sensitive species and species important for recreational or 

commercial harvest. These will include all marine mammals (protected under the Marine Mammals 

Protection Act), some seabirds, all salmon and trout, Pacific cod, most rockfishes, lingcod, dogfish, 

herring, surf smelt, sand lance, Dungeness crab, some shrimps, Pacific giant octopus, market squid, 

geoducks, several other clams, abalone, and perhaps additional species. The same issues that were 

addressed for listed species (see above) should be addressed for these species. The agencies having 

management authority (NOAA Fisheries, USFWS, WDFW, Northwest Indian Fisheries 

Commission [NIFC]) should be consulted. Literature and relevant data, including unpublished 

results from past and ongoing studies in Puget Sound, should be compiled, reviewed, and 

synthesized. 

Rare or sensitive habitats or aquatic communities: These include eelgrass beds, bull kelp, rocky 

reefs (Pacunski and Palsson 1998), and perhaps other habitats or communities. The feasibility study 

should consult with appropriate agencies and review literature and geo-referenced data to determine 

locations of these habitats. These habitats, including buffer zones to prevent indirect effects, should 

be excluded from consideration during site selection. Investigators should survey potential ship 

sites to confirm that they don’t contain these habitats or communities. 

Ecological processes: The previous discussions focused on impacts to particular species. Here we 

explore impacts from the perspective of changes in ecological processes that might result from ship 

sinking. The processes and associated impacts are stated in general terms. Specifics about which 

species might be involved and how large effects might be should be investigated through 

consultation with experts and a thorough literature review and synthesis. Data collected during field 

surveys (see “siting” under “project costs” above) would provide improved knowledge on the range 

of biological communities and physical conditions to be found at sites suitable for ship sinking, 

thereby improving predictions of biological impacts. 

The benthic community at the sinking site (i.e., under the ship) will unavoidably be lost or 

drastically altered. The need and possibility of mitigating for this loss, perhaps through restoration 

of similar habitat elsewhere, should be explored and the cost of such mitigation estimated. 

The benthic topography and community near the ship will likely be altered due to changes in 

sediment transport (deposition or scouring) and detritus load (from deposition or ship colonizers). 

The feasibility study should estimate how far this effect is likely to extend from the ship (see 

“physical processes” above). The area likely to be affected might be subject to mitigation along 

with the area under the ship. Results of this assessment also should be used in recommending a 

minimum distance from a sunken ship to sensitive habitats (e.g., geoduck or eel grass beds). 

Changes in currents, or simply the presence of a large object where none was before, might affect 

the behavior or survival of organisms passing the site. Factors to be investigated include larval 

settlement patterns and juvenile migration pathways. Existing information should be compiled and 

synthesized from consultation with experts and literature review. 

21 
Sessile organisms, many of which are filter feeders, will colonize the hard substrate provided by the 

ship. The feasibility study should assess whether they could strip enough food, nutrients, or other 

material from the water column to create a down-current effect or to impose significant predation 

on larvae or other life stages. The ship and immediate vicinity will be a nutrient sink with the 

consequence that these nutrients won't be available elsewhere. The study should assess the 

importance of this “shadow” effect. 

Mobile organisms may use the ship for shelter but forage in surrounding areas, thus increasing 

competition or predation in those areas. Alternatively, these organisms may forage near the ship, 

competing with or preying on organisms passing the ship. Predation on sensitive species, and in 

particular on juvenile salmon, is a major concern and must be thoroughly assessed through 

synthesis of existing information. 

Sunken ships may attract organisms away from hard substrate habitat in surrounding areas. This 

would be especially problematic if the attraction resulted in reduced survival. Harvest, if allowed, 

could reduce survival because harvest rates can be higher at the ship than elsewhere when attraction 

leads to unusually high densities at the ship. Even without harvest, survival might be reduced by 

other factors including higher concentrations of predators or higher predation efficiency at the ship. 

Sunken ships may “intercept” pelagic larvae such that those larvae settle on the ship instead of on 

down-current habitats. Again, this would be problematic if survival was reduced at the ship 

compared to other hard substrate habitat. Whether the ship is likely to produce new organisms, 

thereby increasing regional production, or to simply attract organisms away from surrounding areas 

is an important issue that should be carefully investigated. 

The feasibility study should address the question of whether sinking ships could negatively impact 

water quality other than through contaminants — e.g., significantly reduce dissolved oxygen levels. 

Such an effect seems unlikely but could conceivably result from increased detritus production, 

altered current patterns, or oxygen consumption by ship colonizers. 

Invasive species: Ships may provide "toe holds" for invasive species that colonize hard substrates, 

thus facilitating dispersal to other parts of the Sound. The feasibility study should identify which 

invasive species are likely to colonize ships by obtaining invasive species lists and by consulting 

with experts. The study should evaluate any threat posed by the invasive species and investigate 

whether sites can be selected that discourage invasives (e.g., exclude sites near or down-current 

from known infestations). Also investigate whether sunken ships could facilitate invasive species 

monitoring in Puget Sound. Because the ships will be visited frequently by recreational divers and 

periodically monitored, they might provide an early detection system for new invasives or for range 

expansions of known invasives. Ship preparation should include thorough removal of live 

organisms to prevent introduction of invasives. 

Cumulative effects: Sinking more than one ship in close proximity should result in cumulative 

effects. The feasibility study should investigate whether cumulative effects are likely to be additive. 

If the expected effects are positively or negatively synergistic, the likely magnitude of these effects 

should be assessed. Of course, work on this task will be hindered by a dearth of information about 

the impacts from even a single ship but data may be available from natural reefs or other habitats, 

and comparable situations may be addressed in the ecological or conservation literature. 

22 
Potential benefits: Fish and other organisms will inevitably colonize the ships, and habitat creation 

could be identified as a secondary goal. The motivation for sinking ships is to create recreational 

diving opportunities, but some options for siting or orientation also may maximize benefits for 

charismatic or sensitive species, species richness, or total biomass. Any of these biological effects 

should enhance the attractiveness to divers. 

The study should contact management agencies (WDFW, NIFC) to see if they support this 

secondary goal. If the goal is supported, appropriate target species or communities — perhaps 

sensitive species that require hard substrate habitat such as rockfish – should be identified, and 

ways to alter the ship sinking program to benefit these species or communities should be 

investigated. The ship’s structure might be altered, or “add-on” structures could be designed for 

attachment to the ship or placement on the seafloor near the ship. Ship sinking sites could be 

selected with the preferences and distributions of target species or communities in mind. Perhaps 

the needs of a particular life stage could be addressed; for example by providing juvenile habitat 

near or down-current from reproducing adults. 

The feasibility study should design and estimate the cost of any promising and approved alterations 

or additions, and include procedures to prevent inadvertent harm to the target species or 

communities, or to other sensitive species. The problem of increased harvest rates at the ship could 

be solved by closing the area to harvest; however, the habitat alterations might be attractive to 

competitors or predators. The biological monitoring program should be designed to detect 

unwanted effects, and the alterations should be designed to be reversible or removable if unwanted 

effects are detected. 

Tasks and costs for biological impacts: Address the preceding six biological issues by acquiring 

and synthesizing existing information on the species, communities, and the ecology of Puget 

Sound, including species distributions, food habits, and habitat preferences or requirements. 

Sources will be published and unpublished literature and data sets and interviews with experts. 

Formulate appropriate conceptual models, incorporate any data from field surveys (see “siting” 

under “project costs” above), and assess the likely range of biological responses to sinking a ship 

and how altering a ship-sinking program might change these responses. Cost: $119,500. 

Socio-Economic Factors 

When evaluating the feasibility of a project involving changes to an area’s natural resources, it is 

important to address many socioeconomic factors that may be affected by the endeavor. For the 

purposes of this scoping document, the social and economic needs are addressed separately. 

However, in many instances, these needs can be addressed simultaneously or in tandem with the 

methods outlined with corresponding cost savings. For example, a single survey could address 

economic and social valuation of sinking ships to divers. 

Social Issues 

The feasibility study must address public understanding, attitudes, perceptions, and preferences 

regarding ship sinking and the social costs and benefits of such an endeavor (e.g., public perception 

of management policies associated with the ship; social values that would be met or conflicted by 

implementation). Obstacles and opportunities likely to arise in the public process for ship sinking 

must also be explored (e.g., clarification of key issues likely to arise in public discussions, likely 

support or opposition to the project, likely stakeholders and institutions to be involved in the public 

decision-making process). 

23 
Some evidence suggests that planning processes that include a broad array of stakeholders produce 

more comprehensive plans that are more likely to be implemented (Burby 2003). The challenge is 

structuring public involvement in ways that are meaningful and productive for agencies and the 

public. Studies of public involvement processes in environmental decision making have shown that 

participants evaluate these processes in terms of both process and outcome. Thus, stakeholders 

desire qualities such as accessibility and depth of deliberation (process components), and an 

otherwise satisfying experience (outcome) (Halvorsen, 2003). An accessible process is one that 

provides a comfortable and convenient setting and is respectful of participants’ time. Deliberative 

processes include open discussion and a forum for respectful exchange of opinions; a deliberative 

process provides opportunities for learning. Finally, a satisfying process demonstrates that decision 

makers take public input seriously, and the results of citizen input are reflected in the final decision. 

Other process-focused measures of success in public involvement include the presence of learning 

opportunities, the development of relationships among group members, and a sense of efficacy 

(McCool and Guthrie, 2001). 

Carr and Halvorsen (2001) drew on criteria proposed by Poisner (1996) to evaluate the 

effectiveness of public participation in environmental decision making. One interesting finding of 

their research was that local participants in land-use planning were not representative of the 

community. Women, young people, and those with lower income and education levels participated 

at a lower rate than their distribution in the community. The lesson is that public managers and 

planners must make special efforts to promote participation by a broad range of stakeholders. 

Documents from other ship sinking endeavors, such as in British Columbia and Florida stress the 

importance of public involvement in all stages of planning (Enemark, 1999). 

The public meeting is the forum often used to collect citizen input. This is problematic for a process 

such as sinking ships. Attendance at public meetings is often inconvenient or impossible for some 

persons that may be affected by the potential action (e.g., those who may live long distances from 

the area of interest). In addition, those who most often attend meetings of this type may represent a 

vocal minority group that is usually not representative of the full range of user groups and local 

community members. Also, the type of scientific baseline data that can be collected through this 

forum is limited. 

Several important approaches to understanding the social environment of a decision process such as 

the potential to sink a ship are outlined below, followed by a detailed explanation of the methods 

that could be used and a range of costs associated with conducting the efforts. 

1. Situation Assessment 

A first step to understanding the obstacles and opportunities inherent to any proposed project is the 

assessment of the current and possible future situation. A situation assessment consists of the 

exploration of any legal or regulatory context in which the project will be decided. A part of a 

situation assessment is an analysis of the policies, structures, and incentives that will likely drive 

the decision process. This is sometimes referred to as institutional analysis. This information can be 

important in determining political support for the project and strategies for proceeding in the 

decision process. 

2. Stakeholder Identification and Assessment 

Early in the process, it is critical to identify stakeholders who would be affected by the proposed 

project and who might support or object to the sinking of ships as well as those people, 

communities, or groups who would potentially benefit or be negatively impacted by the action. 

24 
These may be local groups, organizations or individuals, and may also be regional and national 

interests as well. 

Some obvious stakeholders to be considered when exploring the feasibility of sinking ships in the 

Puget Sound might include the diving community, the commercial and recreational fishing 

community, the shipping industry, recreational boaters, tribal governments, environmental 

organizations in the immediate area, as well as the agencies and organizations that would likely be 

playing some role in the implementation and management of the endeavor. Other groups to be 

considered include tourism development councils and entities that are part of the infrastructure of 

the local tourism industry, including hotels, gas stations, restaurants, dive shops, town councils, 

chambers of commerce, and business development associations. While some stakeholders can be 

identified easily, others are more difficult. Their stake in the issue may be unknown to planners or 

decision makers or they may not be attentive to the issue until an initial decision is made that sparks 

their involvement. 

Once stakeholders are identified, it is important to understand their interests, positions, concerns, 

and role in the decision process. For example, are divers supportive of such an endeavor? How 

likely would they be to visit such a site? What types of recreational diving are they currently 

engaged in? What are their concerns? And for the fishing community—do they perceive harvests 

could be affected or that their livelihood may be restricted or further regulated if ship sinking is 

pursued? 

3. Determining stakeholder and community understanding, perceptions, and preferences 

It is important to gain insight into the perceptions and attitudes of the public as a whole, not only 

key stakeholders. Doing so should provide baseline data on the public’s understanding, preferences, 

and expectations. It also can provide managers and decision makers with a better understanding of 

public acceptability of the project. 

In particular, it will be important to assess the social impacts of the potential project to the nearby 

communities. Note that the attitudes and preferences may not be unified across communities. This 

assessment will allow identification and gauging of the likely strength of support and opposition 

prior to implementation. Having objective data on resident concerns can help enhance the public 

process, should the proposal move forward, by documenting the views of a group of residents who 

may normally not participate or speak out at standard forums such as public meetings. Specifically, 

it will help determine the likely acceptability of the project in general and the likely acceptability of 

specific scenarios or alternatives (e.g., if the endeavor is undertaken, what factors will be 

important?). This is important in the political decision to proceed and if it is pursued, what features 

of the project will be considered socially beneficial or costly. This type of an assessment will also 

allow the social benefits and costs to be quantified so that they can be effectively weighed with the 

economic, biologic, hydrologic and other factors to be considered in the feasibility study. 

Suggested Methods and Costs of Studies to Address Social Issues 

There are several options available and widely used for the purposes of gaining insight into the 

social feasibility of an endeavor such as sinking ships in the Puget Sound. Some of these methods 

include analysis of secondary data, focus groups, public meetings, stakeholder assessments and 

stakeholder or community surveys. It is important to bear in mind that some methods will be more 

appropriate and feasible for the outlined purposes than others. 

25 
1. Comparative studies

Comparative studies involve identification and review of similar projects that have been completed 

or are ongoing. Use of these secondary data can be informative and is a good starting place 

regardless of other methods that are conducted afterwards. 

Some information for the situation assessment and the stakeholder identification can be gleaned 

from secondary data sources (e.g., studies or information from other ship sinking projects for 

recreational diving). While gaining information from secondary sources would be useful, not all 

necessary information will likely be found through those sources. There are a limited number of 

previous instances in which ships have been sunk to increase recreation and tourism opportunities 

and a very limited amount of socioeconomic data related to these projects. 

This scoping phase may also include personal interviews of individuals knowledgeable about 

sinking ships. This is an excellent way to gain a better understanding of the technical nature of a 

project and identify lessons learned from other applications and projects. 

Cost: $10,000 

2. Focus groups (Qualitative) 

Focus groups are an established technique for qualitative explorations of attitudes, and perceptions 

of identified groups (in this case, divers or other identified stakeholders). They can be useful for 

determining potential support or opposition and clarifying likely issues of concern. They can also 

help determine strategic future communication, should the endeavor be pursued. 

They involve a series of small group interviews or discussions on specific topics. They allow for 

group discussion, follow-up questions and observation of emotional reaction. The groups are 

usually led by an experienced, trained moderator through a discussion guide. The discussion guide 

allows for consistency in data collection and keeps the discussions within the purview of the topics 

of interest. The focus groups are ideally audio and video recorded to allow for later review and 

analysis by the moderator and other researchers (Morgan 1997). 

Focus groups have limitations for producing generalized results. Even though organizers may make 

an effort to widely advertise a meeting or focus group, the attendees probably will be more 

representative of one view than of another. The conclusions are based more on the depth of analysis 

rather than the breadth of analysis. 

Focus groups could be conducted independently or as is commonly done, as a precursor to a 

quantitative survey in order to clarify issues and determine focus before sampling a more 

representative cross section. 

While it is difficult to determine the total number of focus groups that would be required prior to 

identification of stakeholder groups, it would likely range from 2 to 6 meetings. 

Cost: $20,000 for one meeting and $10-15,000 for each ensuing meeting. 

3. Surveys (Quantitative) 

Surveys often are recommended and used to gain insight into the perceptions and attitudes of the 

public about a potential project in a way that allows for generalizing from the data. Surveys can be 

conducted numerous ways. The most common methods are telephone, on-site, or mail approaches. 

Costs of these different methods are quite variable, based on sample size, difficulty in locating 

intended audience (e.g., a random sample of local community members will be easier to determine 

than a sample of divers), length of the survey, and the type of report of results. Costs below are 

26 
based on a sample size of around 400-600 individuals—this is the size frequently recommended 

because it keeps costs down while providing acceptable levels of precision—plus or minus 5% at 

95% confidence. 

Any of these survey options have the advantage of providing quantitative, numerical data to inform 

the project. Not only can basic levels of support or preference be elucidated, but with an 

appropriate design underlying reasons for support, opposition, or preference can be inferred. 

Socioeconomic knowledge of this type is a vital component in planning, as often groups that 

oppose such actions argue that the desires of the affected public were not taken into account. 

Although the elicitation of public participation is a worthy exercise, it is imperative that the 

socioeconomic feasibility of the potential endeavor of ship sinking be evidence-based and 

supported by sound science. 

Telephone Surveys 

Telephone surveys are widely used but labor-intensive processes. The resources necessary to 

conduct a telephone survey include individuals who can be trained to conduct surveys as well as a 

facility from which many phone calls can be made at one time. Telephone surveys are necessarily 

brief due to the nature of the media and have become increasingly difficult with the advent of caller 

identification systems and cellular telephones. A telephone survey would be appropriate for a 

survey of community residents, but likely not for a recreation user group such as divers due to 

difficulty in obtaining contact information (see Intercept-Mail Surveys, below). 

Cost Range: $20,000-$50,000 

Mail Surveys 1

Mail surveys are an effective tool for obtaining a large amount of information from a potentially 

large pool of respondents. Because people have the opportunity to fill out the survey at their leisure, 

there is the opportunity to have a longer survey than would be feasible with other mediums. This 

also allows respondents time to critically evaluate their answer, potentially making responses more 

accurate. This option is not available in telephone surveys, in which respondents are required to 

answer immediately. There is also a chance to follow up with non-respondents in order to increase 

the number of overall responses. The feasibility of generalizing depends on the size of the 

population about which the researcher is trying to gain insight and the number of respondents. 

A mail survey would be appropriate for determining perceptions, preferences and understanding of 

communities. Mail surveys tend to be good choices for general community surveys. A community 

survey would allow for a large amount of information to be obtained at one time about a variety of 

issues related to sinking ships. This would be valuable as the success of any endeavor is at least in 

part dependent on the level to which a community embraces the project. 

Cost Range: $50,000–$75,000 

 

1

 If surveys were to be conducted of two groups as outlined in the costs (e.g., both an identified user group or 

stakeholder (e.g., divers) and local community residents), the cost would be less than the totals of both surveys 

individually. While the cost saving is difficult to determine at this juncture, it would likely be on the order of 25-35% 

less. 

27 
Intercept-Mail Surveys2

The type and scope of the survey depends upon the group or groups to be sampled. A survey of 

divers can give decision makers an indication of the extent of interest in recreational diving in the 

area. Additional information related to the present types of diving as well as preferences for diverelated services and costs could also be gleaned. The range of focus for surveys can vary according 

to the requirements of planners. For instance, divers who currently participate in areas adjacent to 

Washington could be targeted, as could divers from other regions who do not currently travel to the 

Pacific Northwest to dive. 

Depending on the availability of contact information for specified user groups (likely divers), it will 

likely be necessary to contact users on-site (e.g., at dive shops, boat launches, or marinas). 

Intercept-mail surveys begin with initial contact made on-site with users to introduce the 

information collection effort and to request their participation. For those who agree to participate, 

contact information is recorded so that a mail-survey can be sent to them at a later date (thereby 

minimizing intrusion on their recreation experience). The mail portion of this method is the same as 

for mail surveys described above. The addition of the on-site name collection adds cost and 

coordination efforts (such as with dive shops or marinas) but may be the only viable option if a 

valid reliable list of users is not available or readily accessible. Costs for an intercept-mail survey 

would be on the higher end of the cost range. 

While a survey that is completed fully on-site is sometimes used in social science research, it is not 

recommended in settings where users are actively engaging in recreation activities as the research 

may have negative effects on the recreation experience and response rates may be compromised. 

Another factor with divers is that completing a survey on a boat or near water often is problematic. 

Cost Range: $120,000-$175,000 

Clearly a range of methods could be applied in a feasibility study. At a minimum, the comparative 

study and at least 2-3 focus groups that would include local community residents and members of 

the dive community should be conducted. Ideally, a comparative study, a series of focus groups of 

residents and divers and other interested parties (likely 4-6 meetings) followed by a quantitative 

survey of divers and communities would provide the most comprehensive information from which 

to judge feasibility. 

Economics 

Because the costs associated with sinking ships to create dive attractions can be significant, the 

economic benefits must be examined to determine if the project would be an advisable investment. 

By comparing anticipated project costs (discussed earlier in the report) with the value of benefits 

from sunken ships, the feasibility of the program can be evaluated. This allows an objective 

informed decision regarding the use of public funds for a ship sinking program. A sunken ship can 

potentially support a number of diverse uses and economic benefits including the creation of new 

destinations for scuba diving tourists, enhancement of cultural values (e.g., crew commemoration; 

historical significance), and education benefits (e.g., Puget Sound Awareness). The actual sinking 

of the ship will also create a tourist and media event that will generate economic benefits and 

exposure for the Puget Sound area. For the purposes of scoping the issues for the feasibility study, 

the economic value of benefits from sunken ships is exclusively focused on the benefits derived by 

 

2

 There are many commonalities in methods for collecting social and economic information. If a survey of divers is 

chosen as part of the feasibility study, a single intercept-mail survey could answer both social and economic questions. 

The cost of a combined social/economic survey would likely not be additive and would be within the cost range 

identified for that method. 

28 
scuba divers. In the future, it might be desirable to expand the scope of the feasibility study to 

include the wider range of economic values associated with sinking ships. 

The suggested steps for estimating the economic value associated with sinking ships for scuba 

diving is described below. Within these steps, several types of data are needed. Data collection 

techniques can range from using pre-existing studies to conducting surveys of current and potential 

Puget Sound divers. Within the steps, we note the data needed and will discuss the approaches and 

associated costs to obtain these data in the economic data methods section. 

Steps for evaluating the economic benefits from sinking ships for scuba diving: 

1. Evaluate Economic Baseline Conditions: 

An assessment of baseline conditions will provide an understanding and evaluation of the local 

economy near the proposed ship sinking site. The assessment should incorporate a regional 

economic profile of the local communities near the proposed sinking site including the local 

tourism and dive tourism industries. The assessment should evaluate the advantages and 

disadvantages of selecting a particular community for ship placement including the availability and 

cost of transportation to the local area and the dive site, distance from airport, availability of diver 

related services, and the level of support from community businesses. Sinking ships for divers in 

British Columbia demonstrated that a long term dive tourism plan and broad tourism community 

support from more than the dive industry is needed to maximize the return on the investment in 

ship sinking. (Enemark, 1999). 

2. Estimate economic values of current diver use (pre-deployment) and anticipated changes 

following placement of the ship (post-deployment): 

The size and economic value of the existing dive tourism industry must first be calculated before 

estimating the potential growth from ship sinking. The economic impact of the current level of 

divers will form the baseline needed for assessing the potential increase in benefits from new divers 

as well as monitoring the actual economic impacts post-deployment. 

Benefits derived by scuba divers involve both market and non-market values which makes 

quantification of total benefits difficult. Market impacts are typically measured by the total amount 

of money non-local divers spend in the local economy and the resulting impacts on local 

employment and income. The amount of spending by non-local divers represents the base upon 

which tax revenues can be generated (Pendleton 2005). While spending by divers represents local 

economic market effects, it does not measure the benefits to the divers themselves. This additional 

non-market value is reflected by the amount divers would pay over and above their existing costs to 

use a dive site. 

The current and anticipated changes in market values can be measured by conducting a regional 

economic impact analysis. Economic input-output models are commonly used to predict the total 

level of regional economic activity that would result from a change in visitor spending. Regional 

economic impacts can include changes in sales revenue, jobs, net income, and tax revenues. The 

size of the region influences both the amount of spending captured and the multiplier effects. An 

economic impact analysis can be conducted for the local communities near the ship site (typically 

defined as all counties within a 30-60 mile radius of the travel destination) and the overall regional

level (e.g., the State of Washington). For the local analysis, only spending by non-local visitors 

living outside the local area (non-local Washington residents and non-residents) is considered an 

infusion of new money into the local economy. The regional economic impact area will capture all 

spending by non-residents in the State of Washington. 

29 
To determine the regional economic baseline impacts of current diver use, data are needed on: 

• the current annual number of divers 

• the percent of divers that live outside of the Puget Sound area (non-local Washington 

residents and non-residents) 

• the average spending of non-resident divers locally in the Puget Sound area (to determine 

the local spending impacts) and other areas in the State of Washington en-route to the Puget 

Sound area (to determine regional spending impacts) 

• the average spending of non-local Washington resident divers locally in the Puget Sound 

area (to determine the local spending impacts) 

In order to determine the change in economic effects associated with ship sinking, data are also 

needed on how current divers would change their number of visits and the anticipated number of 

new divers and how often they will visit the area. 

Factors that can affect dive visitation include: 

• Novelty: Are sites primarily used shortly after sinking or do divers continue to use (i.e., 

make repeat visits); 

• Cluster of ships or sites versus single ships—how does appeal to divers increase as a 

function of the number of ships at a site (or within a 30 minute boat ride?); 

• Proximity to good natural dive sites may be a benefit in a similar manner to multiple ships; 

• Synergy from being part of the “British Columbia circuit;” 

• Ship size and type; 

• Remoteness: availability and cost of transportation to the local area and the dive site, 

distance from airport, and availability of diver related services; 

• Amenities: proximity to other attractions including cities (movies, spectator sports, 

museums, etc) or alternatively the lack thereof (i.e., piece and quiet) or other outdoor 

activities (National Parks, hiking, kayaking, etc.). 

The non-market value of a dive site to the individual diver will depend on diver interest, quality of 

the sunken ship, and substitute dive sites (Pendleton, 2005). The non-market benefits to the dive 

visitors are measured by how much the visitor would pay over and above their existing costs. To 

determine the non-market values of current diver use, data are needed on how much more than the 

existing costs divers would pay for their current trip experience. In order to determine the change in 

non-market values associated with ship sinking, data are also needed on how much more than the 

existing costs current and potential divers would pay for a trip to a sunken ship in Puget Sound. 

Economists have several methods for measuring non-market values. The most appropriate for this 

situation is the contingent valuation method. Contingent valuation is a method that uses a simulated 

or hypothetical market to determine how much more than the current costs visitors would pay for 

their trip experience. The method is recommended for use by federal agencies performing benefit 

cost analysis (U.S. Water Resources Council, 1983). 

30 
3. Determine the Net Economic Value: 

The net economic benefit of sinking ships for scuba diving can be calculated by comparing the 

anticipated initial and ongoing project costs, including the cost of needed infrastructure (see 

“project costs” above) to the anticipated annual economic benefits (market and non-market) from 

new diving tourism. The feasibility study should address how the project costs will be distributed 

among community members. Equity concerns about an increased tax burden on local residents to 

pay for infrastructure has been highlighted by at least one stakeholder group. Other equity concerns 

relate to the initial economic status of the local community near the ship site (as a means of 

assisting a struggling economy). The feasibility study should also address potential conflicts of ship 

sinking with other activities. For example, creation of a no-harvest zone might cause recreational 

anglers to go elsewhere. 

Clearly a range of methods could be applied in a feasibility study. At a minimum, the comparative 

study and at least 2-3 focus groups that would include local community residents and members of 

the dive community should be conducted. Ideally, a comparative study, a series of focus groups of 

residents and divers and other interested parties (likely 4-6 meetings) followed by a quantitative 

survey of divers and communities would provide the most comprehensive information from which 

to judge feasibility. 

Economic Data Collection Methods and Costs 

The cost of conducting the economic valuation steps outlined above would range from $55,000 to 

over $300,000 depending on the technique used to collect the economic data. To keep costs down, 

the feasibility study is designed to use pre-existing data when possible unless a critical need for 

collecting new data is identified. Given the significant project costs associated with sinking a ship, 

it is important to assess the potential benefits as accurately as possible to determine if the 

investment is advisable. The techniques for collecting the economic data range from using existing 

studies (secondary data) to collecting Puget Sound site-specific primary data by surveying current 

and potential Puget Sound divers. Ideally, the data needed on diver use, spending, non-market 

values, and changes in visitation would be obtained by surveying current and potential dive visitors. 

If those costs are prohibitive, data from existing sources can be used exclusively if appropriate. At 

the very least we suggest collecting site-specific data on the annual current number of Puget Sound 

divers because this estimate establishes the baseline and is what will drive both the regional 

economic analysis and non market values for which all future economic impact comparisons and 

resulting decisions will be made. For all other data sources, we provide a set of low, medium, and 

high cost and applicability methods for data collection. The advantages, disadvantages, and costs 

using the low, medium, and high data sources are discussed. 

Methods for obtaining data on current annual number of divers: Total recreational diving use can 

be estimated from a combination of two sources: 1) dive logbook records from all dive charter 

operations in the study area; and 2) on-water survey sampling of diving sites in the study area on a 

stratified random sample of days over a pre-determined time period (Bob Leeworthy, NOAA, 

personal communication). Annual log book data can be obtained from all for-hire dive operations 

that utilize dive sites in Puget Sound. The on-water data sampling can then be used to estimate the 

ratio of private household or rental boat use to charter dive boat use. This information is needed to 

extrapolate the dive charter logbook data to the population of all recreational users (Bob 

Leeworthy, NOAA, personal communication). The costs for logbook data collection depend on the 

number of dive shops and charter operations within the study area. Tasks include monthly data 

collection from all dive charter operators located within the study area, data entry, travel expenses, 

and report preparation. The costs for on-site survey sampling include vessel rental, observer salary, 

31 
and data input. Annual costs would depend on the number of sites within the sample area as well as 

the overall time period of sampling and the number of days that sampling would need to occur for 

the aforementioned procedures. 

Total costs for dive logbook data collection and on-water observation would be $30,000 - $85,000 

depending on number of dive charter operators included in the area and the number of days and 

sites for on-water sampling. 

Range of methods for obtaining other data sources (based on cost and applicability): 

A) Relying only on secondary data sources (low cost and low applicability or specificity to Puget 

Sound): Existing studies can be useful for understanding how previous ship sinking has benefited 

local communities. Using data from existing studies has the advantage of being much more 

affordable and quick to conduct as compared to a visitor survey. These secondary data sources on 

diver use, spending, and benefits can be applied if the situation of the previous study is similar to 

Puget Sound. A literature review on the value of recreational diving at artificial reefs in the United 

States was recently completed and provides a detailed summary of all existing studies (Pendleton 

2005). Few studies have been conducted on the value of artificial reefs and only three included 

artificial reefs constructed of ships (two conducted in Florida and one in Texas). Average diver 

spending estimates from the studies including ships ranged from $50-$185 per day for residents and 

$90-$204 per day for non-residents, and non-market values from a study in Southeast Florida were 

$14 per visitor per day for maintaining existing reefs and $5.60 per visitor per day for constructing 

new artificial reefs (Pendleton, 2005). An average from the diver spending estimates and the nonmarket value estimates could be applied to Puget Sound. However, these studies are from warm 

water areas with well established dive tourism industries and were conducted after ship 

deployment. Therefore, the estimates for diver use do not transfer well to Puget Sound. In British 

Columbia, the Nanaimo Dive Association began keeping dive statistics before the sinking of the 

Saskatchewan in 1996. These data can provide an order of magnitude estimate of the potential 

impact (i.e., whether sinking a ship might generate a $100,000, $1 million or $10 million annual 

impact). Transferring these results to Puget Sound should also be done with caution because British 

Columbia already had an established reputation for artificial reef diving (seven scuttled ships) 

before the Saskatchewan was sunk. 

The biggest drawback of using only data from existing studies is that it would not provide 

information on changes in visitation (from current and new divers) or on what sunken ship 

characteristics would attract the most divers. This information is needed to determine the change in 

economic effects associated with ship sinking. Existing studies would provide only a single 

estimate that would not vary by the different scenarios under consideration in Puget Sound (i.e., 

ship location, single ship or cluster of ships, ship type, close to airport or other outdoor activities, 

etc.). The question of how geographic location of a sunken ship in Puget Sound will affect appeal 

to non-local divers that live within driving distance (Portland area) versus non-local divers that fly 

into Seattle can be particularly important. A sunken ship located in Hood Canal or south of Seattle 

might attract many more visits from non-local divers who typically drive to the area rather than fly 

into Seattle than would a sunken ship located north of Seattle. In contrast, a sunken ship located 

near other activities or tourist attractions (i.e., San Juan Islands; Olympia National Park; etc.) might 

attract many more visits from divers from other out-of-state locations that would fly into Seattle. 

32 
The amount of time and money spent in the local area is very different for non-locals coming from 

Portland (often a one- day trip) versus non-locals flying in from farther away. A visitor survey is 

needed to understand these changes in visitation and what amenities interest divers most (and may 

not be available at other artificial reef sites). This information would give Puget Sound the 

opportunity to develop a niche market that divers are seeking. 

Cost Range: $25,000 - $50,000 

 + $30,000 - $85,000 for current diver data collection 

 = $55,000 - $135,000 Total Economic Evaluation Cost 

B) Survey of current divers to Puget Sound area (medium cost and medium applicability or 

specificity to Puget Sound): As discussed in the social issues section, surveys have the advantage of 

providing site-specific quantitative, numerical data to inform the project. A visitor survey of current 

divers would provide for the economic valuation, including data on current use and trip frequency, 

visitor spending, benefit values, and preferences for the ship-sinking amenities of greatest interest 

to current Puget Sound divers. 

Anticipated changes in current diver visitation can also be estimated by using information on the 

potential sunken ship scenarios (i.e., single ship or cluster of ships, ship type, close to airport or 

other outdoor activities, etc.). Current divers would be asked to report how the number of visits 

would change with each scenario. This approach is known as the contingent visitation or intended 

behavior approach. To estimate the non-market values, a dichotomous choice question should be 

used to make the contingent valuation question more closely approximate market-like conditions. 

For surveying current divers, sampling procedures could involve a modification of the on-water 

survey sampling procedures of diving sites in the study area (described above for estimating the 

annual number of current visitors) to conduct an intercept-mail survey. The procedures for 

conducting an intercept-mail survey are discussed in the social issues section. 

The disadvantage of only conducting a survey of current divers is that the survey is limited to 

individuals already visiting the area. It excludes the potential new divers that would come to Puget 

Sound as a result of sinking ships and therefore would only provide a very conservative estimate of 

increased use, benefits, and spending impacts that would be generated by sinking a ship because it 

would miss participation of new divers. Besides being costly, surveys are also time intensive. The 

process includes survey development, pre-testing, and survey implementation, and might require up 

to 12 months depending on the diving season plus additional time for data analysis. Study duration 

would be approximately 18 months. 

Cost Range: $125,000 - $175,000 

 + $30,000 - $85,000 for current diver data collection 

 = $155,000 - $260,000 Total Economic Evaluation Cost 

33 
C) Conducting a survey of current divers and potential new divers (high cost and applicability or 

specificity to Puget Sound): In addition to surveying current divers, conducting a survey of the 

general scuba diving population to reach potential new divers would provide all the data and 

advantages mentioned above in the current diver survey plus it would have the additional advantage 

of including the increased use, benefits, and spending of potential new divers. This is the only 

method that would provide all data needed for conducting the economic analysis and provide the 

most accurate evaluation of the anticipated total economic impact associated with sinking ships. 

Possible techniques for obtaining a representative sample of general scuba divers include 

subscription lists from Scuba Diving Magazine, member lists from a scuba organization (e.g., 

PADI; DAN), or random digit dialing. Disadvantages are that it would be costly and time intensive. 

Cost Range: $200,000 - $250,000 

 + $30,000 - $85,000 for current diver data collection 

 = $230,000 - $335,000 Total Economic Valuation Costs 

Feasibility Study Budget 

We present three funding options for the feasibility study; others are possible. The Full option 

includes consideration of two vessel classes (ferries and destroyers), provides a rigorous analysis of 

existing data, and for some tasks includes significant development of new data. The purpose for 

these new data is to validate, refine, or provide critical information for making predictions and 

conclusions. The Full option will provide the most reliable assessment of feasibility across Puget 

Sound. Two Minimal options are presented, one with consideration of two ship types and the other 

for ferries only. The latter is included to provide a cheaper option and because ferries may be a 

better option than destroyers for Puget Sound (see “ship selection and acquisition” under “project 

costs” above). Where the Minimal level differs from the Full level, the former includes field 

sampling at only one site rather than at five sites (Siting) or provides no or qualitative results rather 

than quantitative results (Socio-economic factors). The Minimal level relies more on existing data 

whose relevance or accuracy for Puget Sound or for specific sites of interest in Puget Sound often 

is unknown or modest. The uncertainty or risk associated with predictions based on the Minimal 

options will be substantially greater than with the Full option but the cost is approximately 50% 

lower. Selecting only one site for field surveys (i.e., Minimal options) seems most appropriate if the 

feasibility study is done sequentially so that one site has been selected as the desired location for 

sinking a ship, subject to final field verification. Note that a fourth budget option—the Full option 

with consideration only of ferries—can be computed from values in the table (below) by 

subtracting the difference between the two Minimal options from the Full option. 

Values in the following budget table are derived from the means of the ranges given in the text 

unless otherwise noted. Most of the direct costs (i.e., without overhead or indirect costs) were those 

that would be incurred if USGS conducted the feasibility study. Details supporting those costs are 

provided in Appendix A. We believe that the direct costs would be similar for most consultants or 

other potential contractors; however, overhead rates vary substantially, ranging from less than 50% 

(e.g., USGS) to well over 100% (some consultants). We used 100% here to avoid overly optimistic 

expectations. 

34 
Funding level 

Full Minimal 

Section Task (two ship types) Two ship 

types Ferries only 

Project costs Ship selection and acquisition $20,000 $20,000 $10,000

Contaminant removal and effects 

 Estimate contaminant inventories and removal 

 costs; review emerging contaminant effects $29,000 $29,000 $23,500

 Hazmat sampling for emerging contaminants 

 (e.g., PBDEs) $150,000 $150,000 $75,000

Ship preparation, towing, and sinking $9,000 $9,000 $4,500

Siting 

 Puget Sound-wide map from existing data $29,500 $29,500 $29,500

 Field surveys, seafloor $202,500 $40,500 $40,500

 Field surveys, visibility and currents $181,500 $36,300 $36,300

 Field surveys, biological $101,200 $20,240 $20,240

Predeployoment ship stability analysis $10,000 $10,000 $5,000

Permits $10,000 $10,000 $10,000

Liability $10,000 $10,000 $10,000

Infrastructure $24,000 $24,000 $24,000

Maintenance $9,600 $9,600 $9,600

Monitoring $46,000 $46,000 $46,000

Project life span $3,000 $3,000 $3,000

Environmental 

impacts Physical processes $10,000 $10,000 $10,000

Biological impacts $119,500 $119,500 $119,500

Socio-economic factors Social issues 

 Comparative studies $10,000 $10,000 $10,000

 Focus groupsa $70,000 $33,000 $33,000

 Survey (community)b $47,000

Economics 

 Estimating current diver use $58,000 $58,000 $58,000

 Estimating economic impact from existing datac $10,000 $38,000 $38,000

 Socio-economic survey (divers)d $250,000 

Sub-total Sub-total $1,409,800 $715,640 $615,640

Overheade Overhead $1,409,800 $715,640 $615,640

Total Total $2,819,600 $1,431,280 $1,231,280

a

Five focus groups are suggested; two are minimal. 

b

The value reflects a 25% discount on the mean of the range for mail surveys given in the text. 

c

The suggested value is less than the minimal because most data needed to estimate economic impact 

will come from the survey. 

d

The value is at the upper end of the range given in the text because quesitions on economic valuation and 

social issues are included. 

e

Overhead rates vary substantially, ranging from less than 50% (e.g., USGS) to over 100% (some 

consultants). We chose to use 100% to reduce the chance of underestimating the actual cost regardless of 

the contractor. 

35 
Discussion 

The Minimal budget options include collection of new data in three instances. The first is onboard 

hazardous material sampling for PBDEs and other emerging contaminants. We included this 

element in the Minimal options because as far as we know the presence and concentration of 

emerging contaminants in onboard materials has not been established by previous studies. The 

other two instances are field surveys at one site (rather than at five for the Full level), and two focus 

groups (rather than five) to provide at least some information on community support or opposition 

to ship sinking. Note that if a minimal option is selected, we recommend that the single field survey 

be conducted at the site judged to be the most desirable from other data and results of the feasibility 

study. This sampling would be necessary to confirm the many preliminary conclusions about site 

suitability and benign ecological consequences; authorizing ship sinking without such a survey 

would be risky because confirmation of the existence of suitable sites would be lacking. Physical 

and biological field surveys at a candidate site will be an essential prerequisite to ship sinking, 

required by permitting, regardless of whether such surveys are conducted during a feasibility study 

or postponed until afterwards (i.e., only conducted in the event that the decision to go forward with 

ship sinking is made). 

Contaminant removal may be the single most important issue to resolve for a ship sinking program 

in Puget Sound. Contaminants tend to be retained in Puget Sound due to basin morphology and 

current circulation patterns, and sediments and biota show high levels of contaminants. PCBs and 

PBDEs bio-accumulate up the food web and occur at high levels in ESA-listed killer whales. Major 

initiatives are underway to prevent contaminants from entering the Sound and to clean up those that 

are already present. Thorough ship cleaning will be required if ship sinking is to proceed. For this 

reason, a good strategy for the feasibility study might be to accept the strictest contaminants 

standards at the outset. The advantage would be to save the time and expense needed to review and 

reach consensus on acceptable contaminant levels since the endpoint of such deliberations would 

likely be the same (i.e., very strict standards). For PCBs this might mean adopting a maximum of 2 

ppm, based on EPA criteria for “continued use” of materials (Atlantic States Fisheries Commission 

2004), rather than the 50 ppm maximum given in the BMPs for creating artificial reefs from ships 

(U.S. Environmental Protection Agency and U.S. Maritime Administration 2006) which is based on 

criteria for “disposal” of materials. If attaining the 2 ppm level appears to be cost prohibitive, past 

studies could be reviewed to see if a higher level would be acceptable. Because standards for 

PBDEs and other emerging contaminants are currently lacking, past studies must be reviewed and 

standards set for these chemicals unless it proves feasible to completely remove materials 

containing them from ships. 

Economic benefit is also an important issue. Tourism economic development is the primary goal 

for ship sinking. The extent to which economic benefits outweigh monetary and environmental 

costs will be a major factor in deciding whether to proceed with ship sinking. Note that there is a 

large difference in accuracy of economic predictions between the Full and Minimal budget levels. 

The Full level includes a survey of divers nation-wide as well as in Washington, which will 

estimate the number of non-resident divers attracted to the State by ship sinking and the average 

spending by such divers. The survey will also allow evaluation of how economic benefit varies 

among regions within Puget Sound. In contrast, the Minimal level relies on a few studies from 

warm water areas and on statistics from British Columbia that roughly estimate economic benefits 

from sinking ships in the Strait of Georgia. These data may not transfer well to Puget Sound and 

will not provide information on variation in economic benefit among regions. Choosing the Full 

budget level seems advisable due to the importance of accurate economic predictions. 

36 
The feasibility study could be conducted in stages. For example, contaminant issues could be 

evaluated first because of their overriding importance. If thorough cleaning were found to be 

feasible for ships of interest, then other components of the study could proceed. Alternatively, 

economic benefits could be evaluated first, and the other components of the study would proceed 

only if economic projections were favorable, commensurate with claims for ships-to-reefs 

programs in other areas. A sequential strategy would obviously save money if thorough cleaning 

isn’t feasible or if economic projections are judged to be inadequate; however the strategy would 

extend the duration of the study if neither of these factors preclude ship sinking. Whether ship 

sinking is compatible with the initiative to remove derelict vessels from Puget Sound seems to us a 

less critical issue than are contaminants or economic benefits, particularly because a ship sinking 

program can and should include removal of derelict fishing gear. Nevertheless, it would still be 

wise to investigate resolution of this potential conflict early in the feasibility study. If all feasibility 

components were conducted concurrently, the duration of the study should be approximately 18-24 

months. Significant milestones, such as completion of syntheses of existing data, would be 

achieved at various times during this interval. 

Our cost estimates for the feasibility study seem high relative to those for other ships-to-reefs 

programs. The total cost to sink a ship, including feasibility determination, typically averages about 

$500 per ton (Appendix A). On this basis, the larger of our two vessel classes (medium sized 

destroyer; ~3000 tons) should cost about $1.5 million to sink, yet our Minimal estimate for a 

feasibility study alone is $1.4 million (or $1.2 million if only ferries are considered) and our Full 

estimate is $2.8 million (budget table, with 100% overhead). One reason is that the study we 

describe needs to determine programmatic feasibility for a region with no past history of similar 

programs, a task that should be expected to cost more than simply determining feasibility for a 

single ship and site in regions with pre-existing policy and regulatory frameworks and a positive 

track record from ship sinking (i.e., where monitoring of past projects indicates that environmental 

impacts are acceptable). Another reason may be that Puget Sound differs from the Atlantic and 

Gulf coasts, where most ships-to-reefs programs in the United States have occurred, in being more 

sensitive to environmental impacts (e.g., contaminant retention; vulnerability of ESA-listed 

species), and also in the strong environmental ethic of people living in the area. Puget Sound 

therefore requires a thorough assessment of potential environmental impacts, which is expensive. 

Finally, results of the studies we propose will be scientifically defensible, which comes at a greater 

cost than do less rigorous studies. We have described the tasks that we think should be included in 

a feasibility study, along with a cost estimate for each task and information on how we derived the 

estimate. From this information the reader may wish to adjust, eliminate, or add additional tasks, or 

to adjust cost estimates to create other alternatives for study intensity or cost. For example, decision 

makers might select one of the Minimal options but add the socio-economic diver surveys from the 

Full option to ensure reliable estimates of economic benefit. 

If a feasibility study is conducted, the investigators must work closely with the regulatory agencies 

that set the environmental criteria and standards against which decisions are made and that 

ultimately make those decisions. Since ship sinking, as proposed herein, is new to Puget Sound, 

new criteria and standards may need to be established, and regulators may need to direct the efforts 

of the feasibility study to accomplish this. For example, removal standards will need to be reviewed 

and set for emerging contaminants and perhaps also for established contaminants such as PCBs, 

and this will likely require investigators to provide specific information at the request of the 

regulators. 

It would be desirable for the scoping study to include rigorous definition of minimum sampling 

intensities, statistical power, and other criteria defining the quality of the products from the 

37 
feasibility study. Unfortunately the time and funding allocations for this study did not allow that 

degree of elaboration. If the legislature decides to move forward with a program to sink ships for 

divers so that a request for proposals results from the scoping study, personnel charged with 

soliciting or reviewing such proposals may bear some extra burden to ensure adequate rigor. 

Recommendations 

We recommend choosing the Full budget option for estimating economic benefits (i.e., costs listed 

under Economics in Full column of the budget table) due to the importance of accurate economic 

predictions, as discussed above. Other recommendations must follow from the priorities of the 

decision makers. If cost efficiency is deemed more important than minimizing the time required to 

complete the feasibility study, then conducting the feasibility study sequentially is recommended. 

The most important issues appear to be contaminant removal and economic benefits for reasons 

discussed above. Contaminant removal could be investigated first, perhaps for ferries only since 

they may offer greater ease of cleaning than destroyers (see “ship selection and acquisition” under 

“project costs” above). If thorough removal proves economically feasible, then anticipated 

economic benefits from ship sinking could be evaluated. If results from this step are favorable, then 

the study could proceed further. Alternatively, economic benefits could be evaluated first, followed 

by contaminant removal if economic projections are favorable. We recommend conducting all 

feasibility study components concurrently if minimizing time to feasibility study completion is 

more important than cost efficiency. 

Acknowledgments 

We thank the following individuals for helping us to prepare this report: Greg Bargmann, Tom 

Clingman, Melissa Montgomery, Tom Mumford, Randy Person, Michal Rechner, Michelle Reilly, 

and Melodie Selby (WDFW); Paul Hershberger, Carl Ostberg, Scott Smith, and Lyman 

Thorsteinson (USGS); Jeff Dey (REEFMAKERSTM); Mike Racine (Washington Scuba Alliance); 

Bob Jacobs (People for Puget Sound); and Bruce Higgins (Egyptians). 

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39 
Appendixes 

Appendix A: Budget with cost estimate details: The following budget table shows the basis for cost 

estimates presented in the Budget section of the report (see above). The details apply to our Full 

option for the feasibility study except in the one instance noted below. 

Section Task/Subtask Cost category Hours Cost 

Project costs 

Ship selection and acquisition 

Subcontract—Modified from estimate by Jeff Dey, REEFMAKERSTMTotal $20,000

Contaminant removal and effects 

 Estimate contaminant inventories; review emerging contaminant effects 

Senior scientist—Lit. review & synth for emerging contaminants 200 $18,000

Subcontract—Assess & remove PCB's (estimate from Jeff Dey, 

REEFMAKERSTM) $11,000

Total $29,000

 Hazmat sampling for emerging contaminants (e.g., PBDEs) 

Subcontract—Estimate based on costs for Spiegel Grove 

hazmat sampling (EPA & MARAD 2006) Total $150,000

Ship preparation, towing, and sinking 

Subcontract—cost estimate by Jeff Dey, REEFMAKERSTM Total $9,000

Siting 

 Puget Sound-wide map from existing data 

Senior scientist 220 $12,000

Junior scientist 380 $12,000

Biotechnician/clerical 30 $600

Information management (GIS; database mgmt; ...) $4,000

Equipment, supplies, travel $900

Total $29,500

 Field surveys, seafloor 

Senior scientist 1,100 $60,000

Junior scientist 2,000 $55,000

Biotechnician/clerical 250 $5,000

Information management (GIS; database mgmt; ...) $20,000

Equipment, supplies, travel $25,000

Subcontract for vessel $37,500

Total (5 sites) $202,500

 Field surveys, water clarity and currents (2 seasons; per site) 

Senior scientist 950 $51,500

Junior scientist 1,750 $45,000

Biotechnician/clerical 125 $2,500

Information management (GIS; database mgmt; ...) $20,000

Equipment, supplies, travel $25,000

Subcontract for vessel $37,500

Total (5 sites) $181,500

 Field surveys, biological 

Senior scientist 100 $6,000

Junior scientist 560 $17,000

Biotechnician/clerical 160 $4,200

Information management (GIS; database mgmt; ...) $6,000

Equipment, supplies, travel $5,000

Subcontract for vessel and ROV $49,000

Subcontract for benthos sorting and taxonomy $14,000

Total (5 sites) $101,200

Predeployoment ship stability analysis 

Modified from estimate by Jeff Dey, REEFMAKERSTM Total $10,000

Permits 

Subcontract —cost estimate by Jeff Dey, REEFMAKERSTM Total $10,000

40 
Section Task/Subtask Cost category Hours Cost 

Liability 

Senior scientist 50 $3,000

Junior scientist 100 $3,500

Biotechnician/clerical 140 $3,500

Total $10,000

Infrastructure needs assessment 

Senior scientist 200 $12,000

Junior scientist 110 $3,800

Biotechnician/clerical 160 $4,200

Information management (modeling) $2,000

Equipment, supplies, travel $2,000

Total $24,000

Maintenance needs assessment 

Modified from estimate by Jeff Dey, REEFMAKERSTM Total $9,600

Monitoring needs assessment 

Senior scientist 300 $18,000

Junior scientist 220 $7,600

Biotechnician/clerical 320 $8,400

Information management $2,000

Equipment, supplies $2,000

Travel $8,000

Total $46,000

Project life span 

Senior scientist 20 $1,200

Junior scientist 50 $1,800

Total $3,000

Environmental impacts 

Physical processes 

Senior scientist 120 $6,500

Junior scientist 100 $2,800

Biotechnician/clerical 10 $200

Equipment, supplies, travel $500

Total $10,000

Biological impacts 

Senior scientist 1,360 $69,300

Junior scientist 580 $18,200

Biotechnician/clerical 920 $23,400

Information management (GIS; database mgmt; ...) $8,000

Equipment, supplies, travel $600

Total $119,500

Socio-economic factors 

Social issues 

 Comparative studies 

Senior scientist 25 $2,500

Junior scientist 100 $5,000

Information management (GIS; database mgmt; ...) $500

Travel $2,000

Total $10,000

41 
Section Task/Subtask Cost category Hours Cost 

Focus groupsa

Senior scientist 100 $10,000

Junior scientist 360 $18,000

Recorder $5,000

Information management (GIS; database mgmt; ...) $2,000

Equipment, supplies $10,000

Travel $25,000

Total $70,000

 Survey (community)b

Senior scientist 100 $10,000

Junior scientist 240 $12,000

Survey (postage, printing, data entry, ...) $15,000

Information management (GIS; database mgmt; ...) $2,000

Equipment, supplies $2,000

Travel $6,000

Total $47,000

Economics 

 Estimating current diver use 

Estimated from similar efforts in Floridac Total $58,000

 Estimating economic impact from existing datad 

Senior economist 150 $15,000

Economist/Contractor 200 $20,000

Equipment, supplies $1,500

Travel $1,500

(Minimum option)Total $38,000

 Socio-economic surveys (divers)e

Senior scientist 300 $30,000

Senior economist 300 $30,000

Junior scientist 1,000 $50,000

Survey costs (current divers) $80,000

Survey costs (general divers) $30,000

Information management (GIS; database mgmt; ...) $7,000

Equipment, supplies $8,000

Travel $15,000

 Total $250,000

a

Five focus groups are suggested; two are minimal. 

b

The value reflects a 25% discount on the mean of the range for mail surveys given in the text. 

c

Depending on the number of dive shops and operators in the area and the number of days and 

sites for on-water sampling, the cost could range from $32,000 to $85,000 based on costs incurred 

for a similar project in Florida. 

d

The Suggested value is less than the Minimal (given here) because most data needed to estimate 

economic impact will come from the survey. 

e

The value is at the upper end of the range given in the text because questions on economic 

valuation and social issues are included. 

42 
43 

Appendix B: Ship sinking costs from other programs: The following table shows turnkey costs for 

sinking large ships from past or ongoing ships-to-reefs programs. The table was provided by Jeff 

Dey of REEFMAKERSTM

. 

Ship Site 

Deployed 

yet? Deploy date

Weight 

(tons) Cost (US $) 

Cost per 

ton 

Yukon California Yes 2000 3,700 $2,000,000 $541 

Scylla England Yes 2004 3,700 $3,019,688 $816 

Perth AUS Yes 2001 4,000 $2,073,567 $518 

Hobart AUS Yes 2002 4,000 $2,015,984 $504 

Brisbane AUS Yes 2006 4,000 $2,073,567 $518 

Balarus Spain No In process 4,700 $2,294,963 $488 

Speigel Grove Florida Yes 2002 7,000 $1,300,000 $186 

Texas Clipper Texas No 2007 10,000 $5,000,000 $500 

Vandenberg Florida No 2008 13,000 $5,700,000 $438 

Oriskany Florida Yes 2006 34,000 $23,600,000 $694 

Average 8,810 $4,907,777 $520